EPA 560/6-77-013
MICROECONOMIC IMPACTS OF THE PROPOSED MARKING
AND DISPOSAL REGULATIONS FOR PCBs
Final Task Report
Submitted to:
U.S. Environmental Protection Agency
Office of Tbxic Substances
Washington, D,C.
Attention: Mr. David E. W&gner
Project Officer
Contract No. 68-01-3259
Submitted by:
VERSAR INC.
6621 Electronic Drive
Springfield, Virginia 22151
April 26, 1977
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This report has been reviewed by the Office of Toxic Substances,
U.S. Environmental Protection Agency, and approved for publication. Approval
does not signify that the contents necessarily reflect the views and policies
of the Environmental Protection Agency, nor does mention of trade names or
conmercial products constitute endorsement or recanmendation for use.
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PREFACE
His attached document was prepared fay Versar Inc. for the Office of
Ibxic Substances of the Environmental Protection Agency. The purpose of the
work reported in this document was to estimate the probable costs of comply-
ing with the draft PCB marking and disposal regulations, 40 CFR 761
(Appendix B). These regulations are being prepared in fulfillment of the
statuatory requirements of Section 6(e) of the Toxic Substances Control
Act (Appendix A).
This economic analysis program was sponsored by the EPA, but the results
reported are those of Versar Inc. This report was submitted in partial ful-
fillment of the requirements of Contract No. 68-01-3259. The report is not
an official EPA publication. However, this study does meet all of the require-
ments of an economic impact analysis of the proposed regulation.
The economic analysis of the draft disposal and marking regulation
was one of a number of research tasks concerning PCBs which Versar has per-
formed for the Office of Toxic Substances, U.S. EPA. This report was prepared
under the supervision of Mr. Robert Westin, Principal Investigator. Other
major contributors were:
Iouis Fourt, Ph.D. (Economic methodology and transportation
costing)
Marvin Drabkin, Ph.D. (Incinerator technology and costing)
Deborah Guinan (Landfill technology and costing)
David Berkey (Analysis of marking regulations)
Irwin Frankel, Ph.D. (Decontamination and storage costing)
Dave Sood (Incinerator location/transportation cost analysis)
Special acknowledgements must be given for the close support received
frcm Mr. David E. Wagner, EPA Project Officer, and Mr. Harold Snyder, EPA
Regulations Development Group of the Office of Toxic Substances. The factual
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strengths of this report are due to the close cooperation received frctn
industry, particularly representatives of the existing incinerators and the
major electrical equipment manufacturers.
This report is based on the draft regulations as they were written on
April 18, 1977. This draft was undergoing continued review by the Office of
Tbxic Substances and other offices within EPA, and changes which may have been
made to the draft regulations after April 18 could not be considered in this
analysis. Therefore, it is suggested that the draft regulation which is
included in Appendix B be carefully cartpared with the formal proposed regula-
tion which will be published in the Federal Register, and that the econonic
costs developed in this report be recalculated as necessary to reflect any
subsequent dianges in the draft regulation.
This report is being released and circulated prior to the public hearing
cm the proposed regulation. It will be considered along with the information
during the hearings in the establishment of the final regulations. Prior to
final promulgation of the regulations, this study shall have standing in any
EPA proceeding or court proceeding only to the extent that it represents the
views of Versar. It cannot be cited, referenced, or represented in any respect
in any such proceeding as a statement of EPA's views regarding the irrpact of
the proposed regulations.
ii
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 Current PCBs Usage in the United States 1-1
1.2 Effect of the Toxic Substances Control Act on
the Usage of PCBs 1~7
1.3 Draft Regulation for the Marking and Disposal
of PCBs 1-8
1.4 Definition of Economic Impact 1~9
2.0 DISPOSAL TECHNOLOGY 2-1
2.1 Proposed Disposal Requirements 2-1
2.2 Decontamination 2-2
2.3 Storage for Disposal 2-4
2.4 Chemical Waste Landfill 2-6
2.4.1 Proposed Requirements 2-6
2.4.2 General Engineering Considerations .... 2-7
2.4.3 Currently Available Chemical Waste Land-
fills 2-11
2.4.4 Costs of Chemical Waste landfill
Disposal 2-13
2.5 Incineration 2-14
2.5.1 Existing Incinerator Facilities 2-14
2.5.1.1 Liquid Waste Incinerators .... 2-14
2.5.1.2 Solid Waste Incineration 2-16
2.5.1.3 Costs of PCBs Incineration. . . . 2-17
2.5.2 Garments on Draft Liquid PCBs Disposal
Regulations 2-18
2.5.2.1 Rollins Environmental Services,
Inc 2-18
2.5.2.2 General Electric Go., Pittsfield,
Mass. 2-19
2.5.3 New Incinerator Facilities 2-20
2.5.3.1 New PCBs Incinerator Design Bases 2-20
2.5.3.2 New PCBs Incinerator Facility
Cost Estimate 2-23
2.5.3.3 Factors Affecting Expansion of
Ccnmercial Incineration
Facilities 2-27
iii.
