Interim Guidance on Non-Liquid PCB Disposal Methods
to Be Used as Alternatives
to a 40 CFR 761.75 Chemical Waste Landfill (CWL)
(Developed in Conjunction with the Memorandum
on Application of Anti-Dilution Provisions to Super-fund Sites]
July 3. 1990
DP-
OTS personnel will be avmilable to provide consultation on this guidance.
To be consistent with the current process for fielding PCB disposal
questions, please direct any inquiries to the Hazardous Site Control
Division of OCRR. OERR will then coordinate with OTS.
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This document was developed by (he United States Environmental
Protection Agency. It has been subjected to the Agency's review process and
approved for publication as an EPA document. The policies and procedures
set out in this document are intended solefy for the guidance of response
personnel. They are not intended, nor can they be relied upon, to create any
rights, substantive or procedural, enforceable by any parry in litigation with the
United States,
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Introduction
for Options
CFR
Landfill
Requirement!
of to a 40
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I. Introduction
A Chemical Waste Landfill (CWL) is one of several options
for the disposal of non-liquid PCBs. Because the CWL regulations
in 40 CFR 761.75 allow the Regional Administrator (RA) to grant
waivers from some or all of the regulatory retirements, OTS is
providing guidance on what kinds of considerations should be
..-.eluded in decisions regarding the use of these waivers. The
gcal cf this guidance is to allow the flexibility which may be
needed ur.de r site-specific conditions while at the same time
ensuring adequate protection of human health and the environment
from the disposal and/or treatment of PCB-contaminated non-
liquids. This goal can best be met through evaluating a
combination of site-specific risk factors and disposal treatment
factors.
Toward this goal, the guidelines are presented in three
sections. As a reference point, the first section (Item II)
lists the risk factors that should be considered in making any
disposal/treatment decisions. The second section (Item III)
examines how the current CWL requirements relate to these risk
factors. The third section (Item IV) examines alternatives to
the current CWL requirements, including both destructive and non-
destructive approaches. These alternatives are also examined
relative to the risk factors.
For the purpose of this guidance, non-liquid PCBs are
defined as those materials not passing through the filter in the
Paint Filter Liquids Test, Method 9095, in "Test Methods for
Evaluating Solid Wastes" (SW-846). Sludges will generally be
dewatered prior to treatment with the supernatent being handled
consistent with the regulations for liquid PCBs. The
effectiveness of a sludge dewatering process should be
demonstrated using the Paint Filter Test.
iz. Risk factors for Evaluating a 9CB Disposal/Treatment option
In general, PCBs tend to sorb to solid materials, especially
organic solid materials, in preference to partitioning into water
or partitioning into air. Howavar, whan faced with the more
limited option of partitioning into air or into water, PCBs (on
net) prefer to partition into air because of vapor pressure/water
solubility eonsidarations. Therefore, whan sorbad PCBs are
exposed to a vatar/air interface, tha water will in effect (and
on net) causa soaa portion of tha sorbad PCBs to dasorb and
volatilize into tha air.
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Organic liquids can partition out of solid
materials, dissolve PCBs, facilitate drawing PCBs into an aqueous
solution, and transport the PCBs into the water column.
Therefore, in the absence of organic liquids and known geologic
and hydrologic anomalies, the major (though not the only)
potential exposure concerns from disposing non-liquid PCBs arise
frc- vaporization cf PCSs frcn solid materials (inhalation);
dispersion cf fine particulates containing PCBs (inhalation and
derr.al); and direct contact with the PCS solids (dermal).
Appropriate controls before, during, and after disposal (such as
avoiding coincident disposal of organic liquids, avoiding
generation/dispersal of dust, and providing proper containment
from all directions, including elimination/capture of runoff) can
mitigate release of PCBs to the exposure pathways of concern.
A. Evaluation of risk factors shall include
1. consideration of nearby and distant occupational and
non-occupational populations; the magnitude of Che
distance would depend on the potential environmental
transport of toxic materials as determined by a
model such as th*. Industrial Source Complex Long
Tern (ISCLT) modalj
2. all toxic materials rel«as*d before, during, and
after treatment or containment,-
3. data that are most applicable or descriptive cf the
disposal situ i~ If?
4. appropriate ch«m»;al analysis for *"e
material containing PCBsi appropriate incl as
satisfactory elimination of interferences - id having
appropriate sensitivity and selectivity; and
5. when site-specific data are not appropriate and
sufficient, th« appropriate models («.g.,
ISCLT, SESOIL) should reasonable worst
estimates for factors such as r«l«as« to
•nviroiUMAt, «nvironm«ntal d*gradation, and
environmental transport.
