United States Region 4 EPA 904/9-86 141
Environmental Protection 345 Courtland Street, NE August 1986
Agency Atlanta, GA 30365
3EPA Public Health and Draft
Environmental Exposure
Assessment
Unison PCB Separation Facility
Henderson County, Kentucky
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DRAFT
PUBLIC HEALTH AND ENVIRONMENTAL EXPOSURE ASSESSMENT
UNISON PCB SEPARATION FACILITY
HENDERSON COUNTY, KENTUCKY
Prepared b'y
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia 30365
This Draft Public Health and Environmental Exposure Assessment
addresses a proposed Toxic Substances Control Act operating
permit for an alternate method of PCB disposal. This permit is
to be used by a facility owned by UNISON, Inc. and located in
Henderson County, Kentucky. Estimates of the potential exposure
to UNISOK's activities both in Henderson and around the county
are provided. Estimates of how great these exposures are likely
to be and their duration are also presented. A characterization
of the risk associated with these exposure estimates is then
described.
Comments and inquiries should be forwarded to:
Robert C. Cooper
Project Officer, NEPA Compliance Section
3**5 Courtland Street, N.E.
Atlanta, Georgia 30365
404/317-3776
for
Approved by:
Date
AUG 0 1 1986
Regional Administrator
Libraiy Region IV
US Environmental Protection Agency
345 Courtland Street,
Atlanta, Georgia 30365
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EXECUTIVE SUMMARY
PURPOSE OF THE DOCUMENT
The Toxic Substances Control Act (TSCA) is the legislation under which EPA
has the authority to issue an operating permit for this project. Regulations
promulgated under TSCA require EPA to determine whether the proposed project
will present an unreasonable risk of injury to health or the environment. The
purpose of this study is to provide a detailed evaluation of the potential
risks associated with the proposed UNISON project. The study documents the
permit application review and provides the information upon which will be based
the determination of whether the proposed project would present unreasonable
risks of injury to public health or the environment. The study is also intended
to provide an explanation to the public of the permit evaluation process. The
document has been issued in draft form to allow public comment before a final
decision on permit issuance is made.
DESCRIPTION OF THE PROPOSED PROJECT
The overall process begins with the transport of equipment and a solvent
(known as TF-1) from regional warehouses to transformer sites. At the traps-
former sites, concentrated PCBs are drained from the transformer and drummed
for shipment to an EPA approved PCB inoinerator. The transformer? an? then
filled with clean TF-1 which.acts to leach out PCBs remaining in the t/ansformer
cases.
Several month later, UNISON personnel ratugj^jbo the transformer sits with
additional clean TF-1 and more qnptjy d|"ums. Sines the first visit, FCB? which
could .not be drained f;rom the ^ranafqemers in„the,,ipitial vj.fi| Jbave fraciually
dissolved in the TF-1. TF-1 which, has been expoa*d_to PCBs.in thiawayia
call TF-X. At this second visit, UNISON again drains the transformers and
Library Region IV
j US Enviromasnial Protection Agency
34S Cotirtknd Street
Atlanta, Georgia 30365
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refills them with clean TF-1. The TF—X removed from the transformers is drummed
for eventual shipment to Henderson County, Kentucky, for processing.
The draining and refilling operation is repeated every few months until
the PCB concentration has been substantially reduced. The last fill of TF-1 is
then drained and this TF—X is drummed for shipment to Henderson. The transformer
is refilled with a permanent dielectric fluid and recommissioned as a non-PCB
transformer.
The UNISON facility in Henderson County, Kentucky, is located in the
Henderson County Riverport Authority and Industrial Park at the intersection of
Old Geneva Road and Riverport Access Road. It is about 1500 feet south of the
Ohio River at River-Mile 808.
Transportation to and from the facility is along Riverport Access Road to
Highway 136. Highway 136 connects with Highway 425, the Henderson By-Pass,
which terminates at the Pennyrile Parkway. The connection with southern cities
is made over the Pennyrile Parkway. The conection with northern cities is over
Route 41 to Interstate 64. After completion of Interstate 164, traffic through
Evansville will be along it rather than Route 41.
The process to be used at the Henderson facility is physical separation
Physical separations are based on physical chemical properties of substances and
not on chemical reactions. The specific nature of the process is protected
from disclosure by Federal law.
While the process itself cannot legally be described in this report, the
equipment which carries out the process can be described in part. It consists
essentially of sealed tanks and pipes. It has been designed according to the
engineering standards recommended by the Center for Disease Control, and the
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National Institute for Occupational Safety and Health (NIOSH) for the processing
of PCBs.
All parts of the plant processing equipment are sealed against the escape
of vapors except those few parts where it is unavoidable, such as the brief
opening of drums for insertion of the drainage equipment. Vapors drawn off
from various parts of the process pass through one of eight vent lines to the
roof where they are released to the atmosphere. Before being released to the
outside air, vapors must pass through beds of activated carbon at the end of
each line. These remove almost all organic vapors. Vapor analyzers guard the
vent lines just past the carbon beds to alarm any pass through beyond the trace
amounts allowed in the air permit.
ALTERNATIVES
EPA has authority to analyze UNISON'S process at their selected site and
decide whether it would impose an unreasonable risk to public health or the
environment. EPA does not have authority to select a site and make UNISON
operate there.
UNISON claims to have selected Henderson in a three step process. Many
potential sites were initially considered in the first screening. Sites outside
of Kentucky, Indiana, and Tennessee were eliminated because they did not minimize
the total mileage, i.e., the economic costs. In the second screening phase,
Kentucky was selected because it offered the best flexibility in using the only
three permitted incinerators. In the final screening phase, Henderson was
selected as offering the best facilities.
UNISON also described several site characteristics which they say played a
major part in their selection process. These included a site ten to fifteen
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acres in size, a flat site which was out of any floodplain, good highway access
near the interstate system, and a site far enough away from the nearest community
so that it would not result in unreasonable risks and yet close enough to a
good sized labor pool which could supply about thirty employees, some of whom
had to be skilled or technically trained.
There are four methods currently allowed by law for the disposal of PCBs:
o High temperature incineration;
o High efficiency boilers (for oils contamined with low concentrations
of PCBs)
o Landfills (for low concentration solids and drained transformer
carcasses); and
o Alternate methods permitted under 40 CFR 761.60(e).
Alternative methods of PCB destruction include methods which actually
destroy PCB molecules and those which only separate the PCBs from whatever
material they are contaminating. The proposed UNISON facility plans to use a
physical separation process. Physical separation processes include:
o Centrifugation;
o Filtration;
o Reverse osmosis;
o Distillation;
o Electrophoresis; and
o Solvent extraction,
EPA has three options under TSCA in responding to a permit application.
The request can be approved, it can be approved with certain specified conditions*
or approval may not be given.
PUBLIC HEALTH AND ENVIRONMENTAL EXPOSURE ASSESSMENT AND RISK EVALUATION
The discussion is divided into two broad areas. These are ordinary operations
and accidents. The accident discussion is further divided into on—site events
and accidents during materials transportation. The Summary Table In Appendix 11
summarizes the accident evaluation.
IV
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Total air emissions will be less than 400 pounds per year. These emissions
will be almost entirely TF-1 vapors (99.99+%), and they are expected to contain
less than 0.0001% PCBs (less than one part per million).
The highest average annual concentrations found were at the Riverport
Warehouse and Docks where there are typically twelve employees. The concentration
of organic vapor was predicted to average 82.7 nanograms per cubic meter (parts
per trillion) at this location. This is less than one twelfth the concentration
of PCBs at which EPA and NIOSH have found workers could be exposed 40 hours
per week without risk of injury. The projected exposures of TF-1 are also
expected to cause no unreasonble risk.
No surface or groundwater releases are expected to occur during normal
operations.
The accident analysis is divided into two parts. First, potential on-site
accidents were evaluated. This evaluation included the following:
1. Fire and Explosion Related Releases - PCBs, TF-1 and TF-2 are inherently
incapable of behaving like fuels. Technically they can be burned in high-
temperature, high-oxygen environments of special incinerators, but they
have no potential for burning outside of such environments. A number of
scenarios were analyzed where runaway heating could occur, but they all
involved a number of peculiar and unlikely events happening simultaneously.
The chance of this happening was determined to be so remote that it did
not warrant further analysis.
2. Potential Releases Due to Pollution Control Equipment Failure - In the
unlikely event that UNISON'S pollution control equipment fails, and
that several employees are severely negligent within the same time
frame, it was estimated that large releases of TF-1 containing 0.002%
PCB's could continue for a duration of one week. Based on the assumption
that such an event could occur once a year for 20 years, and that the
same people would be downwind of the facility for the duration of all
twenty such incidents, EPA evaluated the exposures to people downwind
of the facility. The expected lifetime exposures and risks would be
several orders of magnitude lower than those which the Agency has
previously found do not pose an unreasonable risk.
3. Airplane crash involving the facility - The UNISON plant is located
approximately one mile east of the Henderson/Henderson County Airport.
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The probability of an airplane accident at the facility of sufficient
magnitude to cause damage greater than minor leaks and spills is very
small. Even though there is a low probability of occurence, the
Agency did look at the exposures and risks which could result from
such a crash. Worst-case PCB exposure estimates at all phases of the
plane crash would result in no significant lifetime cancer risk.
EPA also evaluated the comparative exposures to incomplete combustion
products from a fuel fire cased by a plane crash. The lifetime doses
resulting from exposure to incomplete combustion products from such a
fuel fire would be several orders of magnitude lower than those estimated
for both short-term and long-term on-site exposures to incomplete com-
bustion products in the soot resulting from a PCB transformer fire.
4. Earthquake - Various methods of estimating the chances of a major
earthquake in the Henderson area could be utilized. One study indicated
a 10% chance of a major earthquake in this area in the next 50 years.
EPA concluded that the chances were sufficient enough to warrant an
analysis of what the impact of a major earthquake would be. The three
major potential consequences of an earthquake were evaluated: shaking,
liquefaction and subsidence. Of all three earthquake effects, liquefaction
appears to have the greatest potential for affecting the UNISON site.
However, the character of underlying soils at the facility suggest that
liquefaction effects, if they occur at all, would be very minimal. It
has been concluded that some contamination of soils in the immediate
area could potentially occur but significant contamination of the Ohio
River from PCB's or TF-1 would not occur from a reasonably forseeable
worst case earthquake.
Other types of potential on-site accidents including flooding and tornadoes
were found to be much less likely to occur. The site is located above the 500
year flood level. A flood of this magnitude would put much of Evansville
under water before the UNISON facility was endangered. An evaluation of the
potential effects of tornadoes indicated that there is no unreasonable risk
related to potential releases.
Transportation related releases are a possibility each time a truck load of
materials travels on our nations highways. The potential for releases is
estimated from both local and national perspectives. The national analysis
estimated the total number of additional miles which will be generated by this
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facility. Average rates of accidents and releases were then used to estimate
one releasing incident involving tankers carrying PCB residue or TF-2 every 18
years. There is a 50J chance that this release would involve PCBs. EPA took
this analysis one step further to analyze what the result would be if these
releases involved "worst case" accidents in the project area. Accidents occuring
in two sensitive locations, the Ohio River Bridge and in a high density residential
area, were evaluated.
The site for the bridge accident is the Route 41 bridge which crosses the
Ohio River between Henderson Kentucky, and Evansville, Indiana. It.was assumed
that an entire 23 ton load of PCB residues would be released to the River. Due
to the wide range of release and river flow characteristics, a variety of
related possible bridge accidents were evaluated rather than one "worst case"
incident. Because of this range of possibilities, it is difficult to accurately
estimate the potential exposures and risks associated with transportation
related spills into water supplies. Given the tendency of PCBs to bind to
sediment it is expected that should a large spill occur only a small percentage
of PCB's spilled will actually be carried in the water. Further, any dissolved
PCB's would tend to be dispersed by the flow of the river, so that individual
ingestion exposure to PCB's (either through oontaminated fish or through drinking
water) would be mitigated. The scenario of most oonoern would be a release to
the River above the Evansville water supply intake during high flow conditions.
Evansville does, however, have suitable technology available for effective
treatment. As long as emergenoy notification procedures are properly implemented,
no PCBs should pass into the finished drinking water supply.
VII
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EPA also evaluated several scenarios involving a spill along Highway 41 in
Evansville. The worst of these cases assumed the largest possible amount of
residues 3pilled on hot pavement in a residential area. Exposure to initial
concentrations of PCBs and any vapors would be limited to a maximum one hour
response time (time to cover the spill area in order to mitigate inhalation
exposure). In such a case, emergency response personnel would be subject to the
greatest potential exposure. Assuming that emergency response personnel do not
wear respirators, the resulting exposures would be less, by one or two orders
of magnitude, than those found not to pose an unreasonable risk to workers in
manufacturing facilities which inadvertently generate PCBs.
Available studies indicate that the levels of organic vapors .within one
hundred meters of a large spill from a PCB residue or TF-2 tanker truck could
result in eye and respiratory irritation. Direct contact with the spill
material could result in skin irritation (dermatitis). Such effects from a
a predicted worst case spill are believed to be reversible with no long term
adverse health consequences.
PROPOSED EPA ACTION
Based upon a review of UNISON«s permit application and the material presented
in this document EPA has made a preliminary determination that operation of the
proposed facility at the UNISON site in Henderson will not pose an unreasonable
risk of injury to human health or the environment. This determination Is
conditional upon the Draft Conditions of Authorization which are listed in
Chapter 9.
VIII
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EPA has also authorized the Initiation of the test demonstration in late
August. This test will determine whether the process operations achieve adequate
separation of PCB residues and meet restrictions on emission levels. EPA's
final decision on authorization of plant operation will be based on the results
of the test demonstration as well as the comments received on this Draft Public
Health and Environmental Exposure Assessment.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY I
LIST OF FIGURES XIII
LIST OF TABLES XV
1.0 INTRODUCTION 1-1
2.0 BACKGROUND 2-1
2.1 HISTORY OF THE PROJECT 2-1
2.2 PURPOSE OF THIS DOCUMENT 2-1
2.3 REGULATION UNDER THE TOXIC
SUBSTANCES CONTROL ACT 2-2
2.4 REGULATION UNDER THE RESOURCE CONSERVATION RECOVERY ACT... 2-5
2.5 CHEMISTRY OF POLYCHLORINATED
BIPHENYLS (PCB's) 2-6
3.0 DESCRIPTION OF PROPOSED PROJECT................... 3-1
3.1 OVERALL PROCESS............ 3-1
3.2 OFF-SITE ACTIVITIES 3-3
3.3 TRANSFORMER, REGIONAL WAREHOUSE
AND INCINERATOR LOCATIONS. 3-3
3.4 TRANSPORTATION TO AND FROM HENDERSON. 3-6
3.5 MATERIALS HANDLING 3-10
3.6 SITE LAYOUT 3-11
3.7 IN-PLANT PROCESSES. 3-11
4.0 ALTERNATIVES 4-1
4.1 ALTERNATIVES CONSIDERED BY UNISON. 4-1
4.1.1 Site Selection 4-1
4.1.2 Alternative Processes. .. 4-2
4.1.3 Alternative Pollution Control
Systems.. 4-3
4.1.4 Methods of PCB Disposal... 4-3
4.2 ACTIONS AVAILABLE TO EPA, 4-5
4.2.1 Approval 4-5
4.2.2 Approval with Conditions. 4-5
4.2.3 Non-Approval... 4-6
4.2.4 Effect* bf Non-Approval (tfce "No Action"
Alternative) 4-6
4.2.5 Options Available to
Transformer Owners.. 4-9
4.3 OTHER REGULATORY PROCESSES. ,4-9
IX
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TABLE OF CONTENTS (continued)
Pase
5.0 PUBLIC HEALTH AND ENVIRONMENTAL EXPOSURE ASSESSMENT 5-1
5.1 ORDINARY OPERATIONS 5-1
5.1.1 Air Emissions 5-1
5.1.2 Surface Water Releases 5-4
5.1.3 Groundwater Releases 5-4
5.2 ACCIDENT EXPOSURES 5-5
5.2.1 On-Site Accidents 5-5
5.2.1.1 Potential for Releases Due to
Process Equipment Malfunction 5-6
5.2.1.2 Potential for Releases due to Pollution
Control Equipment Failure 5-7
5.2.1.3 Potential for Fire or Explosion
Related Releases 5-9
5.2.1.4 Potential for Earthquake
Releases 5-12
5.2.1.5 Potential for Releases
Due to Flooding 5-27
5.2.1.6 Potential for Tornado
Related Releases 5-38
5.2.1.7 Potential for Releases Due to
Airplane Impact 5-42
5.2.2 Potential for Transportation Related
Releases 5-51
5.2.2.1 National Analysis -
Annual Mileage by type of Load 5-51
5.2.2.2 Estimated Tanker Release Rates... 5-52
5.2.2.3 "Sensitive Receptors".... 5-55
5.2.2.4 Worfet Case Residential Area Accidents..... 5-59
5.2.2.5 Chance of Fire in Connection
With an Accident 5-63
5.2.2.6 Worst Case Water Impacts Accident 5-64
5.2.2.7 National Analysis - Trucks Carrying
Drums of TF-1 or TF-X . 5-76
5.2.2.8 Local Accident Analysis -
Henderson County 5-79
5.2.2.9 Local"Accident Analysis -
Evansvil^e....... 5-83
5.2.2.10 Comparison With Other Hazardous **
Shipments 5-85
5.3 RISK EVALUATION - OFFICE OF PESTICIDES
AND TOXIC SUBSTANCES. # 5_86
5.3.1 Comparative Risks Associated with Air Emissions
from ordinary separations 5-90
5.3.2 Comparative Analysis of Risks Posed by Exposures"*
Resulting from Accidents On-site 5-91
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TABLE OF CONTENTS (concluded)
Page
5.3.2.1 Earthquake 5-91
5.3.2.2 Flooding . 5-92
5.3.2.3 Tornado 5-92
5.3.2.4 Airplane crash involving the facility 5-94
5.3.2.5 Pollution Control Equipment Failure 5-96
5.3.2.6 Fire of Explosion Related Releases 5-96
5.3.3 Transportation Related Incidents 5-97
5.3.3.1 Residential Spill 5-97
5.3.3.2 Spills into Water Supply.... 5-98
5.3.4 Benefits of the UNISON Facility * 5-99
5.3.5 General Conclusion about the Potential Risks
Associated with the Proposed UNISON Facility at
Henderson, Kentucky 5-99
6.0 SOCIOECONOMIC EFFECTS OF THE FACILITY 6-1
7.0 MITIGATION 7-1
7.1 ADDITIONAL MITIGATIVE MEASURES CONSIDERED BY EPA 7-1
7.1.1 Water Supply Contamination 7-2
7.1.2 Traffic Accidents 7-3
7.1.3 Ultimate Fate of TF-1. 7-4
8.0 PUBLIC INVOLVEMENT 8-1
8.1 ACTIONS BY UNISON 8-1
8.2 ACTIONS BY THE HENDERSON COUNTY BOARD OF
ZONING ADJUSTMENT 8-2
8.3 ACTIONS BY THE KENTUCKY ENVIRONMENTAL
PROTECTION CABINET 8-2
8.4 ACTIONS BY THE UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY 8-2
9.0 PROPOSED EPA ACTION 9-1
10.0 LIST OF PREPARERS 10-1
11.0 REFERENCES 11-1
XI
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APPENDICES
APPENDIX 1. TOXIC SUBSTANCES CONTROL ACT, SECTION 6(e)
40 CFR 761 excerpts
TSCA Compliance Program Policy No. 6-PCB-2 excerpts
TSCA Compliance Program Policy No. 6-PCB-3 excerpts
51 FR 6423 et. seq.
APPENDIX 2.
APPENDIX 3.
APPENDIX 4.
APPENDIX 5.
APPENDIX 6.
APPENDIX 7.
APPENDIX 8.
APPENDIX 9.
APPENDIX 10.
APPENDIX 11.
NIOSH RECOMMENDATIONS FOR PCB STANDARDS
EPA GENERAL PERMIT CONDITIONS
HCBZA CONDITIONAL USE PERMIT
EPA FIRES RULE BROCHURE
AIR EMISSIONS, ORDINARY OPERATIONS
TORNADO EFFECTS
DESCRIPTION OF AIRCRAFT ACCIDENT CALCULATION
FAA ACCIDENT DATA
EVANSVILLE GROUP QUARTERS
OHIO RIVER PCB CONCENTRATIONS IN FISH
LOCAL ACCIDENT CHANCES AND EXPECTATIONS
SUMMARY TABLE
XII
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LIST OF FIGURES
Page
Figure 1. Modeled locations of PCB transformers in the central and
eastern United States 3-5
Figure 2. TSCA permitted PCB incinerators 3-8
Figure 3. Location of UNISON facility.... 3-12
Figure 4. Flow path from ditches 001 and 002 to Canoe Creek and
Ohio River 3-13
Figure 5. Local UNISON transportation routes 3-14
Figure 6. Richter earthquake scale and distribution of earthquake
magnitudes 5-13
Figure 7. New Madrid fault zone.... 5-15
Figure 8. Rough Creek fault zone 5-16
Figure 9. Earthquake epicenters associated with the New Madrid fault
zone, 1811 to 1975 5-18
Figure 10. Earthquake Risk Zones 5-19
Figure 11. Cross-section of PCB Contaminated Soils at site near
Uaukegan Harbor 5-22
Figure 12. Cross-section through Ohio River showing elevation of
UNISON plant relative to river elevation 5-25
Figure 13. Canoe Creek water shed... 5-28
Figure 14. Elevations of notable floods in the vicinity of Henderson
County 5-29
Figure 15. Total precipitation in inches, December 26, 1936 to
January 25, 1937 5-30
Figure 16. Ohio River watershed 5—31
Figure 17. Total precipitation in Inches March 2-5, 1964 and
March 8-10, 1964 5-33
Figure 18. 10 year, 50 year, 100 year, and 500 year project floods
for the Ohio River in the Henderson area 5-34
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LIST OF FIGURES (CONCLUDED)
Page
Figure 19. Flood profiles for Canoe Creek 5-35
Figure 20. FLood of 1937 5-36
Figure 21. 390 Foot Flood........................................... 5-37
Figure 22. Distribution of Tornadoes 5-39
Figure 23. Annual numbers of deaths and of tornadoes by the strength
of the storm 5-40
Figure 24. Potential Receptors in the Evansville Area 5-56
Figure 2b. Potential Receptors in the Henderson Area................ 5-57
Figure 26. Water supplies downstream from the Route 41 bridge with
intakes in the Ohio River 5-58
Figure 27. Water column PCB concentrations along a transect
through Waukegan Harbor 5-68
Figure 28. Time to reach various points downstream from the
Route 41 bridge at four flow rates 5-73
XIV
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LIST OF TABLES
Page
Table 1. Modeled distribution of TF-1 and TF-X transport 3-7
Table 2. Mercali earthquake intensity scale and levels of damage
caused by quakes of various magnitude 5-20
Table 3. Fugita Tornado Scale (F scale) 5-41
Table 4. Distribution of cargo losses from tankers during transit
in Kentucky or Indiana from January 1981 through January
1986 5-53
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1.0 INTRODUCTION
This report summarizes the results of a Public Health and Environmental
Exposure Assessment conducted by EPA Region IV on the proposed UNISON* PCB
separation facility to be operated in Henderson County, Kentucky. The report
is intended primarily as a public information document which describes those
aspects of EPA's study which can be revealed without compromising UNISON trade
secrets. The report summarizes information and analyses required by EPA to
evaluate a request by UNISON to operate an alternate method of PCB disposal
under the Toxic Substances Control Act (TSCA).
Section 2.0 of the report provides a description of the background of the
study, including the project history, study objectives, applicable regulatory
framework, and background information on the chemistry of PCB's. Section 3.0
provides a description of the proposed project, including both on-site and
off-site activities and processes. Section 4.0 summarizes the various site
and process alternatives available to the TSCA permit applicant (UNISON) as
well as options available to EPA regarding permitting of the facility.
Section 5.0 is an assessment of the potential exposures of the public and the
environment which could result from operation of the facility, Including those
resulting from both on-site and off-site activities and processes. Section
6.0 describes the socioeconomic effects of construction and operation of the
facility. Section 7.0 summarizes the applicant's efforts to mitigate health
and environmental effects and discusses additional mitigation available to
minimize risks associated with facility operation. Section 8.0 summarizes
public participation related to the project, and section 9.0 presents EPA's
proposed decision on the application.
*"Unison Transformer Services, Inc., a wholly owned subsidiary of Union Carbide
Corporation" is abbreviated throughout this document simply as "UNISON".
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2.0 BACKGROUND
This section describes the history of EPA's involvement in the UNISON
project and the purpose of this document. An overview of Toxic Substances
Control Act (TSCA) and the Resource Conservation and Recovery Act (RCRA)
regulations as they relate to the proposed facility is also given. Finally,
some background on PCB chemistry is provided.
2.1 HISTORY OF THE PROJECT
Early in 1984, UNISON entered into discussions with EPA's Office of
Pesticides and Toxic Substances (OPTS) regarding the possibilities of decon-
taminating PCB transformers using an alternative disposal method. OPTS has
jurisdiction over alternative methods which are mobile or may be operated in
more than one region. Regional EPA offices have jurisdiction over alternative
methods to be operated solely within each region (See 40 CFR 761.60(e) in
Appendix 1). In September 1984, UNISON submitted an application for its
process to be operated at a site in Chicago. Before action could be taken,
the site was purchased by a competitor.
In September 1985, UNISON updated its application to specify Henderson
County, Kentucky as its preferred operating site and jurisdiction over its
application was transferred to EPA's Region IV offices in Atlanta. Region IV
is processing the application with technical and policy assistance from OPTS.
At about that time, EPA began receiving letters from concerned citizens
in the area requesting a detailed study of the project and a public meeting.
EPA then determined that there were several Issues Which should be investigated
in detail and presented to the public before action was taken on the permit
application. This document presents the results of that investigation.
Before the Scope of Work for this document was finalized, a public meeting
was held in the project area to gather additional input from the public* This
meeting was held in Henderson, Kentucky, on December 2, 1985. Eight hours of
testimony from concerned citizens were gathered at the meeting. A summary of
major issues raised at the meeting is presented in Section 8.0.
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Early in 1986, UNISON submitted its completed permit application for the
proposed facility to Region IV. The Scope of Work for the Public Health and
Environmental Exposure Assessment was then finalized and work on review of the
application was initiated.
2.2 PURPOSE OF THIS DOCUMENT
The Toxic Substances Control Act gives EPA authority to issue an operating
permit for this project. TSCA and regulations promulgated under TSCA. require
EPA to determine whether the project will present an unreasonable risk of
injury to health or the environment. The purpose of this study is to provide
a detailed evaluation of potential risks associated with UNISON's proposed
project. The study documents the permit application review and provides
information concerning EPA's determination regarding potential unreasonable
risks of injury to public health or the environment. This study is also
intended to provide an explanation of the permit evaluation process. EPA has
prepared this public information document as part of its on-going effort to be
responsive to public concerns. EPA believes that a valuable public purpose is
served by the open discussion of the issues involved. The document has therefore
been issued in draft form to allow public comment before a final decision on
permit issuance is made. EPA's proposed decision is described in Section 9.0.
2.3 REGULATION UNDER THE TOXIC SUBSTANCES CONTROL ACT
EPA is given authority to regulate PCBs in the Toxic Substances Control
Act (TSCA) of 1976. Section 6(e) of TSCA (see Appendix 1) generally prohibits
manufacture and use of PCBs as of January 1, 1978. However, exceptions were
made for uses which are "totally enclosed" or which EPA determines "will not
present an unreasonable risk of injury to health or the environment." Regula-
tions promulgated under TSCA Section 6(e) are codified in 40 CFR 761 (See
Appendix 1). Among other things, these regulations require disposal of PCBs
in special facilities and allow and encourage the decontamination of existing
transformers.
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When these regulations were promulgated, PCBs like the ones UNISON
proposes to treat were only allowed to be destroyed in high temperature
incinerators. At that time, incineration was the only proven method. New
methods which might be developed were intended to be covered by Section
761.60(e). This section allows EPA to approve "an alternative method of
destroying PCBs" if "this alternative method can achieve a level of performance
equivalent to ...Incinerators". EPA policy is to treat physical separation of
PCBs as a new method under the same framework as chemical or thermal destruc-
tion of PCBs. UNISON, therefore, has submitted an application for a permit
under the alternative disposal method rules. A copy of UNISON's application,
free of confidential business information, is available in Henderson and
Evansville libraries. The alternative disposal rules and EPA policy state-
ments covering these rules are provided in Appendix 1.
Under TSCA regulations, Industrial processes are regulated rather than
construction of a facility. A "process" would include off-site activities
transportation and materials handling) and on-site facility-specific
details such as valve specifications, Instrument brands, emergency procedures
and content of training programs. EPA's authority Is limited to determining
whether the process at a proposed site might present an unreasonable risk to
human health or the environment. EPA can Impose conditions on the process to
eliminate or minimize rlskd which might be considered unreasonable, or EPA can
refuse to approve the process altogether if unreasonable risks cannot be
avoided.
Any company wishing to receive an approval for the operation of an alter-
native PCB disposal method must first submit an application to EPA. Since
UNISON's proposed separation facility is to be operated in Region IV. the
request for approval will be acted upon by the Region. (Regarding jurldiction
over applications, see 40 CPR 761.60fe^ in Appendix 1). Applications for
approval to operate alternative methods require the-, follovlng^EPAei April
1985):
1. A description of the project organization Including persons re-
sponsible for obtaining permits, the project manager, facility
manager, and safety officer.
2-3
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2. A description of waste intended to be treated in the unit, including
the type of waste to be destroyed (liquid or solid), the proposed
total waste and PCB feed rates, and the matrix* and composition of
the waste, including major and minor constituents and PCB content.
3. A process engineering description including process flow diagram,
narrative description of the system, description of the theoretical
basis for the destruction process, layout diagrams, descriptions of
the plant or mobile unit, detailed engineering drawings, intended
location of the facility and intended location when in storage.
4. A narrative description of the waste feed system, description of
waste preparation, and estimate of waste volume.
5. A description of the automatic waste feed cutoff system when process
conditions exceed normal bounds, and a description of the procedures
to shut off the waste feed line or the whole process in the event of
an equipment malfunction.
6. A narrative description of the destruction** system (e.g., descriptiot
of chemical reactions, stoichiometry, reagents, catalysts, process
design capacity), and a list of products and by-products and their
concentrations,
7. A description of the pollution control system for process effluents
(air emissions, liquid effluents, sludge, solid waste, etc.) design
parameters, and important operating parameters of the pollution
control system and how they will be monitored.
8. A summary of process operating parameters which lists target values
as well as upper and lower boundaries for all measured operating
parameters, instrument settings and control equipment parameters.
9. A sampling and monitoring program to monitor process ooemM™ .«i
to verify PCB destruction. and
10. Sampling procedures including an explanation of the aonarat
calibration procedures, and maintenance procedures. ratU8»
U. Analytical procedures (e.g., methods, instruments, etc.).
12. Monitoring procedures (methods, instruments, etc.).
*The matrix is the set of chemical compounds in which the PCBs are dissolved
or on which the PCBs ar« adsorbed. In this project, the matrix is TF-l a
proprietary solvent used to extract PCBs from transformers. *
~~"Destruction" refers to the elimination of PCBs from the matrix and hence
includes separation as is the case here. matrix and hence
2-4
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13. A spill prevention control and countermeasure plan.
14. A safety plan.
15. A training plan.
16. A demonstration test plan.
17. Test data or engineering performance calculations.
18. Copies of other required permits/approvals.
19. Schedule for operation.
20. A quality assurance plan.
21. A copy of the plant or facility operational plan.
22. A closure plan for the facility.
Once a complete application has been submitted, EPA performs Its review.
The review involves both a review of the application and a demonstration test.
If the technical information in an application indicates that the process
cannot achieve safe and effective PCB disposal* approval will not be given.
If the demonstration test does not show the process to ba effective and safe,
approval for the process will also be denied (see 51 FR 6423 et. seq. in
Appendix 1).
2.A REGULATION UNDER THE RESOURCE COHSERVATIOH RECOVERY ACT
The Resource Conservation Recovery Act (RCRA) was passed by Congress In
1976. RCRA was Intended to be a comprehensive program for the cradle-to-grave
management of hazardous wastes. RCRA Section 1004(5) specifically defines
hazardous waste aa waste,
"which because of its quantity, concentration, or physical, chemical or
infectious characteristics nay -
(A) cause, or significantly contribute ttt anj&er«aee in mortality or an
increase in serious Irreversible, or incapacitating reversible, illness;
(B) pose a substantial present ofc potential hazardv to tauoah health or the
environment when improperly treated, stored* transported, or disposed of,
or otherwise managed."
2-5
-------
This definition of hazardous waste is broad. However, in Subtitle C, Section
3001(a), Congress required EPA to formulate a narrow and specific definition
of the terra "hazardous waste". Congress promulgated this limitation on EPA's
authority because the U.S. Constitution requires that criminal defendants be
given very clear and unambiguous notice of exactly which activities will be
considered criminal. The intent was to make RCRA criminally enforceable.
In response to this Congressional directive, EPA formulated a compre-
hensive definition of hazardous waste (see 40 CFR 261) which would be enforce-
able against those who mismanaged hazardous wastes. It includes any waste
which is ignitable, corrosive, reactive or liable to leach out of a landfill,
and, in order to avoid any misunderstandings, lists a large number of compounds
and many industrial process effluents by name. It does not, however, list
PCBs or the types of materials UNISON proposes to treat. PCBs are not as
hazardous as many of the materials used in modern society. They are not
ignitable, corrosive, reactive or liable to leach out of a landfill. Since,
according to these criteria, PCBs were not as dangerous as other chemicals
regulated under the Act and PCBs were already regulated under TSCA,. PCBs were
not named in the lists of hazardous chemicals.
However, PCBs may soon be regulated under RCRA. Evidence collected by
EPA since the ban on PCB manufacture indicates that the level of PCBs in the
environment is not dropping as fast as expected. PCBs are much tnore persistent
in the environment than was previously believed and an unknown quantity con-
tinues to be disposed of improperly. RCRA rules are currently undergoing
consolidation and simplification. As part of this process, EPA plans to
include PCB products such as those to be treated by UNISON, in the definition
of hazardous wastes. Until then, such wastes remain governed primarily by
TSCA.
2.5 CHEMISTRY OF PQLYCHLORIMATED BIPHENYLS (PCBbI
Polychlorin«ted biphenyls (PCBs) «nd related compounds are classified as
aromatic hydrocarbons. Aromatic hydrocarbons are organic chemicals which are
modifications of and/or combinations of benzene, the simplest aromatic compound.
2-6
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Benzene is a simple ring of six carbon atoms. Most of the bonding energy
of the carbon atoms is devoted to holding the ring together, but each carbon
atom has one bond left over which points out and away from the ring. This
bond attaches to a hydrogen atom (hence, the term hydrocarbon).
If one of the hydrogen atoms is removed and some other element or chemical
group is put in its place, the benzene is converted into another chemical with
different but related properties. Many important chemicals are made with
similar modifications. They include perfumes, dyes, inks, glues, and various
poisons. Aromatic chemistry is the study of different modifications of benzene.
PCBs are made by first joining two benzene molecules together to form a
biphenyl molecule. This biphenyl molecule is made by removing one hydrogen
atom from each of two benzenes so that the two rings combine. The resulting
biphenyl molecule can be visualized as two hexagons stuck together with a
short line. If additional hydrogen atoms are removed from the biphenyl molecule,
other elements and molecules can be substituted to make a wide variety of
blphenyls. If hydrogens are replaced with chlorine atoms, the resulting
molecules are called polychlorlnated blphenyls (PCBs).
Since.there are ten hydrogen atoms on a biphenyl molecule and any one or
combination of them could be replaced with chlorine, there are two choices for
each of ten positions or 2^ (1024) possible combinations. However, many of
these combinations do not have a,distinct chemistry because they are exact
mirror images of ojther combinations. There are 209. distinctly different PCBs.
PCBs can be destroyed by heating them to hiah temperatures. As the
temperature rises, the PCB .molecules collide with each Qth«X tapre and more
violently. Above a few hundred degrees celsius, the molecules start breaking
apart. The pieces recombine in a complicated series of chemical reactions
that result in a great variety of new compounds. Some of these new molecules
can be much more dangerous than PCBs, especially if they are formed, as is
typically the case, in the presence of oxygen*
-------
If the temperature gets high enough, the PCBs break up into individual
atoms. The hydrogen atoms combine with chlorine to form hydrochloric acid or
with oxygen to form water. The carbon atoms combine, if oxygen is present,
with one or two oxygen atoms to form either carbon monoxide or carbon dioxide.
If combustion is complete, almost all the carbon ends up as carbon dioxide.
However, if the temperature does not get high enough and stay high enough long
enough or if not enough oxygen is present, some of the carbon comes out as
carbon monoxide. Under such conditions, there is a chance that some PCBs will
not be destroyed or that they will have been converted into their more dangerous
reaction products. See especially the discussion of fire in Sections 4.2.4,
5.2.1.3 and 5.2.2.5. The efficiency of the destruction of PCBs by incineration
can be determined by monitoring the concentration of carbon monoxide in the
emissions. If no carbon monoxide is detected in emissions, destruction of the
PCB's to hydrochloric acid, water and carbon dioxide is essentially complete.
PCBs can be separated from other materials without destroying them.
There are many ways to do this. Each method takes advantage of some property
of PCBs that differs from the properties of other kinds of molecules the PCBs
may be mixed with. For example, separations based on size differences are
called filtrations, or, if an extraordinarily fine filter is used, reverse
osmosis. Separations based on solubility are called solvent extractions.
Those based on boiling point are distillations.
The proposed separation technology, in order to satisfy TSCA regulations,
must achieve a level of performance equivalent to PCB incineration. EPA is
only able to regulate "completeness" to the limits of accuracy of reasonable
scientific tests. After treatment, the TF-1 must be completely free of PCB's
as measured by whichever test EPA finds Is most suitable.
2-8
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3.0 DESCRIPTION OF PROPOSED PROJECT
This section describes the proposed project, including all stages from
initial transformer draining to final incineration of the PCB residues. The
location of various activities, including transportation between sites, material
handling and site layout, and the proposed physical separation process are
described. Information for this section has been taken primarily from UNISON's
permit application.
3.1 OVERALL PROCESS
The overall process begins with mobilization of equipment and clean TF-1
at the regional warehouses which UNISON proposes to operate. UNISON technicians
take the equipment and TF-1 to a nearby transformer site. At the site, con-
centrated PCBs are drained from the transformers and drummed for shipment to
an EPA approved PCB incinerator. The transformers are then filled with clean
TF-1. Equipment, unused TF-1 and drummed PCBs are then transported to the
regional warehouse.
Several months later, UNISON personnel return to the transformer site
with additional clean TF-1 and more empty drums. PCBs which could not be
drained from the transformers in the initial visit have gradually dissolved in
the TF—1. TF—1 which has been exposed to PCBs in this way is called TF-X.
UNISON drains the transformers during this second visit and refills them with
clean TF-1. The TF-X removed from the transformers is drummed for shipment to
the regional warehouse. Shipments from the warehouse to the Henderson facility
are made when a truck-load (sicty drums) has accumulated.
The draining and refilling operation is repeated every few months until
the PCB concentration is low. After the last fill of TF-1 is drained (this
TF-X is drummed for later shipment to Henderson) the transformer is refilled
with a permanent dielectric fluid, UNISON must still return to the site to
confirm decontamination. The permanent dielectric, fluid must show a concen-
tration of less than 50 parts per mil liotj PCBs after at least three months of
use to be recommissioned.as a non-PCB transformer (40 CFR 761.30 [«)(2)(v))»
If the concentration after three months is wore than 50 ppto but less thfati 500
3-1
-------
ppm, the transformer qualifies for the intermediate status of "PCB-contaminated
Achieving this status has many benefits (see 50 FR 29179 et.seq.) but the
transformer remains subject to a number of regulations.
At the regional warehouses, the initial drainage of concentrated PCBs is
accumulated until a truck-load can be sent to one of several special PCB
incinerators. Approved incinerators are located in Chicago, IL, near Houston,
*
TX, and in El Dorado, AK . TF-X is accumulated until a truck-load can be sent
to Henderson. The warehouse also receives supplies of new TF-1 (from the
manufacturer) or reconditioned TF-1 (from Henderson).
At Henderson, contaminated TF-X is received from the various regional
warehouses. It is off-loaded with special drum handling equipment. The drums
are drained in a part of the facility where vapors in the dead space at the
top of the drum can be contained. Each drum is triple-rinsed with clean TF-1
and then refilled with additional clean TF-1 for shipment back to the regional
warehouses (see 40 CFR 761.79 in Appendix 1). All materials removed from the
drums, including the three rinses, are processed through the facility for
separation into clean TF-1 and concentrated PCB residues. These residues
are stored on-site until a tanker-load can be sent to one of the special
incinerators.
There are a limited number of PCB-transformers (at least 100,000 perhaps
150,000) still in existence. When these have been cleaned, any remaining
inventories of TF-1 and the facility itself will lose their reason for existence.
Leftover TF-1 will then be disposed of or sold for reuse elsewhere, which most
likely will be for continued decontamination of transformers overseas. The
ultimate fate of TF-1 is discussed in Section 7.1.3.
*A fourth incinerator (the GE in-house incinerator) located in Pittsfield, MA
has been approved since 1981, but, until very recently, had only processed
PCBs for a single customer, General Electric. EPA has recently learned (as
this document went to press) that this facility is now soliciting PCBs from
other sources in small quantities. As GE runs oat of PCBs, the Pittsfield
incinerator will likely solicit outside work in greater quanitity. However,
since GE is in the business of supplying new replacement transformers, it
seems unlikely that they will ever do substantial business with UNISON. GE
is an indirect competitor with UNISON.
**The separation is not perfect. Some TF-1 components are lost to the residues
during processing. They are replenished at the end of the process with TF-2.
TF-2 consists of the TF-1 components lost to the residues.
3-2
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3.2 OFF-SITE ACTIVITIES
Off-site activities begin with the arrival of UNISON's service vehicle
carrying drainage pumps and hoses, emergency decontamination and safety equip-
ment, clean TF-1 in drums and clean empty drums for contaminated materials.
The field team first drains each transformer. Experience with similar opera-
tions has shown that 85% to 90% of the concentrated PCBs will drain freely
from the transformers. The remainder is absorbed in the transformer core or
is trapped in undrainable pockets and slowly diffuses into the TF-1 once the
transformer has been refilled.
If 15% of the concentrated PCBs remain in the transformer and all of them
diffuse into the first refill of TF-1, the PCB concentration in the first
batch of TF-X drained and delivered to Henderson could theoretically be as
high as 15%. However, PCBs which drain poorly also diffuse poorly, and even
in the most concentrated straight transformer fluid, PCBs only account for
about two-thirds of the weight. Many contain much lower PCB concentrations.
Because of these limitations, PCBs in the first drainage of TF-X are not
expected to exceed 8%. In fact, they should average something less than half
this amount, and the long term average of all TF-X drained from the transformers
should be less than 2% PCBs. This is the figure EPA used in determining
normal operating characteristics at the proposed facility. Higher figures,
based on maximum possible concentrations, were used for some of the analyses
in order to be conservative.
After draining and refilling have been completed, any drips or spills
will be cleaned using EPA-mandated procedures. The cleaners and adsorbants so
used will be separately drummed for incineration.
3.3 TRANSFORMER. REGIONAL WAREHOUSE AND INCINERATOR LOCATIONS
Transformers filled with concentrated PCBs are located all over the
country. PCB transformers were considered superior to ordinary minetal-oil-
filled transformers because they would not support a fire if the transformer
shorted out. However, they were too expensive to use everywhere. Consequently,
PCB transformers were installed primarily in occupied structures, including
3-3
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multi-unit dwellings, office buildings and certain industries. Fire codes
often dictated use of PCB transformers. We now know that the disadvantages of
PCBs, primarily toxicity and persistence in the environment, far out-weigh the
advantage of non-combustibility (50 FR 29179 et.seq.). Unfortunately, many
transformers are now located in close proximity to population centers.
The general location of most of these transformers is known to EPA (EPA
1976a). The distribution is roughly proportional to the size of populations
in major metropolitan areas (USWAG 1982 Vol. I, Vol. Ill)
UNISON does not propose to decontaminate every PCB transformer. Competitor?
in the business are supplying similar services. Also, the high cost of trans-
portation and reprocessing will probably make servicing the Western'United
States uneconomical from Henderson. Thus, some fraction of the transformers
located In the Central and Eastern regions of the country constitute UNISON's
potential market.
UNISON is under no obligation to decontaminate any transformers and may
or may not conduct operations in any of the metropolitan areas shown in Figure
However, UNISON Is already advertising its remote-site (transformer decontami-
nation) activities in a variety of media with wide circulation. While UNISON'i
exact marketing and operations strategy is confidential, one can model their
activities by assuming regional warehouses will be operated in major metropoll
areas east of Dallas and Kansas City and that the volume of business In each
area will be proportional to the populations of those areas.
Figure 1 is a map of the United States showing metropolitan areas with a
population of more than one million people. Western population centers are
not shown. The areas of the circles are proportional to the number of people
reported in the 1980 census.
3-4
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3> i ¦ M°HTah'a'——'—
/ • —J\
\ .' \ : NORTH DAKOTA : **•«•••
« / • J I MINNESOTA
^ > I }
/ IDA^\ l *'
/ "V
/ / I ! v
' ! i- \
! * —p— , r--— riowA !
• UTAH ! ! NEBRASKA
/
/NEBRASKA
/
TV . I
jColorado
Kansas
I J
V MISSOURI »
—¦S v
I—.. •
:AFnzn?Z --J.
/*"\ -VN.v~
¦\ An i '
4 ffe^CKY
J. I Q) /KENTUCKY .>
/ NEW MEX/CO P"*" 1 •"7"n"c"aB0UN'
/ fan0KLAH0MA WanTas--^"55^
/ j !_ i i..-.^T-Tu-r'^^^scaboun^.
TRfNSFOpMfeRSL-
O
"Alabama. ^
i
i
\ ^ \ X ^ \
• 4,
t-ssjp
1 Q hawaiiN\
- 0
% r%"
: LOUISIANA'
fes-s,ppli rvfowDA^
Figure 1. Modeled locations of PCB transformers in
the central and eastern United States.
-------
Table 1 lists the areas shown on the iiap, reported populations, percentage
*
of business expected for each area, and mileage to or from Henderson ~ The
expected amount of travel between Henderson and the warehouses assuming the
plant 1s operated at capacity is also indicated.
* *
There are only three incinerators suitable for destroying the concen-
trated residues to be separated at Henderson. Their locations are shown in
Figure 2. One reason Henderson was chosen as the site for this facility is
that its central location allows some flexibility in using the available
incinerators. It is expected that UNISON will primarily use whichever
incinerator is most reliable and economical. Generally, this means the bulk
of all residues will be shipped to Chicago. The transportation risk analysis
(see Section 5.2.2) assumes that 80% of the residues will be shipped to Chicago,
15% to Houston (Deer Park) and 5% to El Dorado, Arkansas. This mix is antici-
pated based on projected down time and total cost.
3.4 TRANSPORTATION TO AND FROM HENDERSON
TF-X and TF-2 will be shipped to Henderson. The TF-X drained from trans-
formers and TF-2 from the manufacturer will be shipped in drum-trucks and
tankers, respectively. TF-2 is a make-up transformer fluid used to replace
material lost to the residues during reprocessing of TF-X into TF-1. TF-2
will be shipped to Henderson from the north (about 800 road miles) In tanker
trucks carrying 23 tons each. At full capacity, the plant will consume 45
loads per year of TF-2.
Although TF-2 is not currently considered hazardous by either EPA or The
Department of Transportation, a spill of TF-2 could have adverse effects on
the environment. Transport of TF-2 is discussed in Section 5.2.2.
*
Distances are reported relative to Louisville rather than Henderson
because that data was readily available. Louisville is 150 miles east
of Henderson. This makes the reported mileage low for some sites and
high for others. The total is very slightly less using this method
principally because Louisville is closer to New York.
**See note on page 3-2.
3-6
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Table 1. Modeled distribution of TF-1 and
Metropolitan Area
Population
X of Total
New York
17,606,680
26.34
Chicago
7,212,778
10.79
Philadelphia
4,779,796
7.15
Detroit
3,809,327
5.70
Boston
3,225,386
4.82
Miami
3,103,729
4.64
Washington
2,763,105
4.13
Houston
2,521,857
3.77
Cleveland
2,493,475
3.73
Dallas
2,451,390
3 67
Saint Louis
1,848,590
2.77
Pittsburgh
1,810,038
2.71
Minneapolis
1,787,564
2.67
Baltimore
1,755,477
2.63
Atlanta
1,613,357
2.41
Tampa
1,354,249
2.03
Cincinnati'
1.228,438
1.84
Milwaukee
1.207,008
1.81
Nor folk
1,099.360
1.64
Kansas City
1,097,793
1.64
Mew Orleans
1,078,299
1.61
liuffalo
1.002.285
1.50
1 otal
66.849.981
100.00
'-X transport
Trios/Year
distance
Miles/Year
819.10
766
627,430
335.55
297
99,659
22237
706
156,990
177.22
382
67,697
150.05
962
144,350
144.39
1088
IS 7,098
128.55
601
7/ .256
117.32
941
1 1u ,400
116.00
354
4 1,065
114.04
828
94.428
86.00
256
22.016
8421
393
33 093
83.16
705
56.629
81.67
639
52.186
75.06
415
31.1 49
63 00
838
52,796
57.15
101
5.772
56 15
382
2 1 ,450
51.14
64 7
33.090
51.07
513
26.200
50 16
701
35,165
46.63
545
__ . 25^4 12
3.1 10 00
I ,973.333
-------
OA/
/
/ • ..i\
' \ • NORTH DAKOTA ; *«»«••~
/ \ J Iminnesota <
-¦i ) i \
\
i i
u-f«55s
'c*ssssr>z~^j
Jutah—
/
/
jllinoi
•L-——
: iowa
! NEBRASKA *d
I *
"~J«toR3o—i—i \ .) / ! I
/ I- \ MISSOURI ^ yA | \ ^ / o'iY \V-A'
I j kansas 7 S/ j W r» '^rV/
\ Jsas--/— IN^INERA[TORSte^
\i /newmewto-t—tj-—* y —
; *¦ OKLAHOMA L —> /r'^SpssEE
I :TEXAS n rTo~ MCi« i _¦ TENNEoo"
I
I
a
I
| ARKANSAS
\
\ ^ALASKA **\
f\ Vy-S
^ 1 ^ •* \
• X, jtpX*
| q HAWAII
~ 0
x r909
Figure 2. TSCA permitted PCB incinerators,
-------
TF-X will be transported in specially outfitted tractor trailers
equipped with a seal and liner containment system capable of preventing the
release of any potential leaks or spills due to faulty welds or chimes and
loose or missing bungs. Each truck will also carry emergency response
materials including safety gear, clean-up materials, repair kits and over-
sized drums into which any leaking drums (if discovered) can be placed.
Section 5.2.2.7 discusses the chance of a drum leaking during transit.
The TF-X will be contained in heavy duty 55 gallon steel drums. Each
drum will contain 650 lbs of TF-X. Assuming sixty drums per trailer, each
load will equal 19% net tons. Stacking of drums is not permitted. At
capacity, the plant could theoretically handle as many as 1570 loads per year
or about 30 loads per week.
Various materials will be shipped from Henderson, including clean TF-1
recovered by the plant, liquid waste residues (PCBs) and miscellaneous solid
wdstes. The miscellaneous solid wastes consist of soiled uniforms, spent
activated carbon from the air purification system, materials used for soaking
up minor leaks and spills and similar waste. Since these will be produced in
small amounts and their transport involves only the most minimal hazards, they
will not be discussed further in this report.
TF-1 will be returned to the regional warehouses in the trucks that
deliver TF-X. A total of 1540 loads of TF-1 are expected to be produced
annually by the facility if it is operated at capacity.
PCB residues separated at the facility will be shipped to the in-
cinerators in tankers. Each truck will haul 23 tons of residues. At
capacity, there will be 74 loads per year, or a little less than 1% loads per
week.
UNISON is preparing a plan for driver emergency preparedness and related
matters. Such procedures will be described when available. They shoqld be
available shortly after this report is published.
3-9
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3.5 MATERIALS HANDLING
The majority of all transportation related leaks and spills (in the case
of drums, the overwhelming majority) take place during loading and unloading
rather than during over-the-road travel. Special attention was therefore
given by UNISON's engineers both to avoiding spills and to containing spills
if they were to occur despite such precautions. Much of the materials handling
system is automated and proprietary and cannot be legally disclosed in this
report. Nonetheless, certain key features have been disclosed in proceedings
before the Henderson County Board of Zoning Adjustment or the Kentucky Natural
Resources and Environmental Protection Cabinet and can be mentioned here.
These features are noteworthy:
• The places where trucks park during loading and unloading are pro-
tected from the weather by side-walls and a roof so that spills cannot
be washed away in the rain;
• Loading and unloading areas are diked and sloped toward "blind" sumps
so that spills cannot escape - containment is sufficient for a full
truck-load;
• Concrete surfaces in £jje loading and unloading areas have been coated
with a PCB-impervious material so that spills do not soak in and can
be cleaned up more easily;
• Vents on tankers are connected to the plant air pollution control
system so that vapors do not escape as the tankers fill;
• Lift trucks used for loading and unloading drums are not fitted with
the "forks" one typically finds but with dedicated drum handling
equipment unlikely to cause punctures;
• When the drums are opened, a special exhaust system draws vapors away
and passes them through the plant air pollution control system;
• No drums are opened until they are on the automatic conveyor system;
drip pans underneath this system catch any spills;
• Tractors are removed from the trailers and the trailers are chocked
before they are unloaded; they are also tagged with a "Do Not Move"
sign; and
• All drums are tested with pressurized air in order to detect possible
leaks before they are refilled.
*A "blind" sump is simply a low spot in the floor, usually a square pit,
with no outlet.
**"Impervious" is a relative term. See the discussion on page 5-4.
3-10
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3.6 SITE LAYOUT
The UNISON facility is located in the Henderson County Riverport
Authority and Industrial Park at the intersection of Old Geneva Road and
Riverport Access Road also known as Spencer Road (Figure 3). It is about 1500
feet south of the Ohio River at River-Mile 808. The Administration Building
and employee parking lot are located along the west side of Riverport Access
Road. Further to the west and surrounded by a security fence are the Recovery
Center grounds. A paved area on which trucks can maneuver leads to tne
shipping and receiving docks.
The entire grounds are graded and sloped toward a system of ditches that
surrounds the property and empties (after passing through a series of storm
ditches) into Canoe Creek. The distance from the facility to the Ohio River
along Canoe Creek is a little over five miles (Figure 4).
Transportation to and from the facility is along Riverport Access Road
(or alternatively, from the back of the property, along Industrial Park Drive)
to Highway 136 (Figure 5). Highway 136 connects with Highway 425, the
Henderson By-Pass, which terminates at the Pennyrile Parkway. Here the traffic
splits. The connection with southern cities is made over the Pennyrile Parkway.
The connection with northern cities is over Route 41 to Interstate 64. Traffic
through Evansville will be along Interstate 164 after its completion, rather
than Route 41. The proposed route of I 164 is shown on Figure 24.
3.7 IN-PLANT PROCESSES
The process to be used at the Henderson facility is a physical separa-
tion. Physical separations are based on physical-chemical properties of
substances and not on chemical reactions. Physical separation processes may
include centrifugation, filtration, reverse osmosis, distillation, electro-
phoresis, solvent extraction or other processes. Which of these will be in
actual use at Henderson is protected from public disclosure by Federal, law.
The process is not patented and UNISON believes it could be copied by their
competitors with substantial savings in research and development costs.
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3-14
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The process itself cannot legally be described in this report. The
equipment has been designed according to the engineering standards recommended
by the National Institute for Occupational Safety and Health (NIOSH) for the
processing of PCBs (NIOSH 1977). These standards are more strict than legally
enforceable engineering standards and were developed by NIOSH to protect the
public (including workers inside the facility) from incidental exposure to
PCBs. The recommended NIOSH standards are summarized in Appendix 2.
All parts of the plant processing equipment are sealed against the escape
of vapors except those few parts where it is unavoidable such as the brief
opening of drums for insertion of the drainage equipment. Vapors drawn off
from various parts of the process pass through one of eight vent lines to the
roof where they are released to the atmosphere. Before being released to the
outside air, vapors pass through beds of activated carbon at the end of each
line. These remove almost all organic vapors. A vapor analyzer just past the
carbon beds guards the vent lines to alarm any pass through above trace amounts
allowed in the air permit.
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4.0 ALTERNATIVES
This section describes alternatives which UNISON considered before
deciding on the present process and before deciding to locate in Henderson
County. Alternatives available to EPA, including whether or not to allow
UNISON to operate and what conditions to include are also discussed. Finally,
this section discusses alternatives available to owners of PCB transformers,
including disposal options.
4.1 ALTERNATIVES CONSIDERED BY UNISON
UNISON considered numerous alternatives before applying for a TSCA permit.