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TABLE OF CONTENTS CCon't)
Page
2.5.4 Cerent Kiln Operations 2-27
2.5.5 Power Boilers 2-29
2.5.6 Sewage Sludge Incineration of PCBs .... 2-30
2.5.7 Incinerator Ships 2-30
2.6 Transportation Costs 2-31
2.6.1 Trucking Costs 2-31
2.6.1.1 Shipments of Liquid PCBs .... 2-31
2.6.1.2 Shipments of Capacitors and
Transformers 2-34
2.6.2 Platform Costs 2-34
2.6.3 Other Factors Affecting Transportation
Oosts 2-34
2.7 Reporting and Record Keeping 2-37
3.0 ECONOMIC COSTS OF THE DRAFT DISPOSAL REGULATIONS ... 3-1
3.1 Disposal Demand 3-1
3.2 Decontamination 3-3
3.3 Storage for Disposal 3-7
3.4 Chemical Waste Landfill 3-7
3.5 Incineration 3-10
3.6 Transportation Costs 3-10
3.7 Record Keeping Costs 3-20
4.0 MARKING 4-1
4.1 Requirements in Draft Regulations 4-1
4.2 Methodology 4-1
4.2.1 Containers 4-2
4.2.2 Storage Areas 4-8
4.2.3 Vehicles 4-9
4.2.4 Transportation and Labor Marking Costs . . 4-10
4.3 Economic Impact 4-11
5.0 ECONOMIC IMPACT ANALYSIS 5-1
5.1 Incineration Costs 5-1
5.2 Other Cost 5-3
5.3 Annual Attributable Costs of Ccrnpliance 5-4
5.4 Effect on Prices and Market Structure 5-6
5.5 Energy Consumption Requirements 5-8
5.6 Effect on Supplies of Strategic Materials .... 5-8
iv.
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TABLE OF CONTENTS (Con't)
APPENDIX A - Toxic Substances Control Act
APPENDIX B - Draft PCB Marking and Disposal Regulations
APPENDIX C - Chemical Waste Landfills
APPENDIX D - PCB Incineration
APPENDIX E - References
v.
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LIST OP TABLES
522®.
1-1 Estimates of Cumulative PCBs Production, Usage, and
Gross Environmental Distribution in the United States
Over the Period 1930-1975 in Millions of Pounds . . . 1-2
1-2 Number of PCB Items in Service 1-6
2-1 Existing PCBs Liquid Waste Incinerators 2-15
2-2 Preliminary Engineering Estimate of a Dual Purpose
PCBs Incineration Facility 2-24
2-3 Annual Operating Costs for PCB Capacitor Incineration 2-25
2-4 Truck Freight Charges for Single Drums of Transformer
Oils 2-32
3-1 Disposal Requirements for PCB Electrical Equipment in
1978, millions of pounds 3-2
3-2 Annual PCB Equipment Disposal Requirements, after
July 1, 1979: millions of pounds 3-3
3-3 Disposal of PCB Chanical Substance in PCB Equipment
after July 1, 1979: million lb/year 3-5
3-4 Economic Costs of Storage Facilities 3-8
3-5 Total Cost of PCBs Solids Disposal by Incineration . 3-11
3-6 PCB Disposal Requirements - 1978 3-12
3-7 Location of PCBs Incineration Facilities 3-13
3-8 Incinerator/Transportation Cost Scenario #1 3-15
3-9 Incinerator/Transportation Cost Scenario #2 3-16
3-10 Incinerator/Transportation Cost Scenario #3 3-17
3-11 Incinerator/Transportation Cost Scenario #4 3-18
3-12 Average Transportation Costs of Shipping Solid PCBs
Wastes to Incinerators 3-19
4-1 Sumnary of Compliance Dates for the Proposed Marking
Regulations 4-1
4-2 U.S. Transformer Manufacturing Industry Using PCBs. . 4-3
4-3 U.S. Capacitor Manufacturing Industry Using PCBs. . . 4-4
4-4 Calculation of Utilities' Transportation and Labor
Marking Costs 4-12
4-5 Calculation of Electrical Equipment Manufacturers'
Marking Costs for the Year Ending December 31, 1978 . 4-13
vi.