1. occupational «xpo«tir«» (b«£or«, during, and after
disposal) that a potentially unacceptable risk, it
b€ po««ibl« to attain an acceptable risk by
r*cpairin^ work»r» to v«ar protective clothing.
Workplace monitoring may also b* raguirad to varify
workplace «xposur« l«v«ls»
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111. li»JfB«Md Objective* of thm 48 CFl ?ii.is eneaiemi vast*
Landfill (CWt) R«quir«m«nt*
The requirements for a CWL, found in 40 CFR "761.75, address
tr.e risk factors by providing containment and isolation as veil
as r.easuras for ensuring that, the containment and isolation
rcr.tir.ue for the lifetime of the CWL. A surr.nary of these
requirements 13 as follows,
I. Limits on surrounding and underlying soil permeability;
2. Synthetic liner integrity - composition, thickness, and
underlying support;
3. Limits an hydrologic conditions and restrictions tron sitir.g
near surface water;
4. Protection against floods and other high surface water
conditions;
5, Construction restricted to areas of low topographic relief:
6. Monitoring systems - surface ground, before, during, and
after land-filling;
?. Leachate collection - several options?
8. Operating practices/procedures -
a. prevent damage, organic solvents,
b. prepare an operations plan and solidify/stabilize liquid
PCBs,
c, prohibit th« disposal of ignitaMe w«ac«a,
d, requirt r«cordk««ping; and
9. Supporting facilitiM -
a. r«*triet to landfill,
b, ptrevid« ad*«piate roads for handling transportation
v»hicl«», sa.f»ly, and
c. pr«v«nt safety probl«ma and hazardous conditiona fron
spills vind.
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4
If. ClAjrtot*riifeic« of AlttraativM to « 40 cm 741. ?s
A. Central
1. Any single disposal method for PCBs can do one of tv;
things: (a) eliminate the possibility of
environmental release by destroying the PC3s or i,
decrease tre probability of environ-enta! release = ,-
rcr.tatr.ir.g -re ?C3s . Mcr.itcrir.g is r.eeded tc s.-,5,re
t.-,a lcr,g-terr. effectiveness of ccr.ta ir-er.t . Chs-i^i.
analysts is needed C3 ensure the darr.cr.st rated
effectiveness of destruction methods. -bviously. *.-.-.
combination of destruction and containment ,T,ay se
used together as long as th« result from the
combination is adcquat* protaction of health and the
environment.
2. The af f*ctiven«ss of any destruction/ removal
technique must torn verified by t demonstration far t.-.e
Regional Adminiatrttor (RA) , At a miniaum, the
demonstration should includ* at least three
consecutive teats, aa is the standard r«quirem*nt ir.
th« "Guidance Manual for writers of PCS Disposal
Permits for Alternate f«chnelagi»s" (October l, isaa;
for approval of TSCA alternate destruction
methods, treating
a. the maximum PCS concentration expected to be
treated at the site;
b. material r«pre»«ntative of the PCS contaminated
matrices found on site and froa which the ?C3s
ar* to b* rtaovttd/ destroyed;
c, throughput quantities similar to those expected
during actual tr««ta«nt on-site during full scale
disposal operations; and
ihould b«
conditions/controls aimllir to that would be
at th* tr«»ta«nt »it«,
3. «ff«etiv«n««« of thm dastruetion/ruioval of PCBs
b« by collecting r«pr«»*ntativ«
of tr
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b. other chlorinated organic materials, such as
chlorinated benzenes, chlorinated ethylenes, cr
freons;
c. caustic inorganic materials such as sodium
hydroxide and hydrogen chloride; and
d. any other hazardous or toxic constituents at
regulated levels, levels resulting in an
unreasonable risk to health or the environment,
or levels which might be incompatible with
synthetic liners.
4. Agency quality assurance and quality control
guidelines should be followed.
B. Destructive Alternatives
1. The risk-based effectiveness of any destructive
alternative should be by (a) amount of
destruction on site-specific
considerations (b) demonstrated ability of
the alternative to provide that level of
destruction.
2. Depending on the site-specific risk characteristics,
containment and monitoring requirements may still be
necessary following destruction. Access to the
disposal site may have to be restricted to avoid
inhalation and dermal escposure. Structures may have
to be constructed to eliminate migration to surface
and ground waters.
3. Under TSCA, there is no preference for or
consideration of an innovative destruction process
whose effectiveness has not been demonstrated on the
same scale and on the kind of material as will
occur during treatment. Better projections of cost
and destruction efficiency are made from fully and
appropriately demonstrated technologies. There is a.
considerable cost in both time and resources to
scale up, demonstrate operational reliability ,
and subsequently confirm the disposal effectiveness
of a new technology which has only been verified on
laboratory or pilot demonstrations.