Some of the major considerations included how to engineer a process which
would be both safe and profitable, where and how to build a plant using that
process, and how to market the capabilities of the plant. The more important
alternatives and UNISON's rationale will be presented here.
4.1.1 Site Selection
UNISON has stated that the Henderson site was selected in the following
three step process. In the first screening, sites outside of Kentucky, Indiana
and Tennessee were eliminated supposedly because they did not minimize total
mileage. In the second screening phase, Kentucky was selected because it
offered the best flexibility in using the only three permitted PCB incinerators.
In the final screening phase Henderson-was selected as offering the best
facilities.
Technical Factors Governing the Site
Not every parcel of land is suitable for the facility. The site should
meet certain technological, environmental and economic criteria to be appropriate.
*The Pittsfield, MA incinerator has not been considered in either UNISON's or
EPA's analysis. See note on page 3-2.
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UNISON's engineers felt it desirable that the site be at least ten acres,
preferably fifteen. This allowed placing a fairly wide expanse of grounds
around the facility to enhance security and avoid unintentional intrusion into
the plant. It also protects the plant from possible accidents arising from
neighboring facilities and provides an extra buffer-zone between the facility
and the environment.
The site was required to be essentially flat, to be located above the
*
base (100 year) floodplain and have drainage paths which could be controlled
should any sort of disaster occur at the facility. This was intended by
UNISON to protect against contaminating surface water and groundwater resources.
Good highway access near the interstate system was another UNISON require-
ment. Also, it needed certain utilities, including water and sewers, electricity
police and fire protection and so on. Gas was not required.
Finally, UNISON wanted the site to be far enough away from residential
neighborhoods so that it would not result in unreasonable risks, and yet close
to a good sized labor pool able to supply about thirty employees, some of whom
had to be highly skilled or technically trained.
There are a number of sites within one or two hundred miles of Henderson
which meet these criteria. UNISON has stated that the Riverfront Industrial
Park best met their requirements.
4.1.2 Alternative Processes
UNISON considered no other basic technologies besides the one proposed
On the other hand, during the early stages of developing the proposed process
UNISON considered many alternative ways of engineering and Implementing the
*40 CFR 761.65 requires that the plant be above the one hundred year flo
plain because it has been ruled a storage facility. °
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same basic technology. Early on, substantial work was done on a truck-mounted
process which could have been taken from site to site. It would have avoided
the transportation risks posed by the present facility. UNISON applied for
and was granted a permit to operate this mobile process. Because the process
was mobile, the application was handled by EPA Headquarters. An economic
analysis of this version, however, showed it to be more expensive than disposaL
and replacement of the transformers it was intended to decontaminate.
The engineering effort then changed course toward the present plan. As
planning progressed, consideration of alternatives focused on increasingly
specific engineering details. Details of all this scientific and engineering
work are trade secrets which cannot be discussed by EPA publicly. It can be
summarized, however, by saying that UNISON selected the process details they
believed were the most economical, the most reliable and the most environ-
mentally sound.
4.1.3 Alternative Pollution Control. Systems
A number of air pollution control technologies were investigated. The
activated carbon system chosen is appropriate and a proven technology. UNISON
designed this system to minimize releases and maximize treatability. A backup
monitoring and warning system was also installed.
The facility does not use water in the plant process and there are no
floor drains. These design considerations eliminate the industrial use of
water and therefore eliminate the need for water pollution control. Sanitary
wastewater will discharge directly into the Henderson sewer system and treat-
ment plant.
4.1.4 Methods of PCB Disposal
There are four methods currently allowed by law for the disposal of PCBs:
• High temperature incineration;
• High efficiency boilers (for oils contaminated with low concentrations
of PCBs, < 500 ppm);
4-3
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• Special Permitted Landfills (for certain solids and drained transformer
carcasses); and
• Alternative methods permitted under 40 CFR 761.60(e),
Alternative methods of PCB destruction include methods which actually destroy
PCB molecules and those which only separate the PCBs from whatever material
they are contaminating. Permitted alternative methods which actually destroy
PCBS are limited to a new kind of small scale incinerator currently being used in
California and several types of chemical dechlorination processes. Chemical
dechlorination removes the chlorine atoms from the polychlorinated biphenyls,
leaving the simple unsubstituted biphenyl. The decontaminated fluids are
generally reused but are not required to be reused. The following three
reuse processes have been demonstrated:
• Colloidal Sodium;
• Sodium, Naphthalene and Tetrahydrofuran; and
• Sodium, Polyethyleneglycol and Oxygen (DOE 1982, Kokoszka and
Kuntz 1985)
A number of other alternative methods not involving chemical dechlorination
are in the experimental stage including:
• Plasma arc pyrolysis;
• High-temperature fluid wall reactors;
• Light activated reduction;
• Countercurrent, rotating plate solvent extraction;
• Catalytic wet oxidation; and
• Genetically engineered microorganisms.
~Carcasses are drained, filled with a solvent, held for 18 hours and drained
again before landfllllng.
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Physical separations include:
• Centrifugation;
• Filtration;
• Reverse Osiuois;
• Distillation;
• Electrophoresis;
• Adsorption; qnd
• Solvent extraction.
Of these, the only ones which have been demonstrated on PCBs so far are several
kinds of filtration, distillation, adsorption and several varieties of solvent
extraction.
4.2 ACTIONS AVAILABLE TO EPA
EPA has three options under TSCA in responding to a permit application.
The request can be approved, it can be approved with certain specified condi-
tions, or it can be not approved.
4.2.1 Approval
Approval would allow UNISON to operate the process at the Henderson
facility subject only to operating protocols proposed by UNISON in its appli-
cation. These protocols cover key areas of plant operations, including
instrument and control settings, calibration techniques, laboratory pro-
cedures, safety rules, employee health check-ups, alarm systems, driver
training, transportation routes, reporting periods and forms, processing
rates, security measures and so on. EPA has never granted a permit appli-
cation under TSCA subject only to protocols proposed by the applicant.
4.2.2 Approval With Conditions
Approval with conditions would allow operation of the facility according
to UNISON's proposed operating protocols subject to additional conditions
Imposed by EPA. EPA has always imposed the general conditions listed in
Appendix 3. Additional conditions specific to the particular project have
also been imposed. These are used to clarify any matters in the permit
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application which are vague or ambiguous and to impose additional health,
safety or operational protocols when EPA determines that these might
reasonably lessen risks associated with the facility (Section 7.0). If UNISON
objects to any of the additional conditions, it may decide not to operate the
facility, or it may petition for a modification. Should UNISON petition for a
modification, the facility must be operated, if at alL, in compliance with the
disputed conditions until EPA makes a final ruling.
4.2.3 Non-Approval
Non-approval constitutes the "no action" alternative in this case. If
this option is selected the facility would not be permitted to operate. EPA
does not approve whenever it determines that a process may present an un-
reasonable risk to health or the environment. EPA also does not approve if
the demonstration test does not satisfactorily establish that the process can
achieve complete destruction (see 51 FR 6426 in Appendix 1). EPA will
determine whether the process for the proposed facility works based on
analyses of the TF-1 to be recovered. The levels of PCBs in the TF-1 must be
below the detection limits of the test. Failure to successfully demonstrate
the process is a common reason for non-approval. However, non-approval can be
based on any deficiency presenting unacceptable risks. After non-approval, an
applicant may correct noted deficiencies and petition for a second demon-
stration test or EPA review.
4.2.4 Effects of Non-Approval (the "No Action" Alternative)
The bulk of this report describes effects anticipated if UNISON is
allowed to operate. This section describes what could be expected if UNISON
is not allowed to operate.
The majority of PCB filled transformers are being kept in service. New
transformers with PCBs cannot be manufactured and existing transformers are
only allowed to stay in service "for the remainder of their useful lives," 40
CFR 761.30(a). Certain maintenance procedures are allowed to keep them
functioning properly, 40 CFR 761.30(a)(2). A small percentage of these
transformers develop leaks each year and contaminate surrounding soils until
they are discovered and cleaned up.
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A much smaller number short-circuit and spark away until they are noticed
by maintenance personnel or automatic safety equipment turns them off. During
this sparking, small amounts of PCBs are converted to certain carcinogenic and
toxic chemicals called dioxins and dibenzofurans (NIOSH 1984). One of these
chemicals (2,3,7,8 TCDD) has been previously characterized as "one of the most
toxic substances known to man," and as "the most potent carcinogen" EPA has
evaluated (50 FR 29174). These chemicals, together with the PCBs from which
they formed, can be carried by the soot and smoke caused by the sparking and
drift through the air. Many transformers are cooled by ventilation systems
that draw air from around them and distribute it throughout the building.
When this happens, very serious damage is often caused because everything the
soot contacts becomes contaminated and is dangerous to touch or work around
(NIOSH 1986, EPA August 1984).
A fire on February 5, 1981 generated an estimated half an ounce of these
toxic materials. The materials contaminated an office building in which 700
people worked in Binghampton, New York, After more than five years of cleanup
efforts and more than $30 million, the building still cannot be used. Working
in the building might still present a risk of getting cancer.
EPA is very concerned about incidents like this because serious trans-
former fires appear to be happening to 0.003 to 0.004 percent of all large
transformers located near commercial buildings each year (EPA June 1985a).
There are more than 75,000 such transformers (see Appendix 4).. These trans-
formers are, on the average, expected to last another twenty years. EPA
estimates there will be another 50 serious incidents before these transformers
are decommissioned (50 FR 29179). The cleanup costs alone are estimated at
$399 million (50 FR 29188). "Given that a single serious PCB Transformer fire
in a commercial building can potentially expose thousands of people to PCBs
and oxidation products in soot in air, water or on surfaces, EPA has concluded
that PCB Transformer fires... pose significant risks to human health and the
environment" (50 FR 29186).
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TSCA does not allow the immediate banning of these transformers since it
would result in a loss of needed electric power throughout the country. Manu-
facturing capacity does not exist to replace the transformers rapidly. The
costs for replacement, if possible, would be high. EPA amended the PCB regula-
tions on July 17, 1985, to protect public health and the environment in these
circumstances (40 CFR 761, 50 FR 29179) adding the so-called "fires" rule,
wh ich:
• Requires removal of the most dangerous* (high voltage*) PCB transformers
from commercial buildings by October 1, 1990;
• Requires installation of special* sophisticated circuit breakers* and
other electrical safety equipment* on the less dangerous PCB trans-
formers which are being allowed to stay in service in or near commercial
buildings;
• Prohibits anyone from moving an existing PCB transformer* to the
vicinity* of a commercial building*;
• Requires registration and marking of all dangerous PCB transformers*
with local fire departments and building owners, and notification of
the National Response Center whenever there is a fire*; and
• Requires removal of anything which might burn* from storage* around
PCB transformers.
In conclusion, the No-Action Alternative does not involve simple maintenance
of the status quo. Rather, it involves a variety of changes with regard to
PCBs and PCB transformers. EPA realizes that making these changes will be
expensive for the nation as a whole and transformer owners in particular.
Cost estimates are complex (EPA June 1985b) but totals near $2 billion are not
unrealistic. The choices for transformer owners are few. The high-voltage
transformers must either be removed or decontaminated. The low-voltage trans-
formers could be decontaminated or retrofitted with special safety equipment.
Transformers taken out of service permanently are drained of the bulk of
their PCBs, rinsed once and buried in landfills under requirements listed in
40 CFR 761.60(b)(1)(B). The transformer carcasses usually contain substantial
quantities of PCBs that do not drain or rinse nut readily.
*These concepts are defined more precisely in the regulations.
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Therefore, if there is no way to decontaminate existing transformers, the
costs of removal or safety retrofitting must be borne by transformer owners.
The disposal of PCB contaminated carcasses in landfills also has associated
environmental and economic costs which must be considered.
The extent to which the above costs might be avoided if UNISON is allowed
to operate is one of many factors EPA has weighed in determining whether to
grant or deny the permit. This is required by TSCA Section 6(c)(1)(C) and
(D). Savings to transformer owners are discussed in Section 5.1.4.
4.2.5 Alternatives Available to Transformer Owners
Decommissioning, or removal from service, has been discussed in the
previous section. This section covers available methods of decontamination.
Several methods are permitted and in current use. It is not necessary to
describe in detail how each works. All of the existing methods have one or
the other of two drawbacks. The first major group of processes can only be
used on transformers with low concentrations of PCBs because these processes
have not been demonstrated to be effective on high concentrations (the fires
rule applies only to transformers with a high PCB content). The other group
of processes requires that the transformers be temporarily taken out of service
while they are cleaned. Cleaning can take several months to a year.
UNISON's process is the first to show real promise of avoiding both
drawbacks because the TF-1 acts both as a solvent to extract the PCBs and as a
temporary dielectric fluid so the transformer can remain in service.
4.3 OTHER REGULATORY PROCESSES
EPA is not the only regulatory body from whom UNISON must secure a
permit. UNISON is subject to regulations at every level of government,
including building, fire and electrical inspectors, the City of Henderson
sanitary district, the County Zoning Commission, the state Environmental
Cabinet, and OSHA, EPA and other agencies at the Federal level. In deference
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to the authority of each of the other agencies in its own area of
jurisdiction, EPA will not allow UNISON to operate unless all agencies approve
the project.
The key agency at the county level is the Henderson County Board of
Zoning Adjustment (HCBZA). The HCBZA has exercised jurisdiction over UNISON
on the basis of UNISON'.s use of storage tanks for holding materials in various
stages of the process. The HCBZA has the responsibility of protecting public
health and the environment from dangers that might be associated with such
storage. After an investigation and several hearings, the HCBZA granted
UNISON permission to operate at the site under certain conditions. This is
the Conditional Use Permit recorded in Book 4, page 121 of Proceedings of the
HCBZA. The conditions themselves are comprehensive and too numerous to review
£
here. Possible effects of operations at the plant on residents of the area
were considered. The HCBZA had no authority to demand engineering details of
the plant itself although possible quantities of hazardous materials present
were reviewed.
The key agency at the state level is the Kentucky Natural Resources and
Environmental Protection Cabinet, Department for Environmental Protection
(KDEP). Two divisions within KDEP have jurisdiction over UNISON, the Division
of Air Pollution Control and the Division of Water. The former has juris-
diction over any vapors which might come from the site, the latter over any
waters, including surface runoff of rainwater. EPA has been working in close
cooperation with both divisions within KDEP throughout this project.
The investigation within the Division of Water has been the less com-
prehensive of the two because materials being processed at the plant are
isolated from sewer lines and natural drainage from the site by a number of
containment structures in conformity with KDEP and EPA regulations and NIOSH
recommendations covering PCB processing facilities. Of course, a thorough
examination of possible releases from the site and runoff routes has been
made. However, once the Division of Water confirms adherence to the contain-
*However, the Conditional Use Permit is reprinted in Appendix III.
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merit regulations, issuance of a permit under the Kentucky Pollutant Discharge
*
Elimination System can be expected .
Investigation within the Division of Air Pollution Control has been more
comprehensive. There are eight vents coming from various parts of the process
which emit vapors. Each of these vent lines is fitted with a variety of traps
and condensers to contain vapors within the plant, and indeed within the
system itself so that workers are not exposed. Each vent line passes through
a bed of activated carbon at its terminus before releasing gases to the outside.
The Division of Air Pollution Control has attempted to determine the volume
and mass of vapors of each kind of chemical inside the plant which might pass
through the vent lines during ordinary and extraordinary operations at the
plant.
These calculations are based on well tested principles and the known
characteristics of each of the chemicals and devices in use. However, in
their analysis, the Division of Air Pollution Control had to make certain
simplifying assumptions to keep the calculations manageable. The assumptions
overstate the actual amount of vapors. For example, there is no way to
calculate the actual amount of vapors which come out of a drum when it is
opened. The drums contain fluids from different transformers, they are filled
and later opened at different temperatures and the amount of air space above
the liquid in the drum varies. Drums are expected to be filled warm, opened
at room temperature and have only about three gallons of air space at the top.
The KDEP analysis is based on drums filled at 50°F (10°C), opened at 86°F
(30°C) and having ten gallons of air space. This vapor calculation gives
values which are certain to be more than what might actually occur. The other
calculations are similarly conservative.
*The proposed permit, number KY 0082571, became available as this document
was undergoing final editing. The Division of Water proposes to require
monthly monitoring of rainwater runoff for possible contaminants along with
comprehensive preventative measures, the Best Management Practices Plan.
Like HCBZA, KDEP is requiring a baseline survey to establish existing levels
of contamination at the site and in the ditches downhill.
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By adding together the vapors produced in each part of the process and
then accounting for the effects of pollution control devices, KDEP obtained a
total emission rate of 400 pounds per year total organics. Using this value,
a computer model was run of atmospheric dispersion around the plant to determine
where the vapors might blow. The Industrial Source Complex (ISC) model was
used. The computer was given five years of weather data from the Evansville
Weather Station and the calculated quantity of vapors emitted. Long experience
with the computer model used has shown that it accurately predicts the movement
of emissions from industrial facilities. Similar modeling conducted by EPA is
described in Section 5.1.1.
Based on the results of this work, the Division of Air Pollution Control
determined to grant UNISON a permit to construct the facility. (Permit number
C-85-264, File number 077-1760-0099). The Air Division will review its work
and additional data to be submitted by UNISON before issuing an operating
permit.
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5.0 PUBLIC HEALTH AND ENVIRONMENTAL EXPOSURE ASSESSMENT AND RISK EVALUATION
This section develops estimates of the potential exposure of the public
to hazardous materials related to UNISON's activities both in Henderson and
around the country. It develops estimates of how great those exposures are
likely to be and their duration. It discusses concerns raised by the public,
by other agencies and by EPA. Questions raised about possible exposures due
to events which EPA believes are extremely remote or cannot occur are also
discussed. In each case, the strength of the evidence on which the assessment
was based is reviewed.
The discussion is divided into three broad areas. Section 5.1 deals with
ordinary operations, while Section 5.2 deals with accidents and disasters.
Section 5.2 is further divided into disasters at the plant site and accidents
during materials transportation. Section 5.3 evaluates the risks associated
with the exposure estimates developed in Sections 5.1 and 5.2.
5.1 ORDINARY OPERATIONS
This section estimates health and environmental exposures related to
ordinary operations at the facility. The bulk of the discussion covers air
emissions since no surface water or groundwater emissions are expected from
ordinary operations.
5.1.1 Air Emissions
Air emissions from the facility during ordinary operations were estimated
in cooperation with KDEP as described in Section 4.3. Total emissions will be
less than 400 pounds per year, probably much less. This is a little more than
one pound per day, or about three quarters of an ounce per hour. These
emissions will be almost entirely TF-1 vapors (99.99+%). They are expected to
contain less than 0.0001% PCBs (less than one part per million).
A breakdown of the chemical composition of the vapors was derived from
the known characteristics of materials to be used at the plant and the nature
of the parts of the process which generate the vapors. These figures cannot
be given in this report because they are derived from confidential business
5-1
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information. However, the analysis of risk in Section 5.3 is based on this
complete breakdown with one exception. For toxicological purposes, EPA uni-
formly made worst case assumptions that raised the concentration of PCBs by a
factor of ten to twenty depending on the circumstances. The concentrations of
the other organic vapors were adjusted downward slightly so that the totals
would remain 100%.
Using a method similar to that used by KDEP, EPA entered the 400 lbs/yr
vapor emission rate into a computer program (ISC model) along with Evansville
Weather Station wind and temperature data. The output from the program gives
average annual concentrations at thirty different distances from the plant
along the cardinal points of the compass, i.e. North, North-northeast, Northeast,
East-northeast and so on. The distances ranged from 0.17 km (0.1 miles) to 50
km (thirty miles). Similar results are obtained using the simpler model given
in Versar (1984 Vol. IV).
By interpolating between data points, estimates were made of average
annual concentrations at three nearby receptors. The highest average annual
concentrations found were at the Riverport Warehouse and Docks. There are
usually twelve employees there. The concentration of organic vapor at the
warehouse was predicted to average 82.7 nanograms per cubic meter (parts per
trillion*).
If these vapors were 100% PCBs, they would still meet EPA and NIOSH
standards for workplace air. Those standards were set twelve times higher at
1,000 nanograms per cubic meter based on a large body of data which supports
the belief that one could work in such air 40 hours per week without risk of
injury.
*Nanograms per cubic meter are only very approximately parts per trillion.
The first measure gives the mass of contaminants in a given volume of air,
the latter gives the weight of contaminants in a given weight of air. The
former is not affected by temperature, the latter, however, changes as air
gets more dense in the cold or less dense as it heats up. Because nanograms
and cubic meters may be unfamiliar to many readers, we have included parts
per million, billion or trillion at various places in the text. The two
systems are identical only at 176 F (808C). At 778F (258C), the actual
parts per million, billion or trillion is about 30% less than the value re-
ported in the text.
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The second highest annual average concentration of those examined at the
three nearby receptors was at Henderson Community College, just over a mile
South-southeast of the plant. The concentration here was predicted to be 9.45
nanograms per cubic meter (parts per trillion) or a little more than one tenth
of the concentration at the Riverport Warehouse and Docks.
The third location examined was a residence located 1.4 km (0.84 miles)
west of the facility on Highway 136 just across the street from the airport.
Although a little closer than the College, it is upwind more often and because
of this the concentration will average only 8.48 nanograms per cubic meter
(also about one tenth of the Riverport Warehouse concentration). A complete
printout of the annual average predicted values is included in Appendix 5.
Concentrations, of course, decrease with Increasing distance from the
facility. At Henderson City Hall, concentrations were predicted to average
3
0.58 ng/m , while at the Evansville Civic Center they would average 0.06
ng/m3.
The 1980 census data was combined with the distribution of vapor concen-
trations to find the total quantity of vapors to which various groups around
the facility would be exposed. The major assumption used was that each person
breaths in 22 cubic meters of air in a day.
According to the 1980 census data, 383,151 people live within 50 km
(approximately 30 miles) of the facility. All these people together would
Inhale a total of about 0.59 grams of organic vapor per year or about two
hundredths of an ounce. Of course, this total is not divided evenly. People
closer to the facility would Inhale disproportionately more. 21,932 people,
mostly in Henderson County, would inhale just over half of the total amount.
The 2419 people in the closest census tract would inhale just under a third of
the total (7.81 X 10-^ grams/person/year). The greatest concentrations will
be to the Southeast.
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There are no known effects on nearby flora and fauna of concentrations
this low. The health effects of these concentrations and the other concen-
trations reported in Sections 5.1.2 through 5.2.2.5 are covered in Section
5,3. "Normal" background concentrations of PCBs in air are sufficient to
cause exposures of 3.5 X 10-7 grams/person/year in rural areas and 3.5 X 10 5
grams/person/year in urban areas (Versar 1984 Vol.1).
5.1.2 Surface Water Releases
Surface water releases will not occur during regular operations. All
processing is performed inside the containment structure. Loading and un-
loading activities are within buildings which are enclosed except for the'
r>laces where trucks drive in and out. Loading and unloading areas are graded
and diked to contain any spills (minor in-plant spills are considered a part
of ordinary operations). Drums trucks have a dual-layer inner-liner contain-
ment system so that leaks cannot escape the vehicle. Tankers also have special
fittings which make leaks extremely unlikely. There are no pipes leaving the
facility other than the sewer line and the plant sewerage system does not
serve the PCB processing areas.
5.1.3 Groundwater Releases
Groundwater releases will not occur under normal operating conditions.
There are no underground lines containing PCBs or other hazardous materials
which could leak. The only underground lines are the water lines bringing
drinking water to the plant and the sewer line serving the lavatories. All
sumps in the facility (places where spills would run) are "blind" in that they
have no outlet and must be sucked out with a pump and hose in the event of a
spill. All concrete surfaces in the plant are sealed with a material that is
£
relatively impervious to PCBs to minimize leakage through the concrete. As
*40 CFR 761.65(b)(l)(iv) requires storage facilities to have "Floors and
curbing constructed of continuous smooth and impervious materials, such as
Portland cement concrete or steel . UNISON s coating, applied to concrete
surfaces in the plant at a cost of approximately $100,000, goes well beyond
EPA requirements. The coating, a three layer system manufactured and applied
by Products Research Chemical Corporation of Glendale CA, absorbs less than
0.001 ounces per square foot when soaked in PCBs for 14 days. Under similar
conditions, untreated concrete absorbs 4.7 oz./ft2.
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noted in Section 5.1.2, trucks are not expected to leak on the drives and
roads outside of the facility.
5.2 ACCIDENT EXPOSURES
Accidents may happen at the facility or they may happen during transpor-
tation. On-site accidents are considered in Section 5.2.1 while transportation
accidents are considered in Section 5.2.2.
5.2.1 On-Site Accidents
Discussions with the public, within the Agency and with other agencies
generated a list of major types of accidents and/or disasters which could
occur at the facility. These include the following:
• Processing Failure
• Pollution Control Equipment Failure
• Fire or Explosion of Materials Being Processed or Stored
• Earthquake
• Flood
• Tornado
• Airplane Impact
• Meteor Impact
• Nuclear Explosion
• Terrorist Bombing
Not all of these types of disasters merit additional detailed discussion.
Meteor impacts, nuclear explosions and terrorist bombings affecting the site
are exceptionally unlikely and there is no good way to predict them. They
have Little relation to what will actually occur at the site and, as far as
anyone can predict, are about as likely to happen in one place as another. In
the case of nuclear explosions, PCB contamination would be the least of our
worries. The case of meteors is similar. Large bodies striking anywhere in
Henderson County or small bodies at relativistic velocities would have blast
and radiation effects like a nuclear explosion. Intermediate force meteors
would seem to have the greatest potential for adverse effects due solely to
the spread of contaminants, but the probability of such meteors is so small
that it appears inappropriate to conduct further analysis. The potential for
a terrorist attack on the facility certainly exists, but it appears remote and
5-5
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we know of no way to measure the risk. No further discussion will be devoted
to these scenarios.
The other listed disasters will be covered in some detail. They are
discussed in the following sections in the order they appear in the iist.
5.2.1.1 Potential for Releases due to Process Equipment Malfunction
An engineering study of the process and processing control system un-
covered nothing which might release hazardous materials outside the plant
other than vapors (fugitive emissions) from leaks and spills.
There are many hazards within the plant which require caution, proper
implementation of procedures, and on occasion, protective gear. However, with
respect to the environment outside, the plant is designed with substantial
inherent safety. All operations are carried out inside containment basins
capable of holding the entire contents of all vessels and tanks simultaneously.
Containment, except for small quantities of vapors, would not be compromised
by a complete power outage. All containment is passive. There are no dangerous
contained gases on the premises other than the liquid nitrogen and this gas
presents only minimal cryogenic and asphyxiation hazards. Nitrogen presents
no hazards to those off-site. There are no chemical reactions utilized on-site
and no potential reactions or cross-reactions in which materials present might
participate. No combustible materials are stored at the site. In summary,
there is nothing on-site which could produce a disaster off-site by merely
failing or from causes within the plant itself.
If part of the process does fail, such events will be detected before any
release could occur inside the plant. Dozens of process parameters are monitored
continuously by a redundant computer and alarm system so that the process will
produce a clean separation. Anomalous readings cannot persist for long and
values cannot drift far from their set points without triggering a variety of
responses from the control system. Corrective adjustments are made continously.
Adjustments and low level alarms are triggered by any significant drift.
Substantial drift triggers high level alarms, and if the drift could increase
certain hazards, initiates emergency shutdown. The control necessary to
5-6
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produce a clean separation is within closer tolerances than that required for
safety reasons.
Minor spills and leaks can be expected to occur from time to time. There
is no basis at this time for judging either the size or frequency of these
events. However, the air permit to be issued by KDEP will forbid release of
PCB vapors to the atmosphere in detectible quantities and will limit the
amount of other vapors to safe levels. Based on a study of engineering details
of the plant, it appears unlikely that emission limitations will be exceeded
due to in-plant accidents.
Sabotage, however, could result in a substantial release of vapors.
Minor sabotage could be accomplished by anyone with access to the facility and
a few simple tools. Minor sabotage, however, would not threaten health or the
environment off-site. This sort of sabotage could only cause minor leaks and
spills. Major damage could only be accomplished by someone with access to the
control panels and an Intimate knowledge of the computer codes used to program
the control and alarm systems. Sabotage on this scale could result in releases
similar to those discussed in Section 5.2.1,7.
In summary, there is very little potential for releases due to process
equipment malfunction.
5.2.1.2 Potential for Releases Due to Pollution Control Equipment Failure
UNISON's pollution control system is simple and can be expected to be
reliable (Lees 1980). The plant has eight vents which release emissions to
the atmosphere. At each of the eight vents, vapors pass through beds of
granular activated carbon that adsorb the organic vapors and allow the air to
pass through. As a precaution against failure, each treated stream of air Is
monitored for the presence of organic vapors. If organic vapors are detected,
the monitor activates the main plant alarms, which are the same alarms thajt
would go off if one of the process tanks developed a massive leak. If it ever
goes off, it is unlikely to be ignored.
5-7
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The activated carbon beds are periodically emptied and replenished. The
schedule on which this is done is based on extremely conservative assumptions.
Consequently, if carbon is not changed on schedule, it is unlikely to result
in vapors even getting to the detector, much less past it. For a release to
occur, UNISON must either fail to replenish the carbon for a long time or it
must empty the used carbon and not replace it at all.
Even under these circumstances, a release could not last more than a few
minutes unless either the monitor or the alarm system fails at the same time.
Since the monitor is scheduled to be checked once each shift and recalibrated
once per week, more than a few people have to neglect their duties and the
monitor must fail for a release to be prolonged.
EPA is not aware of any way to estimate the chance of simultaneous equip-
ment failure and multiple party negligence. Nonetheless, an air model, INPUFF,
(EPA October 1984) was run using input data which assumes one of the carbon
units does in fact become overloaded from not being changed and that the full
strength of this stream is discharged to the air above the plant. Because the
emission rate is constant, concentrations downwind soon reach equilibrium.
They maintain the same value until the vent is fixed or the wind changes. The
worst wind conditions are low velocities and stable patterns. At 2.5 m/s wind
speed and stability class E, downwind concentrations in nanograms per cubic
meter (ng/m3, parts per trillion) would be:
These vapors would be almost entirely TF-1. The vapors would be less than
0.002% PCB's. The effect of such concentrations is discussed in Section 5.3.
Distance (m)
Concentration (ng/m3)
300
500
1000
2000
4000
3549
1567
470.7
141.5
34.97
5-8
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5.2.1.3 Potential for Fire or Explosion Related Releases
Fires or explosions occur whenever conditions favor rapid oxidation or
combustion. Generally, this means three ingredients must be present:
• A fuel - something capable of oxidizing rapidly (technically, an
electron donor);
• An oxidizer - usually air or some other source of oxygen, but any
material will do which can rapidly accept the electrons given up by
the fuel; and
• A spark, flame or sufficient heat for autoignition (Sax, 1979).
With minor exceptions, none of these ingredients is present at the facility.
Fuels
PCBs, TF-1 and TF-2 are inherently incapable of behaving like fuels
(NIOSH 1977; Versar 1983 Vol. III). Technically, they can be burned in
high-temperature, high-oxygen environments of special incinerators, but they
have no potential for burning outside such environments. The potential for
sustaining combustion is measured in a laboratory test by attempting to light
the vapors above a pool of the liquid. If the vapors do not burn at low
temperatures, the liquid is heated until the vapors do burn or until the
liquid boils away. This is called the fire point test. A variant is called
the flashpoint test. The value reported is the temperature at which the
material will burn.
Gasoline and alcohol, for example, will both burn at room temperature.
Diesel fuel, however, will not; it must be heated to at least 100°F before it
will burn in a closed container and even higher before it will burn in open
air. PCBs, on the other hand, have no fire point; they can only be burned if
they are heated well above their boiling points (ASTM D2283, NIOSH 1977). The
¦ i
American Society for Testing and Materials has also tested TF-1 and TF-2 for
both flashpoint and fire point and has reported that, like PCBs, these materials
will not support combustion (the citation for this report cannot be given
without revealing the composition of these materials). Some of these materials
5-9
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have a pseudo-flash point below the boiling point. This does not indicate a
fire hazard. Such flashing happens because the material used to create the
test flame contributes fuel to the test material to create a pseudo flash.
Once the flame producing material has burned, the TF-1 and TF-2 cannot sustain
combustion.
There is no storage of combustible materials at the plant. Wooden benches,
originally specified for the employee locker rooms, have been replaced with
steel benches. To the extent possible, all combustible materials are absent
from the plant.
Oxidizers
UNISON's processing system at Henderson is totally enclosed, in com-
pliance with EPA and NIOSH directives on the handling of PCBs. There are no
open vats or containers in the entire process except the vent lines going to
the air pollution control system from the area where drums are opened.. These
are necessarily open at the input end in order to scour vapors from the work-
place air. Special measures are taken throughout the plant to make sure air
does not come into contact with the materials being processed. The space
above the liquid in various tanks and containers is filled with nitrogen, an
inert gas, rather than with air. This has been done to protect the TF-1 from
the small amount of moisture usually present in air (i.e., humidity) because
small amounts of water can ruin the electrical properties of TF-1. Of course,
it has the added benefit of keeping oxygen away from the material, and hence,
doubly insuring that no combustion can take place.
Sparks. Flames and Heat
All of the more likely sources of sparks and flames have been eliminated
from the processing area. Smoking is prohibited anywhere within the reprocessing
center. While this is primarily a health measure designed to prevent inadvertent
PCB contact with lips and mouth, it also serves to eliminate the most common
source of flames.
5-10
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Similarly, electrical equipment in the processing area is all contained
within sealed enclosures following standards contained in Class I, Group D,
Division 2 of the National Electrical Code. These standards are not required
by the electrical code for this type of facility but appear to have been
followed more to protect the electrical equipment from possible PCB contamina-
tion than for safety reasons. Nonetheless, they serve to keep a common source
of sparks away from possible vapors.
One source of sparks and flames not eliminated is from welding operations
which may be necessary at some future date in connection with repairs. Here
again, health measures Intended to protect workers from PCB vapors also serve
to keep sparks and flames away from possible vapors. Repairs can only be
performed under the Hazardous Work Permit provisions of UNISON's Health Plan
which calls for testing the air in the area for the presence of organic vapors
before the work can proceed. Hence, this possible ignition source, although
not eliminated, is at least segregated. Given the non-flammable nature of
materials in the plant, this would not have been required merely for fire
prevention.
Other sources of sparks not eliminated are static electricity, the
scuffing of shoe nails on concrete and so on.
While sources of sparks or flames are virtually absent from the facility,
there are sources of heat. The residue tanks, for example, must be kept warm
to prevent the residues from solidifying; they are too thick to pump at room
temperature. These heat sources have been carefully examined with regard to
the possibility for a runaway heating event. A number of scenarios were
analyzed where runaway heating could occur, but they all involved a number of
peculiar and unlikely events happening simultaneously. The chance of this
happening was determined to be so small that it did not warrant further
analysis.
5-11
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Potential for Fire
After careful review of the data presented above, it was determined that
a fire was not possible from causes within the facility itself. Fire could,
however, occur in connection with a terrorist incident or an aircraft impact
(see Section 5.2.1.7).
5.2.1.4 Potential for Earthquake Related Releases
Although it is not widely known outside the region, the Central
Mississippi Valley is one of the most seismically active areas in the world.
In the winter of 1811-1812, three large earthquakes centered near New Madrid,
Missouri, rocked the region. Witnesses wrote that the ground moved vertically
several feet as well as horizontally and that large amounts of sand and
sulfurous gas were spewed out. For a brief period, the flow of the Mississippi
River appeared to be reversed. A cypress forest in northwestern Tennessee was
lowered several feet and formed what is now known as Reelfoot Lake v(Eblen
1986).
Various estimates of the magnitude of the December 1811 earthquake exist,
but all place it above 8.3 on the Richter scale (see Figure 6). Some authorities
rank it among the most powerful earthquakes of all time. Two aftershocks
early in the following year were of a force comparable to the recent earthquake
that toppled buildings in Mexico City.
Concern that a major earthquake may again rock the Central Mississippi
Valley has generated demands that the potential earthquake Impacts on UNISON's
facility be thoroughly investigated before it is allowed to operate. This
section discusses potential earthquakes and their effects, Including: (1) a
description of the fault system and causes of earthquakes in the area; (2)
estimates of the probability of earthquakes of various magnitude; and (3) a
description of potential effects Including possible releases of hazardous
materials at the site.
5-12
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10 11 12
Figure 6. Richter earthquake scale and distribution of earthquake magnitudes.
5-13
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The New Madrid Fault System
The New Madrid Fault System is named for the Missouri town located at the
epicenter of the 1811-1812 earthquakes. It consists of numerous irregularly
overlapping faults (weak points) in the bedrock several thousand feet below
the surface that criss-cross each other in a broad zone that starts near
Memphis at the southern end (Figure 7). From there it runs north-northeast
under the Mississippi River to southern Illinois. Near the confluence of the
Ohio River and the Mississippi, the fault splits. One branch runs beneath the
Mississippi River ending south of St. Louis. The other runs east under southern
Illinois until it also splits. Here, one branch turns north, following the
Wabash Valley halfway up the western border of Indiana. The other continues
east under the coal fields of Western Kentucky. The latter fault zone is
located near the southern boundary of Henderson County beneath the towns of
Tilden and Sebree, and is sometimes called the Cottage Grove or Rough Creek
fault zone (see Figure 8). Other smaller faults have been found in surround-
ing areas in deep bedrock, although none have been found beneath Henderson
County itself.
The origin of this deep faulting along the new Madrid zone has been
obscure until recently. Geologists now believe that thi«? „ 4 ^
zone coincides with
a very ancient rift (about 600 million years old) which began to break apart
the landmass now known as the North American continent u
um-inent. However, the rifting
subsided before the continent was split. After the. Hf.4
r the rifting abated, a zone of
weakness remained but lay dormant for hundreds of mnu
millions of years. Then,
approximately 65 million years ago, the combined continentai
, „ continental mass composed of
Europe, Africa, and the Americas (which had drifted
® her) began to separate
to form the Atlantic Ocean. This mid-Atlantic rifiM™ <
solns on todflv
and North America continues to drift westward Cn
... . . . * mPre8sive forces associated
with this movement are theorized to have t.
reactivated the ancient fault svnt^n
within the New Madrid rift zone. These forces ar*
strong enough to periodically
create powerful earthquakes like the ones centPr»H
centered near New Madrid in 1811/1812
Extremely weak tremors occur nearly everv dav 1811/181/.
. along this zone, although few
are strong enough to »e felt. Noticeable but generally ,
every few years. Massive quakes occur every several h a ^
1983). 7 S6VeraL hundr^ years (Nuttli
5-14
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5-15
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Figure 8. Rough Creek fault zone. Based on the number 7 coal horizon (Maxwell and DeVaul 1972).
-------
Recent studies have shown that seismic activity is concentrated along the
main north-south New Madrid rift zone (Figure 9). The most likely earthquake
to affect the UNISON site would have its origin 100 to 150 miles to the west
or southwest along this zone. However, an east-west trending fault zone (the
Rough Creek fault) lies less than 15 miles to the south of the facility. This
zone is an inactive branch of the active New Madrid zone to the west; no major
tremors or earthquakes have been recorded along this zone (Figure 8). If the
currently accepted model of earthquake activity in the area is correct, the
Rough Creek fault zone could not give rise to a major earthquake. However, if
it is wrong, one must concede some remote chance of a major earthquake with an
epicenter near Henderson County. Such a quake would theoretically be capable
of doing greater damage than a quake near the Mississippi and could conceivably
destroy the facility. However, resultant severe soils contamination would be
of little consequence compared to the loss of nearby cities.
Chance of an Earthquake During the Life of the Facility
The chance of a major earthquake occurring near the site has been
estimated by scientists using accepted theory that it would occur near the
Mississippi. The USGS estimates that there is only a 10% chance that ground
motions due to an earthquake will exceed four or five percent of the
acceleration due to gravity at any time in the next fifty years in the
Henderson area (USGS 1972). This estimate is based on a calculation of the
forces which have built up in the deep layers of rocks. There is a 90% chance
that no earthquake of this magnitude will occur. If it does occur, objects
near Henderson will move sideways as though they were being moved by a force
about four or five percent as strong as gravity ordinarily pulls downward
(Figure 10).
The force-of-gravity estimate is stated differently in a more recent
study by the U.S. Geological Survey (Hopper et, al. 1983). Instead of
accelerations due to some fraction of gravity this study uses the Mercall
8cale, which directly relates the kind of damage an earthquake might do (Table
2). The USGS estimates that if the New Madrid earthquake of 1811 were ever
repeated, Henderson County would experience destruction at the levels of VIII
®nd IX on the Mercali Scale. Under these conditions, the UNISON site would be
®*pected to be hit by forces which would reach IX on the Mercali Scale.
5-17
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5-18
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Figure 10. Earthquake Risk Zones (Isolines show
the percentage of the force of gravity with
a 10Z chance of being exceeded in fifty years).
-------
Table 2. Mercali earthquake intensity scale and levels of damage caused
by quakes of various magnitude [Photocopied from Strahler (1981)].
The Modified Mercalli Intensity Scale (Richter, 1956)
The quality of masonry, brick or otherwise, is specified by the following letter code
Good workmanship, mortar, and design; reinforced, especially laterally, and bound together by using
steel, concrete, etc ; designed to resist lateral forces.
Good workmanship and mortar; reinforced, but not designed in detail to resist lateral forces
Ordinary workmanship and mortar; no extreme weaknesses like failing to tie in at corners, but neither
reinforced nor designed against horizontal forces.
Weak materials, such as adobe, poor mortar, low standards of workmanship, weak horizontally .
Intensity
value Description
I. Not felt Marginal and long-period effects of large earthquakes.
II. Felt by persons at rest, on upper floors, or favorably placed
III. Felt indoors. Hanging objects swing. Vibration like passing of light trucks. Duration estimated. May not be
recognized as an earthquake.
IV. Hanging objects swing. Vibration like passing of heavy trucks; or sensation of a jolt like a heavy ball striking
the walls. Standing cars rock. Windows, dishes, doors rattle. Glasses clink. Crockery clashes. In the upper
range of IV, wooden walls and frame creak.
V. Felt outdoors; direction estimated. Sleepers wakened. Liquids disturbed, some spilled. Small unstable
objects displaced or upset. Doors swing, close, open. Shutters, pictures move. Pendulum clocks stop, start,
change rate.
VI. Felt by all. Many frightened and run outdoors Persons walk unsteadily Windows, dishes, glassware broken.
Knickknacks, books, etc. off shelves. Pictures off walls. Furniture moved or overturned. Weak plaster and
masonry D cracked. Small bells ring (church, school). Trees, bushes shaken visibly, or heard to rustle.
VII. Difficult to stand. Noticed by drivers. Hanging objects quiver. Furniture broken. Damage to masonry D,
including cracks. Weak chimneys broken at roof line. Fall of plaster, loose bricks, stones, tiles, cornices, also
unbraced parapets and architectural ornaments. Some cracks in masonry C. Waves on ponds, water turbid
with mud. Small slides and caving in along sand or gravel banks. Large bells ring. Concrete irrigation
ditches damaged.
VIII. Steering of cars affected. Damage to masonry C; partial collapse Some damage to masonry B; none to
masonry A. Fall of stucco and some masonry walls. Twisting, fall of chimneys, factory stacks, monuments
towers, elevated tanks. Frame houses moved on foundations if. not bolted down; loose panel walls thrown out
Decayed piling broken off Branches broken from trees. Changes in flow or temperature of springs and wells
Cracks in wet ground and on steep slopes.
IX. General panic. Masonry D destroyed; masonry C heavily damaged, sometimes with complete collapse;
masonry B seriously damaged. General damage to foundations. Frame structures, if not bolted shifted off
foundations. Frames cracked. Serious damage to reservoirs. Underground pipes broken. Conspicuous cracks in
ground. In aUuviated areas sand and mud ejected, earthquake fountains, sand craters.
X. Most masonry and frame structures destroyed with their foundations. Some well-built wooden structures and
bridges destroyed. Senous damage to dams dikes, embankments. Urge landslides. Water thrown on bank, of
canals, rivers, lakes, etc. Sand and mud shifted horizontally on beaches and flat land. Rails bent slightly.
XI. Rails bent greatly. Underground pipelines completely out of service.
XII. Damage nearly total. Large rock masses displaced Lines of sight and level distorted Objects thrown into
the air.
Source: C F Richter. 0958)^ ^ FrinCisC0' P Minor editonal
changes, following B. A. Bolt. (19.8), Earthquakes. A Mmtr, W. H. Freeman and Company. San Francisco, Appendix C, p 204-205
Masonry types
Masonry A
Masonry B
Masonry C
Masonry D
5-20
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These estimates of the kind of forces which might affect the Henderson
facility, although based on the best evidence, are subject to numerous un-
certainties. Earthquake prediction is a recently developed science, and
confidence in these predictions is far from universal. Because of this, EPA
considers it important to consider what might happen In earthquakes of larger
magnitude than those suggested by the prevailing theories.
Potential Earthquake Effects
Earthquakes are caused by sudden movement of rock along a fault zone, in
response to various kinds of stresses acting within the rocks. Earthquakes
have three potentially devastating effects. First, the energy waves generated
by the quake can literally shake buildings apart. Second, the vibrations can
turn saturated sandy soils into a thick mud-like fluid which can flow. This
effect is known as Liquefaction and can result In the sinking and/or tilting
of buildings which rest upon these soils and the cracking of foundations. The
third major effect is a sudden rise or fall of bedrock. Such changes in
bedrock elevation are almost always confined to the immediate vicinity of the
earthquake epicenter.
Shaking
Mere shaking of the UNISON facility at the recently predicted rate would
have little effect. In the recent earthquake In Mexico City, there was little
damage within the chemical processing industry and none that was sufficient to
cause concern. Much greater shaking, such as might result from a major earth-
quake located in the Rough Creek fault zone, could cause some breakage of
pipes and vessels with resulting PCB leakage within the containment structures.
However, unless the foundation Itself were cracked, a significant release
would not occur. If there were a release inside the building and if the
foundation did crack, some losses to nearby soils could be expected. However,
due to the strong affinity of PCBs for soils, it seems unlikely that even a
heavy rainfall concurrent with the event would result In significant transport
°f the pollutants to groundwater or surface water resources. Because of
strong adsorption of the PCBs by the soil, cleanup of such a release would be
costly but could be complete. Figure 11 shows the limited migration of PCBs
5-21
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Cross-section of PCB Contaminated Soils
Ln
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585 •
580 r
575 h
570 h
565 h
560 h
555 h
550 h
540
500 1000 1500
Horizontal Distance in Feet
2000
Figure 11. Cross-section of PCB-contaminated soils at a site near Waukegan Harbor.
Isopleths show PCB concentrations in micrograms /'gram.
-------
in soils, even sandy soils. The soil cross-section is of a site near Waukegan
Harbor where spills occurred over a period of twenty years. Shaking effects
pose a minimal threat to human health or the environment due to hazardous
materials exposure no matter how great the shaking.
Liquefact ion
Liquefaction occurs when a saturated sandy soil is subjected to rhythmic
shaking or other stress. This stress causes the sand grains to settle and
realign in relation to each other. In this process, expelled water causes the
soil to lose its shear strength or ability to stay firm. As a consequence,
the sandy soils may begin to flow like a dense liquid (Dobry et al. 1981).
There are three effects of liquefaction which could hypothetically
threaten the UNISON site. First, massive and widespread flowage of liquefied
soils underneath the facility might conceivably move the facility towards the
Ohio River (1500 feet away). If this happened, a massive release to the river
would result. Second, the facility might topple as underlying soils lose
their ability to support the foundation. This effect was seen in the Niigata,
Japan earthquake of 1964. Third, as they flow, the soils beneath the plant
might spread in a manner that could tear the facility apart.
The potential for liquefaction is related primarily to the type and depth
of soils beneath the site, the depth to groundwater and the magnitude of the
earthquake Itself. In general, only sandy soils will liquefy. This is due to
larger pore spaces between individual particles. Fine soils such as silts and
clays, in contrast, are not known to liquify. Liquefaction is also increasingly
less probable as depth to groundwater Increases (Seed 1979).
Surface soils beneath the site are of three basic types: Henshaw silt
loam, Robertsville silt loam, and Calloway silt loam (USDA 1967). The un-
«~
consolidated deposits in this area consist mostly of fine grained alluvium and
loess materials derived from the Ohio River (Harvey 1956). Silty to clayey
soils and alluvium underlie the facility to a depth of at least 40 feet.
Because of their fine particle size and great thickness, such materials are
unlikely to experience liquefaction in an earthquake (Seed 1979). However,
5-23
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flowage of deeper sandy layers could in turn cause disruption of overlying
silty soils. There is a thick layer of sand beginning about 50 feet beneath
the facility. Despite this, a major episode of liquefaction at the facility
does not seem likely, but it cannot be ruled out without in situ seismic study
of sediments underlying the site.
If liquefaction does occur, the bluffs along the Ohio River would likely
collapse. However, the plant site is far enough south of the bluffs that it
is impossible for the plant itself to be carried to the River (Figure 12).
The drawings in Figure 12 are vertical planes through the plant running north/
south. The upper drawing has a ten-fold vertical exaggeration to show eleva-
tions more prominently and is typical of such drawings in the geological
literature. The lower drawing is to scale. In the upper drawing, it appears
possible that if the bluffs collapsed the plant could be carried to the river.
In the lower drawing, however, one can see that this is plainly impossible.
Mudslides of any consequence can only occur in hilly terrain. There is no
danger from this effect at the Henderson site.
Toppling of the Henderson plant could not occur although some degree of
tilting is a distinct possibility. Toppling occurs when soils can no longer
support the foundation. Large angles of tilt are only possible with multi-
story buildings. Small angles of tilt are possible, however, even with single
story buildings. If all tankage at the site had ruptured so that the con-
tainment bays were full of fluids, a tilt of about half a degree (approximately
1%) in the north/south direction would be sufficient to cause spillage. While
greater slopes could be tolerated in the east/west direction because of the
shape of the containment structure, the most likely direction of tilt is to
the north. Although tilting is unlikely to be substantial, It is impossible
to rule out slopes of one or two percent. Consequently, if most of the tankage
inside the plant ruptures due to shaking, soils contamination outside the
plant could well occur. If major spillage inside the plant does not occur
(and it will not if the quake only registers IX on the Mercali scale,) tilting
of several degrees would result in no release to the environment.
5-24
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VERTICAL EXAGGERATION = 10X
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-------
The third dangerous liquefaction effect is spreading of surface soils
with consequent cracking and dislocation of foundations. In the San Fernando
earthquake of 1971, most of the damage to the Jensen (water) Filtration Plant
was due to this effect. If similar effects occurred at UNISON's Henderson
facility, it is likely that lines would crack as the foundation broke, re-
leasing contaminants to the soils beneath the facility. While no general
release to the environment would be possible other than vapors of little
consequence, the clean-up would be costly and would likely require demolition
of the facility.
Subsidence
The third major hypothetical consequence of an earthquake would involve
an abrupt uplift or subsidence of the ground surface via movement of under-
lying bedrock. Such effects are almost always confined to the area near the
epicenter of a major earthquake which in this case is likely to be 150 miles
from the site. Unless a major earthquake occurs in the nearby Rough Creek
fault zone, subsidence sufficient to damage the facility is exceptionally
unlikely. If it does occur, the effects would be similar to those caused by
spreading of soils due to liquifaction.
Conclus ions
Of all three earthquake effects, liquefaction appears to have the
greatest potential of directly affecting the UNISON site. However, the
character of underlying soils at the facility suggests that liquefaction
effects, if they occur at all, would be very minimal. Of the three types of
liquefaction described above, some degree of tilting or sinking of the entire
building would be most likely. Any PCB spills resulting from such settling
could be contained within the immediate vicinity of the facility. Similarly,
a spill could be contained if the facility were damaged by a spreading flow
pattern. Large scale flowage of the entire sediment pile into the Ohio River
cannot happen.
5-26
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5.2.1.5 Potential for Releases Due to Flooding
The UNISON facility is located in the Canoe Creek drainage basin, approx-
imately lk miles west of the confluence of Canoe Creek and the Ohio River
(Figure 13). It is located only a few hundred feet south of a low ridge which
rises two to three feet above the level of the property. North of the ridge,
run-off is directly towards the Ohio River; south of it, to Canoe Creek.
Thus, flooding could come from either the Ohio River or from Canoe Creek.
However, since there is virtually no land up-hill from the facility within the
Canoe Creek drainage basin and because it is so near Canoe Creek's juncture
with the Ohio, flooding, if it occurs at all, would have to come primarily
from back-up of the Ohio. Nonetheless, the potential for flooding from both
the Ohio River and Canoe Creek was studied.
A recent study by the Corps of Engineers (COE 1985) reports on the
potential for flooding in the vicinity of the project site:
"Significant flooding on Canoe Creek is caused by frontal system storms
and convective storms. Frontal system events are characterized by rain-
fall that is widespread in aerial coverage and generally moves up the
Ohio River valley on a track from southeastern Missouri to western New
York. Runoff is often increased by antecedent conditions. Convective
storms are typified by the thunderstorm. They are often marked by periods
of intense rainfall for short durations and may be extremely variable in
the area covered.
Flooding on the lower portion of Canoe Creek is controlled by the Ohio
River. Notable floods on the Ohio River at Henderson, Kentucky, include
those that occurred in February 1884, March 1913, January 1937, December
1942-January 1943, March 1945, April 1948, and March 1964. Profiles of
these floods, except the 1884 event, are shown on [Figure 14].
January and February 1937 witnessed levels of flooding previously unknown
on the Ohio River resulting from numerous storms that occurred between 26
December 1936 and 25 January 1937. Rainfall totals for this period
ranged from 8 inches on the northern fringe of the basin to 25 inches
near the center of the basin. An isohyetal map [showing where gnd how
much rain fell] of the Ohio River Basin is shown on [Figure 15] . A
series of reservoirs have been constructed on tributaries of the Ohio
since 1937; therefore, a recurrence of the same flood stages would be
less likely today.
jf
Compare the rainfall pattern on this Figure with the shape of the Ohio Basin
itself shown on Figure 16.
5-27
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I
N*
*>>
A.
'c*ee*
Figure 13. Canoe Creek watershed.
5-28
OHIO RIVCR BASIN
CANOt CUf IK
HCNOCRSON, KV.
BASIN MAP
ORLKD-H
FIB 1BB1
-------
I
CO
H
U1
fx)
fa
400
390
380
370
360
350
as
o
n
<5
5»
«
w 340
330
320
820
810 800
RIVER MILES FROM PITTSBURGH
790
00
Lr.
-------
/
'—V
Figure 15. Total precipitation in inches, December 26, 1936
to January 25, 1937. (COE 1985)
5-30
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-------
A more recent event occurred in March 1964 when two periods of heavy
rainfall produced severe flooding along the Ohio River. Prior to March
1964, soil moisture was seriously deficient in Ohio, Indiana, and Kentucky.
The dry period ended abruptly when rain fell in two periods on 2-5 March
and 8-10 March. Heavy rains during the first period covered a broad area
paralleling the Ohio River from southeastern Ohio to western Kentucky.
These rains were a part of strong thunderstorm and wind activity. Tornadoes
killed three people in western Kentucky. A second series of storms hit
the area again in less than a week. Heaviest concentrations were centered
along the Ohio River again with maximum amounts in southern Indiana and
northern Ohio. This time the precipitation extended farther up the basin
into central Ohio and western Pennsylvania. Isohyetals for both storm
periods are shown on [Figure 17]. The March 1964 flood on the Ohio River
at Evansville, Indiana, reached a stage which was 0.6 to 1.1 feet lower
than the floods of 1883, 1884, 1913, and 1945, and 6.0 feet below the
flood of 1937."
Ten-year, one-hundred-year and five-hundred-year flood levels are shown
for the Ohio River on Figure 18 and for Canoe Creek on Figure 19. Based on
this information, waters could be expected to rise as high as 376 feet above
sea level once every one hundred years and as high 378*s feet above sea level
once every 500 years. In the great flood of 1937, water rose to about 381
feet (McCabe 1962) (Figure 20) . These levels are now considered to be about
as high as the river could possibly get barring only the most extraordinary
events. Since the project site is located at an elevation of greater than 389
feet, it is not within an area considered capable of flooding.
Nonetheless, even the most remarkable events do, on rare occasions,
occur. If one extrapolates from the available data, the chance of a flood as
high as 390 feet is so small it is likely to happen only one to five times
every million years. Such a flood would barely wet the foundation of UNISON's
facility but would put much of Evansville under more than ten feet of water.
Extent of a 390 foot flood is shown in Figure 21. Even higher water can be
imagined but the chances of this occurring are extremely small. In conclusion,
there is no significant hazard from this facility associated with flooding.
5-32
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:ORPS Oc ENGINEERS
U. S. ARMY
FLOODS Of MARCH 1964 ALONG THE OHIO RIVER
Iaotayatal map of total precipitation. Match 2-6, 1904.
Iaofcr«tal nap ot total precipitation, March 8-10,1M4.
Prtparad from U.S. Wntttr Bumo data.
PROM U.S.Q.S. WATER-SUPPLY PAPER 1040 -A
Figure 17.