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LIST OF TABLES CCon't)
Page
4-6 Electrical Equipment Manufacturers' Total Marking
Costs for the Year Ending December 31, 1978 4-14
4-7 Calculation of Utilities' Marking Costs for the Year
Ending December 31, 1978 4-15
4-8 Calculation of Industrial and Commercial Entities'
Marking Costs for the Year Ending December 31, 1978. . 4-16
4-9 Calculation of Residential Users' Marking Costs for the
Year Ending December 31, 1978 4-17
4-10 Electrical Equipment Users' Total Marking Costs for
the Year Ending December 31, 1978 4-18
4-11 Calculations for Utilities' Marking Costs for the Year
Ending December 31, 1978 4-20
4-12 Calculations for Industrial and Commercial Entities'
Marking Costs for the Year Ending December 31, 1978. . 4-21
4-13 Electrical Equipment Users' Total Marking Costs for the
Year Ending December 31, 1978 4-22
5-1 Total Attributable Compliance Costs 5-5
5-2 Annual Qiergy Requirements of Disposal Regulations
Disposal Option 1 (Incinerate all Capacitors) 5-9
vii.
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LIST OF FIGURES
Page
2-1 Schematic of Rollins Environmental Services Incin-
erator at Houston Set 1%) for PCB Capacitors Test
Burn . 2-22
2-2 PCBs Incineration Cost as a Function of Plant
Capacity 2-26
2-3 Trucking Charges for Transformer Oil by Type of Ship-
ment and Distance 2-33
2-4 5,000 Gallon Minimum Bulk Shipments Electrical Oil
toy Distance 2-35
2-5 Trucking Charges for Capacitors and Transformers by
of Shipment and Distance. . . 2-36
viii.
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1.0 INTRODUCTION
The purpose of this study was to evaluate the economic impact of the
draft regulations for the marking and disposal of polychlorinated biphenyls
(PCBs), 40 CFR 761. Hie draft regulations were prepared by the Office of
Tbxic Substances of the Environmental Protection Agency with the support of
the Interagency PCB Work Group.
The scope of this analysis included estimates of the quantities of
PCBs and equipment containing PCBs which will be affected by the proposed
regulations, the present and required future availability, feasibility,
and costs of the required PCB disposal facilities, the secondary costs of
controlled disposal including storage, recordkeeping, and transportation,
and the costs of satisfying the various marking requirements. The eco-
nomic analysis included estimates of the additional costs of complying
with these regulations as a function of year and economic sector. The
analysis also considered the possible economic effects of these costs on
price levels, investment requirements, and employment. Finally, the
effects of conpliance on energy requirements and on the availability of
strategic materials were estimated.
1.1 Current PCBs Usage in the United States
PCBs have been used in the United States since 1929. Major
uses of this chemical in the past have included transformer cooling
liquids, capacitor dielectric liquids, heat transfer and hydraulic
liquids, as a dye carrier in carbonless copy paper, as a plasticizer
in paints, adhesives and caulking compounds, and as a filler in investment
casting wax. thder a previous task of this contract, Versar studied the
use of PCBs and reported the estimated usage and distribution of PCBs
as shewn in Table 1-1. ^
(!) Versar Inc. PCBs in the United States: Industrial Use and Environmental
Distribution"! NTIS PB-252 402/3WP. Feb., 1976.
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Table 1-1
Estimates of Cumulative PCBs Production, Usage, and Gross Environmental M,
Distribution in the United States Over the Period 1930-1975 in Millions of Pounds
i
to
Ccmnercial
PrcxViction
Ccxnnercial
Sales
Inluatrial
Purchases of PCB
PCDs Currently
in Service
PCBs Currently
in Envnoniiait
KUa
Destroyed
Estirvitod
Raliability
of Values
U.S. PCB Production
Total U.S. PCB Disports
1,400
a
+ S%
- 20%
1 lot
U.S. PCD Domestic Usaya
total U.S. PCB Exerts
1,253
150
'
+ 5%
- 20%
1 20%
PCB by Use Category:
Petroleun Additives
Heat Transfer
Misc. Industrial
Cartonless Copy Paper
llydiaulics and Lubricants
Olher Plasticizer Uses
C3fiacitOLs
Transfonnica
1
20
27
45
SO
115
630
335
450
300
i 5Gi
I 10%
t 15%
: 5%
1 10%
1 15%
J 204
1 20%
Uses Other than Electrical
8
± 60%
PCB Degraded or incinerated:
Ki iV i riHuu nla 11 y Degraded
Incinerated
30
25
i 70%
t 10*
landfills and PCBs In Duips:
Cdf). .u* 1 Trans. Production
Wastes
Obsolete Ele. Krjuifmont
Other (paper, plastic, etc.)
110
80
100
I 20%
1 4-3%
3. iOi
Free PCBs in the Environment
(soil, water, air, sediment)
150
1 30%
Total
1,403
1,403
1,253
758
440
55
(1) Versar Inc. PCBs in the United States: Industrial Use and Environmental Distribution
February, 1976, NTIS PB-252 402/3WP ~~~~
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The major U.S. manufacturer of PCBs has been Monsanto. Since
1972, Monsanto has limited sales of PCBs to manufacturers of transformers
and capacitors. A previously reported investigation fay Versar indicated
that about one million pounds of PCBs were produced by a small manufacturer
frcm 1972 through 1974 for use as a heat transfer liquid, but that there
were no significant amounts of U.S.-produced PCBs ranaining in use in non-
electrical systems in 1976.^
PCBs have also been imported for use in investment casting wax,
for maintenance of certain mining machinery, and as the coolant in electrical
transformers. The use and industrial importance of these imported PCBs was
(2)
the subject of a recent investigation by Versar.