In the event that appropriate full scale testing
is not available or possible prior to selection of a
disposal option, trtatability can be used to
provide information on the destruction potential of
an unproven destruction technology. When
evaluating the cost of an unproven technology,
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consideration should be given to potential time
delays, cost increase, and decreases in disposal
efficiency resulting from scale up. The ir.pact cf
these factors can be so substantial that existing
demonstrated technologies which, upon initial
consideration, have significantly higher costs, nay
upon closer analysis be more comparable in cost to
less expensive technologies, demonstrated at a small
scale, after including the learning curve and other
development costs for "less expensive"
technologies. For all unproven technologies, full
scale pilot operations and shakedown should be
performed prior to commencement of full treatment
operations.
4, If destructive processes are to be used with no
further treatment or containment, these destructive
processes roust not generate or leave behind unsafe
levels of other toxic constituents or any residual
materials which would facilitate PCS transport in
environment.
Destructive that generate or leave
behind unsafe levels of other toxic constituents
and/or any residual materials which would facilitate
PCS transport in the environment must be followed by
further treatment or containment to mitigate the
exposure and risk from the toxic constituents and
other residual materials.
5- Some kinds of destructive processes have shown
greater promise than others. Greater promise is a
relative nay be very
significantly affected by amount of material to
be treated, the PCS concentration in the material,
and the presence of other chemical s in the soil,
the ambient temperature, and soil characteristics.
6. Table 1 lists the of alternative (NOT a PCB
Incinerator, High Efficiency Boiler, or Chemical
Waste Landfill) destructive and non-destructive PCS
disposal methods which have been used and have been
proposed to be in the disposal of non-liquid
PCBs.
7. For those methods identified in Table 1, Table 2
provides information as to the relative differences
in these methods with respect to estimated cost for
disposal, proven effectiveness-, generation of
, other toxic constituents as by-products of the
disposal, etc.
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C. Non-D«itructiv* Alternatives
1, Th* risJc-tsased effectiveness of any non-destructive
alternative should be measured by (a) the aaount of
containment needed based on situ-specific
considerations and (b) the demonstrated ability cf
the alternative to provide that degree of
ccr. tai .-.rant .
;cr.^-iar~ 5 f f ect ivar.ess cf -esc r.cr.-
iestructive containment 5.3 not known, =r at cest
limited, non-destructive alternatives -ust als- .-.iY-s
requirements to monitor/detact. the sigratisn cf ?C3s
out of th* tr«at*d nat*eial and/or (less preferably
th« migration of PCSs into ground or surface water .
Th« monitoring should eontinu* s«miannually even
after treatment has b«*n coapl*t*d and the site nc
iong«r active. Hov«v*r, th« frtcpancy of monitcri.-.g
nay b* raducad if it can b* daiaonstratad that there
is no potential for migration to water supply wells
or surface water.
3, Tmatafaility studies and field demonstrations are
strongly r«co«m«nd*d wh«r« arganics are solidified cr
stabilized.
4. Additional containment, treatment and/or
stabilization may be necessary when non-liquid ?C3s
are in the presence of other organic (or inorganic,
materials which might directly facilitate the
mobility or transport: of or reduce the
attenuation capacity or the underlying geology. An
exaaple would b« th* requirenent of a synthetic lir.er
under this Jcind of solidified/ stabilized material.
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TABLE 1
List of Alternate Technologies
That Have Been Considered at Superfund Sites
Group 1. Thermal Destruction:
A. Infrared Thermal Treatment
B. Circulating Bed Combustor
Group 2. Physical Separation:
A. Thermal Treatment
(1) Rotary Thermal Desorber
(2) Fluidized Bed
B. Solvent Extraction
(1) Soil washing (TEA)
(2) Liquified Gas
(propane and/or butane)
Group 3. Solidification/Stabilization
A. Chemical Fixation
(1) Plus Encapsulation
(2) In-Situ Inorganic Polymer
(3) Silicates
B. Vitrification
(1) In-Situ
c. Plus Chemical Dechlorination
Group 4. Biological
(A) Digester
(B) In-Situ
Group 5. Chemical Dechlorination
More detail on these treatment technologies is found in the
Appendix
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TABLE 2. Current Comparative Hanking of Technologies for Treatment ol Non-Liquid FCBs
Ranking: 1 - Best, 5 - Worst
Techno-
logies
1A
IB
2A(1)
2A(2)
2B(1)
20(2)
3A(1)
3A(2)
3A(3)
3B(1)
3C
4(A)
4 Ti at-e amounts of the solvent, t r iethy I am i m-, m.iy r t-ma i n
l' Volatile and semi-volat i le organi«'s (I'CHs)
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Appendix
Summary of Alternate Technologies for on Superfund Sites
Grcup 1. Thermal Destruction:
A. Infrared Thermal Treat-ant
Shirco, O.H. Material and Haztech (Westinghouse) have
all demonstrated TSCA disposal requirements and obtained
TSCA PCS operating permits. Heavy metals are not disposed
of, but O.H. Material has demonstrated that chemical changes
occur during treatment so that the ash has passed the heavy
metal-EP Toxieity Test, Process is sensitive and care nust
be taken to use the correct type of liquid fuel and to
maintain the infrared elements so that residual PCBs do not
show up in the ash.