OHIO Hived BASIN
CANOE CHECK *
NOHTH FORK CANOE CREEK
HENDERSON, KV.
TOTAL PRECIPITATION
IN INCHES
US. ARMY ENGINECR DISTRICT
LOUtVIUS KV.
orlMI>-h Fii iaai
-------
U1
I
UJ
¦e-
390
3*0
170
360
350
340
330
7S0
SIO
PROFILES
OHIO RIVER
MILE 780 TO MILE 810
•10 »os
* *ftun meat *>• «ii»iini (i»t »mti)
•00
7»S
HUES mow PIITSIUI6H
780
SIO
Figure 18. 10 year, 50 year, 100 year, 500 year, and project flood profiles in the Henderson aria.
-------
U ft AftMV
Ul
I
W
u
Figure 19. Flood profiles for Canoe Creek.
-------
-------
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5.2.1.6 Potential for Tornado Related Releases
The chance of a tornado strike at the Henderson facility was estimated
based on data kept by the National Climatic Data Center (NCDC) of the National
Environmental Satellite, Data and Information Service of the National Oceanic
and Atmospheric Administration (NOAA). For the period 1953 to 1984, tornadoes
have occurred in Kentucky at a rate of 2.01 per 10,000 square miles per year
(NOAA 1984). However, Eastern Kentucky experiences very few tornadoes, while
Western Kentucky experiences proportionately more (see Figure 22). Note that
Western Kentucky storm frequencies are closer to Illinois and Indiana frequencies
than those further east. The NCDC gives tornado frequencies of 4.80 and 5.70
per 10,000 square miles per year for Illinois and Indiana, respectively (Ibid).
For the purposes of this report, we will assume that Henderson County experiences
2
tornadoes at a rate of 5/10,000 mi /yr.
Tornadoes vary widely in the amount of destruction they cause. Some-
never touch the ground. Others touch, skip and touch again. Some die out
quickly and other continue for many miles. The NCDC has no data on average
characteristics. Based on conversations with several meteorologists, we
estimate that the average tornado touches down along a path 100 yards wide and
continues for less than one mile. Based on these assumptions, the chance of a
tornado strike at the facility is about one in 35,000 per year or 28 strikes
every million years. Most of these are weak tornadoes (Snow 1984).
Fewer than 25% of all tornadoes are classed as strong and fewer than 3%
are violent (see Figure 23 and Table 3). While any tornado might cause roof
or wall damage to the structure, only a strong or violent storm would be
capable of causing a release of pollutants from the proposed facility.
Estimating the effects of a strong or violent tornado on the facility is
made more difficult by the fact that tornadoes are capable of freakish results.
Based on a sizeable body of anecdotal evidence accummulated by the Weather
Bureau (Appendix 6), it appears as though the facility could be substantially
destroyed by any strong tornado. However, the resulting releases are Likely
to be limited to what might leak from damaged drums and tanks tossed about by
the storm. Most of the leakage would probably occur after the tornado had
5-38
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_n
i
r \
^-~-r——
THAN u
Figure 22. Distribution of tornadoes. TORNADOES 1916—55
(Isolines bas£d on total number by 2® squares, counting first point of contact with
ground of 7,206 tornadoes.)
-------
Figure 23 . "The Tornado", John T. Snow, Scientific American,
April 1984
'ALL TORNADOES
/^WEAK TORNADOES
f \
t \
' \
A
•• y\
.•/
— -/
DEATHS-
\„ ^ STRONG TORNADOES ,
- VIOLENT TORRADOES
1950
1955
1960
1965
ANNUAL TOTAL of tornado* recorded in the U.S. ihowi a steady
increase that to attributed to improved record keeping rather than to
a real rise in frequency. The Federal Government began collecting
tornado report* systematically in 1913 and hat «ince extended to data
ha«e (maintained by the National Severe Storms Forecast Center in
Kansas City, Mo.) back to I9S0. Tornadoes are classified whenever
possible according to the Fajita wind-speed scale as weak, strong or
1970
1975
1980
600
500
400 5
8
300 &
200 jjj
100
0
violent; since not all of them can be rated, the total is greater
the sum of the three categories. The increase in the total primarily re-
flects increased reporting of weak tornadoes. The number of strong
and violent tornadoes, which are less likely to escape detection, shows
little change. Fewer than 3 percent of all tornadoes are classified as
violent, but they account tor two-thirds of all tornado deaths) the
peaks in the death curve reflect tbooe in the vMaaMaraado curv*.
5-40
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Table 3. Definition of Fujita Tornado Scale (F scale)
(FO) Gale tornado (40-72 mph): Light damage
Some damage to chimneys; break branches off
trees; push over shallow-rooted trees; damage
sign boards.
(Fl) Moderate tornado (73-112 mph): Moderate
damage
The lower limit (73 mph) 1s the beginning of
hurricane wind speed; peel surface off roofs;
mobile horns pushed off foundations or over-
turned; moving autos pushed off the roads.
(F2) Significant tornado (113-157 mph):
Considerable damage
Roofs torn off frame houses; mobile homes
demolished; boxcars pushed over; large trees
snapped or uprooted; light-object missiles
generated.
(F3) Severe tornado (158-206 mph): Severe
damage
Roofs and some walls torn off well-constructed
houses; trains overturned; most trees In forest
uprooted; heavy cars lifted off ground and
thrown.
(F4) Devastating tornado (207-260 mph): Devastat-
ing damage
Well-constructed houses leveled; structure with
weak foundation blown off some distance; cars
thrown and large missiles generated.
(F5) Incredible tornado (261-318 mph): Incredible
damage
Strong frame houses lifted off foundations and
carried considerable distance to disintegrate;
automobile-sized missiles fly through the air
in excess of 100 m; trees debarked; Incredible
phenomena will occur.
(F6-F12) (319 mph to Mach 1, the speed of sound):
The maximum wind speeds of tornadoes are not
expected to reach the F6 wind speeds.
(FO+F1) Haak Tornado
(F2+F3) Strong Tornado
(F4+F5) Violant Tornado
From J. Atmos. Sci., August 1981, p. 1517-1515
5-41
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passed and it Is most unlikely that any of these containers would move more
than 1/4 mile from the facility (NOAA 1981; Weather Bureau 1960). Thus, the
more probable result of destruction of the facility by a tornado is isolated
areas of severe soil contamination capable of being cleaned up with existing
technology and posing minimal long term threat to human health or the environ-
ment (USWAG 1982 Vol.IV).
However, in the very remote event of a double strike by two tornadoes on
the same day or by two funnel clouds in the same multi-funnel cloud storm,
human health and the environment could be severely compromised. The worst
possible case is for spillage from the first tornado to be spread by the
second. If the spreading is wide enough, few effects could result because the
PCBs might only be present below detectable concentrations. However, if the
entire contents of the facility were spread over a one square mile area, the
resulting vapors in areas immediately downwind would be very concentrated and
clean-up of the soils exceedingly costly. We believe the chance of such an
incident to be less than one in one hundred million annually.
5.2.1.7 Potential for Aircraft Related Releases
This section discusses the potential for releases of hazardous substances
caused by a small airplane crashing into the facility. First, the position of
the facility relative to Henderson/Henderson County airport is described and
the accident history at the airport is reviewed. The chance that a plane
might hit some part of the facility is then estimated. Finally, a model is
developed to describe the worst case emissions from such an accident and the
results of the model described.
Location
The UNISON plant is located approximately one mile east of the Henderson/
Henderson County Airport. The parking lot of the proposed plant is located
exactly one mile east by north (or more precisely, at a bearing of 76°) from
the nearest end of the principal runway). Since the main runway is very
nearly due east/west, the plant is located 14° north of the direct line of
sight along the runway and slightly less than a mile away depending on the
5-42
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part of the plant under consideration. A distance of exactly one mile is used
in the calculation below without correction.
There ire no other airports nearby, so that the chance of n plane from
some other airport hitting the facility is very small and not considered
further. Data on such occurrences based on records kept by the National
Transportation Safety Board and the Federal Aviation Administration are
presented in Appendix 7. The only foreseeable aircraft accident at the UNISON
facility would be due to takeoffs or landings at the Henderson/Henderson
County Airport (H/HCA).
Accidents and other incidents associated with H/HCA.
At EPA's request, Glyn Parsons of the Aircraft Owners and Pilots'
Association in Oklahoma City searched AOPA's computer records for all
incidents associated with H/HCA. While three incidents were found, it is not
clear whether the craft involved were operating out of H/HCA or whether H/HCA
was simply the reporting field. One incident occurred at the airport itself
but amounted to little more than a rough landing. The location of the other
two incidents is not known to EPA.
The three incidents/accidents that have been reported in connection with
the Henderson/Henderson County Airport since January 1980, are:
o On June 15, 1981, the alternator control wire in a private Cessna P206
overheated, filling the cabin with smoke. The pilot flew to Henderson
for an emergency landing. There were no injuries, but the plane
sustained minor damage.
o On September 28, 1984, the oil filler tube fell out of a Piper PA28R,
causing the engine to quit as a result of oil pressure loss. The
pilot attempted to land on a road, turned sideways and lost control.
Although there were no injuries, the plane suffered substantial damage.
o The third incident was fatal. On August 9, 1980, a Cessna 150B was
observed "flying low and making abrupt manuvers." The craft was later
found demolished.
Only this last incident would have been sufficient to threaten UNISON's
plant.
5-43
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The Chance of a Crash into the Plant
The chance of a plane hitting some part of the plant was calculated
according to a method developed by Sandia National Laboratories for use by the
Navy in estimating the risk to its Strategic Weapons Facility at the King's
Bay (Georgia) Submarine Base (US Navy 1985). The Base is located near St.
Mary's Airport, St. Mary's, Georgia, a single-runway field with no control
tower and serving general aviation. "General Aviation" is a term which refers
to aircraft flown under rules other than 14 CFR 121 and 14 CFR 135. Since
these two rules cover large airlines, charter craft, air cargo operations,
commuter airlines and on-demand air taxies, "general aviation" is usually
limited to small private craft (FAA 1984).
The Sandia method is based on a study of accidents related to busy,
single runway fields with no control tower and serving general aviation In
areas without substantial hills (Cornell 1973; Smith 1983; Solomon 1975"; US
Navy 1985). To use the method, one must know the size, shape and orientation
of the facility, its direction and distance from the airport runway, and how
many takeoffs and landings occur annually. The method determines takeoff
associated crashes separately from crashes associated with landings. The
analysis considers crashes which would hit the facility Initially as well as
those which strike the ground in front of the facility and then skid into it.
Persons familiar with operations at H/HCA estimate that there were 22,000
takeoffs and landings in 1985. A more comprehensive description of the calcu-
lation is given in Appendix 7.
Using this data in the Sandia method for crash estimation gives the
chance of an accident in any given year as 0.0000133 or 1.33 X 10~5. This is
13.3 times every 1,000,000 years or about once every 75,000 years. Looked at
another way, we can say there is a 50:50 chance of it happening sometime in
the next 52,000 years or a 99.973% chance that it will not happen in the next
twenty years. These calculations assume H/HCA traffic volume remains constant.
5-44
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If we assume the volume of traffic at H/HCA grows at 6% per year for the
next twenty years, there would be 70,557 takeoffs or landings in the year
2005. That would be 193 per day or one every minutes around-the-clock.
The chance of no plane crash into the UNISON plant in the next twenty years,
assuming 6% growth, is 99.679%. Conversely, the chance of one or more crashes
into the facility would be 0.321%.
Possible Effects of an Airplane Hitting the Plant
Because the 0.321% figure is by no means negligible, EPA determined the
possible range of effects of an airplane hitting the facility and modeled a
"worst case" event•
The most likely event would tear open the roof and break open some pipes
or drums, causing minor spillage and consequent release of small quantities of
vapors to the atmosphere. There is some likelihood that a low velocity, low
angle-of-approach accident would result In the airplane bouncing off the roof
or becoming entangled in the roof support structure without doing any damage
to the storage or processing equipment. There Is some chance, roughly estimated
to be 10%, of a large spill inside the plant due to rupture of a large tank or
major pipe resulting from a major crash. This would allow somewhat larger
quantities of vapor to escape. Emissions would be similar to the phase III
emissions described in the worst case analysis below.
In a major crash, the processing system would go Into emergency shutdown
mode, which kills power to everything except the safety and pollution control
equipment. If all power to the facility were lost, the safety equipment would
not function and greater quantities of vapors would be released. However,
spilled materials would be contained within the concrete containment basin.
Clean-up could be completed within a few days at most.
A hypothetical "worst case" accident was created which involves a high
angle of impact and high velocity. It requires that the bulk of the craft
penetrate the roof without substantial loss of energy and subsequently lodge
in the storage tank holding concentrated PCB residues. It will be recalled
that this tank is kept warm to prevent the residues from solidifying. The
5-45
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"worst case" accident further assumes that the fuel tank on the plane is full
and that all of the fuel spills and catches fire. Finally, warm residues are
assumed to spread across the floor in the main containment basin and give off
vapors until emergency response personnel can either clean them up or restore
vapor containment. The probability of a crash affecting the site resulting in
this worst case accident is estimated to be significantly less than 1%.
In order to model this accident, it was divided into three phases.
During the first phase which lasts a few seconds, the plane penetrates the
residue tank. All of the plane's kinetic energy turns to heat and boils off a
quantity of residues creating a hot cloud of concentrated vapors which rises
out through the hole in the roof. During the second phase, the fuel mixes
with the PCB residues and burns creating soot containing dioxins and dibenzo-
furans. This would last a few minutes. The third phase involves evaporation
from the spill and is assumed to last 72 hours.
In order to model phase one, it is necessary to know the size and velocity
of the plane. Calculations were based on a 4-passenger propeller driven model
fully loaded with fuel and cargo. It was assumed that the terminal velocity
was 90 knots (103.5 mph) and the weight of the 4-passenger fully loaded plane
was 2635 pounds. Since kinetic energy is equal to one-half the mass times the
square of the velocty, the analysis Indicates 3.066 X 10^ Joules of energy are
liberated as heat.
If the plane passed cleanly through the roof and the side of the storage
tank without losing energy, 73,300 calories of heat would be delivered to the
residue tank. This is clearly an unrealistic assumption. It does not consider
energy released through movement of materials or the heating of parts of the
facility other than the PCB residue. But there is no simple method for esti-
mating the energy lost going through the roof and the side of the tank and
energy lost through deformation or movement of materials, so this energy was
not considered.
5-46
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In order to make a conservative analysis, a second assumption was made
that the residues were not merely warm but that they were just below the
boiling point. This raises the quantity of vapors released by sixty to ninty
percent. This was done because each component of the residue has a different
specific heat and a different boiling point. Detailed calculations were
avoided because they could have been used by UNISON's competitors to determine
the kinds of chemicals in the residues.
Finally, it was assumed that the latent heat of vaporization, or amount
of heat necessary to evaporate the material, was 100 BTU's per pound (55.6
calories/gram). Each component actually requires somewhat more heat than this
to evaporate.
Based on these assumptions, the quantity of vapors released by the initial
impact would be 5.52 kilograms or about 12 pounds. This figure was used as
input to the Phase 1 analysis. The Phase I analysis involved use of a computer
model, "PUFF", (Petersen 1982) which determines how vapor clouds caused by
explosions might affect people downwind. Various kinds of atmospheric conditions
were used in the PUFF model to estimate worst case wind and turbulence conditions.
The results of this modelling are reported below.
In order to model phase II, EPA had to determine whether burning of the
spilled fuel would be used simply to add more heat and increase vapor concen-
trations or whether to assume incomplete combustion, soot formation and the
formation of highly toxic by-products. It was decided that the more conserva-
tive approach, given concerns over toxics formation, would be the latter.
Consequently, a fire model developed by Versar, Inc. (EPA June 1985a) in
connection with transformer fires exacerbated by the presence of combustible
materials was used. This model was simplified somewhat by assuming that the
quantity of soot produced would be about 20% of the total weight of fuel.'
Finally, it was assumed that the soot produced would have the same composi-
tion as soot produced in transformer fires. This was done because there is no
data on the kind of soot produced in burning UNISON residues (no one has ever
burned them). Also, the residues have similar physical-chemical characteristics
to typical transformer fluids.
5-47
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Soot dispersion was modelled using INPITFF (EPA October 1984) assuming a
fire temperature of 400°C. While this temperature is too low to permit sub-
stantial dioxin or dibenzofuran formation, INPUFF calculates plume rise based
on wind speed and temperature (the higher the temperature the higher the
plume). The lower temperature caused the plume to be modeled as close to the
ground as possible in order to exaggerate exposures and keep the scenario
conservative. The results of phase II modeling are reported below.
In order to model phase III, evaporation rates were calculated for the
spilled residue by assuming that they spread across the entire surface of the
main containment basin. This basin has a surface area of 401 square meters,
counting equally areas covered by equipment as well as open areas. It was
further assumed that the residue would remain warm (60°C) rather than slowly
drop in temperature. The results of phase III modeling are presented below.
Because the crash might destroy a wall as well as the roof, the vapors in
phase III were modeled using a computer program (D2PC) developed by the Army
(US Army 1986) to determine the effects of chemical weapons on exposed popu-
lations. This was chosen over INPUFF because it can handle vapors close to
the ground more accurately.
Modeling Results
The results for phase I show that the greatest concentrations are found
using low wind speeds (1.0 meters per second) and unstable atmospheric con-
ditions (stability class 1). These are not common conditions but they are
possible. They bring the vapor cloud to the ground the shortest distance from
the plant. The highest concentrations are projected at about half a kilometer
downwind (0.3 miles) from the plant and occur between eight and nine minutes
after the accident. Concentrations peak at 965.3 micrograms per cubic meter
(parts per billion*) and over the first minute average 891,3 ug/m3. Values
drop rapidly after that as the cloud moves on.
* _ _
See note page 5-2.
5-48
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Concentrations at one kilometer downwind peak at 595.5 ug/m3 about 17
minutes after the crash, average 582.0 ug/m3 for the first minute and 375.8
ug/m3 for the first five minutes. Again, values drop rapidly thereafter as
the cloud moves on.
At ten kilometers downwind (6 miles), concentrations peak at 3.722 ug/m3
and average 3.460 ug/m3 for about fifteen minutes. Under stable atmospheric
conditions, these more remote receptors could be exposed to concentrations
that would peak at 48.88 ug/m3 and average 34.51 ug/m3 for about five minutes
before dropping off. The effects of these exposures are discussed in Section
5.3.
After the initial vaporization of materials, a fire was hypothesized to
begin. The greatest exposure to soot was found to occur at wind speeds of 1.5
meters per second in unstable air (stability class A). The highest concentra-
tion was at one kilometer downwind where the plume first touched ground about
11 minutes after the accident. Concentrations average 406 nanograms per cubic
meter for the first five minutes of exposure and average 50.7 ng/m3 for the
first hour. With higher wind speeds (5.0 and 10.0 m/s) stability class D
produces the greatest exposures. At 5.0 m/s, these occur at 2 kilometers from
the site and average 135 ng/m3 over five minutes. At 10.0 m/s, maximum con-
centrations occur at 4.0 kilometers and average 220 ng/m3 over five minutes.
Soot deposition was not modeled based on the small size of this fire.
Levels found after the much larger Jacksonville, Florida fire of Janury 29,
1984 were barely detectible (BESD 1984). Toxic organic compounds in soot are
assumed to have the same breakdown of composition as found in the soot
produced by the Binghampton, New York fire, that is (EPA June 1985a):
• 92.0% polychlorinated biphenyls;
• 1.19% 2,3,7,8 tetrachlorodibenzofurans;
• 0.68% other tetrachlorodibenzofurans;
• 3.75% other chlorinated dibenzofurans;
• 0.065% 2,3,7,8 tetrachlorodlbenzo-para-dioxin;
• 0.012% other tetrachloro dioxins; and
• 1.35% other chlorinated dioxins
5-49
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The effects of this exposure are discussed in Section 5.3.
In the third phase, because the emissions are prolonged, downwind con-
centrations come to equilibrium and remain the same until the wind changes or
the spill is cleaned up. If the wind changes, concentrations rapidly reach a
new equilibrium. If the spill is cleaned up, concentrations drop to zero.
Downwind concentrations are greatest at low wind speeds in very stable air
(stability class F). At 2.5 m/s wind speed, concentrations of toxic organics
downwind are predicted to be as follows:
Distance Concentration
10 meter 37.1 ug/m3
50 meters ........ 10.6 ug/m3
100 meters 5.64 ug/m3
500 meters . 950 ng/m3
1.0 kilometers 201 ng/m3
2.0 kilometers .......... 42.2 ng/m3
3.0 kilometers 16.6 ng/m3
Possible effects of these exposures are discussed in Section 5.3.
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5.2.2 Potential for Transportation Related Releases
Transportation related releases are a possibility each time a truck-load
of materials travels on our nation's highways. Despite the greatest safety
precautions, accidents will happen. The chance of an accident happening to
any one truck-load, however, is small. This section estimates the risk
associated with moving materials to and from the Henderson site. The potential
for releases is estimated from both local and national perspectives. Possible
exposures from several different "worst case" accident scenarios are also
discussed.
The national analysis is in Sections 5.2.2.1, 5.2.2.2 and 5.2.2.7. These
sections present estimates of total annual mileage by type of cargo, releases
of bulk liquids from tankers, and losses from drums carried on box trucks.
Sections 5.2.2.3 through 5.2.2.6 describe potential transportation accidents.
Section 5.2.2.3 describes land uses along UNISON's transportation routes and
notes places where impacts of accidents would be greater. Section 5.2.2.4
decribes a worst case accident in a residential neighborhood. Section 5.2.2.5
considers the chance of a fire in connection with an accident. Section 5.2.2.6
describes a loss of PCB residues to the Ohio River at the route 41 brldae.
Sections 5.2.2.8 and 5.2.2.9 develop estimates of the chance of accidents
along the routes to be used by UNISON in Henderson and Vanderburgh Counties,
respectively. Section 5.2.2.10 compares the risks discussed in the preceding
sections with other risks associated with hazardous materials transport.
5.2.2.1 National Analysis-Annual Mileage by Type of Load
The quantity of materials going to and from Henderson was reported in
Section 3.4 based on the plant operating at full capacity 24 hours a day.
Pull capacity calculations are based on operation at the maximum hourly rate
permitted in the Kentucky Air Permit twenty-four hours per day for 286 days
per year. This gives the maximum allowed annual operation permitted In the
air permit. Alternatively, one could consider full capacity t6 involve
operation at 78% of maximum permitted hourly rate continuously, 24 hours ^er
day, 365 days per year.
5-51
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Few plants ever ran at full capacity, however, and the UNISON facility is
unlikely to be an exception to the rule. In fact, even if marketing efforts
are exceptionally productive, it is not likely the plant will be brought up to
capacity for several years. As a conservative measure, however, estimates of
the probability of transportation related releases have been based on operation
at full capacity.
The annual mileage for each type of cargo is based on the known distances
from Henderson to the incinerators and to the TF-2 production facility, and on
the estimated market for UNISON's services. The following table shows the
mileage by type of cargo based on production at full capacity.
Component Annual Miles Type of Container
—jjpf 977,151 drums
TF_2 36,000 tankers
TF-X 996,184 drums
Residues 35,927 tankers
5.2.2.2 Estimated Tanker Release Rates
According to the U.S. Department of Transportation, Bureau of Motor
Carrier Safety, over-the-road trucks are involved in 1.2 accidents for every
nillion miles travelled. The present analysis assumes tanker trucks have the
same accident rate. Of tanker truck accidents, seventy-one percent are minor
and involve no release of cargo. Conversely, 29% involve some loss of load.
Additionally, tankers develop leaks from causes unrelated to accidents at a
rate of 0.43 per million miles (EPA March 1985). This gives a total release
rate of 0.78 releases per million miles (1.2 times 0.29 equals 0.348; 0.35
plus 0.43 equals 0.78).
DOT'S office of Hazardous Material Transportation maintains a computer
record of every reported transportation related release of hazardous materials.
A printout was obtained of every such release in Indiana and Kentucky which
occurred between January 1, 1981 and January 31, 1986. There were 142 such
incidents involving tankers. The quantity released is charted in Table 4.
Forty-three Incidents (30.3) involved less than ten gallons and accounted for
0.1% of the total quantity released. Twenty-five incidents (17.6%) involved
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Table 4. Distribution of cargo losses from tankers during transit
in Kentucky or Indiana from January 1981 through January 1986.
Size of Spill
(gallons)
Number of
Incidents
Percentage of
All Incidents
Total Lost
(gallons)
Percentage
All Losses
0.1
_
0.3
2
1.4
0.4
0.00
0.4
-
1.0
8
5.6
6.5
0.00
1.1
-
3.2
13
9.2
30.0
0.02
3.3
-
10
20
14.1
135.0
0.08
11
-
32
20
14.1
437.0
0.24
33
-
100
18
12.7
1,033.0
0.58
101
-
316
12
8.5
2,814.0
1.58
317
-
1000
13
9.2
7,441.0
4.17
1001
-
3163
11
7.7
20,985.0
11.75
more
than 3163
25
17.6
145.680.5
81.59
Total
142
100.1
178,562.4
100.01
5-53
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more than 3200 gallons and accounted for 81.59% of the total quantity released.
Based on these figures, the chance of releases of various sizes was calculated
as follows:
Annual Chance of Various Releases
Gallons Released
less than 100
101-316
317-1000
1001-3163
more than 3163
TF-2
Residues
0.016
0.002
0.003
0.002
0.005
0.016
0.002
0.003
0.002
0.005
0.028
Totals: 0.028
This means that if the facility operates for 1000 years, one could expect 28
releasing incidents involving TF-2 and 28 involving residues. This would equal
one releasing incident involving some type of cargo every 18 years. Of these
incidents, only half would involve PCBs. These numbers mean that there is a
31.6% chance of no releasing incident occuring during the twenty-year projected
life of the facility and that there is a 56.7% chance that there would be no
release of PCBs. The most likely result is that there will be exactly one
release and a 50% chance that this release will involve PCBs.
These figures must be qualified, however, because they probably overstate
the chance of a tanker release. In the first place, the data are based on
releases from all tankers, many of which have a aluminum bodies. The tankers
UNISON will use are stainless steel, which are less likely to puncture.
Secondly, the tankers UNISON will use have special caps and seals on the
valves and hoses, which substantially reduce the chance of leaks. Third,
UNISON will use only experienced drivers given special safety training.
Finally, EPA's records regarding hazardous waste shipments show that in
general, hazardous waste tanker drivers have a much better safety record than
truck drivers. After more than nine million road miles, there has been no
release due to an accident from a hazardous waste tanker (EPA March 1985).
Nevertheless, EPA considers any release of PCBs to be significant. EPA
is especially concerned with the potential for tanker related releases because
large amounts might be released and because the chance of such a release
associated with the Henderson facility is by no means negligible. Because of
5-54
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these concerns, EPA analyzed several possible "worst case" accidents. These
are accidents where a whole load Is lost and which happen at the worst possible
places, including residential neighborhoods or where the spill might pose the
greatest threat to public water supplies. The chance of fire in connection
with an accident was also investigated. These "worst case" accident scenarios
are considerably less likely than a release in general. This should be kept
in mind by the reader when reviewing the scenarios. The reader should also
bear in mind the relative risk of this facility compared to risks we live with
every day.
Before we relate the "worst case" scenarios, it is necessary to first
discuss "sensitive receptors" that might be impacted.
5.2.2.3 "Sensitive Receptors"
"Sensitive receptors" is a term used in environmental regulation to
denote living organisms or resources which, if exposed to a hazardous material,
might suffer in some special way. In this particular case it consists of
schools, nursing homes, public water supplies and nature preserves. In
connection with the UNISON project, EPA identified all sensitive receptors
along the routes to be used by UNISON and along the Ohio River for fifty miles
downstream from Evansvllle.
EPA interprets the tern "sensitive receptor" broadly. Residential areas
were determined first. Areas located along Route 41 through Evansville are
plotted on Figure 24, while areas located along the routes to be used by
UNISON in Henderson County are plotted on Figure 25. Schools are also noted
on these figures. Group homes for Evansville and Henderson were determined
exhaustively and are listed in Appendix 8. Much of this information is from
Area Plan Commission (1985}*
Every water supply company which takes water from the Ohio River down-
stream from the Route 41 bridge was contacted. The intake location and treat-
ment method used was recorded. Locations of water supplies are shown in
Figure 26. Not surprisingly, all water supply treatment companies use alum
coagulation for suspended solid removal and have activated carbon on stand-by
5-55
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POTENTIAL RECEPTORS
EVANSVILLE
E - Elementary School
M - Middle School
S - Secondary School
V - Vocational School
C - College
H - Hospital
R - Nursing Home
Residential area
o
w
to
o
PL,
§
a*
vO
Figure 24. Potential receptors in Evansville area.
5-56
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E - Elementary School
M - Middle School
S - Secondary School
V - Vocational School
C - College
H - Hospital
R - Nursing Home
Residential area
POTENTIAL RECEPTORS
HENDERSON
Figure 25. Potential receptors in the Henderson area.
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Downstream
Water Intakes
U»
Ui
oo
IL
Paducah
l.Cairo
•Wickliffe
IN
Evansville
Ht. Vernon
Henderson
[Uniontown
If. Morganfield
KY
^.Sturgis
N
:ter
Figure 26. Water supplies downstream from the route 41
bridge with intakes in the Ohio River.
-------
should the Ohio River ever become contaminated with organics such as PCBs.
Activated carbon is particularly effective in removing such organic chemicals.
PCBs are only one of many contaminants these water supplies might experience;
hence, mechanisms are already in place to clean the water for drinking should
the supply become contaminated.
5.2.2.4 Worst Case Residential Accident
A precise location for this accident scenario was not picked because
there are many residential areas along Route 41 through Evansville. The most
likely accident scenes are discussed in the local accident analysis in Sections
5.2.2.8 and 5.2.2.9. The purpose of this exercise is only to determine the
maximum concentrations of PCBs and other transported materials to which people
near the scene of an accident might be exposed.
First, it was assumed that whatever caused the accident would cause a
release of the entire load. Second, it was assumed that the spill occurred on
hot pavement so that the maximum amount of material would become airborne. A
pavement temperature of 60° celsius (140° fahrenheit) was used. This is too
hot to touch but pavements occasionally get this hot on summer afternoons.
Next, It was assumed that the spill would spread over a large area. Because
all parts of Route 41 are crowned or sloped and because the PCB residues are
viscous (like a thick syrup), the largest area which is likely to be covered
was estimated to be 50 square meters (538 square feet). However, as a con-
servative measure, this figure was arbitrarily raised by a factor of nine to
450 square meters (4842 square feet).
The next step in the analysis was to determine the rate of evaporation of
the various chemicals in the residues. This depends on a number of factors,
the most important of which are the concentrations of the various ingredients
In the residues, their vapor pressures, temperature and wind speed. As noted
before, we assumed a temperature of 60*C. Wind speeds were varied systematically
to find which wind conditions would represent worst case conditions. While
high wind speeds promoted the greatest evaporation, they also tended to disperse
the vapors. Concentrations of various chemicals which might be in the residues
were calculated based on the known composition of TF-1 and various PCB trans-
5-59
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former fluids using a computer modal (which has proved very accurate in
similar situations) of UNISON's process. A problem, however, developed
regarding which vapor pressures to use.
Vapor pressure is a measure of the tendency of liquids to evaporate.
When the vapor pressure of a liquid is equal to the barometric pressure of the
surrounding air, the liquid boils. Water, for example, boils at 212°F when
the barometer reading is 29,92 inches because at 212°F water has a vapor
pressure of 29.92 inches. At 68°F, water has a vapor pressure of less than
one inch (0.69 inch). PCBs have vapor pressures which are much lower than
water. The following table compares a typical PCB with water at various
temperatures. The vapor pressures are stated in millimeters rather than
inches.
Vapor Pressure Comparison
Temp. Water Hexachlorobiphenyl
32°F 4.58 0.00000005
68°F 17.54 0.000001
140°F 149.38 0.00012
212°F 760.00 0.005
The problem which vapor pressure presented in this analysis is that there
are 209 distinct PCBs, no two of which have the same vapor pressure at any
particular temperature. Many of these PCBs have never had their vapor
pressure measured. Of those which have been measured, the one which evaporates
most readily does so about a million times faster than the slowest to evapora
UNISON will be processing many kinds of PCBs most of which are complex mixtur
There is no good way to estimate the actual vapor pressure of the PCBs in th:
spill model.
EPA decided to assume UNISON would only be processing a mixture of PCBi
known as Arochlor 1242. This mixture is known to have the greatest tendenc
to evaporate of all the commercial mixtures UNISON might be processing but
constitutes less than 10% of the PCBs in UNISON's potential market. It wa
further assumed that the mix of PCBs in the Arochlor 1242 was such that ei
homolog was composed entirely of that isomer having the greatest volatill
For example, Arochlor 1242 contains about 25% tetrachloroblphenyl. Varic
5-60
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tetrachlorobiphenyls have vapor pressures at 140°F that range from 0.0004 mm
up to 0.0020 mm. For this spill model we assumed all the tetrachlorobiphenyl
had the highest known vapor pressure, 0.0020 mm. The net effect of all these
assumptions is that the PCB exposures produced by the model are much higher
than what would be produced by a real worst case accident. The values are
certainly five times too high and possibly 50 times. However, unless and
until actual measurements can be made on UNISON process streams, a conserv-
ative approach is the best method available.
Based on these assumptions, evaporation rates were calculated using the
methods of EPA (1974) and Fuller (1966). Rates were calculated for each
component of the residues; in the case of PCBs, assumed components were used
as discussed above. Rates were calculated using wind speeds which varied from
1.0 to 10.0 meters per second (2.2 to 22.4 miles per hour). Various types of
atmospheric conditions were assumed to determine the effect of stable or
turbulent air flow and so on. All these values were entered into a computer
program used by the Army to determine the effects of chemical weapons on
exposed populations. The Army model was chosen over several models used
primarily for industrial emissions because It can model the behavior of vapors
close to the ground more accurately.
The worst meteorological conditions for nearby receptors were found to be
high winds of stability class D. These wind speeds (10 meters per second) nay
be inconsistent with the assumed pavement temperature of 140°F. The worst
conditions for distant receptors were found to be gentle breezes with no
turbulence (2.5 meters per second wind speed and stability class F). Stability
class F only occurs at night. A sample of exposures at various distances from
the spill (directly downwind) and under various conditions is presented in the
following table:
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3
Exposures (in mg/m ) - Hot Pavement Scenario
Wind Speed (in m/s)
10
5
2.5
1.5
Stability Class
D
D
F
A
At Spill - all vapors
2517
2817
1160
541
- all PCBs
10.9
12.2
5.02
2.34
50 meters - all vapors
107
93
67
5.2
- all PCBs
0.46
0.40
0.29
0.022
500 meters - all vapors
1.78
1.14
1.92
0.011
- all PCBs
0.0077
0.0049
0.0083
0.00005
Exposures which would result with different assumptions regarding spill size
and pavement temperature can be calculated from the tabulated values. Evapora-
tion from a circular spill is proportional to the 1.8 power of the spill
radius (Fuller 1966). A fifty square meter spill would produce vapor concen-
trations 0.138 times as great as those reported above. (The square root of
50/450 raised to the 1.8 power is 0.138). A large spill of PCB residues Is
much more likely to be this size (5Qm2) than the size reported above (450ma).
In this case, emissions would be slightly less than one seventh the values for
the extreme worst case. The relative proportion of PCBs in the vapors would
remain the same.
Evaporation rates would be much less if the spill were not on hot summer
pavement (60"C, 140#F) but more likely on warm pavement (35#C, 95#F). Under
these conditions, evaporation rates would be about one fifth of the rate given
for 60°C. Based on the same assumptions, the evaporation rate for total
organics would be 0.189 times the value reported. Moreover, PCBs would con-
stitute only 0.259% of the total organics rather than 0.4325%. Hence, the PCB
evaporation rate would only be 0.113 times as great or about one ninth.
At 25® (77°F) the total organics evaporation rate would be 0.0985 times
the rate at 60°C (less than one tenth). The PCB evaporation rate is only
0.1777% of the total organics rather than 0.4325%. Hence, PCBs would evaporate
at only 0.04 times the 60°C rate (about one twenty-fifth).
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Combining these figures, a typical large spill (50m2) at 35°C (77°F)
would produce vapors at 0.026 times the rate reported above (one thirty-eighth)
and would produce PCB vapors at only 0.0156 (one sixty-fourth) times the rate
reported. At 25°C the rates are lower still by factors of 0.52 and 0.69,
respectively. Hence, at 25°C, a 50m2 spill would produce total organic vapor
0.0135 times (one seventy-fourth) those reported in the table above; the PCB
evaporation rate would be 0.0108 times (one ninty-third) the tabulated rate.
The exposure rates presented will persist directly downwind until the
spill is covered by emergency response personnel. Typical response times for
an urban spill are on the order of ten to twenty minutes. In a worst case,
the spill could be covered in less than an hour. A discussion of what health
effects might result from these exposures is presented in Section 5.3.
5.2.2.5 Chance of Fire in Connection with an Accident
Department of Transportation data (0RI 1978) indicate that trucks are
involved in accidents involving fires at a rate of four per billion vehicle
miles travelled. These data include gasoline powered vehicles and trucks
carrying flammable cargos. The trucks UNISON will use are diesel powered and
will carry non-flammable cargos. This makes the chance of fire much less.
Diesel fuel simply will not burn unless it is heated (see Section 5.2.1.3).
Uhile cases are known where diesel fuel ignited after spilling over a hot
engine, such cases are exceptionally rare. Nonetheless, if this happened and
PCB residues dripped onto the fire, soot could be produced which would be more
dangerous than the PCBs. However, the dripping would have to be at Just the
right rate; if It were too slow, only negligible amounts of soot could be
formed, if it were too great, It would dowse the fire. The PCB residues
UNISON might be transporting would behave like chemical fire extinguisher
fluid In such a case.
Another possibility considered by EPA was a collision with a second
vehicle carrying a flammable cargo. This too is exceptionally unlikely to
happen. A fire could, of course, result from collision with any gasoline
powered vehicle. After modeling a fire at the UNISON facility in connection
with an aircraft impact and finding low levels of soot production (see Section
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5.2.2.7), EPA has determined not to separately model a fire in connection with
a traffic accident.
5.2.2.6 Worst Case Water Impacts Accident
The site for this accident is the northbound Route 41 bridge which crosses
the Ohio River between Henderson, Kentucky and Evansville, Indiana. There are
two structures, one southbound, the other northbound. PCB-laden residues will
only be transported north on their way to incineration in Chicago, never south
across the other bridge. The bridge is located just upstream from river mile
787. It was chosen as the "worst case" site because it is located 4*5 miles
upstream from the water supply intake for the City of Evansville.
As with the other accident scenarios, it was assumed that an entire load
of residues would be released (in this case, to the River). As noted earlier,
a load of residues weighs 23 tons (net). Unlike the earlier scenarios, no
particular release characteristics and/or river characteristics were assumed.
Instead, a range of possible conditions was investigated, not only the worst
case situation.
Four possibilities of how the residues might get from the bridge to the
River were examined:
• The tanker itself could plunge through the guard rail and drop to the
River with its cargo;
• A spill on the bridge could drip into the River;
• A spill on the bridge dripping into the River could be dispersed by
high winds; and finally,
• The tanker could break the guard rail on the approach to the bridge,
spilling residues along the banks of the River into which they could
later be washed by rain water.
Obviously, if the tanker itself plunges into the River, the entire 23
tons would be lost. With the other three scenarios there is a substantial
probability that some (perhaps most) of the 23 tons could be kept from
entering the River. If the tanker itself fell into to the River, the residu
5-64
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would likely form a pool on the river bottom near the accident site and the
area of contaminated sediments would likely be smaller in total areal extent
than that resulting from drippage.
This sort of accident has never happened before, so estimating these
effects involves a certain amount of speculation. However, the behavior of
PCR's in water has been extensively studied. These studies have shown that
PCB's have very little solubility in water. The most soluble commercial
mixture which UNISON will handle is Arochlor 1242. It is soluble to about 0.2
parts per million (mg/1). Other commercial mixtures have solubility limits
one or two orders of magnitude less than this (EPA June, 1985a). Gallon for
gallon, PCB's are 35% to 58% heavier than water. Because of this greater
density and the low solubility, when they are dropped into water they sink and
form a pool on the bottom.
Other studies have shown that PCB's have a strong chemical attraction for
dirt and sediments, especially if the sediments are rich in organic matter.
If one mixed equal amounts of water and sediment in a container and then added
PCB's in amounts which did not overwhelm the binding capacity of the sediments,
the PCB concentration in the sediments would be about a million times greater
than the concentration in the water. Consequently, even in the very worst
spills, the concentration of PCB's in the water never gets near the solubility
limit because the PCB's are so much more strongly attracted to sediments.
Finally, studies have shown what happens to PCB's if they are never
cleaned out of the water. The isomers with only one or two chlorine atoms are
totally destroyed by algae and bacteria in the water within a few days.
Isomers with three chlorines take one to six weeks to disappear. With four
chlorines, several months are required. With five or more chlorines, the
PCB's last a very long time. They gradually accumulate inside the algae and
bacteria that are trying to digest them.
Algae and bacteria are at the base of the aquatic food chain, Small
animal plankton feed on these organisms and further concentrate the PCB's.
This is primarily a result of partitioning into lipid fractions. When animal
plankton are eaten by small fish and these in turn by larger fish, thes PCB'a
5-65
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get passed along at concentrations that become larger and larger. This is
called biomagnification. Because of this, if PCB spills are left in water and
not cleaned up, after several years the fish that feed in that area can become
highly contaminated and unfit for human consumption.
In order to estimate what might happen to a load of residues lost to the
Ohio River, we need to look beyond laboratory and ecological studies and
examine the record of previous accidents.
The largest single recorded spill occurred on September 13, 1974, in
Seattle, Washington. A transformer filled with Arochlor 1242 was being loaded
onto a barge in the Duwaraish River near river-mile 2 (two miles from Puget
Sound) when the sling broke, dropping the transformer onto the edge of the
dock. While the broken transformer remained on the dock, approximately 1*5
tons of concentrated PCB's were lost to the River (EPA 1976b).
There were no labeling requirements at that time and people at the site
assumed that the transformer had been filled with mineral oil (the recent
spill at Louisville was of low concentration PCBs in mineral oil). The normal
oil spill procedures at the dock were instituted. Workers, however became
suspicious when none of the "mineral oil" floated. Two or three days later
someone figured out that the supposed "mineral oil" might have been PCB's and
notified EPA and the State of Washington, Department of Ecology.
When laboratory tests indicated the presence of PCB's, emergency clean-up
procedures were instituted. At that time, about 30% of the spill was still
present on the bottom in visible pools which were recovered by divers using
hand held dredges. The remaining 70% had spread to the surrounding sediments.
These were not removed for another two years, at which time dredging of approx-
imately 40,000 cubic yards of sediments was required.
Based on this case and other lesser spills, EPA believes that loss of a
tanker to the Ohio River at the Henderson site would result in pooling of a
substantial fraction of the load on the river bottom with some contamination
of the surrounding sediments. The extent of physical spreading of the pool of
PCB's would depend primarily on the current speed at the time of the spill.
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It also seems likely that clean-up, if attended to promptly, would not be
prohibitively expensive. It is worth noting that Arochlor 1242 was the
mixture which spilled into the Duwamish River. It is the lightest PCB
mixture, gallon for gallon, that UNISON might handle and is also the most
soluble in water (overall solubility is very low, however, as explained
above). It appears that despite these properties, PCB's have little tendency
to migrate once they fall into water.
If this were a complete picture of PCB's in water, there would be little
cause for concern from a river-spill. However, other factors are involved.
PCB's have a small but measureable tendency to slowly diffuse Into surrounding
waters where they can be transported for some distance by the currents (McKay
et al. 1981). The strong affinity of PCB's for binding to small particles
also means that they are likely to move with particles that get suspended in
river water even without much turbulence. Transport of these suspended particles
is the principal mechanism by which PCB's in water move from one place to
another. It is not a rapid process but it is continuous (McKay et al. 1981).
The best data on solubility and transport of PCB's have been gathered at
two large spills in the Great Lakes, One, in Waukegan Harbor (just north of
Chicago) involved the release of almost 40 tons per year for twenty years.
Most of these PCB's (an estimated 1.6 million pounds) still lie on the bottom
of Waukegan Harbor. Of key interest here are the amounts that are actually in
surface waters and capable of being transported. Water column data gathered
by Hydro Qual in 1979 (EPA 1981) show that the dissolved concentration plus
the suspended concentration of PCBs in Waukegan Harbor ranges from about 0.1
to 1.0 ug/1* (parts per billion) (Figure 27). It is fair to assume that levels
of PCBs in the Ohio River water would be unlikely to exceed these values
following a spill unless there were substantial turbulence capable of lifting
sediments from the bottom.
Returning to our discussion of how PCB's might enter the river after an
accident on the Route 41 bridge, we can see that loss of the tanker Itself to
the river bottom would present the best chance fpjr a rapid and inexpensive
it
"micro", ordinarily abbreviated with the Greek letter mu is abbreviated
"u" in this document.
5-67
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I
<*•
00
S ®
I *
8 _i
OS 5
9 £
» I-
10.0
1.0
0.1
0.01
±
1
±
1
LEGEND.•
SURFACE DATA
5/2-5/19/79
T + i STO. OEV.
~ MEAN
1-1 STO. OEV.
I Z 3
DISTANCE FROM SLIP 3
(1000 FT.)
TT~
i
MOUTH OF
HARBOR
6
RANGE OF OATA
NEAR HARBOR
LAKE AREA
1
A
J_J
7
LAKE
8
Figure 27. Total PCB concentrations along a transect through Waukegan Harbor, from daily survey data (E^ lift).
-------
clean-up. Under Low wind conditions, materials dripping from the bridge would
probably also present good clean-up prospects.
Under high wind conditions, some spreading due to the wind could be
expected. Because the wind would break the drippings into small droplets,
additional spreading could occur once those droplets hit the river due to
river currents. Using Stokes Law and assuming a river depth of 28 feet, the
time it would take various sized droplets to sink to the bottom can be calculated.
A droplet 1.0 millimeter in diameter would sink to the bottom in about 32
seconds; a droplet 0.1 millimeter in diameter (just barely visible to the
naked eye) would sink to the bottom in 53 minutes. These small droplets could
spread some distance even under conditions of relatively low flow. Turbulent
effects on dispersal are discussed below. It is not clear whether droplets
smaller than 1.0 mm could be formed even by very stong winds. Droplets smaller
than 0.1 mm would be extremely unlikely under any conditions.
Therefore, if a spill drips from the bridge under high wind conditions,
pooling is less likely and the area of contaminated sediments could be much
greater. Nonetheless, it appears likely, given low turbulence, that even this
type of spill could be effectively cleaned from the River using existing
dredging technology.
The analysis presented above only applies to river conditions likely
during summer low flow. Flow rates in the Ohio River are usually much greater
from late fall through early spring. During this time period, the Ohio is
much more turbulent than during summer and may be turbulent enough to transport
sediment lortg distances. In order to determine whether sediments could be
carried appreciable distances during peak flow conditions, EPA contacted the
U.S. Army Corps of Engineers, Vicksburg Waterways Experimental Station. The
Corps of Engineers has a sophisticated computer model which can predict when
and how far sediments will be transported. Restilts, however, depend on accurate
characterization of baseline conditions, which are prohibitively expensive to
measure, and on the precise location of the modeled spill which would be
entirely arbitrary.
EPA contacted Mark Griese at the Evansvllle Water Treatment Plant to gain
some insight into how a spill might move in the River. The EWTP regularly
5-69
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tests the waters of the Ohio for their suspended sediment content. Average
values month by month for 1985 are provided below. Concentrations are in
milligrams per liter.
Month
Concentration
January
70
February
91
March
116
April
143
May
48
June
49
July
18
Augus t
14
September
13
October
15
November
250
December
108
While suspended sediment levels fluctuate rather broadly, peak values in late
fall and early spring are not so great that they suggest massive sediment
mobilization. Previous studies of the Ohio River (Finni 1986) suggest that
one-half to one inch of silty sediments are deposited in the study area
each year during low flow. These sediments along with very small amounts of
the ancient sandy/gravelly sediments are mobilized during high flow. Therefore,
it would appear that at only rarely would a spill to the River be dispersed so
far downstream by turbulence that effective clean-up would be impossible.
However, such an event cannot be ruled out. Sediment mobilization would
depend on numerous factors which are not well known for the study area (ASCE
1975; MacKay et al. 1981)
An additional possibility in which a load of residues might be lost to
the River would be a spill on the River bank which is washed in by rains. The
great affinity of PCB's for soils makes substantial contamination of the River
unlikely by this route. However, the PCB laden particles which do wash in
would probably be carried too far downstream for clean-up to be practical.
These PCB's would add incrementally to the background levels of PCB's already
in the sediments over a large area in amounts that would be difficult to
detect. Nonetheless, they would eventually add to the PCB burden of Ohio
River fish, including the larger species consumed by man. Appendix 9 lists
some existing concentrations of PCB's in Ohio River fish.
5-70
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Effects on Drinking Water Supplies
Effects on drinking water supplies will depend on the amount and types of
materials spilled, conditions during the spill, and on the capabilities of the
plant to treat contaminated water. First, it is worth noting that the City of
Waukegan Water Treatment Plant has an intake near the mouth of Waukegan Harbor.
It is used whenever the main intake located well off-shore in Lake Michigan is
frozen or is down for repairs or maintenance. This happens every two or three
years. When the alternate intake is used, water is being drawn from Waukegan
Harbor, a body of water contaminated with PCBs. After thorough study of
Waukegan waters, PCBs are always impossible to detect in the finished drinking
water (EPA 1981).
The Evansville Water Treatment Plant uses the same technology that is
used in Waukegan. However, there is a key difference. Waukegan knows in
advance when it will be drawing on contaminated supplies whereas Evansville
must test the water in their laboratory day by day. Optional and somewhat
expensive processes (activated carbon addition and removal) must be put
on-line in order to remove PCB's to levels which can not be detected. The
regular treatment process only removes the suspended fractions and would leave
the dissolved fraction in the finished drinking water. In theory, PCB's might
rise as high as their solubility limits in the finished water. This is likely
to be between 10 and 100 ug/1 (parts per billion). In practice, it is difficult
to conceive of conditions under which the level would rise much above 1.0
parts per billion (Figure 27). Typical removal rates without activated carbon
average 91 percent (Versar 1983 Vol, IV).
Therefore, Evansville and other riparian water supplies downstream must
know of PCB contamination in the water before they can prevent all human
exposure. Few of the water supplies downstream have the kind of laboratory
facilities available at Evansvilie. Even Evansville could not prevent the
first slug of PCB's from passing through to the finished drinking water
because it takes time to run the analyses and put the activated carbon into
use.
5-71
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The possible effects of these short term low Level exposures on drinking
water quality are discussed in Section 5.3.
The time it takes for contamination from a spill to pass downstream to
various water intakes is plotted on Figure 28 for various flow rates. As can
be seen, the only water supply which might have the PCB's at its intake before
notification could be made is Evansville, and there only under high flow
conditions. Under such conditions, the great mass of water in the River would
greatly dilute any PCB's present.
Environmental Effects
The adverse effects of PCB contamination on aquatic biota are well
documented. In laboratory tests, low concentrations of PCBs exhibit acute and
chronic toxicity to a variety of aquatic organisms, including algae and benthic
invertebrates which are the basis of the aquatic food chain. PCBs inhibit the
growth of some aquatic bacteria, and have been shown to interfere with photo-
synthetic mechanisms and reduce rates of cell growth and division in phyto-
plankton.
Chronic lethal PCB values for three species of aquatic invertebrates that
have been tested range from 0.8 ppb to 4.9 ppb. Chronic values for three
species of freshwater fish range from 0.2 ppb to 9.0 ppb. Acute lethal values
are 10 ppb for one invertebrates species, and 2.0 ppb to 7.7 ppb for three
species of fish (EPA 1980).
There is the potential for PCBs to disrupt the aquatic food chain at all
trophic levels. However, due to the changes which may occur after discharge,
environmental residues of PCBs do not necessarily correspond to commercial
mixtures used in bioassays. There are differences in the way less chlorinated
components and more chlorinated components are volatilized, become soluble,
and adsorb.
5-72
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0
A
Y
S
798
803
0
A
0.01 J
TRAVEL TIME
VI
PLOW RATE
Figure 28. Time Co reach various points downstream
from the route 41 bridge at four flow rates.
5-73
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In cases where PCB concentrations in the water and sediments are below
acute or chronic toxicity levels, the bioaccuraulation and bioraagnification
properties of PCBs can result in significant contamination of the aquatic food
chain. One of the most important environmental properties of PCBs is their
tendency to be bioaccumulated by aquatic organisms into their tissues to
levels much higher than in the ambient water. This property results from the
high solubility of PCBs in lipids and their low solubility in water. There is
a further tendency for PCBs to be concentrated in animals to a higher level
than levels found in their food. Once consumed, PCBs accumulate and are
neither metabolized nor excreted. This phenomenon is known as bioraagnifica-
tion. Fish can bioaccumulate PCBs directly from water, in addition to uptake
in the food, and in most cases, direct uptake is more rapid and leads to a
much higher accumulation in the tissues. This uptake is initially rapid,
followed by a gradual decrease in the rate of uptake, until a steady state is
approached (42 FR 6532).
Bioaccumulation factors have been determined in laboratory studies for a
variety of freshwater invertebrates and fish, and range from 2,700 in the
phantom midge for Aroclor 1254, to 274,000 in the fathead minnow for Aroclor
1242. Results from field investigations of PCB contamination in fish have
shown bioconcentration factors as high as 4,125,000 in the lake trout (EPA
1980).
Bioconcentration and biomagnification processes can result in fish PCB
body burdens in the parts per million range, when PCB levels in the ambient
water are in the parts per billion range. The U.S. Food and Drug administra-
tion has imposed a PCB residue tolerance limit of 2 ppm for fish involved in
interstate commerce.
There are numerous reports in the literature of PCB contamination levels
in fish, but few relate ambient PCB concentrations in water to fish tissue
concentrations (EPA 1977). One reason for this is the difficulty in obtaining
fish that have spent their entire lives in waters of the same PCB concentration.
Areas of more concentrated PCB residues near discharges or in the sediments
may contribute a disproportionate amount of contamination when compared to the
time spent in that area.
5-74
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Vieth et al. (1975) analyzed fish from Lake Michigan which were captured
from waters containing 0.01 - 0.1 ppb PCBs. Some of the fish were captured
near Waukegan Harbor, where over one million pounds of PCBs were discharged
over a 20 year period (see discussion above). Mean PCB concentrations in the
fish from the Waukegan Harbor area were 2.5 ppm for alewife, and 6.1 ppm for
yellow perch.
An unknown quantity of PCBs was released into Lake Hartwell on the
Savannah River prior to 1977. PCB concentrations in the water column near the
discharge area were 0.04 - 0.1 ppb in 1985. PCB levels in the sediments near
the discharge were as high as 47 ppm. Fish in Lake Hartwell have been monitored
for PCB contamination since 1976, and although PCB levels in the fish are
apparently decreasing, some of the larger fish sampled as recently as the fall
of 1985 contained PCB residues as high as 100 ppm.
The effect on aquatic biota of a PCB spill into the Ohio River near the
UNISON plant is difficult to determine, due to the previously mentioned un-
certainties concerning changes to PCBs when they enter the environment, varying
bioaccumulation and bioconcentration factors, and to what extent the spill is
cleaned up. If a large spill occurs, it is possible that some fish and other
aquatic organisms in the immediate vicinity will be killed due to acute effects
of PCBs. Assuming a rapid response and cleanup action, however, it is doubtful
that significant chronic effects on aquatic organisms would occur, and it is
highly improbable that there would be any adverse impacts to the Sauerheben
Wildlife Area. Since PCBs have a high affinity for organic sediments, and a
very low solubility in fresh water, most PCBs which are not cleaned up would
become bound to sediments (EPA 1984). The degree of binding would be dependent
on the silt fraction and organic content of the sediments. These sediment-
bound PCBs could contribute to food chain contamination via bioaccumulation
and biomagnification processes. Bottom dwelling fish such as carp, suckers
and catfish that are in direct contact with ®nd feed within the sediments
would be the most likely species to be directly affected. Benthic algae (in
shallow areas) and invertebrates could accumulate PCBs from the sediments and
pass them up through the food chain to higher trophic levels and affect sport
fish such as bass, perch and sunfish.
5-75
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5.2.2.7 National Analysts - Trucks Carrying Drums of TF-1 or TF-X
As noted earlier, the estimated annual transport distance at full capacity
of trucks carrying TF-1 is 977,151 miles and of trucks carrying TF-X is 996,184
miles. An accident rate will not be calculated for trucks carrying drums
because the rate of leaks caused by accidents for this type of cartage is not
known. The rate of leaking due to accidents is extremely low; the vast majority
of all drums involved in accidents survive without leaking.