Decachlorobiphenyl was imported frcm Italy for several years for
use as a filler in investment casting wax, but this use was ended in mid
1976. Several manufacturers of investment casting vax are presently using
imported polychlorinated terphenyls in their products, and these PCTs may
be contaminated with up to 10% PCBs. It is assumed that the concentration
of PCBs in the PCTs can be reduced to below .05% by stricter quality control
during manufacturing. If this cannot be done, the PCTs will have to be
marked as being PCBs, and the used wax may be subject to the proposed marking
and disposal requirements.
The use of imported PCBs in the maintenance of certain mining
machinery is well documented, and will be investigated in more detail during
a research program to be sponsored by the U.S. Bureau of Mines later this
year. Section 6(e)(2) (A) of the Toxic Substances Control Act requires that
this mining machinery not be used after 1977. The disposal of the PCBs in
the machinery and the contaminated machinery will be subject to the require-
(1) Versar Inc. Usage of PCBs in Open and Sani-Closed Systems and the Re-
sulting Losses of PCBs to the Environment. EPA 560/6-77-009 (unpublished
Draft Report). September 1, 19757
(2) Versar mc. Assessment of the Environmental and Economic Impacts of the
Ban on imports of PCBs. EPA 560/6-77-007 (unpublished Draft Report).
Fphmary 1, 1977.
1-3
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ments of the proposed disposal regulations. Hie disposal of the PCBs from
the approximately 350 mining machines is not expected to have a significant
impact on the availability of landfill or incineration facilities, nor is
it expected to have a significant economic impact on the mines.
Recent imports of PCBs as components of transformers are known to
have exceeded 500,000 lbs. Such imports of PCBs do not significantly effect
the estimates of total amounts of PCBs in service based on U.S. production
data. The PCBs in such foreign built equipment will, of course, be subject
to the proposed marking and disposal regulations.
Due to growing concern about the environmental hazards of PCBs,
Monsanto announced late in 1976 that it would cease operation of its PCB
manufacturing facility in October, 1977. As a result, most manufacturers of
PCB transformers and of large high voltage capacitors have switched to
other liquids in place of PCBs, and most manufacturers of small capacitors
have indicated that they will stop using PCBs during 1977 or 1978.
Based on these previous studies, we can conclude that the marking
and disposal regulations will have little effect on manufacturers who use
PCBs in new equipment, and that the only existing PCB uses that will be
affected will be transformers and capacitors.
For purposes of analysis, the existing PCB electrical equipment has
been classified in the following six categories. The PCB and equipment
weights and the service lives listed for each, category are averages for all
equipment in that category. The total weights listed for the capacitors are
the average weights of the smallest disposable units.
PCB transformers §:
2150 lb PCBs
3000 lb liquid
6500 lb drained weight
40-year average life
1-4
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(IHV) Large High Voltage Capacitors
25 lb PCB
120 lb total
20-year average life
(LLV) Large Low Voltage Capacitors!?:
3.5 lb PCB
20 lb total
15-year average life
(HID) High Intensity Discharge Lighting Capacitors
2 lb PCB
8 lb total
20-year average life
(SA) Small Appliance Capacitors
1 lb PCB
5 lb total
15-year average life
(EL) Fluorescent Lighting Ballasts
0.1 lb PCB
3.5 lb total
15-year average life
Hie total numbers of electrical items containing PCBs is sum-
marized in Table 1-2.
Hie importance of controlling disposal of PCBs from electrical
equipment lies in the fact that there is presently five times as much
PCB in use in electrical equipment as there is free in the environment.
Although controlled disposal of the PCBs presently in use will not solve
the problems which are now being caused by PCBs in the environment, un-
controlled disposal could increase the levels of environmental PCBs by
a factor of six or more.
1-5
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Utilities
Cmunercial and
Apartment Buildings
Industrial
Private Residential
TOTAL,
Transfonners
01,000
28,000
28,000
140,000
Table 1-2
Number of PCB Items in Service
Capacitors
LJJV LLV HID SA FL
7,600,000 1,000,000 800,000
7,500,000 500,000 5,000,000 630,000,000
400,000 7,500,000 19,200,000 130,000,000
4,000,000 45,000,000 40,000,000
8,000,000 20,000,000 25,000,000 50,000,000 800,000,000
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1.2 Effect of the Toxic Substances Control Act on the Usage
of PCBs
In 1971, the President's Council on Environmental Quality
developed a legislative proposal for dealing with pollution fran toxic
chemical substances. Finally, after many carp lex congressional hearings
and debates, the Toxic Substances Control Act was signed into law in
October 1976. The Toxic Substances Control Act became effective on
January 1, 1977. The Act enables the Administrator of the Environmental
Protection Agency to obtain from industry any information bearing on the
use, distribution, production volumes and methods, health effects, and
any other data necessary to understanding whether or not to what extent
any given chemical substance or ocarpound may adversely affect peoples'
lives either directly or indirectly. Ihe Administrator of EPA is em-
powered to act through the courts to prohibit the manufacture, process-
ing, distribution, use, or disposal of any chemical substance or mixture
found to present an unreasonable risk of injury to health or the environ-
ment.