B, Circulating Bed Combustor (CBC)
Qgden Environmental Services has denonstrated that the
CBC meets TSCA disposal requirements and has obtained a TSCA
operating permit, PCS residuals have not been detected in
the ash.
Group 2, Physical Separation:
A, Thermal Treatment
(1) Rotary Thermal Dasorbcr
Chemical Waste Manag*m*nt has completed an RiD
project under a TSCA RiD permit. Results have
mixed. PCls ar» removed from soil to levels of about
10
(2) Fluidlz*d B*
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8, Solvent Extraction
(1) Soil washing (TEA)
Resources Conservation Company used the BEST 'BEST
is the nar.e cf a company) technology of washing scil
with triethylarune (TEA) solvent at the General
Refining Superfund site in Garden City, Georgia. The
process will be tested under the SITE Program.
Biotrol, Inc. attrition scrubbing to separate
the highly contaminated particulars from coarser
particles. Th« resulting contaminated
watar/partieulate mixture is treated by a another
treatment method. The process was used for 2 years to
clean up a wood treatment site in Minnesota. Data ars
not yet available,
(2) Liquified
propane and/or butane)
2¥ Systems Corp. tested the soil washing
technology under the SITE Program. PCBs were removed
to 8 levels.
Group 3. Solidification/Stabilizatioa
A* Chenical Fixation
(1) Plus Encapsulation
Hazcon, Inc. tasted the proc*a» under the SITE
Program, using Chloranan as a plastic encapsu'int. for
organic*. TCLP r*aults indicated heavy metal were
stabilized. Organic* in th« TCLP tests were slow i
ppm, but TCU» results for untreated soil v«re at the
l«v«.I»» cost: $90 - $120 par ton.
(2) In-Situ Inorganic Polymar
Int«mational Waste T«chnologi«s/G«o-eon» Inc.
un«I«r the SITE Program their in-situ
u«ing proprietary ch«aicals. PCBa, although
*ppmr«ntly immobilized, v«r* not d«t*cted in TCLP
on treated a.n4 untreat»d soil*. Rasults could not be
confirned for other organic* as well. Data for heavy
metala art not available. Costs $110 - Sl§4 per ton.
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(3) Silicates
Chemfix Technologies, Inc. uses soluble silicates
and silicate setting agents to solidify/stabilize
contaminated soils, TCL? results from SITE Program
studies indicate copper and laad were irsrr.cDil izsd.
A1 theugh PCSs were present in the soil, PC3 results
'-era r.st offered.
B. Vitrification
(I) In-Situ
Geosafe Corp. has applied for a TSCA permit and is
scheduled to demonstrate the process during the fall of
1990. Tested at a Supcrfund site in legion X, vith lev
level PCBs, results using TCLP negative for both
PCSs and heavy metals.
c. Plus Chemical Oechlorination
A company (Qual Tech.?) is currently performing RiD
tests under a Region VI approval combining solidification
and stabilization- with chemical dechlorination. The
technology looks promising because the cost should be on the
order of $100 to $200 par ton, similar to
sol idification/stabilization processes.
Group 4. Biological
(1) Digester
Biotrol, Inc. was msntion abov«.
Mo-T«eh» Inc. usea solid/liquid contact digestion to
treat biod*gradalsl« vast*. Th* proc»»a will b« *valuated
under tha SITE frogram.
G*n«ral El»ct,rie haa applitd for a TSCA approval to
study tr«*ta«nt o£ PCB centaninati*cl soil/sadiment using a
bioramctor. Approval is imninant.
(2) In-Situ
Pacific is parfeming bior*««diatiori studies
und«r a TSCA approval on contaainat«d soil in
Richland, Utah. Whita rot fungus, an in
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4
Group 5. Chemical Dechlorination
Galson, Inc. has completed a TSCA RiD project using the
KPEG process to clean soil contaminated with PCBs. Results
were mixed, with treated soils in the 5 pom - 10 ppm PC3s
levels.
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