For this analysis, the rate at which incidents (releases of all kinds)
are expected to occur was calculated. Data on hazardous materials incidents
(ORI 1978) indicate that there are 16.5 incidents for every million tons
shipped or 68 incidents for every billion ton-miles. Based on these figures,
the incident rate for TF-1 and TF-X shipments is as follows:
Annual Incident Rate
Basis
Based on tonnage
Based on ton-mileage
In other words, based simply on the total weight of materials shipped one
would expect a releasing incident involving either TF-1 or TF-X to happen, on
the average, once per year and one would expect slightly more than half of
them to involve TF-X. Since these materials travel further on the average
than hazardous materials in general, the releasing incident rate based on
ton-mileage statistics is 162% more. One would expect on this basis about 2.6
releasing incidents per year. Of course the same fraction, 50.5% would be
TF-X.
In order to detrain, the nature of these relea.es, the HAZMAT d.t. base
(see Section 5.2.2.2) was examined for records of 55 gallon drum, involved In
incidents in Kentucky or Indiana between January 1, 1981, and January 22,
1986, There were 346 such incidents.
TF-1 TF-X
0.495 0.505
1.296 1.321
5-76
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The greatest single cause of release was puncture (168 cases). The bulk
of these drums were speared by careless fork-lift drivers during unloading. A
few were punctured when loads shifted during sudden stops, some of which may
have been unreported traffic accidents. These punctures were caused by having
mixed loads of drums and machinery. Since UNISON lift trucks will not be
equipped with forks (see Section 3.5) and since drums will be tightly packed
on the trucks and no machinery will be present, punctures will be extremely
unlikely.
Fifty-six releases were caused by bottom failures. Most of these had
rusted, the remainder were either dropped during unloading or were damaged
when the cargo shifted. Rusted bottoms are unlikely due to the character of
TF-1 and TF-X and because drums are pressure tested before being refilled.
Nonetheless, if a drum does leak on a UNISON truck, bottom failure could well
be the cause.
The number of incidents involving other cauBes of failure are tabulated
below:
Cause
Damaged by other freight
Loose fittings, valves or closures
Body or side failure
Improper blocking or bracing (cargo shifted
fell over, etc.)
Dropped on handling
Weld failure
Other, unspecified
Corrosion or rust
Metal fatigue
Defective fittings, valves or closures
Chime failure (broken rim)
Improper loading (upside down, on its side
with heavy freight on top)
Internal pressure
External heat
Loading/unloading
Friction (between containers or between
container and vehicle
Vehicular accident
Failure of inner liner
Number of Incidents
32
29
22
22
13
13
13
12
11
10
9
5
4
3
2
1
1
1
5-77
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The only vehicular accident occurred on August 8, 1985, in Indiana. The full
contents of two drums were lost when they were damaged by other cargo.
After reviewing these incidents, EPA believes that all of them can be
placed into one of three categories:
• Those which could not occur;
• Those which might occur at UNISON's unloading docks within the
containment area;
• Those which might occur and be contained by the on-board containment
system of UNISON's trucks (See Section 3.4).
However, this eliminates the possibility of any releases to the environ-
ment, whereas a really severe vehicular accident would surely result in some
release. Since there must be some rate greater than zero at which drum contents
could be expected to be lost to the environment, this analysis will assume
that the single vehicular accident out of the above 346 incidents represents
that rate. This is imprecise, but it will allow some measure of the release
rate.
One out of 346 is a release rate of 0.00289. Multiplying this times the
incident rate calculated above gives expected release rates for TF-1 and TF-X
as follows:
Annual Release Rate
Basis . TF-1
Based on tonnage 0.00143
Based on ton-mileage 0%00375
Average 0.00259
Using the average value for the purposes of calculation one finds that there
is a 94.9452 chance that no TF-1 drum will leak to the environment over the
twenty year life of the facility. The twenty year chance that no TF-X will
leak is 94.850%. Conversely, there is a 5.055% chance of one or more TF-1
drums leaking and a 5,150% of one or more TF-X drums leaking to the environ-
ment. The subtle differences between all these values are illustrative only;
0.00146
0.00382
0.00264
5-78
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the estimates themselves have low statistical validity and could easily be
overstated by a substantial margin.
5.2.2,8 Local Accident Analysts - Henderson County
In order to estimate the chance of an accident at various points along
the routes to he used by UNISON, EPA utilized the resources of the Commonwealth
of Kentucky. Ms. Ann Banta of the Kentucky State Police supplied the location
and other statistics concerning all known accidents in Kentucky since January
1, 1980, along the proposed routes. He. Pierson Van Norman of the Kentucky
Transportation Cabinet supplied counts of vehicles for various lengths of the
route.
Vehicle counts were not available for routes 136 and 425. EPA estimated
these value, bssed on area population, land use and vehicle counts at connecting
roads.
* ainna each segment by the vehicle count
Dividing the number of accidents along eacn segu«= j
for that segment gave an estate of the risk Involved each time some vehicle
uses the to*. This analysis makes no distinction among various types of
vehicles and it treats cars and trucks the same.
Road utilization by UHISOH's truck, depends on the type of load. Appro*-
x 81.9% of all TF-i will
lmately 81.9% of all TF-X will come from the oort .
location of PCB transformers.
return to the north based on EPA s model of
av * an* of all residues were arbitrarily
All TF-2 will come from the north. About 80% of all
than 80% may actually go north
assumed to be traveling to Chicago. More
. ^ Ai« fiiA othst h&nd) if tuAt
because Chicago has the nearest lnclnerat • ^ ~
—««« *11 residue will go south. The
incinerator becomes inoperable for any reason,
. , . PpA ha8 used In all the transportation
80:20 split in residue shipments which EPA h
. j _jj- down time at the various
oodeia is an attempt to account for perlodl
Incinerators.
5-79
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Combining this road usage with the number of trips required by the piant
at fuii capacity gives the following breakdown on shipments:
North-South Distrlbuton of Truck Traffic (number of trucks/yr)
Component Common Route Northern Route Southern Route
TF-1 1540 1260.7 279.3
TF-X 1570 1285.3 284.7
TF-2 45 45.0 0.0
Residues 74 49.2 14.8
Total 3229 2650.2 578.8
Two types of estimates were made of the risk of local accidents:
1) An estimate of the number of accidents one should expect; and
2) An estimate of the chance of one or more accidents of any given type
or along any given segment.
When the expectation is very low it is the same as the chance. However, as
events become more likely the two estimates diverge because the chance of
something happening can never be greater than one (100%) while the expected
number of incidents can continue rising. The number of accidents that actually
happen can only be zero, or one, or two or some other whole number. The
expectation is an estimate of how many will occur and usually is some whole
number followed by a fraction. The chance of one or more accidents is the
probability of at least one accident.
Expectations are added together to combine events. Probabilities are
more complicated to calculate. The methods EPA used for this analyses are
described in Ullman (1972). However, a basic understanding can be reached by
considering the simple case of flipping coins. The chance of getting heads on
any one flip is 0.50 or 50% and the expectation is also 0.50. If one flips
two coins, the expectation is 1.0 that one will be heads but the chance of at
least one heads is 0.75. If one flips three coins, the expectation is that
there will be 1.5 heads and the chance of at least one heads is 0.875 or
87.5%.
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Appendix 10 shows both the chance and the expectation for accidents on
various segments of the proposed route. The statistics are broken out by type
of load as well. For example, it is very likely, if UNISON operates at capacity
for twenty years, that there will be one or more accidents involving UNISON
trucks in Henderson County. The chance of that happening is almost 94%.
EPA's best estimate of how many accidents will occur is 2.8, which is the
"expectation."
Of course, the most likely accidents would involve trucks carrying drums
of TF-1 (with no PCB's) or TF-X (with an average of 2% PCB's). These drums
almost always survive traffic accidents without leaking, and large leaks are
exceptionally rare. The chance of concentrated PCB residues being in an
accident in Henderson County is 6.16% over twenty years while the expectation
is for 0.636 accidents. Recall from section 5.2.2.1 that only 29% of tanker
accidents result in spills. About half of those are major spills (more than
1000 gallons).
The segment of Route 41 between Route 414 and the Indiana line Includes
the bridge over the Ohio River, and is of particular concern relative to a
possible spill. EPA attempted to segregate accidents which might occur on the
bridge or its approaches from those on other parts of the highway. However,
variations in the way officers at the scene report accident locations made
this impossible without going back to the original reports. However, the
number of bridge accidents will certainly be less than the total reported for
the segment north of Route 414. The chance of at least one accident of any
type on that segment is 20.6% but the chance of a tanker accident is less than
1% and the chance of an accident involving residues is about half a percent
(all of these are twenty year probability figures).
There is another way to estimate the possibility of a tanker going off
the bridge into the water. Department of Transportation data (ORI 1978)
» j . 4n tamer following accidents about 18 times
indicate that trucks are immersed in water roi.i.uw* *
, , 1 oA This figure cannot be used without
for every trillion vehicLe miles traveled.
. j —.ait /Htehes. ponds and streams as well as
qualification. First, it includes small ditcnes, p°
r.f lysine a tanker to the Ohio it
®ajor lakes and rivers. As an estimate
tj, 1a -iso an average figure for all truck
would thus overstate the chance. It is
5-81
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transportation. To this extent, 18 immersions per trillion miles may
understate the true risk.
Despite these ambiguities, simply multiplying the immersion risk by the
twenty-year mileage figures gives numbers of some interest. The calculation
produces the following expectation values:
Twenty-year Expectation of Immersion
Cargo Expectation
TF-1 0.000352
TF-X 0.000359
TF-2 0.000013
Re s idue s 0.000013
Total 0.000737
Based on this and assuming all immersions are to the Ohio, the twenty-year
probability of losing a truck to the River would be 0.07%.
In order to compare traffic hazards along UNISON's routes through
Henderson County with traffic hazards in other parts of the County, within
Kentucky and Nationally, it is necessary to calculate the number of accidents
per 100,000,000 vehicle miles. For each section of road the annual vehicle
count was multiplied by the length in miles of that segment. These were
summed to give 107,600,000 annual vehicle miles along the proposed UNISON
routes. Since the average annual accident rate for all segments combined is
222.14 (see Appendix 10), there are 206 accidents per 100,000,000 vehicle
miles.
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This is less than the rate for Henderson County as a whole, which, at 556
per 100,000,000 vehicle miles, is the fourth highest in the State of Kentucky
(Banta 1986). National averages for various types of road are listed below
(Lynch and Steelraan 1986):
Type of Road Accldent8/100,000,000 vehicle miles
Undivided:
2 lanes, rural
2 lanes, urban
3 lanes, rural
3 lanes, urban
4+ lanes, rural
4+ lanes, urban
Divided, 4+ lanes:
no access control, rural
no access control, urban
partial control, rural
partial control, urban
full control, rural
full control, urban
200
346
228
164
267
442
169
395
93
196
50
101
5.2.2.9 Local Accident Analysis - Evansville
In order to estimate the chance of an accident in Vanderburgh County at
various points along Route 41, EPA requested help fro. the Stat, of Indiana.
Computerized traffic accident records and vehicle counts, however, are not yet
available. Indiana's system la currently in a start-up phase and substantial
data like the six year data base for Kentucky doe. not yet exist. However,
« to suddIv "rural" accident totals for
the Indiana State Police were able to suppxy
1983 - 1985 by township:
Township
Center
Knight
Perry
Pigeon
Scott
Total
Vanderburgh County Route 41 Rural Accidents
1983
42
23
0
7
kl
113
1984
1985
71
67
13
5
0
1
2
0
5J_
50
137
123
5-83
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Because Route 41 crosses each of Center, Knight and Pigeon townships in more
than one place, there was no way to apportion these accidents to any particular
length of road nor any way to combine them with the traffic count data.
Inspector James Kleeman at the Evansville Police Department supplied
accident data for intersections at various points along Route 41 which cover
the period from January, 1985 through March, 1986. This data is as follows:
Intersection # Accidents
Morgan
33
Columbia
43
Virginia
52
Walnut
40
Lincoln
19
Bellemeade
12
Washington
38
Covert
25
Riverside
19
Southlane
16
Mr. Cliff Ong of the Evansville Urban Transportation Study Group supplied
the following traffic counts:
Location Annual Number of Vehicles
South of I 64 7,059,000
City Limits 7,654,000
North of Pigeon Creek 15,060,000
North of Morgan 16,652,000
North of Oak Hill 12,648,000
South of Division 13,402,000
South of Washington 9,569,000
North of Bridge 9,746,000
These data were used to estimate the risk of UNISON traffic going through
Evansville. In order to account for accidents in between intersections, EPA
sought Inspector Kleemen's opinion on the proportion of such accidents which
would be intersection related. Inspector Kleeman stated that, based on hia
experience with the way Evansville Police Officers report accident locations,
his best estimate for the ratio of mid-block to intersection accidents is 2%.
5-84
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He added that 5% would be conservative. EPA has calculated the risk of mid-
block accidents assuming they add another 5% to the number of accidents re-
ported between the State line and Morgan Street. The vehicle count used for
the mid-block accident rate calculation is the simple arithmetic average of
the other counts used.
In other respects the chance and expectation calculations for Evansville
were made in the same way as the Henderson calculations reported in the previous
section. Results are reported in Appendix 10. However, the twenty year risk
will not remain meaningful because as soon as Interstate 164 is completed,
UNISON will use it instead of Route 41 through Evansville.
5.2.2.10 Other Hazardous Shipments
UNISON is only one of many companies that are involved with shipping of
hazardous materials. This section describes UNISON's shipments in relation to
the other hazardous materials transportation activities.
In the United States, approximately two billion tons of domestic shipments
are by truck each year (DOT, 1977). About one third of all such shipments are
"hazardous" according to the Department of Transportation (DOT) criteria. The
criteria used by DOT to define hazardous materials are similar to those used
by EPA.
At capacity, UNISON will ship a total of approximately 63,382 tons of
materials per year. This will increase the amount of domestic hazardous
materials being shipped by 9.7 thousandths of one percent. This Is, of course
an extremely small increase. The amount by which hazardous materials shipments
will Increase in the vicinity of Henderson and Vanderburgh Counties can be
estimated by assuming current local hazardous materials shipments are proportional
to the local population. Approximately 0.09% of the United States population
lives in Henderson or Vanderburgh Counties. On this basis, Idea], hazardous
materials shipments will increase by ten to eleven percent if UNISON is allowed
to operate.
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5.3 RISK EVALUATION
This section evaluates the risks associated with the exposure estimates
developed in the previous sections (5.1 and 5.2). In evaluating the potential
risks which would result if the various scenarios developed in sections 5.1 and
5.2 occurred, EPA considered the magnitude, duration, and the frequency of
exposures which were estimated in these sections against the background of
previous regulatory decisions and TSCA's "unreasonable risk standard."
Under the Toxic Substances Control Act (TSCA), EPA may authorize
activities involving PCBs upon making a finding that no unreasonable risk of
injury to human health or the environment will result from that activity. In
applying the unreasonable risk standard, EPA balances the magnitude of expected
exposures to humans and the environment (including considerations of the
frequenoy and duration of exposures) and the potential effects on human health
and the environment as a result of suoh exposures, against the benefits to
society of the activity and the reasonably asoertainable eoonomlc oonsequences
of prohibiting or otherwise restricting that activity.
In the course of regulating the manufacture, use, processing,
distribution in commerce, and disposal of PCBs, EPA has previously evaluated
potential exposures to PCBs in various scenarios (e.g., PCBs in the workplace,
in ambient air, and in contaminated soil) and made some determinations about
whether certain levels of exposure pose "unreasonable risks." Unless otherwise
indioated, the previous exposure and risk assessments described in this section
used 38.5 years for the duration of occupational exposure and 70 years for
calculation of lifetime exposure.
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Under section 6(e) of TSCA, EPA promulgated disposal regulations (codified
at 40 CFR 761) which prescribe criteria for permitting PCB disposal facilities.
These criteria are designed to minimize the potential for, and provide maximal
protection against human and environmental exposure to, PCB releases during
normal operations and/or accidents. In establishing these criteria, EPA
determined that an unreasonable risk would not result if a disposal facility
operates in accordance with these criteria.
Thus, the criteria for permitting disposal facilities and/or methods
(specifically landfills and incinerators) are intended to require monitoring of
and limits on the potential routes of PCB release. In permitting a high
temperature incinerator, EPA applies process controls, (e.g., limits upon
emissions from the process, requirements for destruction efficiency of the
process, the requirement of emergency shutoff capability in the event of a
process abnormality, and the requirement for continuous monitoring of releases
and process conditions). In permitting landfills, EPA applies criteria which
are closely tied to the site characteristics (considerations of soil type,
geologlc/hydrologic conditions such as the accessibility of the groundwater and
considerations of historic flood plains, and topography) along with an evaluation
of whether the landfill provides for appropriate leachate collection and
treatment, barriers to public access to prevent exposure, and the prevention
of mixing PCBs with other, incompatible wastes.
For alternative methods of disposal, the regulations require a level of
performance equivalent to that aehieved by EPA approved PCB Incinerators and a
demonstration that the alternative method will not present unreasonable risks
to public health br the environment. In permitting an alternative methdd, EPA
Places the same types of process and site restrictions on the method as are placed
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upon incinerators and landfills under 40 CFR 761. EPA considered the potential
for PCB releases from the normal operation of PCB disposal methods and facilities
and determined that the operation of PCB disposal methods and/or facilities in
accordance with the criteria specified at 40 CFR 761 would not pose an unreasonable
risk of injury to human health or the environment. Therefore, determination
that the disposal method or facility would result in an unreasonable risk to
human health or the environment will be made only if either process or site
conditions of unique environmental significance suggest that the risks from
permitting the process or facility will result in significantly greater risks
than those considered in establishing permitting criteria at 40 CFR 761. Such
conditions include:
1. an unusually high probability of accidental releases due to the process
design or handling procedures; or
2. an unusually high probability of natural disasters or other catastrophic
incidents involving the facility such as earthquakes, floods, tornadoes,
or airplane impacts due to the nature or location of the site.
In this evaluation of the potential risks posed by the Henderson County
UNISON facility, EPA focused upon whether the proposed location of the site
would result in the second of the conditions discussed above. Thus, any con-
clusions drawn in this section about the risks associated with siting the
UNISON facility at Henderson County, Kentucky, apply only to the siting decision.
When UNISON performs a demonstration of their physical separation process, EPA
will make a separate determination of whether the UNISON physical separation
process poses an unreasonable risk by evaluating whether the operating parameters
of the process result in a level of performance equivalent to a PCB incinerator.
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There is some small probability of incidents such as earthquakes and
tornadoes associated with any process and/or facility location. While the
Agency did not explicitly evaluate the risks associated with such incidents in
establishing its disposal permitting criteria, it assumed that some probability
of such incidents is present at any site. However, the frequency of such
incidents is, in the overwhelming majority of cases, so low as to be insignificant
to the Agency's evaluation of the risk associated with the facility's siting
and operation.
As discussed in previous sections of this report, EPA evaluated the
potential exposures associated with possible, though highly unlikely, catastrophic
incidents as well as the exposures resulting from releases during normal faoility
operations at UNISON'S proposed Henderson County, Kentucky facility. Our
evaluation of potential exposure, and the probability of each scenario ooourring,
indicates that there is no extraordinary characteristic of the Henderson County
site which will result in a greater than average probability of accidental
release, or unusally high exposures in the event of a release. Therefore, the
risk of exposure and injury to the population and the environment of Henderson
County does not differ from the risks implicitly considered in developing the
Agency's general permitting criteria. Consequently, the Agency concludes,
based upon available information, that operation of the UNISON treatment
process at Henderson County, Kentucky, will not result in an unreasonable risk
of injury to human health or the environment.
The following sections compare the potential exposures at the Henderson
facility to (1) the exposures which the Agency determined do, and do not, pose
unreasonable risks in its previous regulatory decisions on PCBs, (2) a PCB risk
assessment prepared by the Agency for its Superfund program, and (3) wore
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common risks to which the U.S. population is exposed in everyday life.
Although TF-1 components have been less extensively studied than PCBs, avail-
able public health studies have not indicated any significant public health
problems associated with exposures at the levels reported in this document.
5.3.1 Comparative risks associated with air emissions from ordinary
operations.
As discussed in section 5.1.1, the expected exposure to PCBs at the
nearest off-site receptor via air emissions during ordinary operation of the
UNISON facility are several orders of magnitude lower than the PCB levels
established as re-entry guidelines for indoor, workplace air concentrations
following a PCB transformer fire (0.5 mg/m3). Furthermore, these expected
exposures are several orders of magnitude lower than annual exposures associated
with activities which the Agency determined do not pose unreasonable risks in
establishing limits on manufacturing processes which inadvertently generate PCBs.
Exposure scenarios considered in evaluating the risks to workers in such
manufacturing facilities included inhalation exposures to workers downwind of
leaking equipment, and inhalation exposure to mineral oil mist and to spray
paint mist. These exposures were assumed to occur 40 hours per week and found
not to pose an unreasonable risk assuming that those exposures occurred for
38.5 years.
Potential PCB inhalation exposures to individuals in the Henderson County
population are also several orders of magnitude lower than exposures found not
to pose unreasonable risk to populations near manufacturing facilities which
inadvertently generate PCBs. The amount of PCBs to which the people in the
census tract closest to the UNISON facility would be exposed in one year, is
equal to the magnitude of yearly exposure to each individual living downwind of
a manufacturing facility with inadvertently generated PCBs in its air emissions.
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In fact, the yearly exposure to populations in the census tract closest to the
Henderson facility is on the same order of magnitude as the yearly exposures to
current measured ambient air levels of PCBs in urban areas.
5.3.2 Comparative analysis of risks posed by exposures resulting from
accidents on-site
As indicated by the discussion in sections 5.2.1.1 through 5.2.1.7, the
probability of releases due to certain on-site accidents (i.e., earthquakes,
flooding, tornadoes, airplane Impact, failure of pollution control equipment,
and fires or explosions) is rare. The probabilities of on-site accidents such
as flooding, tornadoes, failure of pollution control equipment, and fires or
explosions seem to be no greater at the Henderson facility than the average
probability of such incidents. While probabilities of other on-site accidents
(i.e., earthquakes, and airplane impacts) are slightly greater than average at
the Henderson County site, these probabilities are not substantially higher
than those assumed by the Agency in establishing the PCB disposal permitting
criteria. Despite the improbability of catastrophic on-site accidents, we have
performed a conservative evaluation of the exposures and risks associated with
such accidents.
The results of these analyses indicate that, while the exposures resulting
from such incidents can be greater than the exposures associated with ordinary
operation of the facility, the exposures and resulting risks are lower than
those the Agency has previously found do not warrant regulation because an
unreasonable risk to human health or the environment will not result.
5.3.2.1 Earthquake
As stated in section 5.2.1.1, there is no possibility that an earthquake
of the magnitude and character necessary to cause damage to the facility such
that releases could not be contained within the Immediate area of the facility
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could occur. The Agency can not determine that the facility will pose an
unreasonable risk.
The potential risks posed by PCB contamination in soil which could result
from an earthquake of lesser magnitude than discussed above are similar to the
risks posed by possible soil contamination following a tornado (see 5.3.2.3,
infra).
5.3.2.2 Flooding
Section 5.2.2.5 concludes that the probability of damage due to flooding
(which could cause uncontrolled releases of PCBs) is much lower for the UNISON
facility than for the remainder of Evansville. The proposed site is located
above the five-hundred year flood plain (i.e., one flood in five hundred years
may affect the site). When the Agency established criteria for PCB storage
facilities at 40 CFR 761.65, EPA found that no unreasonable risk would result
if the facility is sited above the 100 year flood plain. Therefore, the
potential risks associated with PCB releases due to a flood well above the 500
year flood plain are not unreasonable.
5.3.2.3 Tornado
The discussion in section 5.2.2.6 indicates that even if the UNISON
facility were severely damaged by one tornado, the resulting PCB release would
be in the form of subsequent leaks and spills from equipment and containers
tossed about by the tornado. Such leaks and spills will probably be limited to
an area within a 1/M miles radius of the facility.
Should a tornado occur, resulting in such leaks and spills, short term
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exposures to cleanup personnel would occur. If the site were not covered,
short term exposure to surrounding populations could result. Further, workers
on-site and the off-site population could be exposed to residual contamination
(depending upon the cleanup level) after decontamination of the area. However,
based upon the results of a risk analysis for PCBs in soil, Recommendation of
Advisory Levels f«r PolvchloHnatert Blohenyls (PCBs) Cleanup developed by the
EPA Office of Research and Development (ORB) for use In the evaluation of
Superfund sites, no unreasonable risk of acute or chronic effects on human health
would result.
The ORD risk assessment does not quantify allowable PCB concentrations
in sou above the concentration at which the .ir at the soil surface becomes
fn*. fhis is that beyond that point there Is no
saturated with PCBs. The basis for tms is *n««, j
, .u nf prRa available for inhalation exposure and, therefore,
increase in the amount of PCBS avaii.au*®
, , ,,.u th« allowable PCB concentration in the soil. The
no theoretical upper limit to tne aAiowaux*
ORD risk assessment does not specif/ an upper PCB concentration for short tern
(10 day), on-site and off-site, inhalation exposures. That is. short-term
oration of PCBs sufficient to saturate the air
inhalation exposure to a concentration 01 ^
in result in an unreasonable risk of acute health
at the soil surface will not result
effects.
to the area on which the leaks and spills
Long-term inhalation exposures to tne
.v /i.rtftnfcamination level. However, inhalation
occurred would depend upon the
* * fh»n 0 1 kilometer (.0625 miles) from a sniii
exposure to populations greater*
* .i.ir« even if the aoil were only decontaminated
area would not pose significant risks even
th* nearest residence to the projected site
to 90 ppm or less. By comparison, the nearest
, fh# f-etiity and nearly 1.0 kilometers from th.
is more than 1.0 kllomet.r fro
, facility. EPA regulations would, at a minimum,
spill area furthest from the racliiu
, „r fh. area to below 50 W PCBs. Furthermore, both
require decontamination of th
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EPA and UNISON will probably apply a decontamination standard closer to non-
detectable levels of PCBs. Additional measures may be required to mitigate on-
site, worker exposures to residual contamination (i.e., cleanup to detectable
levels, capping the spill area, protective clothing for workers, or some
combination of these approaches) depending upon the size of the area contaminat
and the characteristics of the soil. Therefore, releases which may result in
the unlikely event of a single tornado can be controlled and subsequently
decontamined to safe levels through existing cleanup methods.
Section 5.2.2.6 indicates that only a simultaneous occurrence of two
tornadoes would cause damage sufficient to pose unreasonable risks, and that
the probability of such a double tornado strike is estimated to be one in one-
hundred million. Due to the extremely low probability of occurrence, operation
of the UNISON facility in Henderson County cannot be determined to pose
unreasonable risks based upon the risk associated with a double tornado strike
involving the UNISON facility.
5.3.2.4 Airplane crash involving the facility
In section 5.2.2.7, it is estimated that the probability that an airplane
accident at the facility which is of sufficient magnitude to cause damage
greater than minor leaks and spills which will occur during twenty years is less
than thirty in one million. Even though this is an extremely low probability
of occurrence, the Agency did look at the exposures and risks which could
result from such a high-velocity, high-angle impact airplane crash. For the
purposes of the analysis, EPA made an even more conservative assumption than
warranted by the probability estimates by assuming that one such plane crash
would occur during the twenty years the UNISON facility is in operation.
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5.3.2.4.1 PCB exposures at all phases of a high angle, high velocity
airplane crash
Worst-case PCB exposure estimates at all phases of the plane crash, as
described at section 5.2.2.7, would result in no significant lifetime cancer
risk. Even if the event occurred once in twenty years, the short duration of
exposure (zero minutes to 72 hours) would make the lifetime dose associated
with such an event equivalent to, or less than, the dose associated with ordinary
operations as discussed at section 5.3«1«
5.3.2.M.2 Exposure to soot components other than PCBa at Phaae II of a
high angle, high velocity airplane crash
This analysis is based on the worst—case assumption that the components
of the soot would be present at the same ratios as in the soot resulting from
a PCB transformer fire. EPA evaluated the comparative exposures to possible
incomplete combustion products in the soot resulting from a PCB transformer
fire.
Further, the potential for a fire or explosion-related incident, and the
magnitude of exposures in the event of an incident, would be mitigated by the
presence of trained personnel and the operating prooedures at the facility.
Even in the case of transformer fires where the potential risks are orders of
magnitude higher than for this Henderson scenario, EPA did not require phaseaut
of transformers in industrial facilities or eleotrioal substations because of
the additional controls generally plaoed on such equipment and the presence of
trained personnel. Similarly, in the event of a fuel fire which results from
an airplane crash into the facility, the soot would probably be dispersed into
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11$ Ptotedion Agency
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Georgia 3G35S
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ambient air rather than causing extensive contamination of the building.
EPA also recognized the risk-mitigating conditions inherent to PCB transformer
fires in outdoor settings, and excluded outdoor PCB transformers from the
phaseout requirement. Given the significantly lower level of exposure associated
with a fuel fire due to a plane crash at the UNISON facility, and the improbability
of such an event, an unreasonable risk would not result.
5.3.2.5 Pollution Control Equipment Failure
In the unlikely event that UNISON'S pollution control equipment fails,
and that several employees are severely negligent within the same frame of
time, it was estimated that large releases of TF-1 containing 0.002% PCBs could
continue for a duration of one week. Based on the assumption that such an
event would occur once a year for 20 years, and that the same people would be
downwind of the facility for the duration of all twenty such incidents, EPA
evaluated the exposures to people downwind of the facility. The expected
lifetime exposures and risks would be several orders of magnitude lower than
those which the Agency has previously found do not pose an unreasonable risk
(see discussion at section 5.3.1).
5.3.2.6 Fire or Explosion Related Releases
As indicated at section 5.2.1.3, the possibility of a fire or explosion-
related incident involving PCB residues would be extremely remote, if not
impossible, due to expected operating procedures at the UNISOH facility and
the nature of the materials in the facility. Should suoh an incident occur, it
is not likely to be of a greater magnitude or duration than is hypothesized for
a potential fuel fire resulting from an airplane crash (see discussion at
5.3.2.4). Therefore, the Agency would not find that the Unison facility poses
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an unreasonable risk based upon the possibility of such an incident.
5.3.3 Transportation Related Incidents
It was concluded in section 5.2.2.2 that one transportation related tanker
spill is expected to occur in 20 years, and that there would be a 50J chance
that such a spill would involve PCB residues as opposed to TF-2. Given these
probabilities, EPA evaluated potential exposures assuming that the one spill
would occur in a residential area or a water supply. Of course the probabilities
associated with each of these transportation scenarios is lower than the probabilit
that a spill of PCBs will occur during the twenty years of UNISON'S operation.
5.3.3.1 Residential Spill
EPA evaluated a worst-case scenario assuming that the largest possible
amount of residues was spilled on hot pavement in a residential area. Exposure
to Initial concentrations of PCBs and any vapors would be limited to a maximum
one hour response time (time to cover the spill area in order to mitigate
inhalation exposure). In such a case, emergency response personnel would be
subject to the greatest potential exposures. Assuming that emergency response
personnel do not wear respirators, the resulting exposures would be less, by
one to two orders of magnitude, than those found not to pose an unreasonable
risk to workers in manufacturing facilities which inadvertently generate PCB.
c a Further the doses associated with exposure
(see discussion in section 5.3.1>• Furtner, snc
^ those associated with the 10 day acute
to cleanup personnel are lower than those assowxav
* hv fpa's Offioe of Research and Development
health advisory levels established by tr* s mi
(ORD). All other exposures to observers and surrounding populations would be
one to two order, of magnitude lower than for emergency response personnel, and
inuer than those found not to pose an
three or four orders of magnitude lower *nan ur.wo
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unreasonable risk to populations downwind of a manufacturing facility emitting
PCBs at 10 ppm (at the point of emission). Available studies indicate that
the levels of organic vapors within one hundred meters shortly after a large
spill from a PCB residue or TF-2 tanker truck would result in eye and
respiratory irritation. Direct contact with the spill material would result
in skin irritation (dermatitis). Such effects from a predicted worst case
spill are believed to be reversible with no long term adverse health
consequences.
5.3.3.2 Spills into Water Supply
As discussed in section 5.2.2.6, it is difficult to accurately estimate
the potential exposures and risks associated with transportation related spills
into water supplies. It is true, however, that given the tendency of PCBs to
bind to sediment, only a small percentage of the PCB? spilled will actually be
carried in the water. Further, any PCBs not bound to the sediment initially
can be separated out by a water treatment facility prior to entering a drinking
water supply. Any dissolved PCBs would also tend to be dispersed by the flow
of the river, so that individual ingestion exposure to PCBs (either through
contaminated fish or through drinking water) should be mitigated.
Additionally, the possibility that a transportation accident will actually
result in the release of PCB into water is mitigated by the containment of the
fluids (either in drums or tanks cars). As indicated in section 5.2.2.7, even
if a tank containing PCB residues overturned into the river, the tank will
probably be dredged up before any appreciable release of PCBs into the water occurs.
Section 5.2.2.8 provided estimates of the probabilities that a transpor-
tation spill involving PCB residues would occur on or near the bridge (0.52%)
and the probability that a truck carrying PCB residues would overturn
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into the Ohio River (0.07* or seven in ten thousand) in twenty years. The
probability that a transportation spill involving PCB residues will contaminate
water supplies is most likely somewhere between those two probabilities.
In short, while the uncertainties associated with a possible spill of PCB
residues into a water supply are certainly a factor in considering the potential
risks associated with the UNISON facility, these uncertainties are of no greater
magnitude at the Henderson site than the generic possibilities of such incidents
which were considered in developing EPA's disposal regulations. These prob-
abilities could be compared to the one in ten thousand chance that a person
living in the U.S. will suffer a fatal accident in the home.
5.3.4 Benefits of the Unison Facility
While the Agency's evaluation of the risks posed by the various scenarios
discussed above show the probability of suoh PCB exposures and the potential
risks posed by sueh exposures to be low enough to alio,- a finding of no
unreasonable risk on a pur. risk basis. It Is Important to consider the benefits
of PCB residues at UNISON'S proposed
of the UNISON process. The disposal 01
. * um reduce the overall risks posed by existing
Henderson, Kentucky facility will reauce
. nr pro concentrations in in-service transformers
PCBs by allowing the reduction of PCB concern,
om u«t.s and at a lesser cost, than if new TF-1 were
while generating less PCB wastes, anu
„4„.Mon Further, the reduced generation of PCB wastes
used in each retrofill operation, rurvne.,
/»an«eitv and other permitted disposal capacity
will leave existing incineration capaoiiy an y
i A#* hiffh concentration PCB wsst6s«
free for the safe disposal of high concent-
5.3.5 - i r^luslo- Potential Risks Associated with the
Proposed UMISC" "¦ l"ntUCl'ii
^ and the considerations discussed above,
Based upon the exposure analysis a
_ ,,MTcnN site at Henderson will not pose an unreasonable
EPA concludes that the UNISON site at ner
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risk of injury to human health or the environment, assuming that the types of
risk-mitigating criteria which EPA applies to PCB incinerators are found to be
met by the UNISON disposal process. EPA will separately determine whether or
not routine process operations pose an unreasonable risk (e.g., whether the
process achieves adequate separation of PCB residues and meets restrictions on
emission levels). This determination will be based on observation of, and
analytical results from, an actual demonstration of the UNISON physical
separation process.
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6.0 SOCIOECONOMIC EFFECTS OF THE FACILITY
Construction and operation of the UNISON Transformer Recovery Center in
Henderson County, Kentucky will have national as well as local economic benefits
The bulk of the benefits will accrue to transformer owners. UNISON's customers
will save an average of 30-40% versus the total cost of replacement of a
transformer. Customers savings will range from $11,000 to $83,000 per PCB
transformer. If UNISON's target service level of 5,000 units per year is met,
annual savings, nationally, are likely to be in the range of $100 million.
Other potential benefits include:
• Risk reduction, since the PCB's are removed from operating transformers;
• Avoidance of long-term landfill liabilities, since reclassifying a
transformer to non-PCB status eliminates disposal of a PCB filled
transformer carcass at the end of its service life,
• Less disruption of service due to shorter down time;
• Full utilization of investment process offers improved transformer
^f^Lnce and ability to repair the unit and reclaim material; and
• Financial flexibility, since customers can capitalize or expense the
costs of service
Locally, construction and operation of the Recovery Center will contribute
to the economy of Henderson County, Kentucky. Construction of the proposed
project will result In an estimated $3,500,000 expenditure for equipment,
labor, and Installation of the facility. During operation the facility .111
employ 20 people Initially and 30 at capacity with an annual payroll of
$550,000 and $875,000, respectively. At capacity the follows annual expend-
itures are anticipated:
Taxes W-000
Local Purchases 360,000
Local Services 465,000
utlUtles 475,322
Total 51,390,000
, , * aoa^nut the environmental and public
These benefits must be weighed against
. in >u. other sections of this reports
exposure effects as described in
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7.0 MITIGATION
This section describes some of UNISON's efforts to reduce the chance of
accidents and to Lessen the impact of accidents that might occur despite
precautions. It also describes efforts UNISON might make if EPA determines in
its continuing study of this project that additional mitigation is required
and practical.
Much of UNISON's mitigative efforts have been described in other sections
of this report. Measures which would tend to reduce the chance of transporta-
tion related spills and lessen their impacts are noted in Section 3.5. UNISON's
air pollution control system is described in Sections 4.1.3 and 5.2.1.2. Many
of the measures to be used inside the plant cannot be discussed in detail but
are noted generally in Sections 3.7 and 5.2,1.3,
Additionally, UNISON has prepared and submitted to EPA a comprehensive
Spill Prevention, Control and Countermeasure Plan and a Health and Safety Plan
for the facility detailing how numerous contingencies would be handled and
describing equipment UNISON has to carry out the plans. They also have a leak
detection program which describes how the plant will be frequently and
systematically examined for signs of leakage. This program is described in
the air permit application which has been submitted to KDEP.
UNISON's plans for dealing with various emergencies include isolation,
containment and evacuation strategies and responsibilities of emergency
coordinators. UNISON's plans call for working with local officials and
Urgency response personnel to make sure area emergency management teams have
the equipment, training and contingency plans they might require*
7,1 additional mitigative measures considered BY EPA
EPA has considered requiring UNISON to take additional mitigative
"¦sasures in three areas to:
• Lessen the risk to the Evansville water supply in the event of a
bridge accident;
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• Lessen the risk of traffic accidents generally, and;
• Lessen the long term environmental impact of leftover TF-1 when the
facility is decommissioned.
These will be discussed in turn.
7.1.1 Water Supply Contamination
As noted in Section 5.2.2.6, the travel time between a spill at the Route
41 bridge and the potential appearance of PCBs at downstream water supply
intakes depends on the rate of flow in the Ohio River. Flow rates range from
almost undetectable, when the river is pooled, up to five or six miles per
hour at flood stage. At flood stage, travel time from the bridge to the
Evansvilie water intake could be less than one hour (Figure 28). If the
Evansville Water Treatment Plant is notified within a few minutes of an
accident, there will be no danger to the water. According to Mr. Mark Griese
of EWTP, raw water intakes can be closed within approximately five minutes of
receiving warning. Activated carbon can be brought on-line in less than two
hours. More than enough reserve (stored) capacity exists to supply the city
while the intakes are closed and the activated carbon is brought on-line.
However, there is no guarantee that EWTP would receive timely notification
of an accident. It is unclear how long it might take under worst case conditions
to identify a truck lost to the River, or how long after that it might be
before downstream water users would be alerted.
In order to eliminate the risk of late notification, EPA is considering
requiring that, during periods of high flow, UNISON notify EWTP each time a
tanker of residues leaves the facility on its way to Chicago notify EWTP again
when the tanker has safely crossed the bridge. Then, if the second notification
is not received within a certain period of time, the intakes could be closed
until it could be determined that PCBs had not been lost to the River,
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7.1.2 Traffic Accidents
EPA is considering two types of mitigation in connection with traffic
accidents. One would reduce the chance of an accident occurring and concerns
risks related to transport over icy or snowy roads. The other would reduce
the impact of an accident should one occur and concerns keeping innocent
by-standers away from accident scenes.
The local traffic accident analysis presented in Sections 5.2.2.8 and
5.2.2.9 was based on accidents occurring in a variety of weather situations.
A disproportionale number of accidents occurred during bad weather, especially
ice and snow. Such conditions may make travel by UNISON trucks unreasonably
dangerous and would require mitigative measures.
Of the 1403 traffic accidents studied in Henderson County, 155 (11%)
occurred on snow covered roads. The northern-most two miles of U.S. 41 In
Henderson County were especially likely to be the scene of snow-related
accidents. Of 228 accidents along that stretch, 52 (23%) were on snowy roads.
These accidents occurred only on 1.2% of the possible days. The worst of these
was the morning of November 13, 1984, when, during a one hour period, there
were fourteen separate accidents Involving a total of forty—six vehicles
either on or near the U.S. 41 bridge. Only one of these accidents was fatal.
According to Major Rick Riley of the Henderson Police Department, the
bridge is watched closely by both state and local authorities during cold
weather and is salted immediately when it snows. Nonetheless, sufficient
resources do not exist to prevent snow from accumulating from time to time on
area roads. Snows of one inch or more occur on the average about four times
per year. As a mitigation measure, EPA is considering prohibiting UNISON from
operating its trucks when the roads may be slick with ice or snow.
The second mitigative measure EPA is considering in connection with
traffic accidents is intended to reduce the impact of possible accidents on
innocent by-standers. As noted in Section 5.2.2.3, most of UNISON's trans-
portation routes within Henderson and Vanderburgh Counties pass through urban
areas. In many places, residential development lies astride the route. In
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other places there are busy shopping and commercial districts. If there were
an accident at one of these locations and PCBs or other hazardous materials
spilled onto hot pavement, there is a substantial likelihood that nearby
pedestrians would he exposed to relatively high doses of vapors. Moreover,
accidents in densely populated areas often attract crowds of curious on-
lookers .
EPA believes it is important to minimize the exposure of such persons.
EPA is considering requiring that UNISON, in its training seminars for local
emergency response personnel, include an assessment of the potential for
by-stander exposure and a discussion of available technical means for
minimizing that exposure. EPA is further considering requiring that UNISON
conduct a public information campaign designed to educate the public•regarding
appropriate responses to spills they may observe or be near.
7.1.3 Ultimate Fate of TF-1
When the Henderson facility is decommissioned, any TF-1 remaining in
existence will cease having its original purpose. It may have some use in
connection with another facility either in the United States or elsewhere. It
may be used simply as a transformer dielectric fluid. It may also have no
practical use and require disposal.
This last possibility is of concern to EPA. As a liquid, current law
(RCRA, Section 3004(c)) does not allow TF-1 to be landfilled. However, it
could be adsorbed on some sorbant and containerized. In this form it could be
landfilled.
Under Kentucky law, adsorbed TF-1 would fall into the category of special
or industrial waste. As such, it could not be landfilled without a special
permit. Current Kentucky policy strongly discourages landfilling of adsorbed
solvents. However, under special circumstances, it might be allowed. Moreover
nothing in Kentucky law could prevent TF-1 from being landfilled elsewhere.
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Although regulations In effect at the time would govern TF-1 disposal and
these regulations may be stricter than those in force now, EPA need not rely
on anticipated developments in the law. EPA can condition UNISON's permit
with limitations on land disposal of TF-1.
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8.0 PUBLIC INVQLVEMENT
The purpose of this section of the report is to describe the actions
taken to date to inform and involve the public regarding this project.
Actions initiated by UNISON, the Henderson County Board of Zoning Adjustment,
the State of Kentucky, and EPA are presented.
8,1 ACTIONS BY UNISON
The following is a list of activities in which UNISON/Union Carbide
personnel have participated in efforts to inform the public about the proposed
project.
Date
Activity
August 6, 1985
August 7, 1985
August 22, 1985
August 27, 1985
August 27, 1985
August 28, 1985 to
September 1, 1985
(4 sessions)
August 29, 1985
September 10, 1986
September 20, 1985
October 16, 1985
Presentation to the Henderson Economic
Development Council.
Presentation to media representatives.
Presentation to Henderson Rotary Club.
Presentation to Henderson Downtown
Merchants Association.
Presentation to Henderson Industrial
Association.
Participated in WSON radio call-in talk
show.
Presentation to Henderson Lions Club.
Participated in Henderson County Board of
Zoning Adjustment public hearing. Made
presentation and answered questions.
Presentation to Evansville Sertoma Club,
Presentation to Business and Professional
Women's Club.
Participated in Henderson County Board
of Zoning Adjustment public meeting.
Participated in Henderson County Board
of Zoning Adjustment public meeting.
8-1
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October 17, 1985
Press conference announcing UNISON's
decision to locate at the Riverport
Industrial Park.
December 2, 1985
Attended U.S. EPA, Region IV public meeting.
December 13, 1985
Attended Kentucky Department of Environmental
Protection public meeting on the air
construction permit.
December 19, 1985
Ground Breaking Ceremony.
March 12, 1986
Presentation to Kentucky Environmental
Quality Commission.
April 29, 1986
Presentation to Henderson County Lions Club.
8.2 ACTIONS BY THE HENDERSON COUNTY BOARD OF ZONING ADJUSTMENT
The only major local permit required for this project was given by the
Henderson County Board of Zoning Adjustment. Prior to issuance of this permit,
the Board held public hearings in four sessions from August 28 to September 1,
1985. Additional public meetings were held by the Board on September 20,
1985, and October 16, 1985.
8.3 ACTIONS BY THE KENTUCKY ENVIRONMENTAL PROTECTION CABINET
A Public Hearing was held on the state air construction permit on December
13, 1985 in Henderson, Kentucky. Several hours of testimony were received.
8.4 ACTIONS BY THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
On December 2, 1985, a public meeting was held by the EPA in Henderson,
Kentucky, to learn public concerns so that they could be used as a guide for
development of the Scope of Work for this report. EPA has also solicited and
received written comments on the proposed project. The following is a summary
of the issues raised at this hearing and in correspondence.
8-2
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• Characteristics and Effects of TF-1: unison's use of Confidential
Business Information procedures to maintain secrecy concerning the
constituents of TF-1 was a great concern to many speakers. A strong
belief was expressed that the lack of disclosures was preventing the
public in the local area from fully understanding the risks associated
with the plant.
* Risks of Contamination of Public Water Supply Systems: Several
comments were made expressing concerns about the contamination of
drinking water supplies downstream from the plant site. Fear was
expressed about PGB's entering the Ohio River from the plant site and
from a transportation accident on the Ohio River Bridge. Several
municipal officials expressed concern over the potential need for
alternate sources of water supply•
Risks Associated with Transportation: Many speakers raised the issue
of the safety of major transportation routes in the area and the
possibility of a tanker truck accident. A spill of PCB s or TF—1
along a high density population area was of concern. Other speakers
argued that extensive transportation of PCB's and other hazardous
materials was already occurring in the area with no significant
adverse effects.
Proximity of New Madrid Earthquake Zone: The possibility of an
earthquake along the New Madrid fault line leading to a plant accident
was a serious concern to several comroentators. Liquefaction of tfye#
area soils and the potential consequences were raised as an issue.
Other Concerns with Accidents: There was concern for accidents other
than those as.ocl.tei with transportation and earthquakes. Fires,
faulty equipment, on-site spills, normal maintenance and operating
procedures were all seen aa potential cauaes of accidents.
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Emergency Clean-up and Response Procedures: The suitability of
notification procedures in case of on- or off-site accidents, the
ability of local fire departments to respond to emergency situations,
the existence of appropriate spill clean-up plans and financial re-
sponsibility in case of accidents were raised.
Risks Associated with Normal Plant Operation: The major public
concerns associated with normal plant operations included toxic air
emissions and impacts to ground and surface waters from incidental
spills.
Construction of the Plant Before Completion of An Assessment: Several
speakers expressed concern that UNISON was about to proceed with
construction of the facility before the agency determined if there
would be any unreasonable risks. Several speakers believed it would
be very difficult to deny a permit to operate once a 10 million dollar
facility was in place.
Applicability of the Resource Conservation and Recovery Act (RCRA):
Several speakers requested the agency to apply RCRA as a tool to stop
construction of the plant and to insure safer operating procedures.
There was a great deal of confusion as to why RCRA had not previously
been applied to the regulation of PCB's. The applicability of RCRA to
TF-1 was also addressed.
Alternatives to the Proposed Henderson Project: Several alternatives
were available for both plant processes and location. The existence
of more proven processes and the perceived greater safety of a mobile
rather than a fixed facility were discussed. Many commentators also
expressed concern about the facility being so close to a major river.
Location alternatives in a more isolated area were favored by many.
Safety factors regarding the proximity of the facility to the local
airport were also mentioned as were the benefits of locating near an
existing PCB incinerator.
8-4
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• Benefits to the Local Economy: Some speakers expressed the view that
the facility would be good for the local economy by providing jobs and
an increased tax base. Other speakers argued that the increased
number of new jobs would not be significant to the local economy.
• Risks Associated With PCB's: The fact that PCB's are not a proven
carcinogen was raised at the hearing. Some speakers argued that the
relative risk of PCB's was not that great when compared to other
common hazardous substances.
• Risks Associated With Dioxlns and Dibenzofurans: Concern was expressed
about potential danger from dioxins and dibenzofurans that could be
formed by heating PCB's during normal plant operations or in case of
fire.
• Appropriate Mitlgative Measures: Some speakers expressed the hope
that the study would recommend appropriate measures which could be
taken to insure plant safety.
• Concern for Wildlife Areas: Speakers questioned the potential impact
of the project on sensitive wildlife habitats in the area*
A mailing list was prepared for this project consisting of local public
officials in the project area and all citizens who either attended EPA's
Public meeting or wrote us about the project# A copy of the issues raised at
the public meeting and other materials were sent to everyone on the mailing
list along with a copy of the scope of work for this Public Health and Environ-
mental Exposure Assessment. Four repositories have been set up in the project
area containing copies of public hearing transcriptst permit applications, and
related material from EPA's project files.
8-5
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9.0 PROPOSED EPA ACTION
Based upon a review of UNISON's permit application and the material
presented in this document, EPA has made a preliminary determination that
operation of the proposed facility at the UNISON site in Henderson will not
pose an unreasonable risk of injury to human health or the environment.
This determination is made based on the imposition of certain Conditions of
Authorization which are listed below. If these conditions of authorization are
violated, TSCA prescribes a civil penalty system with fines of up to $25,000
per day per violation.
EPA has also authorized the initiation of the test demonstration in late
August. This test will determine whether the process operations achieve
adequate separation of PCB residues and meet required emission levels.
EPA's final decision on authorization of plant operation will be based on
the results of the test demonstration as well as the comments received on
this Draft Public Health and Environmental Exposure Assessment.
The Draft Conditions of Authorization are as follows:
1. Advance Notification: A non-confidential written notice, to be
received by the addressee no less than thirty days, and no more than one
hundred eighty days prior to the conduct of a permitted PCB disposal activity,
shall be provided to: the appropriate EPA Regional PCB Coordinator, the
appropriate State Agency, and appropriate local town/city/county government
official(s). The content of the notice shall be at a minimum:
(1) The nature of the PCB disposal activity.
(2) The exact location(s), such as street address of a facility
(or, if there is no street address, plant site location with a
telephone contact such that exact location(s) may be determined
by telephone inquiry).
(3) The exact time(s) and date(s) the treatment will take place.
When changes in these time(s) and date(s) are expected, these changes
must be made immediately by telephone to the appropriate officials
(as indicated above) and followed by written notification of the
changes such that the revised times shall still be at least thirty
days following receipt of the written notificaiton.
2. Other Permits/Approvals: Permittee must obtain all necessary
environmental approvals and/or permits from the appropriate Federal,
State and local agencies prior to the treatment of PCBs at any site.
3. Limitation of Treatment Matrix: System will be permitted to treat
only the type of material successfully demonstrated to EPA.
4. Limitation of Matrix PCB Concentration: PCB concentration of the
fluid mixture in the process vessel is limited to the highest levels
successfully treated during the process demonstration.
9-1
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Prior to treatment, samples of the treatment matrix (feedstock)
must be obtained and analyzed by the Permittee using gas chromatography
procedures specified in EPA approved procedures outlined in the following
documents:
"Guidelines for PCB Destruction Permit
Applications and Demonstration Test Plans",
EPA Contract No. 68-02-3938, April 16, 1985:
"Recommended Analytical Requirements for PCB Data
Generated On Site During Non-Thermal PCB Destruction
Tests", USEPA, December 12, 1985 (Draft);
"Quality Assurance and Quality Control Procedures
for Demonstrating PCB Destruction in Filing for
PCB Disposal Permit", USEPA, June 28, 1983
(Draft); and
"Interim Guidelines and Specifications for
Preparing Quality Assurance Project Plans:
QAMS-005/80, Office of Research and Development,
Quality Control; A sample of treated material must be drawn,
and analyzed in duplicate by gas chromatography for the concentration of PCBs
after the treatment at the site where the PCB disposal process is being used.
If the concentration of PCBs in the treated sample is 2 ppm or greater, the
treated material must be reprocessed and reanalyzed to show less than 2 ppm
per peak before the next batch is treated.
6. Processing Time Limitation; If the quality control testing, as
described in Condition (5), reveals that the PCBs have not been adequately
removed after repeated processing (not to exoeed three times the estimated
theoretical time necessary for complete reaction), the facility shall cease
operation. The facility operator must notify the PCB Disposal Site Coordinator
in EPA Region IV immediately and file a written report with that region
within seven (7) days. The facility shall not resume operation until the
problem has been corrected to the satisfaction of the appropriate EPA region.
7. Operations Log/Recordkeeplng: Provisions must be made to assure
that the following process elements are suitably monitored and recorded for
each batch processed, such that materials harmful to health or the environ-
ment are not inadvertently released:
a* name, address, and telephone number of the disposal unit
operator and supervisor;
b. the name and business address of the person or firm
whose PCB-containing material is being processed;
9-2
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the location, manufacturer, rated capacity and
identification (serial) number of the transformer, heat
transfer system or hydraulic system, as appropriate;
d. the date the PCB material is received by Permittee,
the date(s) processed, and the date returned to the
oj.st.ody of the owner .if applicable);
e. estimated quantity and quality of feed material charged
into the reactor;
f. estimated quantity and quality of treated materials
and wastes produced;
g. date, time and duration of treatment per batch or system;
h. a copy of the gas chromatrograph and/or other records
from tests conducted to determine the final concentration
of the treated material;
i. estimated quantity and quality of wastes produced;
the method of disposal and location of the disposal
facility for each waste should be documented; and
j. temperature of reaction in at least one-half hour intervals.
Disposal recordkeeping documents must be compiled within 60 days of
the testing date, must be kept at one centralized location, and must be made
available for inspection by authorized representatives of the EPA. Such
documents shall be maintained for at least five years. Permittee must also
maintain the records required by MO CFR 761.180(f). If Permittee or its
authorized agents terminate business, these records or their oopies must be
submitted to the Regional Administrator, Region IV.
8. PCB Releases: In the event Permittee or an authorized facility operator
of the disposal facility unit believes, or has reason to believe, that a
release has or might have occurred, the facility operator must inform EPA
Region IV by telephone immediately.
A written report describing the incident must be submitted by the
close of business of the next regular business day following the incident.
No PCBs may be processed in that facility until the release problem has been
corrected to the satisfaction of the EPA Region IV.
9. PCB Spills: Any spills of PCBs or other fluids at the facility site
or related to transportation of materials offsite shall be promptly controlled
and cleaned up as provided in the Permittee's spill prevention plan, and in
accordance with the PCB spill cleanup procedures of EPA Region IV. In addition.
9-3
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a written report describing the spill, operations involved, cleanup actions
and changes in operation to prevent such spills in the future must be submitted
to EPA Region IV within seven (7) business days.
PCB spills must be reported in accordance with the PCB spill reporting
requirements prescribed under {311 of the Clean Water Act for discharges to
navigable waters and under the Comprehensive Environmental Response, Compensation,
and Liability Act (Superfund) for discharges to other media.
10. Safety and Health: Permittee must take all necessary precautionary
measures to insure that operation of the disposal facility is in compliance
with the applicable safety and health standards, as required by Federal,
State and local regulations and ordinances.
11. Facility Security: The disposal facility shall be secured (e.g.,
fence, alarm system, etc.) to restrict public access to the area. Any bodily
injury occurring as a result of the PCB disposal process must be reported to
the PCB Disposal Site Coordinator in EPA Region IV the next regular business
day.
12. Reporting of PCB Incidents: Any reports required by conditions (6),
(8), (9), and (11) are to be submitted by telephone to the appropriate regional
PCB Disposal Site Coordinator within the time frame specified. In addition,
Permittee shall file written reports with the Regional Administrator of EPA
Region IV and the Director of the Office of Toxic Substances within the time
frame specified in the aforementioned conditions.
13. Personnel Training: Permittee shall be responsible for ensuring that
personnel direotly involved with the handling or disposal of PCB-contaminated
fluid using the disposal process are demonstrably familiar with the general
requirements of this approval. At a minimum, this must include:
a. the type of materials which may be treated using the
PCB disposal process, and the upper limit of PCB
contamination which may be treated;
b. basic recordkeeping requirements under this approval
and the location of records;
c. notification requirements;
d. waste disposal requirements for process and by-product
wastes generated during the operation of the PCB disposal
process; and
e. reporting requirements.