The Act addresses only one chemical class directly, that being
polychlorinated biphenyls, a class of bicyclic conpounds having between
1 and 10 chlorine atoms per molecule. Section 6 (e) of the Act establishes
dates for the discontinuation of the use of PCBs in open systems, for the
end of manufacturing and importation of PCBs, and for the end of the use
of PCBs in newly manufactured equipment (see Appendix A). Section 6(e) (1)
requires that the Administrator prcnulgate rules prescribing the disposal
and marking of PCBs by July 1, 1977. The draft of the proposed regulation
analyzed by this report was prepared in response to this statuatory require-
ment by the Office of Toxic Substances with the support of the Interagency
PCB Wbrk Group.
With the exception of the regulations for marking and disposal,
Section 6 (e) will have little iripact on the use of PCBs. The Act does not
require that existing capacitors or transformers be removed from service,
nor does it specifically prohibit the continued use of stock-piled PCBs
1-7
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for transformer maintenance. The prohibition on open system uses after
1977 will result in the early retirement or modification of several
hundred mining machines, but no other significant open system uses are
known. The manufacturers of transformers and large capacitors plan to
end most of their usage of PCBs by the end of 1977. Several manufacturers
of small capacitors will continue using PCBs into 1978, working frott
inventories of PCBs as there will be no U.S. production of PCBs after
1977. The marking requirements will apply to these small capacitors
and to the new electrical equipment in which they are used as components,
but these marking requirements should end within a year or two as use of
PCBs is discontinued in new capacitors.
1.3 Draft Regulation for the Marking and Disposal of PCBs
The draft regulation is included in this report as Appendix B.
Ihis regulation specifies the required disposal procedures for various
types of PCB equipment and materials, and establishes requirements for storage
areas, record keeping, and labeling of PCB equipment, containers, storage
areas, and vehicles.
Prior to the enactment of the Resource Conservation and Recovery
Act of 1976 (Pub. Law 94-580) in October, 1976, the Federal EPA had no
jurisdiction over the operations of hazardous waste incinerators and chemi-
cal waste landfills. Regulations have not yet been promulgated under
RCRA. Therefore, EPA has included special requirements for PCB incinera-
tors and landfills in the proposed marking and disposal regulations. These
proposed regulations require that all incinerators and chemical waste land-
fills used for the disposal of PCBs must be approved by the EPA Regional
Administrator, and establish guidelines for the evaluation of the accepta-
bility of the facilities. Since this requirement for Federal approval
has not previously been required, existing facilities operate under state
authorization and do not have the required Federal approval. It is not
kncwn whether any of the existing landfill facilities can meet the pro-
posed requirements without modifying their facilities and/or operating
1-8
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procedures. All existing incinerators will have to be modified to pro-
vide for additional monitoring before they will meet the requirements.
Definition of Economic Impact
Executive Order 11821 (as extended) and GMB Circular A-107
require that major legislative proposals and regulations by agencies of
the Executive Branch must be accompanied by a statement certifying that
the economic inpact of the proposal has been evaluated. EPA's guidelines
on Economic Inpact Analysis Statements (formerly Inflation impact
Statements) provide that regulations shall be considered a major action
and shall require an Economic Inpact Analysis under the following con-
ditions: (1) If the incremental annualized costs of compliance, includ-
ing capital charges, exceed $100 million in any year, (2) the incremental
cost of production of any major product exceeds five percent of the sell-
ing price of the product, (3) net national energy consumption would be
increased by the equivalent of 25,000 barrels of oil a day, or (4) the
supply or demand of certain specified materials would be affected by more
than three percent.
The major impact of the rules will apply to the owners and
users of currently operating PCB capacitors and transformers. These
persons will be affected by increased costs due to the special marking,
storage, disposal, and recordkeeping that will be required for this
equipment. In the following analyses, we have reviewed the availability
and costs of disposal facilities, storage facilities, and transportation
services. Estimates are also made of the amount of PCB equipment requir-
ing controlled disposal by year and segmsnt of the economy. The total
costs are calculated based on the application of unit capital and opera-
ting costs to the disposal requirements. Price impacts are calculated
on the assumption that all costs of complying with the regulations will
be recovered frcm the ultimate consumer of goods and services. Effects
on energy requirements and the supply of strategic materials are cal-
culated on a national basis using the upper bound estimates of the im-
pacts of the regulations.
1-9
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In. a similar way, the effects of the marking, storage, and
recordkeeping costs have been analyzed an a unit basis as applied to
individual items or facilities. Total economic impacts are then cal-
culated based on estimates of the total nurcber of such items or facilities
affected by the regulations.
1-10
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2.0 DISPOSAL TECHNOLOGY
Consideration of the unit costs of storage and disposal are basic to
any calculation of the total economic impacts of the proposed regulation.
The proposed regulations are very specific both, in specifying what is to be
done and in specifying how it is to be done. The following sections of
this report consider in detail the technical and economic aspects of each
part of the proposed disposal requirements.
2.1 Proposed Disposal Requirements
The basic disposal requirement for all PCBs is controlled use and
storage followed by high temperature incineration. Considerations of the
present lade of incineration facilities capable of handling capacitors and
of the high costs that would be incurred by requiring removal of small
capacitors frcm large equipment and requiring special handling of fluores-
cent light ballasts in individual residences have resulted in a number of
exemptions from the basic requirement of incineration:
(1) Until July 1, 1979, non-liquid PCB mixtures (contaminated
soil, rags, sewage sludge, etc.), PCB capacitors and PCB
fluorescent light ballasts may be disposed of in chemical
waste landfills.
(2) PCB containers (tank cars, trucks, drums, etc.) that have
been contaminated with PCBs may be decontaminated by
triple rinsing.
(3) PCB transformers may be disposed of in chemical waste land-
fills following rinsing to reduce their content of PCBs and
the chance of leakage during transportation or after
burial.
(4) Small PCB capacitors in electrical equipment do not have to
be removed before the equipment is disposed of. Since most
capacitors are removed from service because the equipment is
2-1
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obsolete, rattier than due to failure and replacement of the
capacitor, the effect of this exemption appears to be that
the disposal of most snail capacitors will be as municipal
solid wastes as part of larger equipment.
(5) Small capacitors and fluorescent light ballasts used in
private housing units may be disposed of by the occupant
as municipal solid waste.
(6) Material or equipment containing less than 500 ppn (one pound
per ton) of PCBs will not require special handling or disposal.
Incinerators and chemical waste landfills used for disposal of PCBs
will have to have approval from the EPA regional administrator. The proposed
regulations establish detailed technical guidelines for the proper operation
of these facilities.
All industrial plants, utilities and others who dispose of other
than small PCB capacitors will be required to provide special diked and pro-
tected storage areas. Each storage facility larger than two 55 gallon drums
will also be required to maintain records as to hew the PCBs are handled.
Ctaners of significant quantities of PCBs in transformers, capac-
itors, or other equipment are required to maintain records including the
location and scheduled disposal of the PCBs.
2.2 Decontamination
Because of the potential for liability from accidental spills of
PCBs during decontamination, we do rot foresee much use of this alternative
disposal method. There will be seme initial decontamination of tank cars,
tank trucks, and production machinery as production of new PCBs is phased
out. This will not have a major effect on total economic impacts. Any de-
contamination performed after this initial period will result in a slight
decrease in the costs shown for incineration, but the effect should not be
significant.
2-2
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Effective decontamination of drums and small containers has been
reported for pesticides, by triple rinsing of the containers with solvents
which contain < 0.05 per cent of pesticide but have a solubility of 5 per
cent or more for the pesticide. ^ Each rinsing uses a volume of solvent
approximately 10 per cent of the volume of the container, and the rinsing
must be accomplished by sloshing or otherwise forcing repeated contact of
the container internal surfaces with the solvent. The efficiency of de-
contamination depends in part on the degree of solvent contacting and on
the condition of the container surfaces being cleaned. After each rinse,
the solvents are collected and incinerated. This procedure is believed
readily adaptable for PCB containers.
Most large transformers are filled with a liquid which acts both
as a cooland and as an electrical insulator. Approximately 5 per cent of
such transformers are filled with a mixture of PCBs with up to 40 per cent
trichlorobenzene. This non-flammable coolant containing PCBs is known by
the generic term "askarel". Complete decontamination of askarel filled
transformers does not appear feasible. However, partial decontamination of
askarel transformers which are being taken out of service is required. This
can be accomplished by thoroughly draining the askarel fluid frcm the trans-
former, followed by refilling and recirculating for several hours with a
solvent such as mineral spirits. The solvent is then drained and incinerated.
Preliminary results of a test which was performed by Westinghouse, sponsored
by the Federal Railway Administration, and based on the above procedure,
achieved a 99 per cent reduction in the quantity of PCBs in the transformer.
Transformers so treated may then be disposed in a chemical waste landfill.
The remaining 95 per cent of liquid filled transformers are filled
with mineral oil. This mineral oil may be contaminated with small amounts of
PCBs because the same equipment has been used in the past to manufacture and
service mineral oil filled and askarel filled transformers, and the equip-
(1) Midwest Research Institute, Guidelines for the Disposal of Small Quantities
of Unused Pesticides, EPA-67072-75-057, Cincinnati, Ohio: National
Environmental Research Center, USEPA, June, 1975.