9-4
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In this regard, Permittee must maintain on-site during the operation
of its separation facility, a copy of this approval; the spill prevention and
cleanup plan; and sampling and analytical procedures used to determine PCB
concentrations in untreated and treated materials.
11. PCB Transport Limitation: Untreated PCB fluids may not be
transported oft'-site of the disposal facility. Process equipment .i.e.,
reactors, pump hoses, etc.) must be decontaminated in accordance with
procedures described in Permittee's permit application and test plan, prior
to transporting off-site. PCB-contaminated equipment must be transported in
accordance with 10 CFR Section 761.10 and the U. S. Department of Transportation
(USDOT) requirements of Title 19, CFR Part 172, including placarding and
labelling all PCBs.
15. Process and Pollution Control Maintenance and Inspection:
Procedures must be followed in accordance with information provided in permit
application/demonstration plan, including periodic replacement of pollution
abatement parts (e.g., filters).
16. PCB Waste Disposal Requirements: All wastes generated by the PCB
disposal process other than the successfully cleaned material, (e.g., filter
media, sludges, water or other effluents) must be disposed of as if it contains
the original PCB feedstock concentration. EPA will consider amending this
condition only after such waste has been fully characterized to determine
all components, and gas chromatography analysis of the waste demonstrates that
the PCB concentration is below 2 ppm.
17. Financial Assurance: Permittee shall incorporate financial
assurance of closure and liability coverage provisions into its closure plan.
These provisions must be equivalent to those specified in 10 CFR Part 261,
Subpart H of the Resource Conservation and Recovery Act (RCRA), and provide
funds for:
a. proper closure of the PCB disposal units, and
b. compensating others for bodily injury and property
damage caused by accidents arising from operations
of the disposal units.
*8. Notification Requirements for New Facilities: Permittee must
notify the Regional Administrator in writing of any plans for new facilities
at the site. The Regional Administrator will then determine the appropriate
procedures for consideration of an operating permit for the proposed facilities.
19. Notice of Modifications: No major modifications may be made to
the unit design, as described in the application and demonstration plan for
this approval without written approval of the Regional Administrator. For
the purpose of this approval, "major modification" shall be defined as any
change to capacity, design, efficiency, waste type, or any other changes
affecting overall performance or environmental impacts.
9-5
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20. PCB Regulations Requirements: Permittee shall comply with all
applicable requirements of the Federal PCB Regulation, 40 CFR Part 761, in
the operation of the facility. Particular note shall be given to:
a. 40 CFR Section 761.65 - storage for disposal;
b. 40 CFR Section 761.79 - decontamination; and
c. 40 CFR Section 761.180 - records and monitoring.
21. Permit Severability: The conditions of this approval are
severable, and if any provision of this approval of any application of any
provision is held invalid, the remainder of this approval shall not be affected
thereby.
22. Permit Expiration/Renewal: Approvals are effective for a three-
year period. For a renewal approval, EPA may require additional information
and/or testing of the PCB disposal process. In order to continue the
effectiveness of an approval pending EPA action on reissuance, the Permittee
must submit a renewal request letter to EPA at least 90 days, but not more
than 180 days, prior to the expiration date of this approval.
2^ Annual Quality Control Monitoring: Permittee shall conduct
annual monitoring of the facility for PLBs, separation efficiencies and mass
emission rates for TF-1 and PCBs. If limits specified in the conditions of
approval are not complied with, U. S. EPA must be notified within one day of
receipt of the test report, and Permittee shall cease reparation of PCBs.
Otherwise test results shall be incorporated into the annua, ^port. j* no
disposal operations were conducted during the year of an anniversary of this
permit, the first disposal operation in the following year after the anniversary
shall be monitored as required under this condition.
2ii of Cleaned TF-1: Permittee shall not dispose of cleaned
-at^al th.r tHan ty^gi^
commerce or by disposing of the ® should the constituents of
dlSposai faclUty °r approved PCB lncln. haiardous „aste llst, th„,
TF-1 be fully evaluated f°r *nc^J0" 'accordance with any applicable
constituents shall then be disposed of in accoraan^
regulations.
. o^mutoe shall utilize a method (radio,
25 * Accident Reporting. tgnker trucks carrying TF-2 or PCB
telephone, etc.) of communicating drivers of each truck shall notify
residues and the separation fac clllty immediately prior to and
a responsible party at the separation bridge. UNISON shall maintain
Immediately following crossing the U.S. imraediately investigate failure
records of such communications. ^ bridge. Should an accident
to communicate successful crosslng or w n;t'be located, the permittee shall
occur on the bridge or should the ve Treatment Plant and the Henderson
Immediately notify the Evansville Water Treatment
County Sheriff's Department.
9-6
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26. Transport Limitations: Permittee shall assure that no TF-2
or PCB tanker trucks cross the U. S. Highway 41 bridge during periods when
ice, snow, or other severe weather conditions are causing hazardous driving
conditions.
-7• Emergency Training: Permittee shall at their sole expense
furnish to the applicable police, fire and emergency response agencies of the
city and County of Henderson and the City of Evansville, such special training
as is necessary to combat emergency or disaster situations which might reasonably
be anticipated at the subject property and along transportation routes in
these jurisdictions.
28. Safety Procedures and Equipment: Permittee shall follow safety
procedures as outlined in their operating manual. Permittee shall have and
maintain safety equipment at the separation facility as described in their
permit application and operating manual. Permittee shall notify EPA of any
proposed modifications to these operation procedures or changes in safety
equipment.
29. Monitoring Requirements: Permittee shall meet the baseline
environmental monitoring requirements of Henderson County and the operational
monitoring of the Commonwealth of Kentucky. Copies of environmental monitoring
reports shall be provided to EPA Region IV at the same time as provided to
the County and Commonwealth.
30. Process Limitations: Permittee shall not process greater amounts
of contaminated TF-1 CTF-X) than allowed in the State air permit.
31. Closure Plan: Permittee shall notify EPA in the event the
facility is to discontinue operation for an extended period (greater than
three months). Permittee shall notify EPA of any plans for closure and
submit a proposed plan of such closure 60 days in% advance to EPA for approval.
32. Facility Access: The Permittee shall allow EPA inspectors aocess
to the facility and all reports, documents, or other materials required of
this facility by EPA, the Commonwealth and Henderson County at any time with
or without prior notification.
9-7
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10.0 LIST OF PREPARERS
EPA. Region IV
Robert B. Howard - Chief, NEPA Compliance Section
Robert C. Cooper - Project Officer
Robert G. Stryker - Chief, Toxic Substances Section
Constance Jones - Toxic Substances Section
Lew Nagler - Air Programs Branch
EPA, Headquarters
Suzanne Rudsinski - Chief, Chemical Regulation Branch
John H. Smith - Chemical Regulation Branch
Jane Kim - Chemical Regulation Branch
WAPORA. Inc.
Steven D. Bach, Ph.D. - Program Manager
Charles E. Beck, J.D. - Project Director
Anthony F. Moscati, Ph.D.
Thomas Reed Lee, Ph.D.
J. Kevin Chisholm, M.S., P.E.
William H. Murdy, III, M.S.
Eric M. Hediger, M.E.M.
John M. Dwyer
John J. Nugent
Eleanor T. Clements
10-1
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11.0 REFERENCES
Area Plan Commission. 1985. The comprehensive plan 1985. Evansville-
Vanderburgh County, Evansville, IN.
ASCE Task Committee for the Preparation of the Manual on sedimentation of the
Sedimentation Committee of the Hydraulics Division. 1975. Chapter III -
Sediment measurement techniques sedimentation engineering, Vito A.
Vanoni, Editor. The American Society of Civil Engineers, New York, NY.
Banta, Ann. 1986. Kentucky State Police, personel communication, March 20,
1986 with Dr. Steven Bach, WAPORA, Inc.
BESD. 1984. Bio-Environmental Services Division of the Jacksonville, Florida
Department of Health, Welfare and Bio-Environmental Services. Report on
the Fire at Conversion Technology Corporation Warehouse at 495 Ellis Road
(formerly American Electric). Prepared for the Jacksonville City Council
Health and Welfare Committee, February 17, 1984.
COE. 1985. U.S. Army Corps of Engineers, Louisville District, Ohio River
Division. January 1985. Canoe Creek Henderson, Kentucky. Local flood
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Cornell, C.A. 1973. Final report to the Oregon Nuclear and Thermal Energy
Council on Naval Aircraft Accident Risks at the Carby Site. May 31,
1973.
DOE. 1982. U.S. Department of Energy, Assistant Secretary for Nuclear Energy
Office of Uranium Enrichment and Assessment. June 1982. Incineration
facility for radioactively contaminated polychlorinated biphenyls and
other wastes. Final environmental Impact statement Oak Ridge Gaseous
Diffusion Plant, Oak Ridge, Tennessee. Washington, DC.
Dolbry, Ricardo, Felix Y. Yokel and Richard S. Ladd. 1981. Liquefaction
Potential of Overconsolidated Sands in Areas with Moderate Seismicity.
Earthquakes and earthquake engineering! The eastern United States Volume
2, Assessing the Hazard - Evaluating the Risk. Edited by James E, Beavers.
Ann Arbor Science Publishers, Inc., The Butterworth Group. 1981.
DOT. 1977. U.S. Department of Transportation. National Transportation
Choices and Trends.
Eblen, Tom. 1986. Memphis Taking Quake Risk Seriously. The Atlanta Journal
and Atlanta Constitution. April 6, 1986.
EPA. 1974. United States Environmental Protection Agency. Methodology for
Chemical Hazard Prediction. NTIS #AD-A0Q8,-159. October 1974.
EPA. 1976a. United States Environmental Protection Agency. PCBs in the
United States Industrial Use and Environmental Distribution. Prepared by
Versar, Inc. Under EPA Contract No. 68-01-3259. Washington, DC.
11-1
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EPA. 1976b. U.S. Environmental Protection Agency, EPA-560/6-75-004.
National Conference on polychlorinated biphenyls. Prepared for
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Contract No. 68-01-2928, Washington, DC.
EPA. 1977. U.S. Environmental Protection Agency, Surveiliance and Analysis
Division. October 1977. Ambient Concentrations of PCBs in the southeast
from storet data and seLected EPA studies. Athens, GA.
EPA. 1980. U.S. Environmental Protection Agency. Ambient water quality
criteria for polychlorinated biphenyls. EPA 440/5-80-068.
EPA. 1981. U.S. Environmental Protection Agency. November 4, 1981. Draft,
Environmental Impact Statement on the Waukegan Harbor. PCB abatement
project. Chicago, IL.
EPA. March 1984. U.S. Environmental Protection Agency. An Age-Dependent
Model of PCB in a Lake Michigan food chain. Project summary. Robert V.
Thomann and John P. Connolly. Environmental Research Laboratory.
Research and Development. EPA-600/53-84-026.
EPA. August 1984. U.S. Environmental Protection Agency, Environmental
Criteria and Assessment Office. Health Assessment Document for Poly-
chlorinated Dibenzo-p-dioxins. EPA 600/8-84-014A NTIS PB 84-220268.
Cincinnati, OH.
EPA. September 1984. U.S. Environmental Protection Agency, Environmental
Criteria and Assessment Office. Health Effects Assessment for Poly-
chlorinated Biphenyls (PCBs). Prepared by Syracuse Research Corporation,
under EPA Contract no. 68-03-3112. Washington, DC.
EPA. October 1984. Inpuff - A Single Source Gaussian Puff Dispersion Algorithm.
EPA-600/8-84-027.
EPA. March 1985. U.S. Environmental Protection Agency. Assessment of
Incineration as a treatment method for liquid organic hazardous wastes.
Background Report IV: Comparison of Risks from land-based and ocean-
based incineration. Prepared by Industrial Economics, Inc. in
association with Applied Science Associates, Inc. for Office of Policy
Analysis. Washington, DC.
EPA. April 1985. U.S. Environmental Protection Agency, Office of Toxic
Substances, Field Studies Branch. Guidelines for PCB destruction permit
applications and demonstration test plans. By Roy M. Neulicht, Mitchell
D. Erickson, and Rajendra V. Shah. April 16, 1985, under EPA Contract
No. 68-02-3938 and MRI Project No. 8201-A(06) Washington, DC.
EPA. June 1985a. U.S. Environmental Protection Agency Exposure Evaluation
Division. June 26, 1985. Exposure Assessment for polychlorinated
biphenyls (PCBs), polychlorinated dibenzofurans (PCDFs), and poly-
chlorinated dibenzodioxins (PCDDs) released during transformer fires,
final report. Prepared by Versar, Inc. under EPA Contract No.
68-02-3968, Task No. 8, Washington, DC.
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EPA. June 1985b. United States Environmental Protection Agency, OPTS, ETD,
Putnam, Hayes and Bartiett, Inc. Regulatory Impact Analysis of the Final
Rule for PCB Transformers.
EPA. January 1986. U.S. Environmental Protection Agency, Office of Toxic
Substances. Exposure Evaluation Division (TS-798), Verification of PCB
Spill Cleanup by Sampling and Analysis by Bruce A. Boomer, Mitchell D.
Erickson, Stephen E. Swanson, Gary L. Kelso, Midwest Research Institute,
under EPA Contract No. 68-02-3938 and MRI Project No. 8501-A(37) and EPA
Contract No. 68-01-6721 WCG Subcontract to Battelle Columbus Laboratories
No. F4138(8149) 435 Washington, DC.
EPA. March 1986. U.S. Environmental Protection Agency, Office of Toxic
Substances Exposure Evaluation Division. March 17, 1986. PCB spill
cleanup draft report. Prepared by Versar, Inc. under EPA Contract No.
68-02-3968 Task No. 107. Washington, DC.
FAA. 1984. Department of Transportation, Federal Aviation Administration.
December 31, 1984. FAA Statistical Handbook of Aviation. Annual
Calender year 1983. Performing organization - Federal Aviation Admin-
istration. Office of Management Systems. AMS-420, Washington, DC.
Finni. 1986. Gary Finni, Director, Ohio River Study Group, WAPORA, Inc.
Personal communication to Dr. Steven Bach, WAPORA, Inc. June 18, 1986.
Fuller, Edward N., Paul D. Schettler and J. Calvin Giddlngs. 1966. A Method
for Prediction of Binary Gas-Phase Diffusion Coefficients. Industrial
and Engineering Chemistry Vol. 58, No. 5. May 1966.
Harvey, Edward J. 1956. Geology and Groundwater Resources of the Henderson
Area Kentucky. Geological Survey water-supply paper 1356. Prepared in
cooperation with the Agricultural and Industrial Development Board,
Commonwealth of Kentucky. United States Government Printing Office,
Washington, D.C.
Hopper, M.G., S.T. Algermissen and E.E. Dobrovolny. 1983. Estimation of
earthquake effects associated with a great earthquake in the New Madrid
seismic zone, in, A Workshop on continuing actions to reduce losses from
future earthquakes in Arkansas and nearby states. Edited by W.W. Hays
and P.L. Gori, USGS open file report #83-0846.
Lees, Frank P. 1980. Loss prevention in the process industries. Butterworth's
and Co. (Publishers) Ltd, Boston, MA.
Lynch, O.M., and H.M. Steelman, Jr. 1986* North Carolina Department of
Transportation. Letter of July 18, 1986 to Mr. Earl Bozeman, EPA Region
IV.
MacKay, Paterson, Eisenreigh, Simmons. 1981. Physical behavior of PCBs in
the Great Lakes. Chapter 18. Dynamic Mass Balance of PCB and suspended
solids in Saginaw Bay — A case study. William L. Richardson, V. Elliott
Smith, Robert Wethington. Ann Arbor Science.
11-3
-------
Maxwell, B.W. and R.W. DeVaul. 1962. Reconnaissance of ground-water resources
in the western coal field region, Kentucky. Geological survey water-supply
paper 1599. Prepared in cooperation with the Commonwealth of Kentucky,
Department of Economic Development, and the Kentucky Geological Survey,
University of Kentucky. United States Government Printing Office,
Washington, DC.
McCabe, John A. 1962. Floods in Kentucky-magnitude and frequency. Kentucky
Geological Survey, Lexington, Kentucky, July 1962. Prepared by the
United States Geological Survey and the Kentucky Geological Survey with
the cooperation of the Kentucky Department of Commerce. College of Arts
and Sciences, University of Kentucky.
Kokoszka, L, and G. Kuntz. 1983. Methods of PCB disposal. Presented at the
PCB seminar, Netherlands Ministry of Housing and Environment (OECD).
NIOSH. 1977. U.S. Department of Health, Education, and Welfare. September
1977. Criteria for a recommended standard... Occupational exposure to
polychlorinated biphenyls (PCBs) HEW (NIOSH) Publication No. 77-225.
Washington, DC.
NIOSH. 1984. U.S. Department of Health and Human Services. Public Health
Service, Centers for Disease Control. National Institute for Occupational
Safety and Health. January 23, 1984 2,3,7,8-Tetrachlorodibenzo-p-dioxin
(TCDD, "dioxin") Current Intelligence Bulletin 40. DHHS (NIOSH)
Publication No. 84-104. Atlanta, GA.
NIOSH. 1986. U.S. Department of Health and Human Services. Public Health
Service, Centers for Disease Control National Institute for Occupational
Safety and Health. February 24, 1986 Polychlorinated biphenyls (PCBs):
Potential Health Hazards from Electrical Equipment Fires or Failures
Current Intelligence Bulletin 45 DHHS (NIOSH) Publication No. 86-111
Atlanta, GA.
NOAA. 1981. National Oceanic and Atmospheric Administration. National
Environmental Data and Information Service. National Climatic Center.
General Summary of Tornadoes. Henry N. Vigansky, Asheville, NC.
NOAA. 1984. National Oceanic and Atmospheric Administration. National
Administration. National Environmental Satelite, Data and Information
Service. National Climatic Data Center. December 1984. Storm Data
Volume 26, Number 12. Asheville, NC.
Nuttli, O.W. 1983. Historical overview, current status of knowledge and
seismological research in the New Madrid seismic zone, in, A Workshop on
continuing actions to reduce losses from future earthquakes in Arkansas
and nearby states. Edited by W.W. Hays and P.L. Gori, USGS open file
report if83-0846, 1983,
ORl. 1978. Risk assessment of air versus other transportation modes for
explosives and flammable cryogenic liquids. Draft report number I.
Prepared under Contract No. DOT-RC-82036 for Department of Transpor-
tation. Washington, DC.
11-4
-------
Petersen, Bill. 1982. Estimating concentrations downwind from and
instanteous putt release. April 1982. EPA 600/3-82-078.
Sax, Irving N. 1978. Dangerous properties of industrial materials (5th Ed.).
Seed, II. BoLton. 1979. Soil "Liquefaction and Cyclic Mobility Evaluation fur
Level Ground During Earthquakes." Journal of the Geotechnical Engineering
Division. ASCE, February 1979.
Smith, R.E., Sandia National Laboratories. 1983. A methodology for calcula-
tion of the probability of a crash of an aircraft into structures in
weapons storage areas. February 1983.
Snow, John T. 1984. The Tornado, in Scientific American, April 1984.
Solomon, K.A., NUS Corporation. 1975. Estimate of the probability that an
aircraft will impact the Palo Verde Nuclear generating station (PVNGS).
June 1975.
Strahler, Arthur N. 1981. Physical Geology, Harper & Row.
Turner, B. 1970. Workbook of atmospheric dispersion estimates. Research
Triangle Park, NC: U.S. Environmental Protection Agency.
Ullman, Neil R. 1972. Statistics, An Applied Approach, Xerox Corporation.
U*S. Army Chemical Research and Development Center * T.R. CRDC—TR, January
1986.
USWAG. 1982. U.S. Environmental Protection Agency. Comments and Studies on
the use of polychlorinated biphenyls in response to an order of the
United States Court of Appeals for the District of Columbia Circuit.
Volume I, Submitted by the Utility Solid Waste Activities Group, The
Edison Electric Institute and the National Rural Electric Cooperation
Association. Washington, DC.
USWAG. 1982. U.S. Environmental Protection Agency. Comments and Studies on
the use of polychlorinated biphenyls in response to an order of the
United States Court of Appeals for the District of Columbia Circuit.
Volume III, Submitted by the Utility Solid Waste Activities Group, The
Edison Electric Institute and the National Rural Electric Cooperation
Association. Washington, DC.
USWAG. 1982. U.S. Environmental Protection Agency. Comments and Studies on
the use of polychlorinated biphenyls in response to an order of the
United States Court of Appeals for the District of Columbia Circuit.
Volume IV, Submitted by the Utility Solid Waste Activities Group, The
Edison Electric Institute and the National Rural Electric Cooperation
Association. Washington, DC.
United States Department of Agriculture. 1967. Soil Conservation Service in
cooperation with Kentucky Agriculture Experiment Station. February 1967.
Soil Survey, Henderson County, Kentucky.
11-5
-------
U.S. Geological Survey. 1972. The San Fernando California Earthquake of
1971, (JSCS Professional Paper 733, GPO Wash.
U.S. Department of the Navy. 1985. St. Mary's Airport Study. January 31,
1985.
Veith, G.D. , D.W. Kuehl, F.A. Puglisi, G.E. Glass, and J.G. Eaton. 1977.
Residues of PCBs and DDT in the western Lake Superior ecosystem. Archives
of environmental contamination and toxicology 5:487-499.
Versar Vol. III. 1983. U.S. Environmental Protection Agency Office of Toxic
Substances Exposure Evaluation Division Exposure Assessment for
Incidentally-produced polychlorinated biphenyls (PCBs) Appendix B:
Organic chemicals possibly associated with incidentally produced PCBs.
Report by Stanley Cristol, University of Colorado. Appendix C: Chemical
by Chemical Exposure Summary Reports. Draft Final Report Volume III.
Prepared by Versar, Inc. Under EPA Contract No. 68-01-6271 Task No. 21.
August 15, 1983.
Versar Vol. IV. 1983. U.S. Environmental Protection Agency. Office of Toxic
Substances Exposure Evaluation Division. August 15, 1983. Exposure
Assessment for Incidentally produced polychlorinated biphenyls (PCBs)
Appendix D: Prediction of Human Exposure to PCBs - Exposure Assessment
for Hydraulic and Heat transfer authorized uses. Draft Final Report
Volume IV. Prepared by Versar, Inc. under EPA Contract No. 68-01-6271
Task 55.
Versar Vol. I. 1984. U.S. Environmental Protection Agency. Office of Toxic
Substances Exposure Evaluation Division May 2, 1984. Exposure Assessment
for polychlorinated biphenyls (PCBs): Incidental Production, Recycling,
and selected authorized uses final report, Volume I. Prepared by Versar,
Inc. under EPA Contract No. 68-01-6271 Task No. 21. Washington, DC.
Versar Vol. II. 1984. U.S. Environmental Protection Agency. Office of Toxic
Substances Exposure Evaluation Division May 2, 1984. Exposure Assessmnt
for polychlorinated biphenyls (PCBs): Indicental Production, recycling,
and selected authorized uses. Appendix A: Generic Exposure Scenarios
Final Report, Volume II. Prepared by Versar, Inc. under EPA Contract No.
68-01-6270 Task No. 21, Washington, DC.
Weather Bureau. 1960. U.S. Department of Commerce Weather Bureau. Revised
1960. Tornado Occurrences in the United States. Technical Paper No. 20.
Laura V. Wolford Office of Climatology. Washington, DC.
11-6
-------
APPENDICES
APPENDIX 1. TOXIC SUBSTANCES CONTROL ACT, SECTION 6(e)
40 CFR 761 excerpts
TSCA Compliance Program Policy No. 6-PCB-2 excerpts
TSCA Compliance Program Policy No. 6-PCB-3 excerpts
51 FR 6423 et. seq.
APPENDIX 2.
APPENDIX 3.
APPENDIX 4.
APPENDIX 5.
APPENDIX 6.
APPENDIX 7.
APPENDIX 8.
APPENDIX 9.
APPENDIX 10.
APPENDIX 11.
NIOSH RECOMMENDATIONS FOR PCB STANDARDS
EPA GENERAL PERMIT CONDITIONS
HCBZA CONDITIONAL USE PERMIT
EPA FIRES RULE BROCHURE
AIR EMISSIONS, ORDINARY OPERATIONS
TORNADO EFFECTS
DESCRIPTION OF AIRCRAFT ACCIDENT CALCULATION
FAA ACCIDENT DATA
EVANSVILLE GROUP QUARTERS
OHIO RIVER PCB CONCENTRATIONS IN FISH
LOCAL ACCIDENT CHANCES AND EXPECTATIONS
SUMMARY TABLE
-------
APPENDIX 1
TOXIC SUBSTANCES CONTROL ACT
Section 6(e)
-------
(e) Polychlorin-ated Biphevvls.—(l) Within six
months afrer t!u: effective date of tliis Act the Adminis-
trator shall promulgate rules to—
(A) prescribe methods for the disposal of poly-
chlorinated biphenyl?. and
(B) require polyclilorinatcd biphcnvls to be
marked with clear and adequate warnings, and in-
structions with respect to their processing, distribu-
tion in commerce. use. or disposal or with respect to
any combination of such activities.
Requirements prescribed by rules under this paragraph
shall be consistent with the requirements of paraeraons
(2) and (3).
(2) (A) Except as provided under subparagraph (B),
effective one year after the effective date of this Act no
person may manufacture, process, or distribute in com-
merce or use any polychlorinated biphenyl in any man-
ner other than in a totally enclosed manner.
(B) The Administrator may by rule authorize the
manufacture, processing, distribution in commerce or use
(or any combination of such activities) of any poly-
chlorinated biphenyl in a manner other than in a totally
enclosed manner if the Administrator finds that such
manufacture, processing, distribution in commerce, or
use (or combination of such activities) will not present
an unreasonable risk of injury to health or the
environment.
(C) For the purposes of this paragraph, the term "to-
tally enclosed manne.r" means any manner which will en-
sure that any exposure of human beings or the environ-
ment by the* polychlorinated biphenyl will be insignifi-
cant as'dctonnined by the Administrator bv rule.
(3) (A) Except as provided in subparagraphs (B) and
(C)-
(i) no person may manufacture any polychlori-
nated bipnenyl after two years after the effective
date of this Act, and
(ii) no person may process or distribute in com-
merce any polychlorinated biphenyl after two and
one-half ynr- af:-r h (into.
(B) Any person may petition the Administrator for
an exemption from the requirement! of stibparigaph
-(A), and the Administrator may grant by rule fuch an
exemption if the Administrator finds that . u.
(i) an unreasonable risk of injury to health or
environment would not result, ana
(ii) good faith erFort-s have boon made to develop
a chemical substance which does not present an un-
reasonable risk of injury to health or the environ-
ment and which mav be substituted for such poly-
chlorinated biphenyl. , . ..
An exemption granted under th ^subparagraph snail
be subject to such terms and condition? wthe
trator may prescribe and shall be m effect
period (but not more than one year from the date it l*
eranted) as the Administrator may prescribe. ,
(C) Subparagraph (A) shall nottapply to the dis-
tribution in commerce of any
if such polychlorinated biphenyl was sold torjmipj£-.
other than resale before two and one half y#*»
the date of enactment of this Act. .
(4) Any rule under paragraph (U, (2)(B). ot (»)
(B) shall be promulgated in accordance with para-
ornnhs m (8). and (4) of subsection (c). (
(5) This'subsection does not limit t!j ®utJ?"i yA®t
the Administrator, under any other Pr.ov,s^n fny
or anv other Federal law, to take action respecting any
polychlorinated biphenyl.
-------
FART 761—*OlYCHlORlNATID Bl-
PHENYLS (PCBt) MANUFACTUR-
ING, PXOCESSINO, DISTRIBUTION
IN COMMERCE, AND USE PROHIBI-
TIONS
Subpart A—danaral
Sec.
781.1 Applicability.
761.3 Definitions.
761.19 References.
Subpart •— Manufacturing, P'oitning, Dl»tri-
bufian in Cammarca, and Uta at PCIi an4
Kl tfam*
761.20
761.30
Prohibition*.
Authorisations.
Swfepart C ¦ MaHriwf af PCS* and PCS Hmm
761.40 Marking requirement*.
761.4S Marking format*.
Subpart 0—Staraf a and Dltpaia)
761.60 Disposal requirement*.
761.65 Storage for disposal.
761.70 Incineration.
761.75 Chemical waste landfill*.
761.79 Decontamination.
Subpart MsMfNfw
761.80 Manufacturing, processing, and dis-
tribution in commerce exemptions.
t I ¦ Oasarvad)
Subpart J— Records and Reports
781.180 Records and monitoring.
761.185 Certification program and reten-
tion or records by Importer! and persona
generating FOBs In excluded manufac-
turing processes.
761.187 Reporting importers and by per-
son* generating PCBs in excluded manu-
facturing processes.
761.183 Maintenance of monitoring records
by persona who import, manufacture,
process, distribute In commerce, or use
chemicals containing Inadvertently ven-
erated PCBs.
Authority: Sees. 6, 8. and 13. Toxic Bub-
stances Control Act. 15 U.8.C. 2805, 2807.
and 2611.
Subpart A-Oiiwwl
1761.1 Applicability.
(a) This part establishes prohibition*
of, and requirements for. the manufac-
ture, processing, distribution in com-
merce. use, disposal, storage, and
marking of PCBs and PCB Items.
(b) This part applies to all persons
who manufacture, process, distribute
in commerce, use. or dispose of PCBs
or PCB Items. Substances that are
regulated by this rule include, but are
not limited to, dielectric fluids, con-
taminated solvents, oils, waste oils,
heat transfer fluids, hydraulic fluids,
paints, sludges, slurries, dredge spoils,
soils, materials contaminated as a
result of spills, and other chemical
substances or combination of sub-
stances, including impurities and by-
products and any byproduct, interme-
diate or impurity manufactured at any
point in a process. Most of the provi-
sions of this part apply to PCBs only
if PCBs are present in concentrations
above a specified level. For example.
Subpart D applies generally to materi-
als at concentrations of 50 parts per
million (ppm) and above. Also certain
provisions of Subpart B apply to PCBs
inadvertently generated in manufac-
turing processes at concentrations
specified in the definition of "PCB"
under i 761.3. No provision specifying
a PCB concentration may be avoided
as a result of any dilution, unless oth-
erwise specifically provided.
(c) Definitions of the terms used in
these regulations are in Subpart A.
The basic requirements applicable to
disposal and marking of PCBs and
PCB Items are set forth in Subpart
D—Disposal of PCBs and PCB Items
and in Subpart C—Marking of PCBs
and PCB Items. Prohibitions applica-
ble to PCB activities are set forth in
Subpart B—Manufacture, Processing,
Distribution in Commerce, and Use of
PCBs and PCB Items. Subpart B also
includes authorizations from the pro-
hibitions. Subparts C and D set forth
the specific requirements for disposal
and marking of PCBs and PCB Items.
(d) Section IS of the Toxic Sub-
stances Control Act (TSCAV states
that failure to comply with these regu-
lations is unlawful. 8ection IB imposes
liability for civil penalties upon any
person who violates these regulations,
and the Administrator can establish
appropriate remedies for any viola-
tions subject to any limitations Includ-
ed In section IB of TSCA. Section IB
also subjects a person to criminal pros-
ecution for a violation which is know-
ing or willful. In addition, section 17
authorizes Federal district courts to
enjoin activities prohibited by these
regulations, compel the taking of ac-
tions required by these regulations,
and issue orders to seise PCBs and
PCB Items manufactured, processed
or distributed in violation of these reg-
ulations.
-------
i 761.3. are exempt from the require-
ments of Subpart B of this part, pro-
vided that such persons comply with
Subpart J of this part, as applicable.
(2) Persons who process, distribute
in commerce, or use products contain-
ing PCBs generated in excluded manu-
facturing processes defined in J 761.3
are exempt from thp requirements of
Subpart B provided that such persons
comply with Subpart J of this part, as
applicable.
(3) Persons who process, distribute
In commerce, or use products contain-
ing recycled PCBs defined in § 761.3.
are exempt from the requirement* of
Subpart B of this part, provided that
such persons comply with Subpart J of
this part, as applicable.
(Sec. 6. Pub. h. 94-469, 00 Stat. 2020 (25
U.S.C. 2605)
(44 FR 31542. May 31. 1979. as amended at
49 FR 28189, July 10. 19641
8 761.3 Definition*.
For the purpose of this part:
Commerce" means trade, traffic,
transportation, or other commerce:
(1) Between a place in a State and
any place outside of such State, or
<2) Which affects trade, traffic,
transportation, or commerce described
in paragraph U> of this definition.
"Disposal" mean* intentionally or
accidentally to discard, throw away, or
otherwise complete or terminate the
useful life of PCBs and PCB Items.
Disposal includes spUls. leaks, and
other uncontrolled discharges of PCBs
as well as actions related to contain*
ing, transporting, destroying, degrad-
ing, decontaminating, or confining
PCBs and PCB Items.
"Distribute In commerce" and "Dis-
tribution in Commerce" when used to
describe an action taken with respect
to a chemical substance, mixture, or
article containing a substance or mix-
ture means to sell, or the sate of. the
substance, mixture, or article in com-
merce; to introduce or deliver for in-
troduction into commerce, or the in-
troduction or delivery for introduction
into commerce of the substance, mix-
ture, or article; or to hold or the hold-
ing of, the substance, mixture, or arti-
cle after its introduction into com-
merce.
"Excluded manufacturing process"
means a manufacturing process in
which quantities of PCBs. as deter-
mined in accordance with the defini-
tion of inadvertently generated PCBs.
calculated as defined, and from which
releases to products, air, and water
meet the requirements of paragraphs
(1) through (5) of this definition, or
the importation of products contain-
ing PCBs as unintentional impurities,
which products meet the requirements
of paragraph (1) and (2) of this defini-
tion.
(1) The concentration of inadvert-
ently generated PCBs in products leav-
ing any manufacturing site or import
ed into the United States must have
an annual average of less than 25 ppm.
with a SO ppm maximum.
T5) The concentration of inadvert-
ently generated PCBs in the compo-
nents of detergent bars leaving the
manufacturing site or imported into
the United States must be less than 5
ppm.
(3) The release of inadvertently gen-
erated PCBs at the point at which
emissions are vented to ambient air
must be less than 10 ppm.
(4) The amount of inadvertently
generated PCBs added to water dis-
charged from a manufacturing site
must be less than 100 micrograms per
resolvable gas chromatographic peak
per liter of water discharged.
(5) Disposal of any other process
wastes above concentrations of 50 ppm
PCB must be in accordance with Sub-
part D of this part.
"PCB" and "PCBs" means any
chemical substance that is limited to
the biphenyl molecule that has been
chlorinated to varying degrees or any
combination of substances which con-
tains such substance. Refer to
1761.1(b) for applicable concentra-
tions of PCBs. PCB and PCBs as con-
tained in PCB items are defined in
} 761.3. For any purposes under this
part, inadvertently generated non-Aro-
clor PCBs are defined as the total
PCBs calculated following division of
the Quantity of monochlorinated bi-
phenyls by 80 and dichlorinated bi-
phenyls by 5.
"PCB Article" means any manufac-
tured article, other than a PCB Con-
tainer, that contains PCBs and whose
surface(s) has been in direct contact
with PCBs. "PCB Article" includes ca-
pacitors, transformers, electric motors,
pumps, pipes and any other manufac-
tured item (1) which is formed to a
specific shape ordesign during manu-
facture. (2) which has end use
funetion(s) dependent in whole or in
part- upon its shape or design during
end use and (3) which has either no
change of chemical composition
during Its end use or only those
changes of composition which have no
commercial purpose separate from
that of the PCB Arttei*.
-------
"PCB Article Container" means any
package, can. bottle. bag. barrel, drum,
tank, or other device used to contain
PCB Articles or PCB Equipment, and
whose surface(s) has not been in direct
contact with PCBs.
"PCB Container" means any pack-
age. can. bottle, bag, barrel, drum,
tank, or other device that contains
PCBs or PCB Articles and whose
surface(s) has been in direct contact
with PCBs.
"PCB Equipment" means any manu-
factured item, other than a PCB Con-
tainer or & PCB Article Container,
which contains a PCB Article or other
PCB Equipment, and includes micro-
wave ovens, electronic equipment, and
fluorescent light ballasts and fixtures.
"PCB Item" Is defined as any PCB
Article, PCB Article Container, PCB
Container, or PCB Equipment, that
deliberately or unintentionally con-
tains or has a part of it any PCB or
PCBs.
"PCB Transformer" means any
transformer that contains 500 ppm
PCB or greater.
"PCB-Contaminated Electrical
Equipment" means any electrical
equipment, including but not limited
to transformers (including those used
in railway locomotives and self-pro-
pelled cars), capacitors, circuit break-
ers, reclosers. voltage regulators,
switches (including sectionalizers and
motor starters), electromagnets, and
cable, that contain 50 ppm or greater
PCB, but less than 500 ppm PCB. Oil-
filled electrical equipment other than
circuit breakers, reclosers. and cable
whose PCB concentration is unknown
must be assumed to be PCB-Contami-
nated Electrical Equipment. (See
{761.30 (a) and (h) for provisions per-
mitting reclassification of electrical
equipment containing 500 ppm or
greater PCBs to PCB-Contaminated
Electrical Equipment).
*
"Recycled PCBs" we defined as
those intentionally manufactured
PCBs which appear in the processing
of paper products or asphalt roofing
materials as PCB-contaminated raw
materials and which meet the require-
ments of (1) through (5) of this defini-
tion.
(1) The concentration of Aroclor
PCBs in paper products leaving any
manufacturing site or Imported into
the United States must have an
annual average of leas than 25 ppm
with a 50 ppm maximum.
(2) There are no detectable concen-
trations of Aroclor PCBs in asphalt
roofing materials.
(3) The release of Aroclor PCBs at
the point at which emissions are
vented to ambient air must be less
than 10 ppm.
(4) The amount of Aroclor PCBs
added to water discharged from a
processing site must at all times be
less than 3 micrograms per liter (jig/l)
for total Aroclors (roughly 3 parts per
billion (3 ppb)).
(5) Disposal of any other process
wastes above concentrations of 50 ppm
PCB must be In accordance with Sub-
part D of this part.
*
"Storage for disposal" means tempo-
rary storage of PCBs that have been
designated for disposal.
*
Subpart ft—Manufacturing, Process*
ing, Distribution in Commerce, and
Us* of PCBs and PCS Item*
17C1.20 Prohibitions.
Except as authorized in } 781.30. the
activities listed in paragraphs (a) and
(d) of this section are prohibited pur-
suant to section 6(e)(2) of TSCA. The
requirements set forth in paragraphs
(b) and (c) of this section concerning
export and import of PCBs for pur-
poses of disposal and PCB Items (or
purposes of disposal are established
pursuant to sectton 6(e)(1) of TSCA.
Subject to any exemptions granted
pursuant to section 6(e)(3)(B) of
TSCA. the activities listed in para-
graphs (b) and (c) of this section are
prohibited pursuant to section
(6)(e)(3)(A) of TSCA. In addition, the
Administrator hereby finds, under the
authority of section 12(a)(2) of TSCA.
that the manufacture, processing, and
distribution in commerce of PCBs at
concentrations of 50 ppm or greater
and PCB Items with PCB concentra-
tions of 50 ppm or greater present an
unreasonable risk of injury to health
within the United States. This finding
is based upon the well-documented
human health and environmental
hazard of PCB exposure, the high
probability of human and environmen-
tal exposure to PCBs and PCB Items
from manufacturing, processing, or
distribution activities: the potential
hazard of PCB exposure posed by the
transportation of PCBs or PCB Items
within the United States; and the evi-
dence that contamination of the envi-
ronment by PCBs is spread far beyond
the areas where they are used. In addi-
tion. the Administrator hereby finds,
for purposes of section 6(e)(2)(C) of
-------
TSCA, that any exposure of human
beings or the environment to PCBs, as
measured or detected by any scientifi-
cally acceptable analytical method,
may be significant, depending on such
factors as the quantity of PCBs in-
volved in the exposure, the likelihood
of exposure to humans and the envi-
ronment. and the effect of exposure.
For purposes of determining which
PCB Items are totally enclosed, pursu-
ant to section 6(e)(2)(C) of TSCA.
since exposure to such Items may be
significant, the Administrator further
finds that a totally enclosed manner is
a manner which results in no exposure
to humans or the environment to
PCBs. The following activities are con-
sidered totally enclosed: distribution
in commerce of intact, nonleaking
electrical equipment such as trans-
formers (including transformers used
in railway locomotives and self-pro-
pelled cars), capacitors, electromag-
nets, voltage regulators, switches (in-
cluding sectionalizers and motor start-
ers), circuit breakers, reclosers. and
cable that contain PCBs at any con-
centration and processing and distri-
bution in commerce of PCB Equip-
ment containing an intact, nonleaking
PCB Capacitor. See paragraph (c)(1)
of this section for provisions allowing
the distribution in commerce of PCB*
and PCB Items.
(a) No person may use any PCB. or
any PCB Item regardless of concentra-
tion, in any manner other than in a to-
tally enclosed manner within the
United States unless authorised under
( 761,30. except that an authorization
is not required to use those PCBs or
PCB Items resulting from an excluded
manufacturing process or recycled
PCBs defined in i 761.3, provided all
applicable conditions of 1161.1(f) are
met.
fl 761.30 Authorizations.
following non-totally enclosed
PCB activities are authorized pursuant
to section 6(e)(2)(B) of TSCA:
(a) Use in and servicing of trans-
formers (other than railroad trans-
formers), PCBs at any concentration
may be used In transformers (other
than transformers for railroad locomo-
tives and self-propelled railroad can)
and may be used for purposes of serv-
icing including rebuilding these trans-
formers for the remainder of their
useful lives, subject to the following
conditions:
(1) Vu conditions, (i) After October
l. 1985, the use and storage for reuse
of PCB Transformer* that pose an ex-
posure risk to food or feed is prohibit-
ed.
(11) A visual inspection of each PCB
Transformer (as defined in the defini-
tion of "PCB Transformer" under
J 701.3) in use or stored for reuse shall
be performed at least once every three
months. These inspections may take
place any time during the three
month periods; January-March. April-
June. July-September, and October-
December as long as there is a mini-
mum of 30 days between inspections.
The visual inspection must include in-
vestigation for any leak of dielectric
fluid on or around the transformer.
The extent of the visual inspections
will depend on the physical con-
straints of each transformer installa-
tion and should not require an electri-
cal shutdown of the transformer being
inspected.
(iii) If a PCB Transformer is found
to have a leak which results in any
quantity of PCBs running off or about
to run off the external surface of the
transformer, then the transformer
must be repaired or replaced to elimi-
nate the source of the leak. In all
cases any leaking material must be
cleaned up and property disposed of
according to disposal requirements of
1761.60. Cleanup of the released PCBs
must be initiated as soon as possible,
but in no case later than 48 hours of
its discovery. Until appropriate action
is completed, any active leak of PCBs
must be contained to prevent exposure
of humans or the environment and in-
spected daily to verify containment of
the leak. Trenches, dikes, buckets, and
pans are examples of proper contain-
ment measures.
(iv) Records of inspection and main-
tenance history shall be maintained at
least 3 years after dtsposing of the
transformer and shall be made avail-
able for inspection, upon request, by
EPA. Such records shall contain the
following information for each PCB
¦Transformer:
(A) Its location.
(B> The date of each visual inspec-
tion and the date that a leak was dis-
covered. if different from the Inspec-
tion date.
(C> The person performing the la-
spection.
The results of any containment
and dally taapeetton required for un-
corrected active leaks. _
-------
may take place any time during the
calendar year as long as.there Is a min-
imum of 180 days between Inspections.
(A) A PCB Transformer which has
impervious, undrained, secondary con-
tainment capacity of at least 100 per-
cent of the total dielectric fluid
volume of all transformers so con-
tained. or
(B) A PCB Transformer which has
been tested and found to contain less
than 60,000 ppm PCBs (after three
months of lnservice use if the trans-
former has been serviced for purposes
of reducing the PCB concentration).
(vi) An increased visual inspection
frequency of at least once every week
applies to any PCB Transformer In
use or stored for reuse which poses an
exposure risk to food or feed. The user
of a PCB Transformer posing an expo-
sure risk to food or feed is responsible
for the inspection, recordkeeping, and
maintenance requirements under this
section until the user notifies the
owner that the transformer may pose
an exposure risk to food or feed. Pol-
lowing such notification, it is the
owner's ultimate responsibility to de-
termine whether the PCB Transform-
er poses an exposure risk to food or
feed.
(2) Servicing conditions. (1) Trans-
formers classified as PCB-Contaminat-
ed Electrical Equipment (as defined in
the definition of "PCB-Contaminated
Electrical Equipment" under } 761.3)
may be serviced (including rebuilding)
only with dielectric fluid containing
less than 500 ppm PCB.
(ii) Any servicing (including rebuild-
ing) of PCB Transformers (as defined
in the definition of "PCB Transform-
er" under { 761.3) that requires the re-
moval of the transformer coil from the
transformer casing is prohibited. PCB
Transformers may be serviced (includ-
ing topping off) with dielectric fluid at
any PCB concentration.
(Mi) PCBs removed during any serv-
icing activity must be captured and
either reused as dielectric fluid or dis-
posed of In accordance with the re-
quirements oX (761.60. PCBs from
PCB Transformers must not be mixed
with or added to dielectric fluid from
PCB-Contaminated Electrical Equip-
ment.
(iv) Regardless of Its PCB concentra-
tion. dielectric fluids containing leas
than 500 ppm PCB that are mixed
with fluids that contain 500 ppm or
greater PCB must not be used as di-
electric fluid in any electrical equip-
ment. The entire mixture of dielectric
fluid must be considered to be greater
than 500 ppm PCB and must be dis-
posed of in an incinerator that meets
the requirements in 1761.70.
(v) A PCB Transformer may be con-
verted to PCB-Contaminated Electri-
cal Equipment or to a non-PCB Trans-
former and a transformer that is clas-
sified as PCB-Contaminated Electrical
Equipment may be reclassified to a
non-PCB Transformer by draining, re-
filling and/or otherwise servicing the
transformer. In order to reclassify, the
transformer's dielectric fluid *must
contain less than 500 ppm PCB (for
conversion to PCB-Contammated Elec-
trical Equipment) or less than 50 ppm
PCB (for conversion to a non-PCB
Transformer) after a minimum of
three months of in-service use subse-
quent to the last servicing conducted
for the purpose of reducing the PCB
concentration In the transformer. In-
service means that the transformer is
used electrically under loaded condi-
tions that raise the temperature of the
dielectric fluid to at least 50" Centi-
grade. The Assistant Administrator
may grant, without further rulemak-
ing, approval for the use of alternative
methods that simulate the loaded con-
ditions of in-service use. All PCBs re-
moved from transformers for purposes
of reducing PCB concentrations are
subject to the disposal requirement* of
{ 761.60.
(vi) Any dielectric fluid containing
50 ppm or greater PCB used for servic-
ing transformers must be stored in ac-
cordance with the storage for disposal
requirements of i 761.65.
(vii) Processing and distribution In
commerce of PCBs for purposes of
servicing transformers is permitted
only for persons who are granted an
exemption under TSCA 6(e)(3)(B).
*
Subpart 0—Storage and Disposal
Note This subpart does not require re-
moval of PCBs and PCB Items from service
and disposal earlier than would normally be
the case. However, when PCBs and PCB
Items are removed from service and dis-
posed of, disposal must be undertaken in ac-
cordance with these regulations. PCBs (in-
eluding soils and debris) and PCB Items
which have been placed in a disposal site are
considered to be "in service" for purposes of
the applicability ot this subpart. This sub-
part does not require PCBs and PCB Items
iandfllled prior to February 17. 1978 to be
removed for disposal. However, if such
PCBs or PCB Items are removed from the
disposal site, they must be disposed of in ac-
cordance with this subpart. Other subparts
are directed to the manufacture, processing,
distribution in commerce, and use of PCBs
and may result in some cases in disposal at
an earlier date than would otherwise occur.
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9 7(1.60 Disposal requirements.
(a) PCBs. (1) Except as provided in
paragraphs (a) (2). (3). (4), and (5) of
this section. PCBs at concentrations of
50 ppm or greater must be disposed of
In an incinerator which complies with
I 761.70.
(2) Mineral oil dielectric fluid from
PCB-Contaminated Electrical Equip-
ment containing a PCB concentration
of SO ppm or greater, but less than 500
ppm. must be disposed of in one of the
following:
(i) In an incinerator that complies
with i 761.70;
(ii) In a chemical waste landfill that
complies with 1761.75 if information
is provided to the owner or operator of
the chemical waste landfill that shows
that the mineral oil dielectric fluid
does not exceed 500 ppm PCB and is
not an ignitable waste as described in
i 761.75(b) (8) (lit);
(Hi) In a high efficiency boiler pro-
vided that:
*
In a facility that is approved In
accordance with 1761.60(e). For the
purpose of burning mineral oil dielec-
tric fluid, an applicant under
1761.60(e) must show that his combus-
tion process destroys PCBs as effi-
ciently as does a high efficiency boiler,
as defined in paragraph (b)(2)(iii) of
this section, or a 1761.70 approved in-
cinerator.
(3) Liquids, other than mineral oil
dielectric fluid, containing a PCB con-
centration of 50 ppm or greater, but
less than 500 ppm, shall be disposed
of:
(i) In an Incinerator which complies
with f 761.70;
(ii) In a chemical waste landfill
which complies with 1761.75 if infor-
mation is provided to the owjter.or op-
erator of the chemical waste landfill
that shows that the waste does not
exceed 500 ppm PCB and is not an ig-
nitable waste as described in
i 761.75(b)(B)(iii);
(iii) In a high efficiency boiler pro-
vided that.
*
-------
drained liquids are disposed of in an
incinerator that complies with
{761.70.
(ii) PCB Articles with a PCB concen-
tration between SO and 900 ppm must
be disposed of by draining all free
flowing liquid from the article and dis-
posing of the liquid in accordance with
paragraph (a)(2) or (3) of this section.
The disposal of the drained article Is
not regulated by this rule.
(6) Storage of PCB Articles. Except
for a PCB Article described in para-
graph (b)(2)(li) of this section and hy-
draulic machines that comply with the
municipal solid waste disposal provi-
sions described in paragraph (b)(3) of
this section, any PCB Article, with
PCB concentrations at 50 ppm or
greater, shall be stored in accordance
with 1761.65 prior to disposal.
(c) PCB Containert. (1) Unless de-
contaminated in compliance with
1761.79 or as provided in paragraph
(c)(2) of this section, a PCB container
with PCB concentrations at 50 ppm or
greater shall be disposed of:
(1) In an incinerator which compiles
with 1761.70, or
(li) In a chemical waste landfill that
complies with 1761.75; provided that If
there are PCBs in a liquid state, the
PCB Container shall first be drained
and the PCB liquid disposed of In ac-
cordance with paragraph (a) of this
section.
(2) Any PCB Container used to con-
tain only PCBs at a concentration less
than 500 ppm shall be disposed of as
municipal solid wastes; provided that
if the PCBs are in a liquid state, the
PCB Container shall first be drained
and the PCB liquid shall be disposed
of in accordance with paragraph (a) of
this section.
(3) Prior to disposal, a PCB contain-
er with PCB concentrations at SO ppm
or greater shall be stored in a facility
which complies with 1761.65.
(d) SpiUs. (1) Spills and other uncon-
trolled discharges of PCBs at concen-
trations of 50 ppm or greater consti-
tute the disposal of PCBs.
(2) PCBs resulting from the clean-up
and removal of spills, leaks, or other
uncontrolled discharges, must be
stored and disposed of in accordance
with paragraph (a) of this section.
(3) These regulations do not exempt
any person from any actions or liabil-
ity under other statutory authorities,
including but not limited to the Clean
Water Act, the Resource Conservation
and Recovery Act, and the Compre-
hensive Environmental Response.
Compensation, and liability Act of
1980.
(e) Any person who la required to in-
cinerate any PCBs and PCB Items
under this subpart and who can dem-
onstrate that an alternative method of
destroying PCBs and PCB Items exists
and that this alternative method can
achieve a level ol performance equiva-
lent to 1761.70 incinerators or high ef-
ficiency boilers as provided In para-
graph (a)(2)(iv) and (a)(3)(iv) of this
section, may submit a written request
to either the Regional Administrator
or the Assistant Administrator for
Pesticides and Toxic Substances for an
exemption from the incineration re-
quirements of 1761.70 or 1761.60. Re-
quests for approval of alternate meth-
ods that will be operated in more than
one region must be submitted to the
Assistant Administrator for Pesticides
and Toxic Substances excejft for re-
search and development involving less
than 500 pounds of PCB material (see
paragraph (i)(2) of this section). Re-
quests for approval of alternate meth-
ods that will be operated in only one
region must be submitted to the ap-
propriate Regional Administrator. 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 in-
formation, the Regional Administrator
or Assistant Administrator for Pesti-
cides and Toxic Substances may. in his
discretion, approve the use of the al-
ternate method if he finds that the al-
ternate dUposal method provides PCB
destruction equivalent to disposal in a
1761.70 Incinerator or a 1761.80 high
efficiency boiler and will not present
an unreasonable risk of injury to
health or the environment. Any ap-
proval must be stated in writing and
may contain such conditions and pro-
visions u the Regional Administrator
or Assistant Administrator for Pesti-
cides and Toxic Substances deems ap-
propriate. The person to whom such
w*lver is Issued must comply with til
limitations contained in such determi-
nation.
-------
(11) At the request of any state or
local government, annual notice of the
Quantities and general description of
PCBs di-sposea of during the year.
This annual notice shall be given no
more than thirty (30) days after the
end of the year covered.
*
(2) Any person who disposes of PCBs
under a paragraph (aXSXIli) of this
section incineration or chemical waste
landfilling waiver shall give written
notice at least thirty (30) days prior to
conducting the disposal activities to
the state and local governments
within whose jurisdiction the disposal
U to take place.
(g) Testing procedures. (I) Owners or
users of mineral oil dielectric fluid
electrical equipment may use the fol-
lowing procedures to determine the
concentration of PCBs in the dielec-
tric fluid;
(i) Dielectric fluid removed from
mineral oil dielectric fluid electrical
equipment may be collected In a
common container, provided that no
other chemical substances or mixtures
are added to the container. This
common container option does not
permit dilution of the collected oil-
Mineral oil that Is assumed or known
to contain at least SO ppm PCBs must
not be mixed with mineral oil that Is
known or assumed to contain less than
50 ppm PCBs to reduce the concentra-
tion of PCBs in the common contain-
er. if dielectric fluid from untested,
oil-filled circuit breakers, reclosera, or
cable is collected in a common contain-
er with dielectric fluid from other oil-
filled electrical equipment, the entire
contents of the container must be
treated as PCBs at a concentration of
at least SO ppm. unless all of the fluid
from the other oil-filled electrical
equipment has been tested and shown
to contain less than 50 ppm PCBs.
(U) For purposes of complying with
the marking and disposal require-
ments, representative samples may be
taken from either the common con-
tainers or the individual electrical
equipment to determine the PCB con-
centration. except that if any PCBs at
* concentration of 500 ppm or greater
have been added to the container or
equipment then the total container
contents must be considered as having
* PCB concentration of 500 ppm or
ti^ater for purposes of complying
w«th the disposal requirements of this
subpart. For purposes of this subpara-
graph, representative samples of min-
eral oil dielectric fluid are either sam-
D'e* taken in accordance with Ameri-
can Society of Testing and Materials
method D-923 or samples taken from
a container that has been thoroughly
mixed In a manner such that any
PCBs In the container are uniformly
distributed throughout the liquid in
the container.
(2) Owners or users of waste oil may
use the following procedures to deter-
mine the PCB concentration of waste
oil:
(I) Waste oil from more than one
source may be collected in a common
container, provided that no other
chemical substances or mixtures, such
as non-waste oils, are added to the
container.
1711.15 Storage for disposal.
This section applies to the storage
for disposal of PCBs at concentrations
of 50 ppm or greater and PCB items
with PCB concentrations of 50 ppm or
greater.
(a) Any PCB Article or PCB Con-
tainer stored for disposal before Janu-
ary 1. 1988. shall be removed from
storage and disposed of as required by
this part before January l, 2884. Any
PCB Article or PCB Container stored
for disposal after January l, 1983,
shall be removed from storage and dis-
posed of as required by Subpart D of
this put within one year from the
date when it was first placed into stor-
age.
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17(1.70 Incineration.
Thi» section applies to facilities used
to Incinerate PCBs required to be in-
cinerated by this part.
(a) Liquid PCBs. An incinerator used
for incinerating PCBs shall be ap-
proved by an EPA Regional Adminis-
trator or the Assistant Administrator
for Pesticides and Toxic Substances
pursuant to paragraph (d) of this sec-
tion. Requests for approval of inciner-
ators to be used in more than one
region must be submitted to the As-
sistant Administrator for Pesticides
and Toxic Substances, except for re-
search and development Involving less
than 500 pounds of PCB material (see
1761.60(1X2)). Requests for approval
of Incinerators to be used in only one
region must be submitted to the ap-
propriate Regional Administrator. The
incinerator shall meet all of the re-
quirements specified In paragraph (a)
(1) through (9) of this section, unless a
waiver from these requirements is ob-
tained pursuant to paragraph (d)(5) of
this section. In addition, the incinera-
tor shall meet any other requirements
which may be prescribed pursuant to
paragraph (d)(4) of this section.