2-3
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ment has not always been decontaminated thoroughly after handling PCBs.
Recent surveys have indicated that the contamination of the mineral oil is
almost always below a concentration of .02 per cent PCBs. No cases are
documented where transformer mineral oil has contained over . 05 per cent
PCBs though the ultimate disposal of any such oil would have to be by high
temperature incineration under the requiranents of the proposed regulations.
It is possible that routine incineration of transformer mineral oil may
eventually supply a significant portion of the fuel required to incinerate
PCB capacitors. Such incineration of mineral oil would not be expected
to have a significant economic impact because its value as a fuel would off-
set the cost of handling the oil.
Askarel transformers which are kept in service, but retrofilled
with, a silicone or other oil, should be thoroughly drained of askarel oil
prior to refilling with, replacement oil. Subsequent drainings and refillings
of such transformers will require eventual incineration of the oil used to
retrofill the transformers. In the case of silicone oil, it has been re-
ported that treatment with an activated carbon will remove the PCBs and
permit reuse of the oil.^ In the case of mineral oil, the initial retro-
fill must be incinerated. Subsequent mineral oil retro-fills must also be
incinerated until the level of PCB is less than 500 ppn.
2.3 Storage for Disposal
Most storage areas required by the proposed regulations will be
established by office and ccumercial buildings, electrical repair shops, and
small industrial buildings for the storage of small capacitors and fluores-
cent light ballasts that are ranoved during normal maintenance. These
storage requirements may be fairly significant in the case of a large
building. For instance, the World Trade Center in New York City has 250,00
fluorescent light ballasts; replacement of failed ballasts may result in the
requirenent to store several hundred ballasts per v^ek prior to disposal.
Small facilities may generate only a few capacitors or ballasts each year for
disposal.
(1) Personal ccmnunication, Mr. Tbr Orbeck, Dow Corning, Midland, Michigan.
2-4
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If the storage areas for accumulation of small capacitors (and
presumably fluorescent light ballasts) are limited in size to two 55 gallon
drums stored inside, no special flooring, diking, or record keeping will be
required. The cost of establishing such an area will be the cost of pro-
curing a DOT spec 5, 5B, or 17C open head drum, parking the drum and area,
and establishing maintenance policies requiring the collection of capacitors
and ballasts. Total costs would be about $25 for the drum, plus $10 (one
man hour) for labeling the drum and setting up the storage location, and an
additional administrative expense of $80 for ordering the drum, establishing
policy, etc. First year costs vrould therefore be about $115 per snail storage
area plus an equivalent of rent for the storage area of $30, or a total of
$145 per area.
Annual operating costs of the small storage facilities include the
equivalent of rent for the area dedicated to PCB accumulation (10 square feet
x $3/ft2/year), replacement drum costs (0.6 drums/year x $25), and $50 per
year administrative costs, for a total of $95 per year.
While all of these costs can be attributed to the establishment and
operation of small storage areas, they may not all be econonic costs. By
locating the drum in an unused area of the basement or warehouse, the facility
could reduce or eliminate the economic costs of the storage area. Similarly,
by using second hand drums and by setting up the storage area during a time
of slack labor demands, the out of pocket costs for the establishment and
operation of the storage areas could be reduced to the few dollars a year
required to purchase the special labels and procure (or not return for credit)
the drums.
In addition to the small storage areas, special indoors storage
facilities which may not now exist will be required by utilities, transformer
repair shops, and other operations which store large capacitors or trans-
formers or which stockpile PCBs for transformer maintenance. These storage
areas will require impermeable floors and dikes. Engineering and construction
costs of $1000 to $5000 would be incurred in meeting these specifications for
2-5
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each, major storage facility. An average major storage facility might have
an area of 200 square feet, requiring a capital outlay of $2000. Equivalent
rental costs of $3.00 per square foot per year would still apply, and drum
costs would be about $225 per year. Labor costs would be incurred in
handling the PCB equipment and checking the drums; two man hours per week
would result in an annual cost of $1000. Administrative costs of $300 per
year might also be attributable to the storage area. The operating costs
for each major storage area would therefore be $2125 per year.
2.4 Chemical Waste Landfill
Chemical waste landfills provide environmental safeguards and long
term protection designed to prevent the entry of stored PCBs into the environ-
ment. Although the PCBs will only be immobilized, rather than destroyed,
the use of chemical waste landfills is to be preferred to uncontrolled dis-
posal of PCBs where incineration capabilities are not available.
2.4.1 Proposed Requirements
The draft regulations require that chemical waste land-
fills used for the disposal of PCBs be approved for such use by the EPA
Regional Mministration. The proposed regulations specify the following
guidelines for approval of chemical waste landfills:
(1) The composition and volume of each waste is known and approved
for site disposal by pertinent regulatory agencies.