(1) Combustion criteria shall be
either of the following:
(1) Maintenance of the introduced
liquids for a 2-second dwell time at
1200'C(±100'C) and 3 percent excess
oxygen in the stack gas; or
(U) Maintenance of the introduced
liquids for a lvt second dwell time at
1600*C(±100*C) and 2 percent excess
oxygen in the stack gas.
(2) Combustion efficiency shall be at
least 99.9 percent computed v follows:
Combustion efficiency*
Cco,/Cco.4-Ccoxl00
where
Cco«> Concentration of carbon dioxide.
Ceo-Concentration or carbon monoxide.
1711.79 Decontamination.
(a) Any PCB Container to be decon-
taminated shall be decontaminated by
flushing the internal surfaces of the
container three times with a solvent
containing less than 50 ppm PCB. The
solubility of PCBs in the solvent must
be five percent or more by weight.
Each rinse shall use a volume of the
normal diluent equal to approximately
ten (10) percent of the PCB Container
capacity. The solvent may be reused
for decontamination until it contains
50 ppm PCB. The solvent shall then
be disposed of as a PCB in accordance
with 1761.60(a). Non-liquid PCBs re-
sulting from the decontamination pro-
cedures shall be disposed of tn accord-
ance with the provisions of
I 761.60(a)(4).
(b) Movable equipment used in stor-
age areaj shall be decontaminated by
swabbing surfaces that have contacted
PCBs with a solvent meeting tne crite-
ria of paragraph u> of this section.
None Precautionary measure* should be
taken to ensure that the solvent meets
safety and health standards u required by
applicable Federal regulations.
(44 PR 31542, May 31,1970. Redesignated at
47 PR 18527, May «, 1M2]
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TSCA COMPLIANCE PROGRAM POLICY NO. 6-PCB-2
Distillation. Solvent Extraction, Filtration,
and other Physical Separation Methods for PCBs
TSCA Section; 6(e)
ISSUE;
Does the physical separation of PCBs from liquids and solids require EPA
approval?
The physical separation of PCBs from liquids and solids requires an
approval if the use or disposal of these liquids and solids avoids, or is
alternative to, the disposal requirements that would have applied to the
original material before separation. An approval is required for physical
separation activities that can be construed to be part of, or an initiation of
a disposal activity. How.v.r, an approval 1. not required for Physical
separation activities vhich process PCBs during authorized servicing
activities and reus, the procea.ed -tarlals in e,ulp«nt authorised for
continued use in the PCB rules.
*
DISCUSSION:
*
* -h. use of a physical separation technique is
The following example of the use or a Pn7
. . j{aO0ged of by incineration or by an approved
applicable. Capacitors must be disposea 017 t ^ l
4„M««ration (AO CFR 761.70). It is theoreti-
alternate method equivalent to incl
_ , j^-Bosal method the first step of which
cally possible to develop a capacitor disposal metn
.... -at.rials solvent extraction).
1« to separate the PCBs fro. th. .olid «t.ri«l. •
the separation proc.ss. r.,ulres specific prior approva! by th. Re ion !
Administrator or Assistant Ad-lnl.tr.tcr for Pe.ticlde. and Toxic ubstanc..
under section 76..60(e) sine, it 1. P«« •' "" "
-------
authorized under section 761.60. If such a method were successful in completely
removing all detectable PCBs from the solids, the PCB-free solid materials
could later be salvaged without subsequent treatment or EPA approval. Although
the PCBs removed from the solid materials and any unprocessed materials require
incineration, it is also theoretically possible to obtain approval to use a
physical separation technique to remove PCBs from the liquid materials in a
similar manner.
In contrast, a permit is not required to service electrical equipment for
purposes of reducing PCB concentration. Physical separation techniques can be
used to service PCB-containing electrical equipment as long as the processed
materials are ultimately returned to electrical equipment regulated under the
PCB rule. This type of servicing is authorized under 40 CFR 761.30(a).
Filtering PCBs from the dielectric fluid of transformers and returning that
fluid to the transformer is an example of this type of activity. Because the
processed liquids and solids are returned or reused in regulated equipment,
EPA controls the ultimate disposition of all the processed materials and no
disposal requirements are circumvented.
Without an EPA disposal approval, processed liquids and solids that
formerly contained PCBs must be treated as if they still contain PCBs and may
not be distributed in commerce without an exemption under section 6(e)(3)(B)
of the Toxic Substances Control Act (TSCA). Therefore, it is possible to
physically separate PCBs from liquids and solids without EPA approval as long
as these liquids and solids are treated (used, stored, disposed of, etc) as if
they still contain their original PCB concentration. The PCB residue which
results from physical separation activities, as well as any materials not
eventually reused in regulated electrical equipment, must be disposed of in a
manner which complies with section 761.60.
*
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TSCA COMPLIANCE PROGRAM POLICY No. 6-PCB-3
Residual PCBs in Processed Liquids and Solids
TSCA Section: 6(e)
ISSUE:
Are PCBs at concentrations less than 50 ppm in liquids and solids that
have been physically separated from higher concentration PCB materials
regulated for the purpose of disposal?
POLICY;
, „ . __ tu-n 50 ppm in liquids and solids that have
PCBs at concentrations less than w pp«»
• fvnm higher concentration PCB materials are
been physically separated from higher
4.,„ orisinal PCB concentrations,
regulated as if they still contain the origmax
DISCUSSION:
*
A separator who is servicing electrical equipment may dispose of the
"heavy" PCB fraction according to 40 CFR 761.60 and return the "light-
fraction to the electrical equipment, in which case all materials are con-
trolled by the PCB regulation. In the alternative (if he intends to produce a
light fraction which will not be disposed of according to the PCB rule or
reused in electrical equipment), the separator must obtain a disposal approval
from either the Assistant Administrator for Pesticides and Toxic Substances or
a Regional Administrator under 40 CFR 761.60(e). Only after the light fractioi
has been shown to contain no detectable PCBs, however, can the activity be
approved by EPA as a disposal activity and considered an unregulated material.
-------
Fedcrn! Register / Vol. 51, No. 3fi / Monday. February 24. 19)10 / Proposed R-j':es
6423
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 261
IOPT8-21101T; PRL 2M2-1)
Hazardous Waste; Polyehforlnafd
Blphanyla (PCBa); Raaponaa to
Citteena' Petlttona
aoincy: Environmental Protection
Agency (EPA).
ACTtOM: Notice of Response to Citizen*'
Petitions.
summary? This notice responds to
citizens' petitions submitted fey Citizens
for Healthy Progress and Valla; Watch
under section 21 of lha Toxic
Subatancai Control Act (TSCA) (13
U S.C. 2630) and taction 7004 of the
Resource Conservation and Recovery
Act (RCRA) (42 U.S.C. 69741.
Each TSCA petition it • request that
EPA exercise authority under TSCA
taction 5(a) to prevent the constroctfon
of a PCB dispone! facility fat Htbdertoh,
Kentucky, pending the development of
additional taformstton ngardtog the
health and environmental effects arising
from the operation of the proposed
facility. An application for an approval
under TSCA 9er.iion 6(e) for this
proposed PCB disposal facility is
pending before EPA Region IV.
As explained in Unit II. EPA is
denying the TSCA requests of both
petitions on two grounds: (l) EPA
cannot amend TSCA. as requested by
Citizens for Healthy Progress: and (2)
EPA does not have the authority under
section 5(e) of TSCA to issue a proposed
order to prevent construction of a
proposed facility when a proposed
process does not involve either a "new
chemical substance" or a "significant
new use" of a substance.
In addition. Valley Watch has
petitioned for rulemaking under RCRA.
seeking regulation of the Henderson
facility and, if possible, seeking to halt
construction and operation. EPA
regulations issued under RCRA impose
additional notice and comment
procedures which are applicable only to
RCRA section 7004 petitions. These
regulations require EPA to publish a
tentative decison to grant or deny the
petition, to solicit public comment on
that tentative decision, and then, to
issue and publish its final decision.
In this notice, EPA has tentatively-
decided to deny the Valley Watch
petition under RCRA. The Agency
solicits public comment on this tentative
denial: interested persons may also
request an informal public hearing
regarding this tentative decision.
However, the Agency notes that It
intends to list wastes containing PCBs
as hazardous wastes under RCRA.
thereby subjecting PCB waste
management facilities to RCRA
regulation.
AOORlMts: Copies of the petitions and
all related information are located in:
Document Control Office (TS-793).
Office of Toxic Substances,
Environmental Protection Agency, Rm.
E-107,401M St., SW., Washington. DC
20460.
They are available for review and
copying from 6 a.m. to 4 p.m. Monday
through Friday, except legal holidays.
Comments on EPA's Tentative
Decisions under RCRA and any requests
for an Informal public meeting under
RCRA should be in writing atnd 'sent to:
Prancine Jacoff, Waste Identification
Branch fWH-SMB), Office of Solid
Waste. Environmental Protection
Agency, 40V M St.. SW., Washington. DC
20460,
oatis; Comments on EPA's Tentative
Decision umjer JICRA and any written
requests for in informal public hearinf
under RCRAahould be sent to the above
address by April 25.1986.
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6421
Federal Register / Vol 51, No. 3G / Monday, February 24, 1966 / Proposed Rules
FOR FURTHER INFORMATION (TSCA
PETITIONS) contact: Edward
Klein, Director, TSCA Assistance Office
(TS-799). Office of Toxic Substances,
Environmental Protection Agency, Rm.
E-543, 401 M St., SW.. Washington. DC
20460. Toll Free: (800-424-9005), In
Washington, DC: (554-1404), Outside the
USA: (Opera tor-202-554-1404).
SUPPLEMENTARY INFORMATION:
1. Background
A. Summary of Petitions
On November 20,1985, Citizens for
Healthy Progress (CUP) petitioned the
EPA under section 21 of TSCA to take
action under section 5(e) of TSCA to
halt construction of a planned PCB
disposal facility in Henderson,
Kentucky. The petitioner asserts that the
Agency lacks sufficient information at
this time to make a decision on the
cafcty of the facility and that
construction of the facility should not be
allowed to occur until such information
ns available for the Agency to evaluate.
The petitioner argues that the fact that
funds have been expended for
construction of a costly facility could
bias the Agency's decision to permit or
not permit the facility in favor of the
applicant and could, therefore, place the
public at unreasonable risk.
The CHP petition specifically requests
that the Agency "amend an order" under
TSCA section 5(e) by adding language to
paragraph (1)(A) of the TSCA section
5(e) which would, among other things,
enable the Administrator to issue a
"proposed order" to prohibit the
construction or completion of a facility
auch as the one planned for Henderson,
Kentucky, pending the development of
information.
On December 9,1985, Valley Watch
(VW) petitioned the EPA under section
£1 of TSCA to take action similar to that
requested on November 20,1985, by
Citizens for Healthy Progress. Valley
Watch petitioned EPA under section
5(e), to issue either a "proposed order"
or an injunction which would prohibit
the commencement of construction of
the Henderson facility pending the
development of additional information.
Specifically. VW.argues that the
authority to enjoin the construction of
the Henderson, Kentucky, facility is
"inherent" in the authority reposed in
the Administrator by TSCA section 5(e)
to prohibit or limit activities involving a
new chemical substance pending the
development of information. The Valley
Watch petition is premised upon the
belief that the Agency lacks information
with respect to the health and
environmental risks posed by the
proposed PCB disposal facility, the
processes to be employed in the facility,
and the chemicals to be used and
manufactured in the facility. In
particular, the identity of and possible
risks associated with the material
known as "TF-1" appears to be at the
heart of VW's concern that insufficient
information is available regarding the
proposed disposal facility. VW asserts
that construction of the Henderson
facility should not occur until such time
as this information is available and has
been subjected to reasoned evaluation
by the Agency.
In addition, Valley Watch petitioned
for the issuance of a regulation under
section 7004(a) of RCRA (42 U.S.C.
6974(a)). The petition did not request
any specific rules or cite specific
provisions of RCRA as possible
authority for rulemaking but generally
sought regulation of the PCB facility in
Henderson under RCRA and, if possible,
a ban on construction and operation.
The basis for the petition is that there is
insufficient information available to the
Agency to evaluate health and
environmental effects from the activities
at the facility. The Agency is treating the
RCRA request as a petition seeking
rulemaking under Subtitle C of RCRA
(Hazardous Waste Management).
B. TSCA Section 21
Section 21 of the Toxic Substances
Control Act (TSCA) provides that any
person may petition the Administrator
of EPA to initiate a proceeding for the
issuance of rules under section 4 (rules
requiring chemical testing), section 6
(rules imposing substantive controls on
chemicals), or section 8 (information-
gathering rules). Also, section 21
authorizes a petitioner to request the
issuance, amendment, or repeal of
orders under section 5(e) (orders
affecting chemicals involved in
premanufacture notification) or section
6(b)(2) (orders affecting quality control
procedures). Section 21(b)(3) requires
that EPA grant or deny citizens'
petitions within 90 days of the filing of
the petitions (15 U.S.C. 2620(b)(3)).
If the Administrator grants a section
21 petition, the Agency must promptly
commence an appropriate proceeding. If
the Administrator denies the petition,
the reasons for denial must be published
in the Federal Register.
If EPA denies the petition, or fails to
grant or deny the petition within 90 days
of the filing date, the petitioners may
commence a civil action in a Federal
district court to compel the Agency to
initiate the requested action. This suit
must be filed within 60 days of the
denial, or within 60 d3ys of the
expiration of the 90-day period if the
Agency fails to grant or deny the
petition within that period (15 U.S.C.
2620(b)(4)).
In the case of a section 21 petition
which requests an order which can be
issued under section 5(e), EPA may
issue such an order if EPA determines
that information is insufficient to
evaluate a subject chemical, and that in
the absence of sufficient information,
the chemical may present an
unreasonable risk or. may cause
substantial or significant human or
environmental exposure (15 U.S.C.
2604(e)(1)(A)).
C. RCRA Regulations Governing
Citizens' Petitions
EPA regulations set out a process for
addressing petitions for rulemaking
under RCRA Subtitle C at 40 CFR 260.20.
They provide that the Administrator is
to issue for publication in the Federal
Register a tentative decision to grant or
deny a petition and solicit public
comment on the tentative decision. That
notice may take the form of an advance
notice of proposed rulemaking, a
proposed rule, or a tentative decision to
deny the petition. Upon written request
of any interested person, the
Administrator may. at his discretion,
hold an informal public hearing to
consider oral comments on the tentative
decision. A person requesting a public
hearing must state the issues to be
raised and explain why written
comments would not suffice to
communicate the person's views. The
Administrator may, in any event, decid*
to hold an informal public hearing on hi*
own initiative. After evaluating all
public comments. EPA is to make a final
decision by issuing for publication in th<
Federal Register a regulatory
amendment or a final denial of the
petition.
This notice contains EPA's tentative
decision on the RCRA petition. A
subsequent Federal Register notice will
announce the Agency's final decision.
II. Response to TSCA Petitions
The Citizens for Healthy Progress and
Valley Watch petitions are motivated by
concerns that allowing the construction
of the Henderson PCB disposal facility
might bias the Agency's ultimate
permitting decision in favor of the
applicant. EPA addresses these
concerns in Unit III. However, in
requesting relief from EPA under TSCA
sectional, the petitioners rely
exclusively upon the remedies set forth
in TSCA section 5(e). Therefore, the
decision to grant or deny petitioners'
requests depends upon whether CHP
and VW heve presented circumstances
which suggest the proper application of
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Federal Register / Vol-
51. No. 36 / Monday. February 24, 1986 / Proposed Rules
6425
section 5(e) authority. EPA mast deny all
°f petitioners' TSCA requests because of
congressionally mandated limitations on
*he applicability of section 5(e)
Authority. This unit sets forth the
Masons for these denials.
4. Request To Amend TSCA Section
S(e)
While phrased as a request to "emend
order," the Citizens for Healthy
Progress in effect ask EPA to amend
TSCA section 5(e) by adding to
Paragraph (1)(A) of section 5(e) language
^hich would enable the Administrator
'o initiate necessary legal proceedings to
Prohibit construction of a facility
Intended primarily for activities
Evolving a substance which EPA can
•ubject to a proposed order.
EPA denies the CHP petition, because
cannot amend TSCA. Any such
J^uest should be addressed to
Congress, rather than this Agency.
£ Requests for Issuance of Proposed
Order
The Valley Watch petition requests
•nat EPA issue a TSCA section 5(e)
Proposed order or injunction which
y*°uld prohibit construction of the
tt®nderson PCB disposal facility until
•efficient information is developed
'®8arding the health and environmental
iiv.8c's associated with the facility.
k*°wise, the Citizens for Healthy
y°8ress petition could be construed to
e9jj®st the same relief.
„ "hen construed in this manner, both
re CHP and VW petitions must be
enied because the petitioners have not
'l*8ed circumstances which would
88« the availability of either a
Pfoposed order or an injunction under
*«cUon 5(e).
The "proposed order" provision of
*?cUon 5(e) does not apply to all
rj'wtfcal substances; rather, the
^vision applies only to those chemical
. u">tancea with respect to which notice
Squired by section 5(a). Section 5(a)
luires persons who intend to
®nufacture or import a "new chemical
^•tance," (or. who intend to
.anufacture, import, or process a
e»nical substance in a "significant
H* u»e") to notify EPA at least 00 days
M c Ie »uch activity begins (15
^•C. 2604(a)(1)). TSCA defines a "new
, substance" in section 3't9) as a
"Stance not included on the inventory
IJ'P'Ud under section B(b).
true that under TSCA section
)(Z), EPA has authority to designate
'si chemicalsubstancesas
rf.^ficant new uses." But, such a
^.•Wtotion must be undertaken through
(Jem«>king after EPA has considered
•tatutory factors enumerated in
section 5(a)(2). In this instance,
however, the components of TF-1 are
not "new chemical substances." Nor are
these components subject to any
"significant new use" rules.
EPA understands that the petitioners
are unaware of the precise nature of the
material identified as TF-1. This
circumstance arises from the claim to
business confidentiality asserted by
Union Carbide under TSCA section H
with regard to the composition of TF-1.
Nevertheless, EPA is aware of the
identity of the TF-1 components, and
there is available to EPA a considerable
amount of information regarding the
effects of the TF-1 components. The
PCB disposal permitting process
(described in Unit III) enable* the EPA
to consider comprehensively the
possible health and environmental
effects presented by the proposed
Henderson PCB disposal facility,
including the effect* of TF-1.
EPA has detennined that the
substances comprising TF-1 are
contained on the section 8(b) inventory
of exisiting chemical substances. Thus.
TF-1 is not composed of "new chemical
substances" subject to section 5(a)(1)(A)
premanufacture notification. Likewise,
the use of TF-1 components as organic
solvents or dielectric fluids is not
currently subject to a rule designating
such uses as "significant new uses," and
thus, would not give rise to section
5(a)(1)(B) significant new use
notification. Because TF-1 and its
components are not subject to any
section 5(a) notification requirements,
TF-i cannot be the subject of a
proposed order under section 5(e)(1) or
an injunction under section 5(e)(2).
TSCA section 5 affords EPA the
opportunity to screen new substances
for their health and environmental
effects prior to their being manufactured
and introduced into commerce, but it
does not extend to other chemical
substances (such as those comprising
TF-l) unless a designated "significant
new use" is involved.
However, the CHP and VW petitions
do raise an issue of significance In the
PCB disposal permitting program;
whether construction of a PCB disposal
facility should be prohibited durjng the
pendency of the permitting review for a
disposal process.
While the petitioners did not
specifically request that M»e PCB
disposal permitting process be altered,
the Agency believes that the
construction issue merit! consideration
in this response. EPA has concluded that
the existing permittingprocess, which
allows construction eT t facility prior to
the grunting of an approval, provide* the
best assurance that a PCB disposal
process will in fact achieve safe and
effective disposal of PCBs. As an
essential part of the permitting process,
EPA requires that PCB disposal facilities
be demonstrated to meet EPA's
regulatory requirements. Necessarily, a
facility must be constructed before it
can be demonstrated.
To aid in understanding EPA's
conclusion that the existing permitting
process should not be altered, EPA has
included below a description of the PCB
disposal permitting process.
III. The PCB Disposal Permitting
Program Under TSCA
A. The Application and Review Process
EPA. under section 6(e) of TSCX.
issued regulations in the Federal
Register of May 31.1979 (44 FR 31514}
governing the disposal of PCBs and PCB
Items. These regulations, codified at 40
CFR 761.60 et seq., contain requirements
for the disposal of PCBs and PCB Items
and detailed specifications that must be
met by incinerators, high efficiency
boilers, landfills, and alternative
methods of disposal in order to be
approved by EPA for the disposal of
PCBs and PCB Items. For example, 40
CFR 761.70 requires that incinerators
used for incinerating PCBs be approved
by EPA and meet specific standards for'
dwell time, temperature, excess oxygen,
and combustion efficiency. In practical
terms, these incineration standards
mean that PCB incinerators must
achieve a destruction efficiency for
PCBs of 99.9999 percent. The owner
operator of a proposed facility is
required by EPA to submit an
application which contains information
on the location of the incinerator, a
detailed description of the incinerator,
including general site plan* and design
drawing*, engineering report* on the
anticipated performance of the
incinerator, the availability of sampling
and monitoring equipment and facilities,
estimates of waste volume* expected to
be incinerated, any local, State, or other
Federal permits or approvals, and
schedules and plans for eomplyfng with
the approval requirements (e.g., the trial
burn requirement) (40 CFR 761.70(d)(1)).
The owner or operator is also required
to subject the incinerator to a trial bum
and to submit to EPA a full plan for
conducting the trial bum. EPA requires
trial bums to monitor destruction
efficiency and safe operation prior to
full permitting and commercial
operation. Monitoring data and results
from the trial burn are analyzed by EPA
to insure that the applicant meets the
regulatory requirements regarding
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642G
Federal Register / Vol. 51, No. 2t> I M(;!iday. February 24. 1 *)»'••> / P: rpcsec Hi,Irs
destruction efficiency «nd safety 140
CFR "61."0(d)(2)).
EPA engineers unci scientists review
the material provided in the application
and the results of trial bums and make
determinations on whether the
incinerator meets the regulatory
Tequirements for effective and safe
destruction of PCBs (40 CFK
7ttl.70[d)(4)).
The proposed PCB disposal facility
which is '.ho subject of the Citizens for
Healtlily Progress petition and the
Valley Watch petition is whnt EPA
terms an alternative method for PCB
destruction. Alternative methods of PCD
destruction include, but are not limited
to. catalytic dehydrochlorination.
chlorolysis, plasma arc, ozonation,
catalyzed oxidation, and microbiological
ar.fl sodium-catalyzed decomposition of
the PCB molecules.
Methods for decontamination of PCB-
contaminated materials by
concentration and removal of the PCBs
also are considered alternative methods
of PCB destruction. The planned
Henderson. Kentucky facility is an
example of an alternative method,
employing a physical separation
technique the particulars of which are
protected by a claim to business
confidentiality asserted by Union
Carbide under TSCA section 14.
The proposed PCB disposal facility in
Henderson. Kentucky would house
material and personnel necessary to
accomplish the physical separation of
PCBs from a solvent (which also serves
as a temporary dielectric fluid). The
solvent (hereafter referred to as TF-1) is
then intended to be recycled for future
use and the PCBs will be shipped to an
EPA-approved PCB incinerator for final
destruction.
For such an alternative method of PCB
destruction, EPA requires that this
method achieve a "level of
performance" or "destruction efficiency"
equal to or greater than hi^h
temperature incineration (40 CI'K
701.60(e)). For physical separation
processes, the requirement of 99.9999
percent PCB destruction efficiency
translates into a requirement of
complete separation of the PCBs from
the solvent. The person proposing such
an alternative disposal process must
demonstrate that after separation has
occurred, there are no PCBs present in
the solvent above the practical limits of
detection. This is demonstrated by
chemical analysis of the solvent after
separation has occurred. EPA requires
that the solvent contain less than 2 parts
per million (ppm) PCBs, which is the
lowest level of PCBs which is practically
detectable or measurable in the solvent.
Further. EPA requires that the process
operate in a manner which will not
present unreasonable risk to public
health or the environment.
In the first phase of the permitting
procedure for alternative methods of
destruction, EPA requires the
submission of an application. The
applicant must provide complete
information on the proposed process,
including:
1. A description of the project
organization including persons
responsible for obtaining permits, the
project manager, facility manager, and
safely officer.
2. A description of waste intended to
be treated in the unit, including the type
of waste to be destroyed (liquid or
solid), the proposed total waste and PCB
feed rates, and the matrix and
composition of the waste including
major and minor constituents, and PCB
content.
3. A process engineering description
including process flow diagram, and
narrative description of the system,
description of the theoretical-basis for
the destruction process, layout diagrams
and descriptions of the plant or mobile
unit; detailed engineering drawings,
intended location of the facility and
intended location when in storage.
4. A narrative description of the waste
feed system, description of waste
preparation, and estimate of waste
volume.
5. A description of the automatic
waste feed cutoff system when process
conditions exceed normal bounds, a
description of the procedures to shut off
the waste feed line and whole process in
the event of an equipment malfunction. -
6. A narrative description of the
destruction system (e.g., description of
chemical reactions, stoichiomotry,
reagents, catalysts, process design
capacity), and a list of products and by-
products and their concentrations.
7. A description of the pollution
control system for process effluents (air
emissions, liquid effluents, sludge, solid
waste, etc.). design parameters, and
important operating parameters of the
pollution control system and how they
will be monitored.
8. A summary of process operating
parameters which lists target values as
well as upper and lower boundaries for
all measured operating parameters,
instrument settings and control
equipment parameters.
9. A sampling and monitoring program
to monitor process operation and to
verify PCB destruction is equivalent to
or greater than 99.9999 percent.
10. Sampling procedures including an
explanation of the apparatus,
calibration procedures, and
maintenance procedures.
11. Analytical procedures \ex-.
methods, instiuments, etc.).
12. Monitoring procedures (methods,
instruments, etc.).
13. A spill prevention control and
countermeasure plan.
14. A safety plan.
15. A training plan.
16. A demonstration test plan.
17. Test data or engineering
performance calculations.
18. Copies of other required permits/
approvals.
19. Schedule for operation.
20. A quality assurance plan.
21. A copy of the plant or facility
operational plan.
22. A closure plan for the facility.
A full description of what EPA
requires of applicants for approval to
dispose of I*CBs is contained in
"Guidelines for PCB Destruction Permil
Applications and Demonstration Test
Plans" (April 16,1985).
Once EPA has received and evaluate''
the information contained in the
application, a demonstration test of th«
effectiveness and safety of the disposal
process is scheduled. However, if
technical information contained in an
application (or in an applicant's
demonstration test plan) indicates to
EPA that a process cannot achieve saft
and effective PCB disposal, the
demonstration test will not be
scheduled, and the application proceed*
no further. Thus, there is conducted a
phased review of a proposed alternative
disposal process.
At the process demonstration test,
EPA completes an audit of plant
operations, an audit of the laboratory
which will be routinely conducting
analyses of process samples, and take*
samples to verify independently the
effectiveness of the process. EPA
ensures that the process is operating i»
the manner described in the application
that the process is as effective as high
temperature incineration in destroying
PCBs (i.e.. that the process meets the
99.9999 percent PCB destruction
requirement), and that it is being
operated in a manner that does not
present unreasonable risks to public
health or the environment. The proce**
demonstration test is critical to EPA'».
evaluation of applications for approval
to dispose of PCBs under TSCA. EPA
will deny a permit if the applicant
cannot successfully demonstrate a
process.
Since ERA Headquarters began .
reviewing applications in March of l#3
for mobile and alternative methods of
PCB destruction. EPA Headquarters W
received 11 complete applications. ,.
Demonstrations have been completed"'
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Federal Resistor / Vu!.
No. 3(i / Mond.ty. February 24, V.W, / Proposed Kn'.rs
6 K
the 11 applicants, and EPA has granted
permits to operate to 7 of the applicants.
Four of the eleven applicants that have
filed complet' applications and have
held demonstrations have been denied
Permits based on EPA's determination
that the process does not meet lbs
required level of PCB destruction, or.
that it presents unreasonable risks to
public health or tha environment. S.':v.p!y
put, the PCB destruction equivalency
criterion and the unreasonable risk
standard which govern the review of
•Ucrnative disposal processes assure an
objective permit review that is insulated
from concerns for the applicant's
financial commitments.
EPA agrees with the general premise
that a proposed PCB disposal facility
#hould not be permitted under TSCA
until there has been conducted a
Masoned evaluation of the health and
environmental effects posed by the
operation of such a facility. The Agency
believes that a reasoned evaluation
Squires that there is sufficient
information available concerning the
proposed disposal process and the
*ub»tances involved in the process. A
Particularly valuable information
element is actual data on the
effectiveness of the alternative process
*# demonstrated.
The description of the PCB permitting
Process set forth above (and in much
theater detail in "Guidelines for PCB
Destruction Permit Applications and
Demonstration Test Plans" (April 16,
*885)), underscores EPA's commitment
'o conducting a thorough and reasoned
•valuation. Indeed, the TSCA permitting
Process for PCB disposal requires a
jfteat deal of information on proposed
•®CB disposal facilities and require# that
toe facilities meet standards for safety
and destruction efficiency prior to EPA
Permitting.
Benefits of Existing Permitting
Process
It is true that prohibiting the
construction of a disposal facility before
toe permitting evaluation has been
completed might avoid wasteful
**penditures on ineffective disposal
Processes, and might also avoid any
appearance of bias in the permitting
'eview process. But, the Agency
Sieves that these concerns are
Outweighed by the value of obtaining
Actual data to assess the safety and
effectiveness of PCB disposal processes,
such data are particularly valuable in
toe case of a proposed alternative
Method of disposal.
The approval process for alternative
"'•posai methods was designed to
•"courage new PCB dispos.il
technologies which could be
demonstrated to be as effective as
incineration in their ability to destroy or
remove PCBs. Incineration capacity is
scarce, and the alternative technologies
hold out the greatest prospects for
assuring an adequate capacity for safe,
yet cost-effective disposal. While EPA
requires a demonstration lest in the case
of a proposed PCB incinerator, the
reasons for requiring a dcmonslraiion
are much more compelling when an
alternative disposal process is proposed.
Unlike an incinerator, for which the
design and operation conditions
required to accomplish PCB destruction
are well established, the design and
operation parameters for an alternative
process are not always amenable to
being prescribed by this Agency in
advance of actual demonstration.
Because of the Innovative nature of
these technologies, it is essential that
the safety and efficacy of these '
processes be thoroughly demonstrated
to the Agency prior to the issuance of a
permit. The existing permit review
process assures thai the Agency can
evaluate a disposal facility on the basis
of actual operations on a commercial
scale, rather than relying upon mere
"paper proof," theoretical yields, and
the like.
Moreover, it is demonstrably wrong
that the mere expenditure of funds for
the construction of a PCB disposal
facility influences the Agency's decision
to permit or not permit a facility in favor
of the applicant. Rather, the efficacy of
PCB destruction and the "unreasonable
risk" determination are the crucial
consideration# In the TSCA PCB
permitting decision. The PCB disposal
regulation# contain objective destruction
cri teria for evaluating the efficacy of a
disposal process, ana these criteria,
combined with the process test
demonstration, assure « thorough and
unbiased evaluation. But. as a practical
matter, construction of a facUity is
necessary under the TSCA permitting
process before EPA can hold a
demonstration i»nd then moke.a
determination whether the fgcility.meets
the regulatory requirerrjrnts for disposal
of PCBs.
The current permitting process allow#
EPA personnel to be on site at the trial
demonstration, and.to teke sample# to
verify dejtmptiom effectiveness nnsf
process safety. Tho Agency believes
that this proems is the optimal
mechanism forassuring that the
operation of a procei»do?i not prevvnt
unreasonable risks to pyfelic, health or
the environment.
Thctxwtinf perstfWfoii proem mux
encourage the comihilment of
considerable resources tttihe
construction and demonstration of
TSCA disposal facilities, but EPA
believes that this review procedure best
accomplishes the Agency's mandate to
protect human health and the
environment, without unduly impeding
innovation. Moreover, the record cf EPA
denials of proposed disposal processes
shows that the permitting process is not
swayed by factors irrelevant to the
regulatory standards governing
approvals. For these reasons. EPA
would deny any request that the Agency
alter its PCB disposal permitting
program to prohibit construction of a
facility before an approval is issued.
EPA believes that the existing permitting
process represents a reasonable
exercise of the discretion granted EPA
by Congress to prescribe disposal
methods for PCBs under TSCA section
6(e)(1)(A).
IV. Response to RCRA Petition
The V W petition seeks the issuance of
a regulation under RCRA which would
prohibit the construction and operation
of the Henderson facility. The Agency
has tentatively decided that VW't
petition for rulemaking under RCRA
should be denied.
RCRA hazardous waste regulations
do not currently apply to the Henderson
factli tyEPA reguliles the generation.1
transportation; treatment, storage, and
disposal [management) ofhaeafrfou®
wostcs under Subtitle C of RCRA.
However, the management requirem#ftts
apply only to "substances ''identified" !6r
"listed" by regulation as hazatdoiis
wastes. (See RCRA Section 3001.42
U.S.C. 6921; 49 CPU Part 281.) Therefore,
until a waste ii identified or listed as
hazardous in a final regulation, the
management requirements of EPA's
regulation# do not apply. Neither fh£
wastes coming to the' Mendersori'facihty
nor any wastes generated in the PCB
disposal process have been lasted as
ha;-utdous or exhibit a Characteristic of
hazardous wastfe (i.e.; tgnttability.
con'osivity. reactivity, or extra'-,tiort
procedure (EP) toxicity), based upor. the
tL-str. performed byUnibn Carbide and
other information available to SPA-
Petitioners ttave requested that EPA
promulgate RCRA regulations covering
the Henderson facility, arguing thdt
tlicre lo
determine th
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Federal Resistor / Vol. 31, .N't). 30 / Monday, February 24, 19ofi / Proposed R„,!es
of managing the wastes at the
Henderson facility.
Under RCRA section 1004(5) (42
U.S.C. 6903(5)), a hazardous waste
means a solid waste which because of
its quantity, concentration, or physical,
chemical, or infectious characteristics
may: (1) Cause or significantly
contribute to serious irreversible illness
cr •:?. increase in mortality, or (2) pose a
suustantial present or potential hazard
(o health or the environment when
improperly managed. To identify or list
such hazardous wastes and thereby
subject their management to RCRA
standards, EPA must possess or obtain
information on the hazardous nature of
the substances or evidence of
substantial risk if mismanaged. The
Agency generally conducts an industry-
wide study to identify the different
wastes which are generated, how they
are managed, and the potentially
hazardous constituents in these wastes.
The Agency then gathers and evaluates
any toxicity data available on the
wastes and their hazardous
constituents.
EPA must make a decision to list or
not list a waste based upon its
consideration of several factors set forth
in the RCRA regulations (40 CFR
261.11(a)(3)). These factors include the
nature of the toxicity, the concentration
of the toxic constituent, the potential for
degradation into non-harmful
constituents, the degree of
bioaccumulation in ecosystems, the
persistence of the toxic constituent (or
degradation product), the potential for
the toxic constituent or degradation
product to migrate into the environment,
and the plausible types of improper
management to which the waste could
be subjected. Should this analysis
suggest that listing ii appropriate, the
listing mutt be accomplished through
rulemaking proceedings which require
the publishing of the proposed listing
rule, the opportunity for public comment
on the proposed rule, the consideration
of comments received on the proposed
rule, and the promulgation of o final
listing rule.
EPA ha« information on both PCDs
and TF-1 (and its constituents) and
intends to propose listing wastes
containing PCBs as hazardous wastes.
After opportunity for comment and
consideration of any comments. EPA
may promulgate the rule listing wastes
containing K?Bs as hazardous wastes.
The Agency, in fact, tentatively decided
to propose this listing before the VW
petition was received. (The primary
reason for deciding to regulate wattes
containing PCBt under RCRA was a
desire to regulate all hazardous wastes
under the RCRA program, but not any
concern that these wastes were not
being properly managed under TSCA
regulations.) Also, EPA is now
investigating several of the constituents
of TF-1 to determine their toxicity and
whether they should also be listed.
If EPA lists wastes containing PCBs as
RCRA hazardous wastes (as intended),
the Henderson facility probably will be
brought under RCRA jurisdiction at that
time. Whether the Henderson facility
will be regulated under RCRA depends
on whether the PCR waste listing covers
the wastes processed at the facility.
Based on EPA's very tentative plans, the
PCB waste listing regulation would
include the wastes managed by the
Henderson facility. However, RCRA
requirements will not apply to the
facility until the Agency lists PCBs as a
hazardous waste. Since listing of PCBs
has not yet occurred, EPA cannot now
speculate as to which particular
management standards will apply to the
activities at the Henderson facility.
Because the Henderson facility is not
now subject to RCRA jurisdiction,
neither RCRA nor the RCRA regulations
prohibit construction or operation. EPA
could ban operation by regulation in
response to this petition only if EPA
found that wastes containing PCB or
constitutents of TF-1 were currently
within RCRA jurisdiction.
While RCRA and the RCRA
regulations require a permit before
construction may commonce, this
restriction applies only to waste
management facilities that are
constructed after a final listing
regulation has baan issued for wastas
being managed at tha facility (RCRA
section 3005(a), 42 U.S.C. 6925(a); saa
also 40 CFR 270.10(0). Should the
Henderson facility ultimately receive a
TSCA section 6(e) approval to dispose
of PCBs, ft would likely be constructed
and operating by the time the Agency
lists wastes containing PCBs as
hazardous wastes under RCRA. Thus,
the construction or operation of the
Henderson facility would not be banned
by this provision of RCRA. Rather, at
such time as listing occurs, the
Henderson plant would likely be subject
to RCRA management standards
necessary to protect humun health and
the environment for existing facilities
(i.e., the "interim status" management
standards) (see 40 CFR Part 265). To
continue operation, the facility would
later be required to obtain a final RCRA
permit. Such a permit may require
compliance with management standards
more stringent than Interim status
standards (sea 40 CFR Port 204).
For the above reasons, the Agency
has tentatively decided to deny Valley
Wutch'i RCRA petition seeking the
issuance of a RCRA regulation.
EPA requests comment on all aspects
of this tentative decision under RCRA.
(Note, however, that the decisions to
deny the TSCA section 21 petitions are
final Agency decisions). After
consideration of comments on its
tentative RCRA decision, EPA will make
a final decision, and will issue.it for
publication in the Federal Register.
V. Official Record for the Petition
The following documents constitute
the record for this action:
1. Citizen's for Healthy Progress
Petition to the Environmental Protection
Agency, dated November 15,1985.
2. Valley Watch Petition to the
Environmental Protection Agency, dated
December 2,1905.
3. USEPA. "Guidelines for PCB
Destruction Permit Applications and
Demonstration Test Plans," dated April
16,1985.
4. Union Carbido Corporation. Public
Information Copy of Permit Application
for PCB Destruction Unit, dated
November 21,1984 (document available
at OPTS fJocurnent Control Office,
Room E-107, Environmental Protection
Agency. 401M Street SW., Washington,
DC).
5. Union Carbide, Permit for PCB
Destruction (complete application),
dated November 21,1984 (confidential
business information contained in this
document not available for public
viewing, but document filed for record at
OPTS Document Control Office, Room
E-201, Environmental Protection
Agency. 401M Street SW., Washington,
DC).
6. Official rulemaking record from
"Poly chlorinated Biphenyls (PCBs)
Manufacturing, Processing. Distribution
in Commerce and Use Prohibitions
Rule" published in the Federal Register
of May 31,1979 (44 FR 31514).
7. Official rulemaking record from
"Polychlorinated Biphenyls (PCBs);
Disposal and Making Final Regulation"
published in the Federal Register on
February 17,1978 (43 FR 7150).
6. USEPA, Polychlorinatod Biphenyls
(PCBs); Procedural Amendmcmt of tne
Approval Authority for PCB Disposal
Facilities and Guidance for Obtaining
Approval (48 PR 13181, March 30,1983).
9. USEPA, document dated January !•
1980. summarizing data reflecting
number of firms applying the PCB
disposal approvals, numoer of firms
conducting demonstrations, end number
of firms uruntod approvals.
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APPENDIX 2. NIOSH RECOMMENDATIONS FOR PCB STANDARDS
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I. RECOMMENDATIONS FOR A POLYCHLORINATED BIPHENYLS (PCBs) STANDARD
The National Institute for Occupational Safety and Health (NIOSH)
recommends that employee exposure to polychlorinated biphenyle (PCB.) in
the workplace be controlled by adherence to the following .ection.. The
standard is designed to protect the health and provide for the ssfety of
employee, for up to a 10-hour workday, 40-hour workweek, over a normal
working lifetime. The stand.rd is me.sur.ble by technique, that are valid,
reproducible, and available to indu.try and governmental agencie..
Compliance with the etsndard should subetantially reduce .ny risk of
reproductive or tumorlgenic effect, of KB. and prevent other sdver..
effect, of exposure in the wofkpl.ce. Employee, .hould regard the
recommended workplace environmental limit «« the upper boundary for exposure
and make every effort to keep exposure a. lo* •• .possible.
Evidence indict., .dverse reproductive and tumorigenlc effect, in
experimental animal, expo.ed to certain commercial PCB preparation..
Currently available information 1. not «d.,«.te to demon.tr.te that other
commercial PCB preparation, do not have th.se Should sufficient
Information become available to indict, that the etandard offers greater
* - rhiorobioh«nyl isomers or commercial
or Itsser protection from chiorooiw ny
j j 4* .wn h« considered for revision,
preparations than la needed, it
The Toxic Subetance. Control Act of 1«« (Public Law 94-W) required
the US Environmental Protection Agency (EPA) to pre.crib, m.rking „d
t..i„ i 1977 (Federal Register 42:26563-
disposal regulations for PCBs by July I, ®
May 24, 1977). By this Act, the manuf.cture, processing, distribution
1
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in commerce, or use of PCBs in any but totally enclosed systems is to be
banned, effective 1 year after the date of its enactment, October 11, 1976.
Two years after the enactment date PCB manufacture is to be banned, and
processing and distribution in commerce are to be banned 2.5 years from
that date. However, the Act allows the Administrator of EPA to rule
otherwise if he finds that manufacture, processing, distribution in
commerce, or use in other than totally enclosed systems will not present an
unreasonable risk of injury to health or to the environment. The Act does
not affect use of equipment already containing PCBs in totally encloaad
systems, so that a potential for occupational exposure to PCBs will
continue to exist for many years as a consequence of their transportation,
installation, use, and disposal. The part of the Act specific for PCBs Is
presented in Figure 1-1.
"PCBs" are defined for this recommended standard as commercial
preparations of chlorinated blphenyl compounds, Including those
preparations which may be described as single Isomers or classes of
isomers, such as Decachlorodiphenyl. Blphenyl and its monochlorlnatsd
derivatives occurring in commercial preparations of PCBs shall be measured
along with the polychlorinated derivatives, and shall b« treated In this
standard as the polychlorinated components of ehe preparations.
"Occupational exposure to PCBs," Is defined as working with PCBs or with
equipment containing PCBs that can become airborne or that can spill or
splash on the skin or Into the eyes, or the handling of any solid products
that may result in exposure to PCBs by skin contact or by Inhalation. The
tern "PCB work area" Is defined as an area where tl>ere 1s occupational
exposure to PCBs. In areas where no occupational exposure to PCBs occurs,
2
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but where PCBs are present in equipment in the workplace, adherence is
required only to Section 8(a).
Section 1 - Environmental (Workplace Air)
(a) Concentration
Occupational exposure to polychlorinated blphenyla (PCB.) .hall be
controlled so that no worker 1. exposed to PCBe at a concentration greater
than 1,0 microgram total PCBe par cubic meter of air (1.0 «g/cu m),
determined a. a time-weighted average (TWA) concentration, for up to a 10-
hour workday, 40-hour workweek.
(b) Sampling and Analysis
The recommended TO occupational expoeure limit for PCBe hae been
determined to be the lowest reliably detectable limit by the eampllng and
analytical method, recommended in thl. document. Environmental .ample,
.hall be collected and analyzed a. de.cribed In Appandlce. I and II, or by
any method, ahown to be at laaat equlvalant In accuracy, preci.lon, and
sensitivity to the methods specified.
Section 2 - Medical
Madleal .urveillance .h.U be mad. available to all employ... .ubject
to occupational exposure to PCBs.
(a) Pr.placem.nt or initial medical examination, for worker, .hall
include:
(1) Comprehen.lv. medical and work hi.toria. with apaclal
enphaels on hepatic function, .kin condition, and raproductlv. hi.tory.
3
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(2) Comprehensive physical examination with particular
attention to the skin and to hepatic function including determinations of
serum glutamic-oxaloacetic transaminase (SGOT) and serum glutamic-pyruvic
transaminase (SGPT) activities. The responsible physician may also wish to
obtain measurements of serum triglyceride concentrations or of other
indices of fat metabolism.
(3) A Judgment of the employee's ability to use positive
pressure respirators.
(b) During examinations, applicants or employees having medical
conditions that could be directly or indirectly aggravated by exposure to
polychlorinated biphenyls or formulations containing polychlorinated
biphenyls shall be counseled on the increased risk of impairment of their
health that might result from working with these substances.
(c) Women in the work force who are of child-bearing age shall be
advised of the potential adverse effects of PCBs on the unborn child.
Those who bear children while working with PCBs shall be counseled
concerning the advisability of nursing their babies.
(d) Initial medical examinations shall be made available to all
workers as soon as practicable after promulgation of a standard based on
these recommendations.
(«) Periodic examinations shall be made available at least
annually and include: (1) interim medical and work histories, and (2)
physical examinations as outlined in paragraphs (a)(1) and (a)(2) of this
section.
(f) If evidence of adverse effects of exposure to PCBs is
suspected or confirmed, appropriate medical care shall be made available to
the affected worker(s).
A
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(g) Pertinent medical record, shall be maintained for .11
employee* expo.ed to PCB. In the workplace. Such medical record, .hall be
maintained for the period of employment plu. 30 year.. The., record, .hall
be made available to the designated medical repra.ent.tlve. of the
Secretary of He.lth, Education, and Half ere, of the Secretary of Labor, of
the employer, and of the employee or former employee.
Section 3 ~ *r-d Poetlng
All label, and warning signs .hall be printed both m Engll.h and In
the predominant language of non-Ingli.h-readlng worker.. Illiterate
worker, end worker, reeding "Unguage. other than tho.e u.ed on label, and
po.ted sign. >h.ll be othervl.e informed regarding ha.ardou. are., and
.hall be informed of the ln.tructlon» printed on label, and eigne,
(a) Labeling
The following warning l«bel .hall be affixed in e reedlly vi.ible
loeeeion on PCB-proc...ing or other equipwnt. and on PCB-.tor.ge tank, or
container*:
POLYCHLORINATED BIPHENYLS
(PCB«)
DANCER! CONTAINS POLYCHLORINATED BIPHENYLS
CANCER SUSPECT AGENT
Uta only with adequate v«ntil»tion.
Do not ft in »yw. or on ,kin 01 clothin*.
fir.t Aid: In c.e of .kin or eye cojjit.cc, nw!> »Ub running water.
3
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(b) Posting
Warning placard* shall ba affixed in readily vislbla location* in or
near PCB work area*. The information contained thereon shall be arranged
a* in the following example.
POLYCHLORINATED BIPHENYLS
(PCBs)
DANGER!
CANCER SUSPECT AGENT
AUTHORIZED PERSONNEL ONLY
Do not enter unless area is adequately ventilated.
Do not get in eyes, or on skin or clothing.
First Aid: In case of skin or eye contact, flush with running water.
Section A - Personal Protective Equipment and Clothing
(a) Protective Clothing
In any operation where worker* may come into direct contact with
PCBs, protective clothing impervious to PCB* shall be worn. Gloves, boot*,
overshoe*, and bib-type apron* that cover boot top* shall be provided when
necessary. Protective apparel shall be made of material* which moat
effectively prevent skin contact with PCB* where it 1* most likely to
occur. Employer* ahall ensure that all peraonal protective clothing la
lnapacted regularly for dafacta and that it la In a clean and aatlafactory
condition.
(b) Eya Protection
Chemical aafaty goggles, face ahialda (8-inch minimum) with gogglea,
or aafaty glaaaaa with aide shields ahall ba provided by mployara and
ahall be worn during any operation In which PCBa are preaent. If liquid or
6
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•olid PCBs contact the eyes, the eyea shall be irrigated immediately with
large quantities of water and then examined by a physician or other
responsible medical personnel. (A drop of vegetable oil on the eye has
been found to reduce the resultant irritation.) Eye protection shall be in
accordance with 29 CFR 1910.133 and ANSI Z 87.1-1968.
(c) Respiratory Protection
(1) Engineering controls shall be used when needed to keep
cone.ntr.tion. of airborne PCBe at or below the reconundad TVtt
occupational exposure limit. Th. only condition, undar «hleh co.pli.nc.
vlththe permissible expeeure limit may ba achieved by tha uaa o£
respirators are:
(A) During the time necessary to install or teat the
required engineering controls.
(8) For nonroutine maintenance or repair activities.
(C) During emergencies when concentrations of
alrborna PCB. may exceed the perml..lbla limit.
(2) Shan the u.a of ra.plrator. 1. permitted by pare,raph
j «... «h*il be selected and used in Accordance
c(l) of this section, respirators shall »•
with the following requirements:
(A) The employer shall establish and anforce a
— —Mmr the reflulransnts of 29 CfR 1910.134.
respiratory protection program meeting tne
(B) The employer shall provide respirators In
accordance with Tabla 1-1 - -Pl0T*" ~ **
raapirator. provide. Tha ra.pir.tor. ahall ha tho.a approve by «
„ mmA safety Administration. The standard for
the Mining Enforcement and Sara y
, 4 mad in 30 CFR 11. sawyer shall ensure that
approval Is specifled m
7
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respirators are properly cleaned, maintained, and stored when not in use.
TABLE 1-1
RESPIRATOR SELECTION GUIDE
Concentration
of PCBs
Respirator Type Approved under
Provisions of 30 CFR 11
Greater than 1.0 /jg/cu m
or Emergency (entry into
area of unknown concentra-
tion)
(1) Self-contained breathing apparatus
with full facepiece operated In
pressure-demand or other positive
pressure mode.
(2) Combination Type C supplied-air
respirator with full facepiece
operated in pressure-demand or other
positive pressure mode and an
auxiliary self-contained breathing
apparatus operated in pressure demand
or other positive pressure mode.
Section 5 - Informing Employees of Hazards from PCBs
(a) All new and ' present employees in any area in which PCBs art
used shall be informed of the hazards, relevant symptoms, and effects of
overexposure to PCBs, and the precautions to be observed for safe use and
handling of these materials.
(b) All employees involved with the manufacture, use, transport,
or storage of PCBs shall be informed that PCBs have been found to Induce
tumors in experimental animals after repeated oral ingestion and that
because of these findings it is concluded that PCBs are potential human
carcinogens; employees shall also be informed that adverse reproductive
8
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effects nay result from occupational exposure to PCBs.
(c) The employer shall institute a continuing education program,
conducted by instructors qualified by experience or training, to ensure
that all employees occupational^ exposed to PCBs have current knowledge of
Job hazards, proper maintenance and cleanup methods, and proper use of
protective clothing and equipment, including respirators. The instructions
shall include a general description of the medical surveillance program and
of the advantages to the employee of participation. Special attention
shall be given to women in the workplace. They shall be made aware of the
potential adverse effects of PCBs on the unborn child, and of the known
transport of PCBs to breast milk. Elements of the program shall also
include:
Emergency procedures end drill*;
Instruction in handling spilli •»<* 1#ak-»
Decontamination procedures?
Pirefighting equipment location and us«.
First-aid procedures, equipment location,
Rescue procedures;
Confined space entry procedures;
Low warning (odor) properties of PCBs.
(d) Th. Information «pl«i»l»t th. hawrd. of »rkl«i «lth PCB.
.h.11 b. k.pt on fll. .nd b. rwdily «ce...lbl. to « .11 »!«.. of
•aployn.nt -h.r. PCB. ,r« -nuf.ctur.d, »«d. .tor.d, or Cr.n.porr.d.
*.,„lr.d lnfonatlon .h.11 b. »cord«. on th. "M.t.ri.1 S.f.ty D.t. Sh..t"
.how in Appendix III. or .1.11« for. «P1>»«d b, th. Occup.tl.n.1 S.f.ty
.nd H..lth Ad.lnl.tr.tlon, US ».p.ft»nt of Ubor.
9
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Section 6 - Work Practices and Engineering Controls
(a) Regulated Areas
Access to PCB work areas shall be regulated and limited to authorised
persons. A daily roster shall be kept of persons entering such areas.
(b) Handling of PCBs and General Work Practices
(1) Operating instructions shall be formulated and posted
where PCBs are handled or used.
(2) Transportation and use of PCBs shall comply with all
applicable local, state, and federal regulations.
(3) PCBs shall be stored in tightly closed containers In
well-ventilated areas.
(4) When PCB storage containers are being moved, or when
they are not in use and are disconnected, valve protection covers shall be
In place. Containers shall be moved only with the proper equipment and
shall be secured to prevent dropping or loss of control during transport.
(5) Storage facilities shall be designed to contain epllle
completely within surrounding dikes and to prevent contamination of
workroom air.
(6) Ventilation ewltches and emergency respiratory
equipment shall be located outside storage areas In raadily accessible
locations which will remain minimally contaminated with PCB« in an
emergency.
(7) Process valves and pumps shall be readily accessible
and shall not be located in pits or congested areas.
(8) Containers and systems shall be handled and opened with
care. Approved protective clothing as specified in Section 4 shall be worn
10
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by employee* engaged in opening, connecting, end dieconnecting PCS
conteiner. end syatema. Adequ.ce ventiletion .hall be provided to minimize
expoeurea of auch employeee to airborne PCBe.
(9) pCB-opereclng end etorage equipment end ayateme ehell
be lnepected deily for eigne of leake. All equipment. Including velvee,
fittlnga, and connectlona ahall be checked for leek, immedietely after PCBe
are introduced therein.
(10) When a leak is found, it shall be repaired or otherwise
corrected immediately. Work .hall reaume normally only after neceaaary
repair or replacement he. been completed, the ere. ha. been ventileted, end
the concentration of PCBe haa been determined by monitoring to be at or
below the recommended TWA concentretion limit.
(c) Control of Airborne PCBe
(1) Suitable engineering controla, dealgned to maintain
•»r«. .t or below the limit praacribed fn Section 1(a),
exposure to airborne PCBe at or
at processes is the recommended method
•hall be used. Compile* enclosure of proce.
for control of PC. axpoaure. Local «h.».t ventilation may al.o b.
effectiva, uaed alone or » combination with pro.... «clo.u„. When .
la used, it shall ba eo designed and
local exhaust ventilation systsm
or recirculation of airborne PCBa in
operated a. to prevent eccumulation or
« _ -ffactively remove PCBa from the breathing
the workplace environment end
. . .r«fitilation systems discharging to outaide air
zones of employees. Exhaust ven
W1 - ,4l itate, and federal regulations and mist
»ust conform to applicable local,
, „ Mmiovess or to the general population. Before
not constitute a hazard to employ
_ Lig{«a the generation of airborne
maintenance work on control equipment bagln.,
MB. .hall b. •liminat.d to the «t«it f.a.H>
U
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Enclosures, exhaust hoods, and ductwork shall be kept in good repair
so that designed airflows are maintained. Airflow at each hood shall be
measured at least semiannually and preferably monthly. Continuous airflow
indicators are recommended, such as water or oil manometers properly
mounted at the juncture of fume hood and duct throat (marked to indicate
acceptable airflow). A log shall be kept showing design airflow and the
results of semiannual airflow measurements.
(2) Forced-draft ventilation systems shall be equipped with
remote manual controls and shall be designed to shut off automatically In
the event of a fire in the PCB work area.
(d) Special Work Areas
(1) PCB Hazard Areas
A hazard ares shall be considered as any space having physical
characteristics and containing sources of PCBs, such as transformers, that
could result in PCB concentrations In excess of the recommended airborne
PCB exposure limit. Exits shall be plainly marked, conveniently located,
and open outwardly into areas which will remain minimally contaminated in
an emergency.
(2) Confined or Enclosed Spaces
Entry into confined or enclosed spaces, such as tanks, pits,
process vessels, and tank cars where there is limited egress, shall
controlled by a permit system. Permits shall be signed by an authori*«d
representative of the employer and shall certify that appropriate tneasur**
have been taken to prevent adverse effects on the worker's health •• •
result of his or her entry into such space.
12
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Confined or enclosed spaces which have contained PCBs shall be
thoroughly ventilated to assure an adequate supply of oxygen, tested for
PCBs and other contaminants, and Inspected for compliance with these
requirements prior to each entry. Adequate ventilation shall be maintained
while workers are In auch spaces. Leakage of PCBs Into such confined or
enclosed spaces while work Is in progress shall be prevented by
disconnecting and blanking the PCB supply lines. Each Individual entering
such confined or encloaed space .tail furnished with appropriate
p.r.on.1 protective equipment and clothing and be connected by a lifeline
her.,., to a standby worker stationed outside of the space. The standby
worker shell elso be equipped for entry with approved person.1 protective
j - /.««net with a third person. The standby
equipment end clothing end have contect witn .
fvieuel. voice, signal line, telephone,
person shall maintain communication {visual,
\ u4£h the employee inside the confined or
radio, or other suitable means) wifh
enclosed space.
(e) Emergency Procedures
. ~.»,«*.« ia a potential for the occurrence
For all PCB work areas where there uip
-h.il take all neceaaary ateps to ensure that
of emergencies, employers shall
• the procedures specified below as
employees are m.truct.d In, «nd foll°». pr
the specific oparation or process.
well as any others appropriate to
, . _ ,re .pilled, the following steps snail
(1) If PCBs laak or are '
be taken *
(A) *11 nonessential personnel sn.u 0. evacuated
from the leak or spill araa.
«. .r.a of the leak of ffiill 'tall b.
(B) The araa
* Phm accumulation of yapo^a.
Adequately ventilated to pravent
13
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(C) If the PCBs are in liquid form, they shall be
collected for reclamation or sorbed in vermiculite, dry sand, earth, or
similar nonreactive material.
(2) Personnel entering the spill or leak area shall be
furnished with appropriate personal protective equipment and clothing. All
other personnel shall be prohibited from entering the area.
(3) Only personnel trained in the emergency procedures and
protected against the attendant hazards shall shut off sources of PCBs,
clean up spills, control and repair leaks, and fight fires, In areas where
PCBs arc used.
(4) All wastes and residues containing PCBs shall ba
collected In PCB-raslstant containers and appropriately disposed of
(Federal Register 42:26563-77, May 24, 1977).
(5) Safety showers, eyewash fountains, and washroom
facilities shall be provided, maintained in working condition, and located
so as to be readily accessible to workers in all areas where the occurrence
of skin or eye contact with PCBs is likely. If liquid or solid PCBs are
splashed or spilled on an employee, contaminated clothing shall be removtd
promptly and the skin washed thoroughly with soap and water for at least 15
minutes. Eyes shall be irrigated immediately with copious quantities of
running water for at least 15 minutes if liquid or solid PCBs get into
them. A drop of vegetable oil may be applied to the eye to relieve the
irritating effect of PCBs.
Section 7 - Sanitation Practices
(a) Employees occupationally exposed to PCBs shall be provided
14
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with separate lockers or other storage facilities for street clothes and
for work clothes.
(b) Employees occupationally exposed to PCBs shall not wear work
clothing away from their place of employment.
(c) Employees occupationally exposed to PCBs shall be provided
clu, work clothing dally, and clewing e.t.bli.hmente .hell b. Informed ..
to th. hazards of handling PCB. and proper disposal procedure. (or PCB-
contaminated waste water.
(d) Facllltlea (or shower hatha shall be provided for employee*
occupationally «po.ed to PCB.. Worker, .hould .hover before changing Into
•tract clothes.
(.) Employees exposed to PCB. .h.U b. advised to va.h their hand,
and exposed .kin before ..ting, drinking, -oking or u.ing toilet
facilities during the work .hift.
(f) Food, drink, or rooking mat.ri.le .hall not b. permitted in
area, where PCB. are handled, proce..ed, or .tored.
Section 8 - Monitoring Recordkeeping Requirements
(a) Monitoring
(1) A. .oon ». practicable after the promulgation of a
.eandard b...d on th... reco~.end.tlon.. «ch «*loyer .ho aenufecturee.
proce...., handle.. ."re. or oth.r.1.. u... PCB. .hall determine by „
accusational expo.ur. to PCB. may occur.
Industrial hygl.n. .urv.y «h.th.r occup.ti
lust one. every year and within 30 day. of
Survay. .h.U b. r.peated at 1M" one
likely to r..ult m occupational expo.ur. to PCB..
any proce.. change lmeiy
. including the basis for any conclusion that there
Record, of the.e eurveye, including
15
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atay be no occupational exposure to PCBs, shall be retained until the next
survey has been completed.
(2) If occupational exposure to PCBs is determined to be
possible, a program of personal monitoring shall be instituted to measure
or permit calculation of the exposures of all employees,
(A) In all personal monitoring, samples
representative of the employees' breathing zones shall be collected.
(B) For each TWA concentration determination, a
sufficient number of samples shall be taken to characterize each employee's
exposure during each work shift, Variations in work and production
schedules and in employees' locations and job functions shall be considered
in choosing sampling tines, locations, and frequencies.
(C) Each operation in each work area shall be
sampled at least once every 3 months.
(3) If an employee is found to be exposed to PCBs In excess
of the recommended TWA concentration limit, control measures shall be
Initiated, the employee shall be notified of the exposure and of the
control measures being implemented to correct the situation, and the
employee shall be monitored every 30 days. Such monitoring shall continue
until two such consecutive determinations indicate that the employee's
exposure no longer exceeds the recommended TWA concentration limit.
Routine monitoring may then be resumed.
(b) Recordkeeping
Environmental monitoring records shall be maintained for at least 30
years after the employee's last occupational exposure to PCBs. Thess
records shall include the dates and times of measurements, job function and
16
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location of employ", within the "ork.lt., method. of ..mpllng and analy.l.
u.ed, type, of respiratory protection In u.a at the time of ...pllng, TWA
concentration, found, and Identification of expoaed employ.... Each
employee .hall b, able to obtain Information on hi. or h« own
environmental expo.ure., Dally ro.ter. of authorized per.ona .ho enter
regulated area, .h.ll be retalnad for 30 year., Environment.! monitoring
record, and entry ro.ter. .hall b. ~de -iUble to d..lgnat.d
repre.ent.tlve. of the Secretary of Labor and of th. Sacretary of Health.
Education, and Welfare.
Pertinent medical record, for each employe. .hall ba r.talnad for 30
u„ occupational exposure to PCS., Record, of
years after the employe® s
t0 «r employee should be Included In
environmental exposures applicable to an emp
j medical records shall be made
that employee'. medical record., The.e -Mica
, 4 medical representatives of the Secretary of
available to the designated medical r y
Health. Education, and Welfare, of the employer,
Labor, of the Secretary of Healtn,
and of th. employe, or former -ploy"-
17
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APPENDIX 3. EPA GENERAL PERMIT CONDITIONS
HCBZA CONDITIONAL USE PERMIT
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APPENDIX 3. EPA GENERAL PERMIT CONDITIONS
The following items are typical conditions of approval included in alternate
PCBs disposal permits issued by OTS:
1. Advance Notification: A non-confidential written notice, to be received
by the addressee no less than thirty days, and no mora than one hundred
eighty days, prior to the conduct of a permitted PCB disposal activity,
shall be provided Co: the appropriate EPA Regional PCB Coordinator, the
appropriate State Agency, and appropriate local town/city/county government
official(s). The content of the notice shall be at a minimum.
(1) The nature of the PCB disposal activity.
T1,„ locations), such as street address of « facility
or if there is no street address, plant sit. location with a telephone
c^a" locations) «ay be determined by telephone
inquiry).
/« -ru ... and date(s) the treatment will take place.
(3) The exact timand date(s) are expected, these changes
When changes in ' . telephone to the appropriate offlcals (as
must be made immediately sy written notification of the changes
indicated above) an u m be at least thirty days follow-
such that the revised times iwj
ing receipt of the written notification.
-i-. Permittee must obtain all necessary environ-
2. Other Pen-'t'B^Approv4**-• froB the appropriate Federal, State and
mental approvals and/or p t of PCBs at any site.
local agencies prior to the treau-
a. u.triv System will be permitted to treat only
3. Limitation at ^'.^^"^Jtrated ^ ^
the type of material successfully
, T4 , , f ^ttix POTConcsntratios: PCB concentration of the fluid
Limitation of Matrix , levels successfully treated
mixture in the 'process is lftttt*° ™
during the process demonstration:
of the treatment matrix (feedstock) must
Prior to treatment, « using g«» chromatography procure.
be obtained and sialyl *,,,!!! outlined in the following documents:
specified in PA approv.d procadures
"Guidelines <«r^CBO^troetton ^
&i£ir toXU u. ,»»
1 +4«*l RsQuirements for PCB Data
-Recommended Analytic PCB Destruction
wlwm'E"*" "• 1985 (cr"t,:
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2
"Quality Assurance and Quality Control Procedures
for Demonstrating PCB Destruction in Filing for
PCB Disposal Permit", USEPA, June 28, 1983
(Draft); and
"Interim Guidelines and Specifications for
Preparing Quality Assurance Project Plans:, QAMS-
005/80, Office of Research and Development, USEPA,
December 29, 1980.
5. Quality Control: A sample of treated material must be drawn, and
analyzed in duplicate by gas chromatography for the concentration of PCBs
after the treatment at the site where the PCB disposal process is being
used. If the concentration of PCBs in the treated sample is 2 ppm or greater
the treated material must be reprocessed and reanalyzed to show less than
2 ppm per peak before the next batch is treated.
6. Processing Time Limitation: If the quality control testing, as described
in Condition (5), reveals that the PCBs have not been adequately removed
after repeated processing (not to exceed three times the estimated theoretical
time necessary for complete reaction), the affected unit shall cease operation.
The facility operator must notify the PCB Disposal Site Coordinator in the
appropriate EPA region immediately and file a written report with that region
within seven (7) days. The affected unit shall not resume operation until
the problem has been corrected to the satisfaction of the appropriate EPA
region.
7. Operations Log/Recordkeeping; Provisions must be made to assure that
the following process elements are suitable monitored and recorded for each
batch processed, such that materials harmful to health or the environment are
not inadvertently released:
a. name, address, and telephone number of the disposal
unit operator and supervisor;
b. the name and business address of the person or firm
whose PCB-containing material is being processed:
c. the location, manufacturer, rated capacity and
identification (serial) number of the transformer, heat
transfer system or hydraulic system, as appropriate;
d. the date the PCB materials are received by Permittee,
the date(s) processed, and the date returned to the
custody of the owner (if applicable);
e. estimated quantity and quality of feed material charged
into the reactor;
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3
f. estimated quantity and quality of treated materials and
wastes produced;
g. date, time and duration of treatment per batch or
system;
h a copy of the gas chromatograph and/or other records
from tests conducted to determine the final
concentration of the treated material;
i. estimated quantity and quality of wastes produced, the
method of disposal and location of the disposal
facility for each waste should be documented; and
j. temperature of reaction in at least one-half hour
intervals.
Disposal recordkeeping docu«nts ».t be c»piled^thi„60
days of the testing date, must be kept at one reDresentativ ' ®f the
„ust be made available for Puttee
EPA. Such documents s required by 40 CFR 761.180(f). If Permittee
must also maintain t 1te business, these records or their copies
or its authorized agent. "^'J^hToflice ot Tosic Sub.tance.,
must be submitted to the Director oj.
t Permittee must maintain, aboard the mobile unit. a
In addition, Perm oervices performed by the unit during the pre-
record of the PCB dispo available for inspection by authorized
vious month. These records must oe avan« *
representatives of EPA.
the facility
to believe, that a re priate EPA region by telephone immediately,
operator must inform tne off* r
scribing the incident must be submitted by the
A written report deacr * business day following the incident.
close of business facility, until the release problem has been
No PCBs may be processed in ti»» appropriate EPA region,
corrected to the satisfaction ot tne »ff k
„ .11. 0£ PCBs or other fluids shall be promptly
9. PCB Spills; Any sp rovi{jed in the Permittee^ spill prevention
controlled and cleaned °P v. PCB spill cleanup procedures of the appro-
plan, and in accordance . . a written report describing the spill,
priate EPA region; in^aa _ ^ changes in operation to prevent puch
operations involved, cie P a,ibmitted to theappropriateEPA region within
spills in the future must be suDmitt«« "rr
seven (7) business days.
. ^Mnv.tsd in accordance with the PCB spill reporting
PCB spills must be p Clean Water Act for discharges
requirements prescribed under $311 or tne
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A
to navigable waters and under the Comprehensive Environmental Response,
Compensation, and Liability Act (Superfund) for discharges to other media.
10. Safety and Health: Permittee must take all necessary precautionary
measures to unsure that operation of the disposal facility/mobile unit(s)
is in compliance with the applicable safety and health standards, as re-
quired by Federal, State and local regulations and ordinances.
11. Facility Security: The disposal facility/mobile unit shall be
secured (e.g., fence, alarm system, etc.) at each commercial site to
restrict public access to the area. Any bodily injury occurring as a result
of the PCB disposal process must be reported to the PCB Disposal Site
Coordinator in the appropriate EPA region by the next regular business day.
12. Reporting of PCB Incidents: Any reports required by Conditions (6),
(8), (9), and (11) are to be submitted by telephone to the appropriate
regional PCB Disposal Site Coordinator within the time frame specified. In
addition, Permittee shall file written reports with the Regional Admin-
istrator of the appropriate EPA region, and the Director of the Office of
Toxic Substances within the time frame specified in the aforementioned con-
ditions.
13. Personnel Training: Permittee shall be responsible for ensuring that
personnel directly involved with the handling or disposal of PCB-contaminated
fluid using the disposal process are demonstrably familiar with the general
requirements of this approval. At a minimum, this must include:
a. the type of materials which may be treated using the
PCB disposal process, and the upper limit of PCB
contamination which may be treated;
b. basic recordkeeping requirements under this approval
and the location of records;
c. notification requirements;
d. waste disposal requirements for process and by-product
wastes generated during the operation of the PCB
disposal process; and
e. reporting requirements.
In this regard, Permittee must maintain on-site during the operation
of Its mobile unit a copy of this approval; the spill prevention and cleanup
plan; and sampling and analytical procedures used to determine PCB concentra-
tions in untreated and treated materials.
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5
14. PCB Transport Limitation: Untreated PCB fluids may not be transported
off-site on the disposal facility/mobile unit. Process equipment (i.e.,
reactors, pump's hoses, etc.) on the mobile unit must be decontaminated in
accordance with procedures described in Permittee's permit application and
test plan, prior to transporting off-site. PCB-contaminated equipment must
be transported in accordance with 40 CFR Section 761.40 and the U.S. Depart-
ment of Transportation (USDOT) requirements of Title 49, CFR part 172,
including placarding the mobile facility and labelling all PCBs.
15. Process and Pollution Control Maintenance and Inspection:
Procedures must be followed in accordance with information provided in
permit application/demonstration plan, including periodic replacement of
pollution abatement parts (e.g. filters).
16. PCB Waste Disposal Requirements; All wastes generated by the PCB
disposal process other than the successfully cleaned material, (i.e.,
filter media, sludges, water or other effluents, etc.) must be disposed
of as if it contains the original PCB feedstock concentration. EPA will
consider amending this condition only after such waste has been fully
characterized to deternioe all components, and gas chromatography analysis
of the waste demonstrates that the PCB concentration is below 2 ppm.
17. Financial Assurance: Permittee shall incorporate financial assurance
of closure and liability coverage provisions into its closure plan. These
provisions must be equivalent to those specified in 40 CFE Part 264, Subpart
H of the Resource Conservation and Recovery Act (RCRA), and provide funds
for:
a. proper closure of the PCB disposal units, and
b. compensating others for bodily injury and property damage caused
by accidents arising from operations of the mobile disposal units.
18. Notification Requirements for -Pufllicatt Pnlt^ Permittee must 111© a
written pre-operation tfiporfc with tb© Di^*$ctojr of tnn OfxicG of Toxic Sufe—
stances within thirty (30) days from the date of aanufacture of each addi-
tional PCB disposal facility/mobile unit which is to be operated in the United
States. This report shall contain the following information:
a. date of manufacture of the unit;
b. identification and/or serial number of the new
facility/unit;
certification by an indepentfeiat, registered professional engineer
to the effect thtt the facility/unit is suJ>Mantially idenMcal
to the original urfit in terms of engineerings..design, hardware,
process capacity." quality and workmanshipj
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6
d. certification by the Permittee (chief executive officer
signifying that the PCB disposal facility/unit construction
has been completed in such manner; and
e. a list of all substantive and nonsubstantive changes made
to the design and construction of any new disposal facility/
unit which is not identical to the original unit.
19. Notice of Modifications: No major modifications may be made to the
unit design, as described in the application and demonstration plan for
this approval, without written approval of the Director of the Office of
Toxic Substances. For the purpose of this approval, "major modification"
shall be defined as any change to capacity, design, efficiency, waste type,
or any other changes affecting overall performance or environmental impact.
20. PCB Regulations Requirements: Permittee shall comply with all appli-
cable requirements of the Federal PCB Regulation, 40 CFR Part 761, in the
operation of the mobile PCB disposal unit(s). Particular note shall be
given to:
a. 40 CFR, section 761.65 - storage for disposal;
b. 40 CFR, section 761.79 - decontamination; and
c. 40 CFR, section 761.180 - records and monitoring.
21. Permit Severabilty: The conditions of this approval are severable,
and if any provision of this approval or any application of any provision
is held invalid, the remainder of this approval shall not be affected
thereby.
22. Permit Expiration/Renewal: Approvals are effective for 3-year period.
For a renewal approval, EPA may require additional information and/or testing
of the PCB disposal process. In order to continue the effectiveness of as
approval pending EPA action on reissuance, the Permittee must submit a re-
newal request letter to EPA at least 90 days, but not more than 180 days,
prior to the expiration date of this approval.
23. Annual Quality Control Monitoring: (for an alternate thermal destruc-
tion operation) Permittee shall conduct annual monitoring of the facility
for PCBs and HC1 destruction and removal efficiencies, and mass emission
rates for particulates, 2,3,7,8-TCDD, and 2,3,7,8-TCDF and total polychlor-
inated dibenzodioxin and total polychlorinated dibenzofurans. If limits
specified in the conditions of approval are not complied with, U.S. EPA
must be notified within one day of receipt of the test report, and Permittee
shall cease commercial incineration of PCBs. Otherwise test results shall
be incorporated into the annual report. If no disposal operations were
conducted during the year of an anniverary of this permit, the first disposal
operation in the following year after the anniversary shall be monitored as
required under this condition.
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BEFORE THE
HENDERSON COUNTY BOARD OF ZONING ADJUSTMENT
IN RE: THE MATTER OF THE
APPLICATION OF THE HENDERSON COUNTY
RIVERPORT AUTHORITY AND UNISON TRANSFORMER
SERVICE, INC, FOR A CONDITIONAL USE PERMIT
APPEAL NO. 146
FINDINGS OF FACT. CONCLUSIONS AND
rONPITIONAL USE PEKmi
#***
Thi. cute CM before the Henderson County Board of Zoning Adjustment
* •-*. Henderson County Riverport Authority and Unison
on the application of the Henoereau
. „ for - conditional use permit in accordance with
Transformer Service, Inc. for a c«w
of the Code of Zoning Ordinances of Henderson
Article XXII, Section 22.03 ol me
^ rh«t»t«r 100 of the Kentucky Revised Statutes to store oil
County, Kentucky and Chapter
above ground In exceet of 500 gallon.s «nd
The Board of Zoning AdJMtwnt having conaidar.d th. .pplictlon,
. _ thereon and being otherwise fully and
conducted an evidentiary hearing
»j_.i mnA conclude as follwis
sufficiently advised does find *
The Board of Zoning Adjust**** TISD5:
^ .re the Sanderson vounty Riverport Authority, a
1. The appli®*nt* «»
* .u. r.nimtv of Sanderson*, Commonwealth of Kentucky and
unit of government of the County
t_- - «ew York corporation wholly owned by the
Unison Transformer Service#
Union Carbide Corporation,
2. The conditional «« is »ou*ht £or * tract °f land "id to
. County, Kentucky owned by the Henderson County
contain 15 acres in Henderson t,oun
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Riverport Authority located on a public road designated as the Rlverport Access
Road.
3. The applicant. Unison Transformer Service, Inc., has an option to
purchase the subject property from the Henderson County Rlverport Authority and
intends to do so If a conditional use permit is granted.
4. The Henderson County Rlverport Authority vill not operate the
premises, but instead intends to sell the subject property to Unison Transformer
Service, Inc.
5. Unison Transformer Service, Inc. proposes to build a plant on the
subject property to engage in an enterprise which Involves the removal of liquid
substances from electrical transformers which contain (among other things) a
chemical compound known as polychlorinated blphenols, (PCBs).
6. The Congress of the United States of America has determined that
PCBs are injurious to the public health and welfare and has directed that they
should be removed from the environment.
7. PCB laden materials and substances will be transported to and from
the subject property by truck.
8. Unison Transformer Service, Inc. will contract with the
transporters of the material and substances containing PCBs.
9. The PCB laden materials and substances exceeding 500 gallons will
be stored upon the subject property In heavy duty metal drums and tanks.
10. The handling of the PCB laden materials and substances will,
except for their transport to and from the plant site, take place at the plant
site.
11. The proposed use of the subject property under the conditions
herein Imposed will not emit detrimental, obnoxious or objectionable conditions
-2
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beyond the confines of the .object property. However, unless the conditions
herein imposed are strictly performed, complied with end adhered to by Union
Carbide Corporation and Unison Transformer Service, Inc. there exists the
potential for harm to the public health, safety and welfare which will emit
beyond the confines of the subject property. Por that reason the conditions
herein stated should be strictly performed, compiled with and adherad to by Union
Carbide Corporation and Unison Transformer Service. Inc..
The Board of Zoning Adjustment CONCLUDES:
1. The subject property for which the conditional use permit is
sought is presently zoned H-2. a heavy industrial district. The uses for this
.one are primarily of a manufacturing. assembling 'testing »«ure
. railroad and/or river and water access and
requiring good access by road, raixroao
vn* utilitv services. (Code of Zoning Ordinances of
needing special sites or public utility
Henderson County, Kentucky, Article XXII).
2. Permitted uses upon the subj.ct prep.rty are (a) any use permitted
, n manufacturing, fabrication and/or processing
in a light industrial district, id/ w*uu
, , . buildings and uses - garages and other
of any commodity; and
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(c) Any other use which in the opinion of the Board of Zoning
Adjustment would emit objectionable conditions beyond the
confines of its property. (Code of Zoning Ordinances of Henderson
County, Kentucky, Article XXII, Section 22.03).
4. A "conditional use" i6 a use which is essential to or would
promote the public health, safety or welfare in one or more zones, but which
would impair the integrity and character of the zone in which it is located, or
in adjoining zones, unless restrictions on location, size, extent and character
of performance are Imposed in addition to those imposed In the Zoning
Regulations. (KRS 100.111(6)).
5. A "conditional use permit" Is a legal authorization to undertake a
conditional use Issued by the administrative official pursuant to authorization
by the Board of Adjustments, consisting of two parts: (a) a statement of the
factual determination by the Board of Adjustments which justifies the issuance
of the permits; and (b) a statement of the specific conditions which oust be set
in order for the U6e to be permitted. (KRS 100.111(7)).
6. The Board of Zoning Adjustment concludes that the use to which
Union Carbide Corporation and Unison Transformer Service, Inc. intends to put
the subject property is one which is essential to or would promote the public
health, safety or welfare in one or sore zones, but because of the nature of the
undertaking and the hazardous materials and substances which will be transported
to and from, stored, processed and/or handled upon the subject property such use
may reasonably be expected to impair the integrity and character of the
adjoining property and cause damage end harm to the public health, safety and
welfare generally unless restrictions on the character of performance of UnioO
-------
Carbide Corporation and Unison Transformer Service, Int. at the subject property
herein imposed in addition to tho.e imposed in the Zoning Regulation it.elf are
strictly performed, complied with and adhered to by Union Carbide Corporation
and Unison Transformer Service, Inc. For such reason, the conditional use
permit should not issue except upon the conditions herein stated.
7. Union Carbide Corporation, the parent corporation for Unl.on
Transformer Service. Inc.. should be a record permittee with It. said subsidiary
and should be bound and equally responsible in all respect, for the operations
conducted upon the .ubject property by it. subsidiary. Union Transformer
Service. Inc. For such reason the application ahould be amended to reflect
_ 40int applicant with its subsidiary, Unison
Union Carbide Corporation as * J°"t «ppa*
Transformer Service, Inc.
8. The application for a conditional use p.rmit .hould b. amended »
. atJolicantB upon the subject property which,
as to reflect a proposed use by the applies r
1. <« -inoosed are strictly performed, complied with and
unless the conditions herein i»P°»«a
r«moration and Unison Transformer Service. Inc. may
adhered to by Union Carbide Corporatio
v ... »tv and welfare which will emit beyond th*
cause harm to the public health, aataty •
confines of the subject property.
roKDlTIONA* ttSE PERMIT
v .Plication for conditional use permit is granted
NOW, THEREFORE, the applica
• nw4,on Transformer Service, Inc. sublect to and
to Union Carbide Corporation and Ir,MI
"Pon the following .pacific condition..
-van be a record permittee with its
1. Union Crtlde Corporation rt»U "
, _r garvic* ,h,u ln *U '«•«"«• •"
•ubsidiary, Unison Transformer sarv*
„ _„-r«tions conducted upon the aubject property bv
•qually responsible for all op
5-
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itB subsidiary, Unison Transformer Service, Inc. As evidence of itE agreement
to be in all respects equally rsponsible for all operations conducted upon the
subject property by it6 subsidiary, Unison Transformer Service, Inc., Union
Carbide Corporation shall present to and file with the Board of Zoning
Adjustment corporate minutes stating such agreement.
2. This conditional use permit shall not be assigned to any person,
firm or corporation without prior written approgal of the BZA.
3. Union Carbide Corporation and Unison Transformer Service, Inc.
shall file with the Board of Zoning Adjustment and keep current an emergency
response plan acceptable to the Board of Zoning Adjustment which plan shall
include among other things the manner in which disaster and emergency situations
at the subject property are to be handled by Union Carbide Corporation and
Unison Transformer Service, Inc., the method of notice to the public generally
of emergency situations and a specific plan of addressing such emergency
situations so as to prevent harm to persons in and about the premises and to
persons and property of the public generally. The Board of Zoning Adjustment
reserves the right, from time to time, to review the emergency response plans so
filed; to additions theretoom accprdmace wotj omdistru standards; to disapprove
all or Forti°ns thereof; and to order Union Carbide Corporation and Unison
Transformer Service, Inc. to cease operations at the subject property in the
event it Is determined that Union Carbide Corporation and Unison Transformer
Service, Inc. are unable to Implement and execute an acceptable emergency plan.
A. Union Carbide Corporation and Unison Transformer Service, Inc.
shall file with the Board of Zoning Adjustment all permit applications and
permits which are considered public Information and which they make to all
local, state and federal agencies regulating the enterprise being conducted upon
the subject property by Union Carbide Corporation and Unison Transformer
Service, Inc.
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5. When received Union Carbide Corporation and Unison Transformer
Service, Inc. shall file vlth the Bo.rd of Zoning Adjustment .11 notices of
remit violations Issued by any local, state or federal agency pertaining to
operations upon the subject property and/or the transport of PCB laden materials
and substances to and from the subject property. In the .vent of any such
violations the contamination of which would pos. an immediate threat of injury
or damage to persons, property or the environment. Union Carbide Corporation and
Unison Transformer Service, Inc. shall Mediately case operations upon the
subject property until such violations are corrected and th. agency Issuing the
, , writ in R that the violation has been abated,
notice of violation acknowledges in writing
6. Onion Carbide Corporation and Unison Transformer Service. Inc.
4+u Board of Zoning Adjustment a current list of
shall file and maintain with the Boaro
J . to transport PCB laden materials and substances to
all transporters used by them to trans^*
tcee-ther with documentation that all such
and from the subject property togexner
- with all regulatory agencies. In addition
transporters are in good standing vitn
. o and Unison Transformer Service, Inc. shall
thereto Union Carbide Corporation ana
.fl t#g of insurance for each such transporter,
file and maintain current certificat
a - Tt«*«on Transformer Service, Inc. shall be
Union Carbide Corporation and Unison
, *ii ^.rations, actions and inactions in Henderson
primarily responsible for all operation®.
._._.nnrt«rs including, without limitation, loss,
County. Kentucky of such tran.port.rs u.
damage or harm to persons, property, and the .nvironwnt.
7. Union Csrbid. Corporation snd Unison Transferor Sarvic. Inc.
narnini systems linked to police, fire,
.hall inat.ll approved emergency «rly «.™»g ,
* r
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agencieB of the City and County of Henderson and an explanation of 6uch system
filed and maintained current with the Board of Zoning Adjustment.
8. Union Carbide Corporation and Unison Transformer Service, Inc.
shall obtain prior written approval from the Board of Zoning Adjustment of all
transportation routes it proposes to use for the transport of PCB laden
materials and substances to and from the subject property and shall not deviate
from the approved routes except upon prior written approval from the Board of
Zoning Adjustment.
9. Union Carbide Corporation and Unison Transformer Service, Inc.
shall submit to the Board of Zoning Adjustment for its prior approval a Federal
EPA approved audit or accounting system which will set forth completely and
specifically the method by which they intend to account for the nature and
quantity of PCB laden materials and substances coming into and leaving the
subject property. The books and records of such audit or accounting shall be
open for Inspection by the Board of Zoning Adjustment or Its designee at all
reasonable times.
10. Should any person be exposed to PCB laden materials or substances
while at the subject property or be exposed to such materials or substances
outside of the subject property In Henderson County, Kentucky while the same are
being transported to or from the subject property, Union Carbide Corporation and
Unison Transformer Service, Inc. shall upon request from a person so exposed,
his or her family or treating or consulting physicians, provide to any such
person making the request the name of the material and all necessary datea of
such materials and substances as are received for the proper treatment of such
persons.
8-
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11. Onion Carbide Corporation and Uniaon Transformer Service • Inc.
.ball not maintain or atora an, PCB laden -tarlala or aub.tanc.a outalda of «h.
plant to be erected upon tha aubject property.
12. Union Carbide Corporation and ttalaon Ir.nafon.er Service, Inc.
•hall file with the police and fir. agenclea of the Clt, and County of Henderaon
and State of Kentucky a collate and .pacific aacurlt, plan vhich .hall be
approved by each auch agency.
13. Union Carbide Corporation and Dnlaon Iranafonaar Service. Inc.
.to.ll « ,u reaaonable tlaea •"« """ " "* £or tn""Ctl°11 k*
repreaentatlvea of the Board of Zoning AdJ«at«nt and all police, fire and
emergency reaponae agencies of the Clt, and County of Henderaon and Stat, of
Kentucky.
U. Union Carbide Corporation and Uniaon iranaformer Sarvice. Inc.
ahall nalntain at tha aubject proparty e.er,ancy raaponae p.r.onnal adequately
.4*. th.t miaht reasonably be expected to arise at
trained to co«bat all energanclea that Mgnt
« -«-reency response personnel ahall be properly
the subject property. Such emergency
the necessary equipment to combat any such
trained and equipped vlth all of the nee
r^-^nration and Unison Transformer Service, Inc. shall
emergency. Union Carbide Corp
, * 7nnine Adjustment and maintain current a list of their
file with the Board of 2oning * J
-i .nd of the equipment provided to such emergency
emergency response personnel
response personnel.
. r««ifl*ation and Unison Transformer Service• Inc.
15. Union Carbide Corp***"™
furnish W the P°lic#» fi*« *»* *******ey
shall at their sole expense furni
, _ cltv ,nd County of Bende**on and local agencies: of the
response agencies of the city
.-I training, equipment and supplies as are necessary
State of Kentucky such special tmnw».
JJ atmr Situations which might reasonably be anticipated
to combat emergency or diss
•t the subject property.
-------
16. Union Carbide Corporation and Unison Transformer Service, Inc.
shall file and maintain current with the applicable police, fire and emergency
agencies of the City and County of Henderson, and local 6tate police agencies
plans of all buildings on the subject property with areas designated on those
plans where hazardous materials and substances might be encountered by emergency
response personnel in times of emergencies.
17. Union Carbide Corporation and Unison Transformer Service, Inc.
shall be responsible for removing from the environment in an EFA approved manner
all PCB laden substances which are spilled within Henderson County while being
transported to and from the subject property regardless of the cause of such
spill.
18. The proposed plant to be erected on the subject property shall be
designed and constructed in strict compliance with the requirements of all state
and federal agencies having jurisdiction thereof including local, state and
federal environmental agencies.
19. No commercial operations shall commence upon the subject property
until Union Carbide Corporation and Unison Transformer Service, Inc. shall have
obtained building and operating permits from all local, state and federal
agencies, including, local, state and federal environmental agencies having
jurisdiction thereof.
20. No operations shall commence upon the subject property until
Union Carbide Corporation and Unison Transformer Service, Inc. shall have
obtained approval from the Kentucky Airport Zoning Commission and the
Henderson-Henderson County Airport Board.
-10-
-------
21. Should the plant to be constructed upon the subject property be
permanently closed and/or disapproved for operations either voluntarily or
Involuntarily for any reason. Union Carbide Corporation and Unison Transformer
Service. Inc. shall be responsible for: the removal of all PCB laden materials
and substances from the subject property; for decontaminating and restoring the
plant, equipment, plant site and its environ, to the conditions existing prior
to commencement of operations and .hall not after .uch time reintroduce PCB
laden materials and aub.t.nc.s to the .ita. All .uch decontamination and
raatoration operations shall be completed not later than on. (1) y.ar following
the closure or disapproval for operations.
22, Union Carbide Corporation and Unison Transformer Service. Inc.
•hall fund a .tudy to be conducted under th. auspice, and direction, of the
B ... the our pose of which shall be to determine the
Board of Zoning Adjustments tne purpu»
. .. -t,.„.ieals presently existing in the environment
present level of PCBs and other chemicaxs j
designated transportation routes, nearby
at the subject property, its environs, design-
u a* mm of water and water courses. The Board of Zoning
rivers, streams, bodies of water
firm or corporation to conduct this study
Adjustment shall select the person, firm or co P
. nl t0 t!lft Board of Zoning Adjustment. After the
which shall be answerable only
, . „ .ucted. tbe Union Carbide Corporation and Unison
initial baseline study is conducted,
_v_n when requested by the Board of Zoning
Transformer Service, Inc. snail,
funds to the Board of Zoning Adjustment for
Adjustment, provide the necessary funas *
¦ - it levels of PCBs end Other chemicals in the
follow-up studies to determine if the levels
„_rv its environs, nearby rivers, streams,
environment at the su^ect property,
^ j;..*.** Mrid along the transportation routes used by
bodies of water and water courses ana s
j a alenificant increase in the levels of PCBs and
the applicants have increased. * sign*
-H
-------
other chemicals traceable to the operation above the baseline levels shall
constitute a violation of this conditional U6e permit.
23. Union Carbide Corporation and Unison Transformer Service, Inc.
shall at their expense, when requested by the Board of Zoning Adjustment,
provide the necessary funds for the Board of Zoning Adjustment to employ
independent Inspectors and auditors answerable only to the Board of Zoning
Adjustment for the purpose of determining continual compliance with thi6
conditional use permit.
24(A). Union Carbide Corporation and Unison Transformer Service, Inc.
Bhall file and maintain with the Board of Zoning Adjustment an indemnity bond or
bonds in amounts to be determined by the Board of Zoning Adjustment after a
hearing for that purpose with sufficient surety thereon in the opinion of the
Board of Zoning Adjustment conditioned upon the following:
(1) That all of the conditions herein stated
shall be strictly performed, complied with and
adhered to by Union Carbide Corporation and Unison
Transformer Service, Inc.
(2) That Union Carbide Corporation and Unison
Transformer Service, Inc. and their surety or
sureties are bound to and shall indemnify the City
and County o£ Henderson and all other persons*
firms or corporations for ell damages, losses and
expenses incurred by any or all of them because of
the failure or refusal of Union Carbide
Corporation and/or Unison Transformer Service,
Inc. to strictly perform, comply with and adhere
to the conditions herein stated or arising out of
the enterprise in Henderson County, Kentucky
conducted by Union Carbide Corporation and Unison
Transformer Service, Inc. upon the subject
property for which this conditional use permit Is
granted.
24(B). The indemnity bond or bonds shall be in form and amounts
satisfactory to the Board of Zoning Adjustment and shall provide, among othe*
-------
things, that the City .nd Count, of Hender.on .nd .11 other p.r.ona, fira. or
corporations suffering d.mge or lo.a or incurring .xpen.es c.used b, the
operations of Union Carbide Corporation and/or Unl.on Transformer Service, Inc.
upon the subject property or becauae of the failure or refu..l of Union Crbide
Corporation .nd Unison Transformer Service, Inc. to atrictly perform, comply
with .nd adhere to the conditions of thl. condition.1 uae permit ah.ll h.ve .
direct right of .ction .gainst Union Carbide Corporation, Unison Transformer
Service. Inc. .nd their surety or auretiea.
24(C). The aureties upon theae bonds sh.ll be responsible insurance
j L„e^ctg in the state of Kentucky and acceptable to
companies authorized to do business in tne
the Board of Zoning Adjustment.
24(D). Should the surety or sureties (or any one when there is more
v 4, certificate to operate in the state of Kentucky, be
than one) lose its or their certitxcaie * r
. assignment for the benefit of creditors or become
adjudged a bankrupt, make an ass g
* ~»,• Board of Zoning Adjustment, then, and in such
insolvent in the opinion of the Boara o*
and Unison Transformer Service, Inc. shall
event, Union Carbide Corporation ana
^ sureties acceptable to the Board of Zoning
secure a successor surety or
-11 operations at the subject property until the
Adjustment and shall cease a °P
^ -nrf accepted by the Board of Zoning Adjustment,
successor surety is approved a
• bo„d or bonds herein required to be filed and
24(E). The indemnity bona
r«rr>oration and Unison Transformer Service, Inc.
maintained by Union Carbide Corporation
- for so long as Union Carbide Corporation
shall continue in fore. «nd .Me" '«
Inc. are conducting operations upon the
and/or Unison Transformer Service,
. * lona thereafter as the subject property, its
subject property and for
„ . „ .r.ct»d thereon, the equipi&ent therein, and all
environs, the improvements o
-13"
-------
transportation routes in Henderson County, Kentucky used for the transportation
of PCB laden materials to and from the subject property remain contaminated from
operations upon the subject property.
25. No commercial operations shall commence at the subject property
until the conditions herein imposed 6hall have been strictly performed, complied
with and adhered to by the applicants.
26. The conditions herein imposed are of a continuing nature and the
violation of any such conditions shall be cause for the revocation of the
conditional use permit herein granted.
27. The Board of Zoning Adjustment shall have the authority to
enforce the provisions of this conditional use permit and to seek damages fot
its violation by all applicable laws, ordinances and regulations.
Issued this day of 1985.
HENDERSON COUNTY BOARD OF ZONING
ADJUSTMENT
By:
Chairman
AGREED TO BY:
UNION CARBIDE CORPORATION
By:
ATTEST:
UNISON TRANSFORMER SERVICE, INC.
By:
ATTEST:
-14-
-------
STATE OF KENTUCKY
COUNTY OF HENDERSON...SCT.
The foregoing was acknowledged before me by Richard Crafton, Chairman
of the Henderson County Board of Zoning Adjustment on this day of September,
1985.
My commission expires:
Notary Public
STATE OF
COUNTY OF .. .SCT.
The foregoing was acknowledged before me by
and > _________________________ secretary of Union Carbide
Corporation on this day of , 1985.
My commission expires: __________________________
Notary Public
STATE OF __
COUNTY OF ___•. • SCT.
The foregoing was acknowledged before me by
and » an<* secretary of Union Carbide
Corporation on this _____ day of ___ , 1985.
My commission expires: __________________________
Notary Public
-------
APPENDIX 4. EPA FIRES RULE BROCHURE
-------
PCB Transformers and
the Risk of Fire
-------
The greatest danger from a fire usually is not
the flames or the heat but the smoke and
gases given off from burning substances. The
burning of chemicals as toxic as PCBs
(polychlorinated biphenyls) produces gases
which are particularly dangerous.
Individuals may be exposed to PCB gases if
a fire occurs in or near an electrical
transformer which uses PCBs in its insulating
fluid.
ff you are the owner of a commercial
building, you have a special responsibility to
reduce the threat to the health of your tenants
and local fire fighters that could stem from a
fire in or near a PCB transformer. {A
commercial building is a non-industrial
building—such as an apartment house,
school, meeting hall, or store—which is
typically accessible to the general public.)
PCB electrical transformers were
manufactured between 1929 and 1977. An
estimated 77,000 PCB transformers are in use
this country today. Only about 18,000 of
these are owned by utility companies. The
peat majority of PCB transformers belong to
building owners.
U.S. Environmental Protection Agency
regulations now require owners of PCB
ksnsformers to take specific actions to help
®nsure the public safety.
Do You Own a PCB Transformer?
a building owner, you need to know if you
®Wn the electrical transformer(s) for your
gilding. If you are uncertain, contact your
'°cal utility company. If the utility does not
0vvn the transformer in your building, then
you do.
If you own the transformer in your
"Gilding, your next step is to determine if it
c°ntains PCBs.
, The tranformer will be in or near the
gilding it serves. It may be on the roof, in
1)6 basement, in the parking lot, on an
^terior wall, in a vault under the sidewalk,
^ in some other location close to where the
P°Wer cables enter the building.
Generally, a transformer will have a
nameplate attached to one side of the unit.
Trade Name
THREE PHASE TRANSFORMER 08692747008
I 500 | TYPE | AT | CYCLES | to | | 6644 |
RISEftn%C IMftDf 5.17 |\ BILHV( 96 |*V BLLvQSTJlCV
H-C
13300
J
L-v.r
208Y/120
HIGH VOLT
TAP CHANGER
voire
AMPS
DIAL
CONNECTS
13M0
20.(
A
1 to 2
13630
21J
1
2 to 3
13200
22J
C
3 to 4
12170
224
0
4toS
12440
210
E
Slot
L.Jstkd
mm—m
-am
Pnni
a e
-<
PLAN VCW
GALLONS Of OnQr
AffROX. WEIGHTS WKXJNOS
WHEN UNTANKINGI W0 I
TANK IN FITTING I 1H6 I
OIL OTMNOU I IMS I
total r~Bsn
Since PCBs were marketed under different
trade names, the nameplate on a PCB
transformer may not carry the specific term
"PCBs." Trade names for PCBs include:
Chlorextol
EEC-18
Kennechlor
Abestol
No-Flamol
Aroclor
Askarel
Inertera
Phenoclor
Pyranol
Chlopben
Pyniene
Non Flammable Liquid
Fenclor
Solvol
Saf-T-Kuhl
DK
If the nameplate says "PCBs" or any of the
names on the above list, then the transformer
most likely contains PCBs in concentrations
of between 600,000 and 700,000 parts per
million (ppm). Any transformer containing
PCBs at a concentration of 500 ppm or greater
is subject to the new EPA regulations listed
below.
Should your transformer's nameplate not
carry any of the above labels, or if the label is
missing or illegible, your utility company
may be able to tell you if the transformer
contains PCBs. Otherwise, the only way to be
certain is to have the fluid tested.
-------
New Requirements
For some time, regulations have been in effect
which govern the use, servicing, and disposal
of PCB transformers. The recently issued rule
described here applies to all PCB transformers
in commercial buildings and establishes strict
requirements for the owners of those
transformers.
• Installation of PCB transformers in, or near,
commercial buildings is prohibited.
(Although PCBs are no longer manufactured
for use in transformers, many PCB
transformers are currently in storage for
reuse.)
• Owners must register PCB transformers
with their local fire department.
• Utility companies that own PCB transformers
located in or near commercial buildings must
register the transformers with building owners
as well as with their fire department.
• PCB transformer areas, excluding grates
and manhole covers, must be marked.
• Combustible materials cannot be stored
within a PCB-transformer enclosure or within
five meters (approximately 16 feet) of an
unenclosed transformer.
• Owners of PCB transformers which are
involved in a fire must report the incident
immediately to the U.S. Coast Guard National
Spill Response Center by calling
800-424-8802 toll-free. (In the Washington,
DC metropolitan area, call 426-2675.)
As of October 1, 1990:
• The use of PCB units that EPA believes
have a relatively high probability of electrical
failure is prohibited.
• Improved electrical protection must be
installed on other PCB transformers to avoid
fires caused by electrical faults.
It is critically important that commercial
building owners register PCB transformers
with local fire departments or brigades. PCB
fires pose serious risks to building occupants
and fire fighters. If fire fighters and other
emergency personnel know they may be
dealing with PCBs, they can be prepared and
equipped to deal with the fire. Both fire
fighters and building owners also should be
aware of the need to quickly evacuate
occupants in an emergency situation, and of
the need to insure that proper and adequate
cleanup occurs prior to reoccupation of the
building.
A Serious Health Concern
EPA's regulations covering transformers are
part of a series of rules the Agency has issued
in recent years to protect the public from
PCBs. There are a number of adverse health
effects associated with these chemicals. Tests
on animals show that PCBs can harm
reproduction and growth, and can cause skin
lesions and tumors. When PCB dielectric
fluid is partly burned—as it may be in a
tranformer fire—the PCB fluid produces
by-products, which include polychlorinated
dibenzodioxin and polychlorinated
dibenzofurans, that are much more toxic than
the PCBs themselves. Tests on rats show that
furans can cause anemia and other blood
problems. Dioxin is associated with a number
of health risks, and has been shown to cause
cancer of the liver, mouth, adrenal gland, and
lungs in laboratory animals.
For More Information
If you need help in complying with the new
regulation, please contact your nearest EPA
Regional Office (see back cover). For more
information about the transformer regulation,
or other EPA rules controlling PCBs, write to
the Office of Toxic Substances (TS-799), U.S.
EPA, Washington, DC 20460, or call that
office toll free at 800-424-9065 (in
Washington, D.C., call 554-1404).
-------
APPENDIX 5. AIR EMISSIONS, ORDINARY OPERATIONS
-------
APPENDIX 5 Ordinary Operations Air Model.
•# 6RQUND L£v€L CONCENTRATION i HIlROBRAHS PER CUBIC METER i DUE TO SOURCE ;o». *
- BfilD SYSTEM RECEPTORS -
- X
AXIS (RANGE
, HETERSj -
166.670
j-j3. jjO
50C.000
666.6~0
9j j.ijO
1000.000
1 jiiO
1660.670
I '00.000
i iAZIMTH BEARING, BE6REES i
- CONCENTRATION -
337.500
0.9783E-0I
0.4482E-01
0.2649E-01
0.1740E-01
0. i2j3t-vi
0.9256c-02
0.5949E-02
j.* me-: 2
0. r 147-fc—02
315. OCK»
0.1041E+00
0.4886E-01
0.2928E-01
0.1935E-01
0.1377E-01
0.103SE-01
0.6658E-02
0.4o7?E-02
0. .SifoE-w
292.500
0.9562E-01
0.4206E-01
0.2466E-0i
0.1614E-01
0.1143E-01
0.8554E-02
0.5483E-C2
0.3659E-02
0. ii.S8£-02
270.00.)
0.13~-:jE*00
0.6963E-01
0.4373E-0;
0.2951E-01
0.2126E-01
0.1610E-01 '
0.1044E-01
0.7375E-02
O.iKSE-£
247.500
0.1007E+00
0.5926E-0I
0.3649E-0j
0. 2t;wxE~01
0.1910E-01
0.1454E-01
0.9467E-02
0.672 6E-02
0.5',o4E-C
225.000
0.7176E-01
0.3909E-01
O.2475E-01
0.1675E-01
0.i208£-01
0.9162E-02
C.5943E-C2
0.4212E-02
."167E-02
202.50c
0.52;7t-'Ji
0.2909E-01
0.1851E-0:
0.1255t-01
0.9064E-02
0.6879E-02
0.4469E-02
o.3:7:£-o:
160.000
0. i^5E*00
0.7476E-01
0.4725E-?:
0.31962-01
0.2306E-01
0.1749E-01
0.1l36£-0i
0.E0oiE-02
O.o 65E-02
157.5*>0
0.1153Et00
0.8S79E-01
0.6232E-0:
0.4393E-01
0.3239E-01
0.2492E-01
0.1639E-01
0. ::72E-jj.
0...65SE-.;2
135.000
0.1573E*00
0.1235E+00
0.9147E-01
0.6479E-01
0.4791E-01
0.3691E-01
0.2433E-01
0.I740t-0i
0..314E-01
112.500
0.1315E+00
0.8827E-01
0.5991E-01
0.4171E-01
0.3056E-01
0.2341E-01
0.1535E-01
0. K-95E-01
_ ^ci7E~v».'
90.00'.'
0.1230E+00
0.6397E-01
0.4012Z-01
0.270oE-01
0.1949E-C1
0.1477E-01
0.9579E-02
0.6791E-02
v.5K>6£-02
67.500
0.9644E-01
0.4747E-01
0.2901E-01
0.1934E-01
0.13B4E-01
0.1044E-01
"i.6735E-0_
0.4755E-02
C..571E-.2
45.000
0.1146E+00
0.52B4E-01
0.3145E-01
0.2071E-01
0.1472E-01
0.1105E-01
0.7G9BE-02
0.5002E-02
O.7746E-0I'
22-500
0.782«E-01
0.3380E-01
0.1943E-01
0.1259E-01
0.BS64E-02
0.661'.'E-02
0.4222E—02
0.2966E-:2
0.1216E-02
0.000.
0.1720E+00
0.8170E-01
0.4899E-01
0.3237E-01
C. ^j05E"vl
0.1732E-01
.!•. 11.5E-C
0. "5o
0.7395E-02
-------
APPENDIX 5
Ordinary Operations Air Model (continued).
2333.330
r AXIS (AZIHLTH SEARING,
2666.670
i
- GRID SYSTEM RECEPTORS -
- X AXIS {RMGE , METERS) -
3000.000 3333.330 3666.670
- CGaCEKTRATIGN -
4000.000
4333.33J
'tLC-O.OH-
.¦^7.50)
0.2475E-02
0.2011E-02
0.1674E-02
0. 1428E-02
0.1235E-02
0.1064E-02
0.960SE-03
0. J'I94E -u3
j."745c-i7
5.
0.2774E-02
0.2255E-02
0.1676E-02
0.1603E-02
0.1387E-02
0.1218E-02
0.138GE-02
0.76o5t~yc-
. t '. 4c.-...
292.500
0.2272E-G2
0.1844E-02
0.1534E-02
0.1307E-02
0.1130E-C2
0.99If£-03
0.6736E-03
•*. /c54t
... "j'i.E-or
m. m
0.4392E-C2
0.3579E-32
0.2986E-02
0.2553E-02
C.2214E-02
0.1947E-02
0.1729E-02
0.1542E-02
v..:?rc
247.500
0.40JOE-02
&.3273E-02
0.2734£-02
0.2341E-02
0.2033E-02
0.1739E-02
G.1590E-02
0. i 42aE~02
v. *25tiE -02
225.000
0.2504c-02
0.2041E-02
0.1703E-02
0.1457E-02
0.1265E-02
0. ill2E-02
0.9S74E-03
0.3547c--.'.
0.7967E-C-:
202.500
O.i808E-u2
0.1540E-02
0.1286E-02
O.iiOOE-02
0.9557E-03
0.8401E-03
0.7464E-03
0.66dVc~u3
0.604OE-.;
180. OX'
0.4798E-02
0.3912-02
0.3266E-02
0.2795E-02
0.2425E-02
0.2133E-02
0.1395E-02
0. is9E?E-,.'2
0. ;527L-02
157.500
0.704i£-02
0.S764E-02
0.4S27E-02
0.4144E-02
0.3606E-02
0.3I3CE-02
0.2S3IE-02
0._54iE-.:C
135.000
0.1047E-01
0.6574E-02
0.7182E-02
0.C169E-02
0.5370E-02
0.4737E-02
0.4213E-02
0.3/a9E-l£
v. . »
112.500
0.6562E-02
0.5365c-02
0.4489E-02
0.3850E-02
0.3348E-02
0.2950E-Q2
0.2625E-02
0.2355E-J2
j.2;29E-C-
90.000
0.4036E-02
0.3289E-02
0.2744E-02
0.2347E-02
0.2036E-02
0.1791E-02
0.1590E-0I
iiZH-K.2
o.. ;3 a-;-:
67.500
0.2618E-02
0.2293E-02
0.19UE-02
0.1633c-02
0.1414E-02
0.1243E-02
0.1103E-02
0.'571E-O3
5903E->3
45.000
0.2950E-02
C.239BE-CE
0.1996E-C2
0.:?03E-02
0.1474E-C2
0.1293E-02
C-.i;47E-02
0. i - *~uL
. ^7E-07
22.500
0.1741E-02
0.;4i2E~02
0.1174c-02
0.9993E-03
0.S633E-O3
0.756oE-03
0.67iX£-03
>j. z9h7"vZ
.339IE-v7
0.000
0.4647E-O2
0.3778c-02
0.3147E-02
0.26fcE-C2
0.2325E-02
0.204IE-02
0. lBiOE-CC
0. i £2C«E-02
v. ;46v£-02
-------
APPENDIX 5
Ordinary Operations Air Model (continued).
• SRID SYSTEH RECEPTORS -
- SS AXIS (RANGE , METERS) -
6666.670 8333.330 1GGOO.OGO H66o.670 13333.330 15604.000 16333.330 21fc6t>.6*0
V MIS iAZIMUTH BEAMING, DEGREES ) - CONCENTRATION -
337.500
0.5016E-03
315.000
0.5651E-C3
292.500
('.4574E-03
270.000
0.9100E-03
247.500
0.8410E-03
225.600
0.52C6E-03
262.500
0.3940E-03
180.060
0.9992E-O3
157.500
0.1509E-02
mm
0.22SE-G2
ft2.500
0.1395E-02
90.000
0.8370E-03
67.500
0.5785E-03
45.006
0.5992E-03
22.500
0.348GE-03
0.000
0.9473E-O3
0.36&4E-03 0.2754E-O3
0.4068E-03 0.3U4C-03
0.3284E-03 0.2509E-03
0.6574E-03 G.5047E-03
0.6090E-03 0.46WE-03
0.3764E-03 0.2892E-03
0.2850E-03 0.2190E-OI
0.7223E-03 0.5546E-03
0.1097E-02 0.3466E-C3
0.163SE-02 0.1264c-02
0.1012E-02 0.7BWE-03
0.6045E-03 0.4639E-03
0.4171E-03 0.3196E-03
0.431lt-03 0.3299E-03
0.2494E-u3 0.1902E-03
0.6819E-63 0.5219E-03
O.2190E-O3 0.I8i1E-03
0.2488E-Q3 0.2052E-03
0.2002E-03 (. 1649E-03
G.4040E-03 G.3337E-03
0.3753E-03 G.3103E-03
Q.2316E-03 0.1914E-03
0.1754E-G3 0.1449E-03
0.44WE-03 0.3667E-03
C.6797E-G3 0.5629E-G3
0.1&15E-02 0.841(1-03
0.6256E-03 0.5176E-03
0.37llE-v3 0.3064E-03
0.2555E-03 0.2KWE-03
0.2635E-03 0.2173E-03
0.1516E-03 0.1248E-03
0.4169E-03 0.3438E-03
¦J. 1 jiot— 0. ii5zE"*.o
0.I731E-G3 0.1310E-03
0.13B9E-03 0. I049E- 03
0.2817E-03 o.214<£-03
0.2621E-03 0.I995E-03
0.1616E-03 0.1228E-03
0.1224E-03 0.9302E-04
0.3096E-03 0.2351E-03
0.4762E-03 0.363&E-03
0.7116E-03 0.5436E-03
0.4376E-03 0.3335E-03
0.2586E-03 0. iV62£-03
0.1779E-03 0.1348E-03
0.1332-03 0.1336£-03
v. 1C5JE-03 0.7915E-04
0.2699E-03 0.2193E-03
V.2h£-04 0.74£5E-Ov
~, ivE~o3 .8j»'_>:-v4
~,g3S5£0. ujj.E-04
0. >703E-Ci3 ! . .4 ! !£-.>!
0.159ut-0"Z 0. ;3iCc-v»;.
0.9754E-04 0.8l-59E-&4
(K 7407E-04 0. dUjt-'H
-------
APPENDIX 5
33333.340 41666.672
Y AXIS (AZIMUTH BEARING, DEGREES )
337.500
0.5060E-04
0.3764E-04
315.000
0.5795E-04
0.4322E-04
292.500
0.4614E-04
0.3436E-04
270.000
0.9542-04
0.7136E-04
247.500
0.3936E-04
0.6692E-04
225.000
0.5491E-04
0.4110E-04
202.530
0.4153E-04
0.3106E-04
130. >30
0.1047E-C3
0.7822E-04
157.50*3
0.1641E-03
0.1232E-03
2 j . J-'U
0.I456E-03
0.1844E-03
112.300
0.i499E-03
0.1123E-03
90.000
0.E724E-O4
0.651SE-04
67.500
0.59ME-O4
0.447IE-04
£5.000
0.ci32t-04
0.4576E-04
22.500
0.3465E-04
0.2576E-04
0.000
0.9694E-04
0.7228E-04
Ordinary Operations Air Model (concluded).
- GRID SV3TEM RECEPTOR? -
- X AXIS (RANGE , HETERS) -
50000.000
- CONCENTRATION -
0.2962E-04
G.3406E-04
0.2704E-04
0.5634E-04
0.5289E-04
6.3247E-04
0.2452E-04
0.6170E-04
0.9745E-04
0.1459E-03
0. S877E-04
0.5140E-04
0.3527E-04
0. 3607E-04
0.2026E-04
0.5696E-04
-------
APPENDIX 6. TORNADO EFFECTS
-------
APPENDIX 6. TORNADO EFFECTS
Reprinted from: U.S. Dept. of Commerce
Weather Bureau
Technical Paper No. 29
Tornado Occurrences in the United States
Washington, D.C. 1960
pages 8-10
Because of the erratic behavior and intense forces demonstrated by
tornadoes, many unbelievable and freakish occurrences have resulted during
their passage. The furious winds of a tornado turn normally harmless objects
into missiles of great penetrative power. Frequently, reports show that
boards or even stalks of straw were driven into tree trunks, posts, and
sides of buildings, huge trees were ripped from the earth and hurled hundreds
of piles, persons were lifted into the air and carried for distances, and
chickens were cleanly plucked of their feathers but unhurt. Other reports
tell of fine dirt, stones, and bits of leaves being driven into the flesh
of persons exposed to the wind, and clothes saturated with mud under similar
conditions are said to be almost Impossible to clean.
The terrific force and lifting power of the whirling tornadlc winds
are shown in the following descriptions. On April 16, 1879, a tornado at
Walterboro, S.C., lifted a hickory .tree, measuring 54 inches in circumference,
out of the ground and moved it 10 feet up a bank; geraniums blooming In pots
were found by the owner 1 mile away undamaged. At Marshall, Mo., an Ice
chest weighing 800 pounds was carried a distance of several miles on April 16,
1880. After the St. Louis, Mo., tornado of May 27, 1896,a 2x4-inch scantling
was found protruding several feet through Iron 5/8 inch thick on the Eads
Bridge; wheat straws were found forced into a tree trunk to a depth of over
1 inch; and a 6x9-inch timber was driven 4 feet almost straight down into
the hard ground. Following the tornado of November 10, 1915, at Great Bend,
Kans., an iron water hydrant was discovered full of wooden splinters. The
force of the wind at Fergus Falls, Minn., on June 22, 1919, split a huge
tree, hurled an automobile Into the split, and closed the opening In the
tree, holding the automobile as if It ware In a vise. After the tri-State
tornado of March 18, 1925, a large plank several feet long was found driven
horizontally into a tree trunk so firmly that the far end could^support a man's
weight without loosening it from the tree; at Griffin, Znd., a piece of wall-
paper about 2X3 inches was observed driven edgewise into thi southwest side
of a box elder tree about 6 feet above ground. At Nashville, Tenn., on
March 14, 1933, a 2x4-inch timber was plunged through a panel door, without
causing the slightest splitting or splintering sad fit the opening perfectly;
another plank, measuring 1x6 inches was forced through the trunk of a sturdy
tree, splitting the tree in half. On July 4, 1956, at Edlsonv Nebr., lX8-inch
boards were driven into the ground in a straight line as if measured and placed
there.
The powerful force of the rotating winds was shown in the tornado on
May 27, 1931, at Moorhead, Minn., when farm Implements of heavy iron and steel
were twisted beyond recognition; at Nashville, Tenn., on March 14, 1933, when
a high tension tower was bent to the ground in a tangled mass without breaking
-------
loose from its concrete moorings; and on April 6, 1936, at Gainsville, Ga.,
when a telephone pole was so twisted it resembled a huge corkscrew but still
remained upright. On June 12, 1957, a tornado at a Dallas County, Texas,
airport struck a steel hanger built to withstand winds up to 120 m.p.h., and
pulled the concrete piers from the ground. During the tornado of June 22, 1919,
at Fergus Falls, Minn., a trunk containing clothing was carried from one house
and deposited in the attic of another two blocks away, and when found was
undamaged. Galvanized roofing was carried 50 miles from La Plata, Md., on
November 9, 1926. On May 7, 1927, a 5-ton caterpillar tractor was turned over
and rolled 500 feet at Hutchinson, Kans.; a span of steel highway bridge near
Medicine Lodge, Kans., was blown downstream for 100 feet. At Gothenberg,
Nebr., on June 24, 1930, two concrete blocks, weighing 2,000 pounds each, were
torn from their fastenings and moved several feet. The courthouse bell,
weighting nearly a ton, was carried 350 yards in the Gainesville, Ga., tornado
on April 6, 1936, and portions of a huge sign which extended across a Gaines-
ville mill were found at Easley, S.C., over 85 miles away.
Clothing and other small articles have been recovered many miles away from
the scene of the storm. An unmailed letter and check which had evidently been
blown from Great Bend, Kans., on November 10, 1915, were found 85 miles to
the northeast. An insurance policy from a home in Marion County, Ala., was
blown into Lauderdale County, a distance of 75 miles during the tornado of
April 20, 1920. A picture postcard bearing an Orestes, Ind., address was
recovered on April 17, 1922, at Mt. Cory, Ohio, 124 miles away, torn at one
corner, but otherwise in good condition. After the tri-State tornado of
March 18, 1925, a pair of trousers with $95 in the pocket was picked up 39
miles away, and a check and calling card were carried 125 miles. An old
postcard which had been kept in a trunk at Gainesville, GA., was found, fol-
lowing the April 6, 1936, tornado, at Liberty, S.C., 80 miles distant. Pieces
of stationery from Gainesville were picked up at Easley, S.C., over 85 miles
away. A letter was carried 100 miles by a tornado in Pennsylvania on
June 23, 1944. Various objects were reported to have been carried 90 miles
from their original position at Corn., Okla., on June 8, 1951. A government
bond from Kay County, Okla., was found at Williamsburg, Kans., over 100 miles
away, following the April 2, 1956 storm. Another government bond and eight
$100 bills were found intact many miles away in an envelope bearing an El
Dorado, Kans., address, following the tornado of June 10, 1958. On April 3,
1956, a package of knitting products from a wrecked Berlin, Wis., mill was
recovered undisturbed 35 miles northward; a package of papers was found 75
miles to the north-northeast and a carton of deer hides was recovered 60 miles
northeastward. Debris from the Hickman Mills, Mo., tornado of May 20, 1957,
was found 180 miles distant. A jar of fruit was reported to have been carried
a long distance from Wilkes Barre, Pa., on August 19, 1890, and when found was
undamaged, except for the porcelain lining of the cover.
There are a number of instances on record of human beings and animals
being whisked up from the ground and carried through the air for varying
distances. A farmer was picked up, carried 150 yards, and put down without
serious injury on May 12, 1896, at Elkhorn, Nebr. During the tri-State
tornado of March 18, 1925, 16 pupils were blown 150 yards into a field from a
country school amd none were killed. On April 9, 1947, as a man opened the door
of his home near Higgins, Tex., the door was torn loose from his grip and he
was picked up by the wind and carried for 200 feet over the tree tops.
2
-------
„ „ u I iQ«;n -in Pennsylvania a woman was carried 30 feet; on July 6,
Sj TS: d ;8 Minn. ^farmer was lifted 40 feet and dropped to the ground
1954, a Hard g, on M 3> 1958, a man was carried 50 feet,
unhurt; at Co ns Q ^ t St Martin, Minn., on June 4, 1958. Also
and another was carried 100 teet ^ ^ ^ a ^
during the torna ^ ^ begide her was found a broken record
through a window, n automobile with 2 passengers was carried 100
feet**and dropped side up without injury to the passengers on April U,
1955, near Lanark, 111-
t. kppn damaaed and derailed by the wind force
Railroad ™1une 22, 1919. the Great Northern
during the passage of ^ ^ m p>h^ when the tornado at Fergus
Limited was traveling gage car behind the tender, throwing 7 of the
Falls, Minn., struck th gg . car was torn from the train and set
11 coaches from the ra . right angles. The tornado of May 27,
down about 30 feet from e d the Great Northern Railroad track, strik-
1931, at Moorehead, Mi angles. One 83-ton train coach with 117
ing the "Empire tfce rails, carried through the air, and laid in
passengers was littea i death resulting when a passenger was
a ditch 80 feet away, wit 1957. on November 10, 1915,
passage of a hurricane in ax d & dresser was splintered, but its
during the Great Bend, ^J8;' and set down unbroken against a fence. At
mirror was carried some ®18C* 1919> a buffet was moved 2 feet from the
Fergus Falls, Minn., on June * , all other furniture was in splinters and
wall without breaking a dJstl» unsafe to enter. A similar story is told
the house so badly damaged, scattered the roof and parts ot a Shreveport,
of the February 1950 tor"°a feut left the floor intact on which was a china
La., home over a half-mil® ' oketl An incident of* the Gainesville, Ga.,
closet filled with dishes, non smaU boyg who ruahe4 the
storm of April 6, 1936, was t ^ the storm's roar approached. The
front steps of their home in t away> leaving oniy the front steps ana the
house and all foundations JCharmed. An awesome story is told about a boy
little boys frightened but unnarm^ 8ticks protrtding from his chest after
who wa& found with a dozenjplij june lQ> l958.
the El Dorado, Kans., tornado 01
f several tornadoes striking the same area
There have been incidences 0 ^ Austin, TX., on May 4, 1922, two at
within a short space of ldwyn Miss., on March 16, 1942, two 25 minntes
a 30-minute interval, andatBa tornado occurred on April 9, 1947,
apart. In Ellis Cofty*^do'passed over the same area. Dae to the extensive
and on May 31, another
-------
destruction resulting from the first storm, further damage from the second
was negligile as very little was left to destroy. The town of Codell, Kans.,
was struck in three successive years, 1916, 1917, and 1918, and each time on
May 20 and at about the same hour of the day.
In some instances damage by tornadoes may result at treetop or housetop
levels, indicating that the cloud did not completely reach the earth's
surface. This characteristic was very noticeable in two great tornadoes, one
at Louisville, Ky., on March 27, 1890, and the other at St. Louis, Mo., on
May 27, 1896. In the majority of cases damage was confined to upper floors,
and most wrecked buildings owed their destruction to the collapsing of their
walls from the weight of debris of ruined upper levels. At St. Louis, nearly
all trees in Lafayette Park were broken and twisted off at an elevation of
about 30 feet. Reports of more recent years show the concentration of damages
above the ground level in the following tornadoes:
April 16, 1954 - Ft. Valley, Ga.- $2,000 damage at rooftop level.
May 10, 1954 - East Hartland, Conn. - $1,000 damage at treetop levels.
June 20, 1954 - Grand Island, Nebr. - $3,000 damage to upper parts of
higher buildings.
July 19, 1954 - Kingsland, Ark. - $1,000 damage to tops of houses.
July 12, 1955 - Terrytown, Nebr. - Damage (not estimated) to roofs and
treetops.
February 25, 1956 - Cedarville, Ohio - Overhead at elevation sufficient
to tear roofs from houses, damage $250,000.
July 21, 1956 - Collinsville, Okla. - Slight damage as'funnel reached to
100 feet of ground.
April 22, 1957 - Kingfisher, Okla. - passed just above ground, damage
$100,000.
May 12, 1957 - Carnegie, Okla. - slight damage and funnel reached to
rooftop level.
June 12, 1957 - Tuscola, 111. - slight damage at treetop level.
July 1, 1957 - Tulsa, Olka. - dipped to treetop level, damage $20,000.
August 14, 1957 - Hanson, Okla. - about 20 feet above ground, no estimate
of damage.
July 29, 1958 - Worcester to Shrewsberry, Mass. - slight damage at
treetop level.
4
-------
APPENDIX 7. DESCRIPTION OF AIRCRAFT ACCIDENT CALCULATION
-------
APPENDIX 7.
This appendix presents an explanation of the methods,
assumptions, input data and probability model used to assess
the risk of Henderson County Airport flight operations to the
Unison PCB separation facility. Methods employed to assess
this risk were developed by Sandia National Laboratories, a
specialist in the aircraft accident probability field. Sandia
has produced aircraft crash probability models for risk analyses
on a variety of facilities, including weapons storage and assem-
bly areas (U.S. Navy 1985; Smith 1983) and nuclear power gen-
erating plants (Solomon 1975).
The model used in this analysis was taken from a study conducted
by the U.S. Navy to analyze the statistical probability that an
aircraft operating from the St. Mary, Ga., Airport could crash into
a ballistic missile assembly and storage facility at the King's
Bay Nuclear Submarine Base (U.S. Navy 1985). This model was
chosen due to the following similarities between the St. Marys
Airport and the Henderson County Airports
1. Both are general aviation airports.
2. There is no commercial air traffic at either airport.
3. Both are open to the public.
4. Both lack a control tower.
5. Both have only one runway.
6. Runway lengths are comparable (5000' and 4800').
While the Henderson County Airport has more flight operations
per year than the St. Marys Airport, this difference is accounted
for in the probability model.
The probability model used in this analysis is of the forms
P= Ax[Nmx5(10"6)e~r/1,6e"e/12 + NT x5.3 (1CT7)e"1"/1 ¦ 6e~e/22 •23
r r
where
P = The probability per year of an aircraft crash into a selected
structure.
A = The effective plant area (in square miles).
N
-------
Aak accounts for an aircraft crashing in front of a building and
bouncing or skidding into it. A typical skid distance of 300
feet was used (Cornell, 1973). For a building of width a,
ASk * a x 300.
The Unison facility does not have a rectangular profile, due
to the refractory column extending through the roof of the process
building. Therefore, it was necessary to divide the building
into 3 rectangular sections (see Figure 5.2.4.1), compute the
probability of a crash into each section, then sum those probabilities
to obtain overall risk. See Table 5.2.1.4 for effective plant
areas for the 3 parts of the Unison facility.
Nt and Nl were based on the number of operations at the Henderson
County Airport for 1985. In the Henderson County airport 10 year
plan (1975 - 1985), it was estimated that there would be about
35,000 operations at the airport in 1985. However, there were
only 22,000 actual operations in 1985. The new 10 year plan for
the airport has not been submitted at this time, so that figure
was used as a basis for determining N
-------
TABLE 5.2.4.1
crash
Building Division r 0 A probability
1 1.0 mi 14° 4.22 x 10-4 mi2 2.27 x 10~6
2 1.0 mi 140 1.03 x 10-3 rai2 5.50 x 10~6
3 1.0 mi 11° 1.03 x 10-3 mi2 5.50 x 10"6
Total Crash Probability 1.33 x 10-5
FIGURE 5.2.4.1
This is a schematic of the profile of the Unison facility relative to
the direction from which a plgne would approach on either takeoff or
landing. The dashed lines indicate the division of the building into
three rectangles for modelling purposes. All dimensions are In feet.
V0
1
*0
tiO
-------
AIRCRAFT ACCIDENTS, ACCIDENT RATES, AND FATALITIES—
U.S. AIR CARRIER ALL OPERATIONS: 1971-1980*
Year
Number of Accidents
Aircraft
Miles Flown
(000)a
Acciden
Per Mi
Aircraft M
t Rate
llion
I.ES Ft OWN
Fatai itifs
Total
Fatal
Total
Accidents
Fatal
Accidents
Total
Passengers
Crew and
Others
1971
1972
1973
1971
1975(c:
1976
1977
1978
1979(0)
1980
18
50
13
17
15
28
26
21
32(R)
20
8(b)
8
9
9
3
1
5
6
6
2
2,660,731
2,619,013
2,616,669
2,161,295
2,177,761
2,568,113
2,681,072
2,712,860
2,899,131
3,035,600
0-018
0-019
0-016
0-019
0-018
0-011
0-010
0-009
0-011
0-007
0-002
0-003
0-003
0-003
0-001
0-002
0-002
0.002
0-002
0.001
203
190
227
167
121
15
656
163
355(R)
11
171
160
200
121
113
39
382
111
323(R)
11
29
30
27
16
11
6
271
22
32
3
(a) NoNREVENUE MILES OF THE SUPPLEMENTAL AIR CARRIERS ARE NOT REPORTED'
(b) Includes midair collision accidents nonfatal to air carrier occupants- Number of
ACCIDENTS EXCLUDED FROM FATAL ACCIDENT RATES (1971*2).
(c) Beginning in 1975, figures include accidents involving commercial operators of large
aircraft-
Co) Beginning in 1979, figures include accidents involving deregulated all cargo carriers-
(R) Revised
Preliminary
NOTE: Sabotage accident (9/8/74) is included in all computations except rates- In 1977,
Fatalities (Other) includes 218 on aircraft of foreign registry.
SOURCE: National Transportation Safety Board-
1981-1984 data not available at time of publication by EPA.
-------
AIRCRAFT ACCIDENTS, FATALITIES AND ACCIDENT RATES-
U.S. GENERAL AVIATION FLYING: 1971-1980
Year
Accidents
Fatalities
Aircraft
Hours Flown
(000)
Accident Rates
100.000 Aircraft Hours
Total
Fatal
Total
Fatal
1971
4, m
661
1,355
25,512
18.2
2.59
1972
4,256
695(a)
1,426(b)
26,974
15.8
2.57
1973
1,255
723(a)
1,412
29,974
14.2
2.41
1974
4,425
729(a)
1,438
31,413
14.1
2.31
1975
4,237
675(a)
1,345
32,024
13.2
2-10
1976
4,193
695
1,320
33,922
12.3
2-04
1977
4,286
702
1,436
35,792
12.0
1.%
1978r
4,494
793
1,770(8)
39,409
11.4
2.01
1979r
4,051
682
1,382
43,417
9.3
1.57
1980p
3,799
677
1,375
41,300
9.2
1.64
(a) Suicide/sabotage accidents are included in all computations except for
rates <1970-1, 1972-3, 1973-2, 1974-2, 1975-2, 1976-4, 1977-1).
(b) Includes air carrier fatalities (1972-5, 1978-112) when in collision
WITH GENERAL AVIATION AIRCRAFT'
SOURCE: National Transportation Safety Board.
p - Preliminary-
r - Revised*
-------
COMPARATIVE ACCIDENT DATA: 1970 THROUGH 1979
(PASSENGER FATALITIES PER 100 MILLION PASSENGER-MILES)
Year
Passenger
Automobiles
and Taxis
Buses
Railroad
Passenger
Trains
Domestic
Scheduled
Air Transport
Planes
1970
2.10
.19
.09
•00
1971
1.90
.19
.24
.15
1972
1.90
.19
.53
.13
1973
1.70
.24
.07
.10
1974
1.50
.21
.07
.12
1975
1.10
.15
.08
.08
1976
1.34
.17
.05
.003
1977
1.33
.13
•04(r)
.04
1978
1.30
.17
.13
.01
1979
1.31
.15
.05
.12
Source: Motor Vehicle (automoviles, taxis,, and buses) and railroad
PASSENGER TRAIN DATA FROM THE NATIONAL SAFETY COUNCIL- DOMESTIC
SCHEDULED AIR TRANSPORT DATA FROM THE NATIONAL TRANSPORTATION
Safety Board.
(r): Revised
-------
APPENDIX 8. EVANSVILLE GROUP QUARTERS
-------
GROUP QUARTERS POPULATION FOR 1985
Institution/Address
Alpha Omega Psi
Lower Mt. Vernon Road
Bethel Sanitarium
6015 Kratzville Road
Braun's Nursing Home
909 First Avenue
Brentwood Convalescent Center
30 E. Chandler Avenue
Christ the King Rectory
3109 Bayard Park Drive
Christian Home
1615 N. Fulton Avenue
City-County Jail
Civic Center Complex
Columbia Health Care facility
1100 N. Read Street
Columbia Nursing Plaza
621 W. Columbia Street
Corpus Christi Rectory
5528 Hogue Road
Daughters of Charity
9400 New Harmony Road
Evansville Healthcare Center
4301 Washington Avenue
Evansville Protestant Home
3701 Washington Avenue
Evansville State Hospital
3200 Lincoln Avenue
Gertha's Nursing Center
617 Oakley Street
Good Samaritan Home
601 N. Boeke Road
Census Tract
104.01
39
26
16
5
27
18
25
20
104.1
105
37.02
37.02
37.01
20
2.02
Population
3
64
55
28
closed
208
25
128
20
118
137
535
152
112
-------
Page 2
Ins titut ion/Address
Hillcrest Washington Home
2700 W. Indiana, P.O. Box 6347
Holiday Home Healthcare Community
1201 Buena Vista Road
Holy Redeemer Convent
924 W. Mill Road
Holy Redeemer Rectory
918 W. Mill Road
Holy Spirit Convent and Christ the
King Convent - 1760 S. Lodge
Holy Spirit Rectory
1800 S. Lodge Avenue
Lambda Chi Alpha
213 S. Weinbach Avenue
Little Sisters of the Poor
1236 Lincoln Avenue
Mater Dei Sister's Residence
1300 Harmony Road
McCurdy Residential Center
101 S.E. First Street
Medco North
650 Fairway
Memorial High School Faculty Residence
1500 Lincoln Avenue
Memorial High School Convent
1640 Lincoln Avenue
Monastery of St. Clare
6825 Nurrenbern Road
Normal Life Group Homes
1016 S. Weinbach Avenue
Parkview Convalescent Center
2819 N. St. Joseph Avenue
Phi Kappa Tau
2112 Lincoln Avenue
Census Tract
30
39
39
39
10
10
Population
43
202
14
30
18
33
3
3
104.02
10 Locations
28
1
47
138
11
257
136
6
8
23
70
95
18
-------
Page 3
Institution/Address
Smith Healthcare, Inc., dba
Pinehaven Nursing Home
3400 Stocker
Regina Pacis Home
3900 Washington Avenue
Res-Care Community Alternatives
862-A S. Green River Road
Sacred Heart Rectory
2701 W. Franklin Street
St. Agnes Convent
1626 Clendale Avenue
St. Agnes Rectory
1600 Clendale Avenue
St. Anthony Convent
718 First Avenue
St. Anthony Rectory
704 First Avenue
St. Benedict Convent
1328 Lincoln Avenue
St. Benedict Rectory
1312 Lincoln avenue
St. John Rectory
617 Belleraeade Avenue
St. Joseph Convent
618 E. Virginia Street
St. Joseph Rectory
600 E. Virginia Street
St. Mary Rectory
609 Cherry Street
St. Theresa Convent
725 Wedeking
St. Theresa Rectory
600 Herndon
Census Tract
30
37.01
7 Locations
30
31
31
19
19
14
14
15
21
21
16
24
24
Population
93
124
53
3
2
3
9
4
1
-------
Page 4
Institution/Address
St. Vincent Day Care Center
611 First Avenue
Second Chance Halfway House
3901 Kratzville Road
Seton Manor
800 St. Mary's Drive
Siena Hall
2735 1/2 W. Franklin Street
Sigma Alpha Cpsilon
1732 Lincoln Avenue
Sigma Phi Epsilon
1332 Lincoln Avenue
Tau Kappa Epsilon
1119 Lincoln Avenue
Tau Kappa Epsilon
317 N. Wabash
University of Evansville
1700 Lincoln Avenue
P.O. Box 329
Welborn Hospital Medical Center
500 S.E. Fourth Street
Woodbridge Health Care Center
815 Second Avenue
Census Tract
19
Population
7
39
68
37.01
54
30
14
15
15
15
28
950
16
closed
16
56
TOTAL (S) 4156
-------
APPENDIX 9. OHIO RIVER PCB CONCENTRATIONS IN FISH
-------
1983 ORSANOO OHIO Ki'/i:* FISH SURVEY
CHANNEL CATFISH FILf.^rs
Tagf
#1 Sitp
Date
Caught
L.
(cm)
1 W. | %
nongahela R.
9/7/83
47
1.13
9.30
4.46|
63tftononqaiieia R.
9/7/83
41
0.85
0.74
1.03
64|fK>nongahela R.
9/7/83
34
0.31
4.20
0.95
65|Allegheny R.
9/8/83
41
0.62
12.56
2.63
70JAllegheny ft.
9/8/83 137
0.39
6.74
1.11
71|Allegheny R.
9/8/83
38
0.45
5.74
0.71
56|llafiiiield
9/9/83
41
0.57
11.26
2.45
Dashield
9/9/83
44
0.65
1.78
0.97
54
Dashieltl
9/9/83
43
0.76
5.64
3.43
~J'l
New G»«lx?rland
9/20/83
41
0.62
4.96
1.68
445
•< JjJ |
New curt >er land
9/20/83
42
0.65
2.22
0*30
44c
New Cumberland
9/20/83
37
0.60
6.80
1.66
215
Pike Island
9/21/83
38
0.60
6.34
1.79
213
Pike Island
9/21/83
44
6.71
6.20
2.58
214
Pike Island
9/21/83
50
1.22
11.6
2.59
16
Hannibal i
8/19/83
39
0.62
0.76
0.65
19
llanmlwl
8/19/83
44
0.91
5.78
1.30
33
Hannibal
8/19/83
43
OM
10.0
2.30
400
Willow Isl.
9/22/83
44
1.11
6.36
1.90
399
WtlUjurlsl.
9/22/83
57
2.04
11.8
3.57
395
wi I low Isl.
9/22/83
55
1.79
10.48
1.34
LKWM"
Big sarply R.
Oct 15
43.9
.n
0.18
0.10
1 KWP-5
Piii Randy R.
Oct 15
31.8
0.22
0.70
0.17
KWP-6
1*;
53.4
1.90
9.02
2.05
461
G»H •JfV'iis
KV6/83
33
0.31
3.76
0.67
462|<1 H i ipolis
lO'C/83
47
1.05
16.48
1.88
403joilJ ipolis
10/6/8 i
50 j
1-525J
S.no
r ii
am ft! If
Taq|
Da to ) L.
W. | %
(m*0
1 j Si to
Ciu}iit ] (cm)
(kg)i Fat
PCB
199|r-Vjl.lil»l
9/27/83j61
2.55
0.92
3.02
200|Holdihl
1/2 7/83
47
1.02
6.82
1.45
201
9/27/83
34
0.37
8.12
0.49
JPI! 5**jLicking R.
Oct 19*
48.8
1.27
1.54
0.90
JPH 6 ji,ieking R.
(3c t 19
42.2
0.80
4.06
3.43
3TX)|M;:Alpiue
9/29/83
53
1.03
6.28
2.55
304 |Mc Alpine
9/29/83
41
0.55
0.82
.55
305|mca!pine
9/29/83
48
1.16
1.36
2.50
SS 4
Ohio R.
Oct 19*
58.4
2.58
7.16
1.65
SS 5
West Pt.
Oct 19
49.3
1.23
5.20
2.54
SS 6
(Mile 628)
Oct 19
45.7
1.08
6.88
2.17
DEB 4**
Green R.
Nov 22*
38.7
0.74
2.98
0.43
306
Un iontown
10/4/83
53
1.38
5.92
3.75
307
llniontown
10/4/83
49
1.37
7.80
1.84
308*
Uninntown
10/4/83
45
0.83
1.86
.41
Spoonbill 0
Uniontown
10/4/83
42
0.21
4.58
.22
315
omithland
10/5/83j50
1.29
7.46
.87
J16|SmU hland |10/5/83|44
1.09
7.30
1.72
317|Smithland j 10/5/83 j 39
0.73
5.06
.69
t
* Blue Catfish
** Flathead Citfish
0 Whole Fish
T (Trace) - thsn 0.01 ppm.
-------
198* ORSANCO OI1IO U - 9 i SURVEY
GAHP FILLETS
Tag
Date
L.
w. -
%
la R.
9/7/83
3 i
0.76
1.26
0.27
(Pcun) 76*
Allegim:y P.
9/8/83
34
0.58
3.36
0.97
72
Alleglx-ny
9/8/83
39
0.74
0.74
0.18
69
Dasliiei *
9/9/83
42
0.82
1.00
1.24
67
Dishioi?
9/9/83
44
1.13
0.70
1.07
57
Dashiel-i
)/9/83
37
0.68
0.84
0.36
431
New Cunwv-rle
720/83
39
0.48
2.32
0.70
432
New Cimv^ei I.-.:.
•/20/83
41
0.48
0.84
0.36
441
New Curt-or1 ¦
'/21/83
42
0.96
3.58
0.26
21!
Pik'"i I.'iU;
J/21/83
43
0.85
0.74
0.26
32
limn i I vi L
i/19/83
44
1.08
2.26
0.33
34
II inniha!
0/19/83
44
1.15
6.28
0.76
35
innnilvi j
5/19/03
43
1.05
2.36
0.45
390
Willow Isl.
9/22/83
51
1.84
3.38
0.43
394
Willow Isl.
9/22/83
46
1.45
8.28
1.15
393
Willow Isl.
9/22/83
50
1.19
1.80
.41
KWP-1
Hiq Sandy R.
Oct 15
55.9
2.22
6.98
0.65
KWP-2
Hig Sandy R.
Oct 15*
56.6
2.25
2.42
0.34
KW-3
Big Smdy R.
Oct 15
54.6
2.06
2.86
0.25
464
Gil1ipolis
10/6/83
51
2.04
8.46
1.85
460
tjal 1 ipol is
10/6/83
57
2.78
3.92
0.85
401
ItelloviIle
10/2/83
50
1.90
7.34
1.92
402
Oellevi1le
10/2/83
48
1.62
5.26
1.55
403
Belleville
10/2/83
46
1.22
1.24
0.23
413
Racine
10/4/83
53
2.01
9.98
2.46
414
Racine
10/4/83
55
1.90
1.54
0.63
415
Racine
10/4/83
48
1.28
1.60
0.38
191
ftei'ialil
9/27/83
52
1.79
1.2
0.34
195
B?ld »lil
9/27/83
51
1.70
0.48
0.16
190
tteldihl
9/27/83
48
1.59
0.98
0.33
Tag
<
- -1
Site
Oate
Ought
L.
(cm)
W.
(kg)
%
Fat
PCB |
JPH
1
Licking R.
oci l-:*
48.3
1.50
0.42
0.13|
JPH
2
Licking R.
45.5
1.38
2.00
0.11|
JPH
3*
Licking R.
Oct
39.9
0.95
0.52
0.58 J
JPH
4*
Licking R.
i'.i'.'l :T-
36.1
0.66
0.70
0.1-1/
301
McAlpine
1 > . 4
56
3.11
1.06,
0.4.?/
302
McAlpine
9/i 3
50
1.83
0.90
.17|
303
McAlpine
9.-/.... 3
56
2.99
0.44
. 12\
SS
1
Ohio R.
<
48.3
1.60
B.OO
0.67 \
SS
2
West pt:.
44.7
1.13
3.6A
0.2«\
SS
3
(Mile (>.?B)
C..
45.0
L .32
3.60
0.4O|
DEN
1
Green R.
p *
54.6
2.23
6.40
1.3B|
DEB
*>
Mi lo 12)
Nov
53.3
1.90
1.60
0.281
DEB
3
Mile 4;m
N
46.5
1.30
1.82
0.2flj
309
ihiionLiHvn
*0/4/63
46
1.34
0.24
.ooj
310
Uniontown
10/4/63
50
1.70
0.1C
.07 j
311
IJni'iit own
10/4/83
51
1.62
0.16
.071
312
Smitlil •)!»]
IC/5/13
55
2.09
0.5C
. 121
313
SmiLhl.mil
1D/S/83
56
2.14
1.66
1.701
314
Smi till ami
10/5/83
46
0.94
O.Ofl
.05!
RJ
1
Tenn. R.
v ••
55.9
2.34
3.44
0.311
RJ
2
Mile 2 -5
'_A- .
39.4
.78
1. 3€
0.08 j
RJ
3**
Mile 2-5
39.4
0.74
1.18
0.24 j
T (Trace) - Les.3 than 0.01 ,'pn-.
* B. M. Buffalo
** River Carpsnckor
-------
APPENDIX 10. LOCAL ACCIDENT CHANCES AND EXPECTATIONS
-------
UNISON Project, Local Traffic Accident Analysts
Kentucky Accident Data
Start of Reporting Period = 01/01/80
End of Reporting Period = 02/28/86
Years in Reporting Period = 6.1629
Road Number of
Segment or Reported
intersection Accidents
Route 136 3
Route 425 11
Pen. Pl.y. So. to Co. Ln. 107
Pen. Ply. No. toRt. 41 141
fit. 41, Pen. Pky. to Barrett 123
Rt. 41, Barrett to Barter 295
Rt. 41, Barker to Rt. 414 368
Rt. 41, Rt.414to1nd. Line 321
Total, HendersonCouhty 1,369
South lane 16
Riverside .19
Covert 25
Washington 38
Bellemeade 12
Lincoln 19
Walnut 40
Virginia 52
Columbia 43
Morgan 33
Non~ Inter section (« 5%) 15
Total, Evansville 312
Indiana Accident Data
Start of Reporting Period = 01/01/8
End of Reporting Period = 03/31/86
Years in Reporting Period = 1.2457
Average
Daily
Annual
Annual
Vehicle
Vehicle
Accidents
Count
Count
0.49
300
109, 575
16.50
2,500
913,125
17.36
6,248
2,282,Ot-2
-22.88
8, 190
2,991,3y8
19.96
20,803
7,598,296
47.87
35,227
12,866,66?
59.71
30,783
1 1 ,243,491
52.09
32,689
11,939,657
222.14
12.84
26,684
9,746,331
15.25
26,684
9,746.371
20.07
26,199
9,569, If-5
30.50
26,199
9,569,185
9.63
26,199
9,569,185
15.25
36,692
13,401,753
32. 11
36,692
13,401,753
41.74
34,628
12,647,*77
34.52
34,628
12,647,>J77
26.49
45,591
16 $52, 1 17
11 .92
32,020
1 1 ,695, 1 r-9
250.34
-------
Annual Trips
Common
North
South
Estimated Values:
TF-1
1,540
1,260.7
279.3
Traffic counts, Rt. 136
TF-X
1,570
1,285.3
284.7
arid Rt.
4
TF-2
45
45.0
0.0
Accident Rate, Ev^nsville
Residues
74
59.2
14.8
non-intersections
Road-
Annual Acc idents Expected
Segment m
Intersection
TF-1
TF-X
TF-2
Residues
Drums
Tankers
T r u <; k s
Route 136
0.00684
0.00697
0.00020
0.00033
0.01362
0.00053
0.014 34
Route 425
0.02783
0.02837
0.00081
0.00134
0.05620
0.00215
0.05835
P*n. **i y. So. to Co. Ln.
0.00212
0.00217
0.00000
0.00011
0.00429
0.00011
0.0044"
Pen. Ply. No. toRt. 41
0.00964
0.00983
0.00034
0.00045
0.01947
0.00080
0.02027
ft. 41, Pen. Plcy. to Barrett
0.00331
0.00338
0.00012
0.00016
0.00669
0.00027
0.00696
Rt. 41, Bar rett to Barker
0.00469
0.00478
0.00017
0.00022
0.00947
0.00039
0.00986
Rt. 4J, Barker toRt. 414
0.00670
0.00683
0.00024
0.00031
0.01352
0.00055
o.O1407
Rt. 41, Rt.4.14 to Ind. Line
0.00550
0.00561
0.00020
0.00026
0.01111
0.00045
0.01 1 Si •
Total, Hender son County
0.06663
0.06793
0.00208
0.00318
0.13456
0.00526
0. 1398.:
South! a ne
0.00166
0.00169
0.00006
0.00008
0.00336
0.00014
0.0034•)
Riverside
0.00197
0.00201
0.00007
0.00009
0.00398
0.00016
0.004 i5
Covert
0.00264
0.00270
0.00009
0.00012
0.00534
0.00022
0.0055'
Washington
0.00402
0.00410
0.00014
0.00019
0.00812
0.00033
0.0084
Bellemeade
0.00127
0.00129
0.00005
0.00006
0.00256
0.00010
O.00267
Lincoln
0.00143
0.00146
0.00005
0.00007
0.00290
0.00* J12
0.00302
Walnut
0.00302
0.00308
0.00011
0.00014
0.00610
0.00025
0.006 55
Virginia
0.00416
0.00424
0.00015
0.00020
0.00840
0.00O34
O.0O875
Columbia
0.00344
0.00351
0.00012
0.00016
0.00695
0.00O28
i >. 0072
Morgan
0.00201
0.00204
0.00007
0.00009
0.00405
0.00017
o.004/
Won- Inter s'settdrt (+5*)
0.00129
0.00131
0.00005
0.00006
0.00260
0.00011
0. 0027<1
Total, EVansville
0.02691
0.02744
0.00096
0.00126
0.0543532
0.0022245 C
>.<>505777
I ©t a\ *W»suc ed
0.09355
0.09537
0.00304
0.00444
0.16892
0.0074 P.
0.19640
-------
Road
Accidents Expected Over Twenty Years
Segment or
Intersection
TF-t
TF-X
TF-2
Residues
Drums
Tankers
Tr ucks
Route 136
0.13683
0.13949
0.00400
0.00657
0.27632
0.01057
0.2866y
Route 425
0.55655
0.56739
0.01626
0.02674
1.12394
0.04301
1.16695
Pen. Pky. So. to Co. Ln.
0.04250
0.04332
0.00000
0.00225
0.08582
0.00225
0.08807
Pen. Pky. No. to Rt. 41
0.19284
0.19660
0.00688
0.00906
0.38945
0.01594
0.4053V
Rt. 41, Pen. Pky. to Barrett
0.06623
0.06752
O.OOZ36
0.00311
0.13375
0.00547
0. 1392.:
Rt. 4 f, Bar r ett to Ba rk er
0.09380
0.09563
0.00335
0.00440
0.18943
0.00775
0. 1971 >i
Rt. 4\, Barkef to Rt. 414
0.13591
0.13652
0.00478
0.00629
0.27043
0.01107
0. i'8149
Rt. 41, Rt.414 to Inch Line
0.10999
0.11214
0.00393
0.00517
0.22213
0.00909
0.23123
Total, Henderson county
1.33265
1.35862
0.04156
0.06359
2.69127
0.10516
2.7964 7.
South lane
0.03323
0.03388
0.00119
0.00156
0.06710
0.00275
0.06985
Riverside
0.03946
0.04023
0.00141
0.00185
0.07969
0.00326
0.08295
Ccrvert
0.05288
0.05391
0.00189
0.00248
0.10679
0.00437
0.11116
wasnington
0.08038
0.08195
0.00287
0.00377
0.16232
0.00664
0.16897
Belfemeatfe
0.02538
0.02588
0.00091
0.00119
0.05126
0.00210
0.05336
Lincoln
0.02870
0.02926
0.00102
0.00135
0.05795
0.00237
0.0603?
walnut
0.06041
0.06159
0.00216
0.00284
0.12200
0.00499
0.12700
Virginia
0.08322
0.08484
0.00297
0.00391
0.16806
0.00688
0.17494
Columoia
0.06881
0.-07016
0.00246
0.00323
0.13897
0.00569
0.14466
Morgan
0.04011
0.04089
0.00143
0.00188
0.08101
0.00332
0.08432
Hon-intersection (+52)
0.02570
0.02620
0.00092
0.00121
0.05190
0.00212
0.05407
Total, Evansville
0.53828
0.54878
0.01921
0.02528
1.08706
0.04449
1.1315C
Total Measured
1.87093
1.90741
0.06078
0.08887
3.77834
0.14965
3.9279V
-------
Road
Chance of One or More Accidents in Any Year
Segment or
intersection
TF-1
TF-X
TF-2
Residues
Drums
Tankers
T r uc !¦ s
Route 136
0.00682
0.00695
0.00020
0.00033
0.01372
0.00053
0.01424
Route 425
0.02744
0.02797
0.00081
0.00134
0.0546*5
0.00215
0.05663
Pen. Pky. So. to Co. Ln.
0.00212
0.00216
0.00000
0.00011
0.00423
0.00011
0.004 59
P«n. Ply. No. toRt. 41
0.00960
0.00978
0.00034
0.00045
0.01923
0.00o80
0.02007
Rf« 41, Peh. Pky. to Barrett
0.00331
0.00337
0.00012
0.00016
0.00667
0.0002 i
0.00694
fti. 41, Barrett to Barker
0.00468
0.00477
0.00017
0.00022
0.00943
0.00039
0.00931
Rt* 41, Barker to Rt. 414
0.00667
0.00680
0.00024
0.00031
0.01343
0.00O55
0.01398
m. 41, ftt.414 to Irvcf. Line
0.00548
0.00559
0.00020
0.00026
0.01105
0.0004 5
0.01149
Total, Henderson County
0.06446
0.06568
0.00208
0.00317
0.12590
0.00524
0.13049
Southlane
0.00166
0.00169
0.00006
0.00008
0.00335
0.00014
0.00349
Riverside
0.00197
0.00201
0.00007
0.00009
0.00398
0.00016
0.00414
Ci^fert
0.00264
0.00269
0,00009
0.00012
0.00533
0.00 <,<22
0.00554
Washington
0.00401
0.00409
0.00014
0.00019
0.00803
0.0003?
0.00841
BHlemeade
0.00127
0.00129
0.00005
0.00006
0.00256
0.00010
i'.00266
Lincoln
0.00143
0.00146
0.00005
0.00007
0.00239
0.000 12
0.0030 I
walnut
0.00302
0.00307
0.00011
0.00014
0.00603
0.00025
»).0063'¦
Virginia
0.00415
0.00423
0.00015
0.00020
0.00837
0.00034
i).00871
Columbia
0.00343
0.00350
0.00012
0.00016
0.00692
0. OQi >2 8
O.00721
Morgan
0.00200
0.00204
0.00007
0.00009
0.00404
0.00017
O.00421
Hon- Intersection (+5%)
0.00123
0.00131
0.00005
0.00006
0.00259
0.00O11
i». 0027-1
Total, Evansville
0.02656
0.02707
0.00096
'0.00126
0.05290
0.00222
i1. O^'.O 1
Iota* Measured
0.06930
0.09096
0.00303
0.00443
0.17215
0.0074 5
0.1 78
-------
Road
Segment or
Intersection
Route 136
Route 425
Pen. Pky. So. to Co. Ln.
Pen. Pky. No. to Rt. 41
Rt. 41, Pen. Pky. to Barrett
Rt. 41, Barrett to Barker
Rt. 41, Barker to Rt. 414
Rt. 41, Rt.414 to ind. Line
Total, Henderson County
South lane
Riverside
Covert
Washington
Bellemeade
Lincoln
Walnut
Virginia
Columbia
Morgan
Non-intersection ( +
Total, Evansville
)
Total Measured
Chance of One or More Accidents in Twenty Years
TF-1
TF-X
TF-2
Residues
Drums
Tankers
T r ucks
0.12788
0.13020
0.00399
0.00655
0.24143
0.01052
0.24941
0.42682
0.43300
0.01613
0.02639
0.67501
0.0-4209
0.66869
0.04161
0.04239
0.00000
0.00225
0.08224
0.00225
0.05430
0.1753-3
0.17849
0.00686
0.00901
0.32257
0.01561
0. 3332:5"
0.06408
0.06529
0.00236
0.00311
0.12519
0.00546
0.12997
0.08954
0.09120
0.00334
0.00440
0.17257
0.00772
0.17896
0.12533
0.12761
0.00477
0.00627
0.23695
0.0!101
0.24535
0.10416
0.10608
0.00392
0.00515
0.19919
0.00905
0.20644
0.73622
0.74299
0.04071
0.06161
0.93221
0.09982
0.93897
0.03268
0.03351
0.00119
0.00156
0.06490
0.00274
0.06747
0.03869
0.03943
0.00141
0.00185
0.07659
0.00326
0.07960
0.05151
6.05243
0.00189
0.00248
0.10129
0.00436
0.10521
0.07723
0.07868
0.00286
0.00377
0.14983
0.00662
0.15546
0.02506
0.02555
0.00091
0.00119
0.04997
0.00210
0.05196
0.02829
0.02883
0.00102
0.00135
0.05630
0#00237
0.05854
0.05862
0.05973
0.00215
0.00283
0.11486
0.00498
0.11926
0.07985
0.08134
0.00297
0.00390
0.15470
0.00685
0.16049
0.06650
0-.-06775
0.00245
0.00323
0.12975
0.00567
0.13463
0.03932
0.04007
0.00143
0.00188
0.07781
0.00331
0.08086
0.02537
0.02586
0.00092
0.00121
0.05058
0.00212
0.05259
0.41625
0.42235
0.01903
0.02496
0.66280
0.04352
0.67747
0.84602
0.85154
0.05897
0.08504
0.97714
0.13899
0.98032
-------
APPENDIX 11
SUMMARY TABLE
-------
SUMMARY TABLE
FIRST RECEPTOR
MHMMWI
EVtSMS
expected
CVKTt «
NNMTMM
SECOND RECEPTOR
MMTATI0M
or
Eiraswc
mmacit or
PIRSOMS
TOTAL
0R6ARIC
TOTAL PC0
nETEORLOSICAL
CONDITIONS
noocis
Ttnm
KMS
OF CVfffl
THIRD RECEPTOR
HE Alt
mcrPTOt
POtlUTANI
CONCENTRATION
CONCENTRATION
PROOUCIN6
EXPOSURE
FOURTH RECEPTOR
•MrKr<*Mm
¦IMl
tMr|| r.iw Hi
19
m y «•/•>*
jj uuzi iV*1
(tM'A
KHNTTU'
MNwi
tart*
CmMNMN^I CMhQK
V*«r% *****
iS
«)Uu**
r*Hr«4MB
1
1
I
¦H*1
ini*/.*
<1 «la«/ai*
Vint 2 3t*/t
S«u'
•hmUMmmI2
a«
OteMwtto M
HMars Aorim
MIVMQmim *
sm m'—*
$4*lMv CU*« f
plant
CM*
Mht»
*
osnto'
Vh< 2 3 *.'«
SNM«*Clto»F
POLLUTION*
CHTM
t%t>ra
wevwowe*
M
VIMMI
VM.2S«/t
UMKCImC
ttimrlkiMil
mw mi
i
i
I
¦>
mm-v*
*
VM,25a/i
ttAMfCtetl
IWIWWT
ruuM
M*
Mp>
i
i
f
47I««A>*
ni^n/n1
CUfa C
*»««
1
i
i
i M
-OwHta*
IS
•son-o*
VM, 1 0«v/«
ArM« 6«i*iH*» CkM t
•mm
Oof H »l
Hwa>w A«if
•fMHkMW
<300
IMM/M*
-7 Smte'
VM. f On/i
Aram UAtMt CUm l
AHTMrWi*
It Hiii ili i
Z«r»
I«r.
«M, 1 9u/i
(t»«
VM, I3a/i
*<*•!*« ClM« A
lltnu
ttMrmrOki
«vi|
<300
vf«». ®
>T« •»*
¦ 3w.'»
£(*«••* CUft A
<4Hrv«r Dr««
Kilni'iglori Avi|
-------
1
mr 1m
IMn
UMVW(»Mf»
tan.'
'1 Mi**,.3
'i ii-/«
»*.»•* llinl
PUK CMASM
nun mm
STIfcl WPtAMT
73
Mww(tolMn<
HMn Ami
UMVNOm^H
mm*
SM
<2*1 m/**
VM. 2Sia/»
Mws
KlHrtr Av«g
IMIVMCMpi
ODD
301 h/o1
<10 3 M/«.J
m,i3n/|
n««%ct—f
£££*£
IMIVMC1mp«H
<1000
It* •(/•>*
OHhAi'
VM.2S»/|
UM^ClwF
ANnrTM
mi»«
IkMVWttap
ZSTm*/*1
44 7 |*f/m*
SUM, Clai 0
•Mi Mvatm
Hot
uStlrAMa
1
I
3
<1009
4 »¦»/¦.*
<14 (ll*/**
»*tM» CUM f
if
II
IMaVMCftM»a»
»'
<» ot
VM. i' 5«»/i
Oat* F
mmnmlm
IMIVMftwp
_ 7
fmtpmi >HWi
faiawt
ISS^Tto*
< lIJM'o5
**•4. 3 0 mA
M4fc8rt* CUs* D
IMSC'2
¦SMK srn
WMI MVBTO
mm
IMnMi
IIMVMOniM
c., '
Em—il
2 «0 •«/<•*
VM.^On^i
&t*4Nv CUMlt
Mmv
mmnm^rn
K9wafer •»«»
1
I
1
MOM
M4M*»*
O.H 119/w*
««H j3m/i
iUM»j CU«* f
UMrfiMttofi
'JOtti
!»»«/•»*
<424 «11 Mill
till IH/O,*
»*.iMy I l«u D
¦ WUMMWEMH
Nmt
•MTMrte
I
f
1
<1000
mh''1
< 1 9H 114-rR *
VM. :5n«/»
cirii f
i!
I
J
1
am
IttM/n*
Vnd. 2 " rr*tt
$»rf,0rty '
-------
Summary Table:
Expanded Version
-------
SUMMARY TABLE
INHAIAIION
LXPOSIJRF
MODI 1 S
1XPECfED
I VENI'S IN
TWENTY
YEARS
FIRST RECEPTOR
DURA! ION
or
EXPOSURI
DURATION
OF EVENT
SECOND RECEPTOR
THIRD RECEPTOR
FOURTH RECEPTOR
PI RMI1 no
Rl MASKS
Continu'- is
24 Hour s
Per Day
5f>5 Days
Per Year
Riverport Warehouse
and Docks
Yearly Awi i'.i'
Henderson
C"nimunity College
Yearly Aver.vj*:
Pesideni e
Near Airport
¦<;
>
T
Nearest
Census Tract
i y Av : i>
SPII Lb
INSIDE
PI ANT
iliSUi ftC;--:it"
Dat.i
Hours
Observer Ten
leters Away
Unti- -'irid s it¦ •
Ct"jerver One Hundred
Meters Away
Unu ji>d Ch.iit'.- ;
Observer One
y ilometer Away
Unti- Vunj < *.;!•
observer Three
\ tometers Array
Unt! Wind ( ' i'i
^ « T* . v.
-------
NUMBER OF
PERSONS
NEAR
RECEPTOR
TOTAL
ORGANIC
POLLUTANT
CONCENTRATION
TOTAL PCB
CONCENTRATION
METEORLOGICAL
CONDITIONS
PRODUCING
EXPOSURE
10
82 7 ng./m3
<0.0827 pg/m3
Evansville Compositr
<1000
9.45 ng/m3
<0.00945 pg/m3
Evansville Composite
Unknown
8 48 ng/m3
<0.00846 pg/m^
Evansville Composite
2419
0 56 ng/m3
<0.00058 pg/rr!"'
Evansville Composite
None J
37.1 ug/m3
<1.93 ng/m3
Wind, 2.5 rr./s
Stability Class F
None^
5.64 pg/m3
<293 pg/m ^
Wind, 2.5 m/s
Stability Class F*
<500
201 ng/m3
<10.5 pg/m3
Wind, 2.5 m/s
Stability Class F
<1000
16 6 ng/m3'
<0.86 pg/m3
Wind, 2.5 m/s
Stability Class F
\• -i o c -
-------
POU U! ION*
CON1R0I
I OUIPMfN F
t ah urn
A
insurfic erit
Dat.-
Observer fen
Meter? Away
Ufi Wind ' Kv i' ^
S.'ven
Oh-.^rver One Hundred
Meters Away
Uii Wiiid ' '' i
[ays
Observer One
Kilometer Away
(.In'. Vy I'ni < III!
Observer Three
Kilometers Away
Urr Wind • i. i
PI AN* ( RASH
PARI ONI
INIIIA1 J MP AC I
! • !>»"' »
Vver.il
be ends
Observer T. t III; .
PI A HI (RASH
PARI 1 WO
FUtl 1 IRE
0.o0',">.5
Five
Mi'iutes
Observer Ten
Meters Away
AT'..i
Observer One Hundred
Meters Away
.•Vth
Observer One
Kilometer Away
i qlu N;'>.:U
Observer Three
Kilometers Awry
l-n flinut'.-i
PLANE CRASH
PART 'THREE
5PII.L IN PLAN!
0.00'>3
72
Hours
Observer Ten
Meter s Away
Unl , Wind '-tifiH'je'j
Observer One Hundred
Meters Away
Um;i Wi r-d 1 hdi-oes
Observer One
Kilometer Away
Uri! i Wind Chai.qes
Observer Three
Kilometers Away
Ur»t 1 Wind Changes
-------
30
not modeled
not modeled
Wind, 2.5 m/s
Stability Class E
30
15.6 pg/m3
<311 pg/m3
Wind, 2.5 m/s
Stability Class E
<500
471 ng/m3
<9.42 pg/m3
Wind. 2.5 m/s
Stability Class E
< 1000
*
88.2 ng/m ^
< 1.76 pg/m3
Wind. 2.5 m/s
Stability Class E'
30
Zero
Zero
Wind, 1.0 m/s
Army Stability Class 1
30
149 pg/m 3
<3 0 pg/m3
Wind, 1 .0 m/s
Army Stability Class 1
<500
376 pg/m3
<7.5 pg/m3
Wind, 1 0 nv's
Army Stability Class 1
<1000
37.8 pg/m^
<756 pg/m 3
Wind, 1.0 m/s
Army Stability Class 1
30
Zero
Zero
Wind. 1 5 m/s
Stabilty Class A
30
Zero
Zero
Wind, 1 .5 m/s
Stabilty Class A
<500
406 ng/m3
374 ng/m3
Wind, 1.5 m/s
Stabilty Class A
<1000
103 ng/m3
95 ng/m 3
Wind, 1.5 m/s
Stabilty Class a
i
None "
37.1 pg/m3
< 1.93 ng/m*'
Wind, 2.5 m/s
Stability Class F
None'
5.64 pg/m3-
<293 pg/m 3
Wind, 2 .5 m/s
Stability Class F
<500
201 ng/m3
<10.5 pg/m3
Wind. 2.5 m/s
Stability Class F
\ <\000
16.6 ng/m°
<0.86 pg-'m3
Wind, 2.5 m/s
Stability Class F
-------
1
Kilometers Away
unui wino cnanges
MAXIMUM11 J
RESIDUE SPILL 1 «o.o?4
ON HOT PAVEMENT 1
Observer Ten
Meters Away
Urtf.il Wind Changes
One
Observer One Hundred
Meters Away
Until Wind Changes
Hour
Observer One
Kilometer Away
Until Wind Changes
Observer Three
Kilometers Away
Until Wind Change:•
LARGE12 I
RESIDUE SPILL 1 <0074
ON HOT PAVEMENT I
One
Hour
Observer Ten
Meters Away
Until Wind Changes
Observer One Hundred
Meters Away
Until Wind Changes
Observer One
Kilometer Away
Until Wind Changes
Observer Three
Kilometers Away
Until Wind Changes
MAXIMUM13 I
RESIDUE SPILL J «o.il
ON WARM PAVEMENT
One
Hour
Observer Ten
Meters Away
Until Wind Changes
Observer One Hundred
Meters Away
Until Wind Changes
Observer One
Kilometer Away
Until Wind Changes
1
Observer Three
Kilometers Away
Until Wind Changes
-------
<1000
16.6 ng/m°
<0 .86 pg/m3
Stability Class F
Emergency Response'
Personnel
257 mg/m 3
<819 ug/m3
Wind. 5 .0 m/s
Stability Class D
Emergency Response'
Personnel
20.3 mg/m3
<64.7 pg/m3
Wind, 5 0 m./s
Stability Class D
<1000
4.38 mg/m3
< 14.0 pg/m ^
Wind. 2.5 m/s
Stability Class F
<2000
961 ug/m3
<3 06 pg/nf*
Wind, 2 5 m/s
Stability Class F
Emergency Response7
Personnel
35 .5 mg/m 3
< 113 ug/m3
Wind, 5.0 m/s
Stability Class D
7
Emergency Response
Per sonnel
2 80 mg/m 3
< 8.93 pg/mJ
Wind. 5.0 m/s
Stability Class D
<1000
604 ug/m 3
< 1.93 ug/m3
Wind, 2.5 m/s
Stability Class F
<2000
133 ug/m 3
<424 ng/m 3
Wind. 2 5 m/s
Stability Class F
Emergency Response7
/Personnel
48.6 mg/m 3
< 92.5 ug/m3
Wind, 5.0 m/s
Stability Class D
Emergency Response'
Personnel
3.84 mg/m3
<7.31 ug/m3
Wind, 5.0 m/s
Stability Class D
<1000
828 ug/m 3
< 1.58 pg/m 3
Wind, 2.5 m/s
Stability Class F
<2000
182 ug/m 3
< 346 ng/m 3
Wind, 2.5 m/s
Stability Class F
-------
i:\-
f « n
r-> 4-,¦* 2
6-)- M
Notes:
1. Assumes 40O lb/yr total organics; see S 5.1.1.
2. Remote.
5. Assumes plant personnel are evacuated.
4. Impossible if UNISON follows proposed protocols.
5. 401 square meters covered by spill e 60"C, spill assumed not to cool.
6. Smoke and soot associated emmissions only.
7. Until area is cleared, may include innocent by-standers.
8. Total failure of carbon adsorption on highest volume vent line.
9. Assumes high velocity and high angle of impact; for other assumptions, see § 5.2.1.7.
|f Pr | ^ 10. Assumes 26 gal. of fuel, temperature of smoke cloud of 400*C.
->> s»
— ^11. 450 square meter spill on 60"C pavement.
z
x 12. 50 square meter spill on 60*C pavement.
i
f* 13. 450 square meter spill on 35*C pavement.
------- |