(2) The site should be geologically and hydrologically approved
for hazardous wastes. Included in the criteria would be
soil or soil-liner permeation rate of less than 10"7 cm/sec;
in-place soil thickness of 4 feet or canpacted soil liner
thickness of 3 feet, greater than or equal to 30 percent passing
a number 200 sieve; liquid limit greater than or equal to 30;
a plasticity index of greater than or equal to 15; and an
artificial liner thickness of 30 mils or greater. Some typical
liner materials include clay, rubber, asphalt, concrete and
plastics such as Hypalon (a chlorinated polyethylene plastic)
2-6
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and FVC (polyvinyl chloride). The water table should be at
least 50 ft below the lowest level of the landfill and adequate
provision should be made for diversion and control of surface
run off. If the soil is massively impermeable, the level can
be as little as 5 feet to the water table.
(3) Monitoring wells are provided.
(4) Leachate control and treatment (if required).
(5) Three-diinensional records of burial coordinates to avoid any
chemical interactions.
(6) Registration of the site for a permanent record of its location
once filled.
At this time there are no secured sites known to be approved
by the regional administrator for disposal of PCBs. For further detail on
criteria see Appendix B, Sections 761.41 and 761.45(b).
2.4.2 General Engineering Considerations
Chemical waste landfills should be sited to take advantage of
geologic factors responsible for optimum, attenuation of the wastes and any
decomposition products, and designed to overcome the disadvantages posed by
less favorable sites.
In selecting and evaluating a chemical waste landfill site,
sane general criteria to be considered are:^
(a) Chemical waste landfills ideally should be located in
areas of low population density, low alternative
land use value, and low ground water contamination
potential.
(b) All sites should be located away fron flood plains,
natural depressions, and excessive slopes.
(1) Battelle Pacific Northwest laboratories, Program for the Management of
Hazardous Wastes, (EPA Contract No. 68-01-0762), Richland, Wa.,:
July 1S73.
2-7
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(c) All sites should be fenced, or otherwise guarded to
prevent public access.
(d) Wherever possible, sites should be located in areas
of high clay content due to the low permeability and
beneficial adsorptive properties of such soils.
(e) All sites should be within a relatively short distance
of existing rail and highway transportation.
(f) Major waste generation should be nearby. Wastes
transported to the site should not require transfer
during shipment.
(g) All sites should be located an adequate distance from
existing wells that serve as water supplies for human
or animal consumption.
(h) Wherever possible, sites should have low rainfall and
high evaporation rates.
(i) Records should be kept of the locations of various
hazardous waste types within the landfill to permit
future recovery if economics permit. This will help
facilitate the analysis of causes if undesirable
reactions or other problems develop within the site.
(j) Detailed site studies and waste characterization
studies are necessary to estimate the long-term
stability and leachability of the waste sludges
in the specific site selected.
(k) The site should be located or designed to prevent
any significant, predictable leaching or run-off
frcm accidental spills occurring during waste
delivery.
(1) The base of the landfill site should be a suffi-
cient distance above the high water table to prevent
leachate movement to aquifers. Waste leachability
2-8
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and soil attenuation and transmissivity character-
istics are important in determining what is an
acceptable distance. Evapotranspiration and pre-
cipitation characteristics are also important. The
use of liners, encapsulation, detoxification, and/or
solidification/fixation can be used in high water or
poor soil areas to decrease ground water deterioration
potential.
(m) All sites should be located or designed so that no
hydraulic surface or subsurface connection exists
with standing or flowing surface water. The use
of liners and/or encapsulation can prevent hydraulic
connection.
(n) In arid regions where the cumulative precipitation
is less than the evapotranspiration, water will not be
likely to accumulate in the landfill or migrate through
the soil. Under such conditions, leachate containment
precautions (liners, etc.) will not be necessary unless
the water table is high or large quantities of liquid
wastes are disposed.
(o) Unless leachate generation or escape is prevented in
sane manner, such as by encapsulation, location in
arid regions or naturally impermeable basins, or by
irrrnediate cover with an impermeable membrane to prevent
infiltration, it will be necessary to line the basin
with an impermeable mmbrane, collect the leachate in
headers, and recycle it through the fill or pump it to
an appropriate treatment facility.
(p) All liners, cover materials, and encapsulating materials
must be tested or have known chemical resistance to the
materials it will contain or might otherwise cane in
2-9
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contact with. Ideally, such materials should have
effective life greater than the toxic life of the wastes
they contain.
Cq) Studies will be necessary to determine general site
monitoring requirements, Hydrogeological monitoring
will be required to detect routine and accidental
releases of liquid effluents. A system of observation
wells should be installed in aquifers around the site
and concentrated in potential water and waste movement
paths downgradient frcm the site. A monthly sampling
frequently has been suggested by one source. Down-
stream monitoring stations and a bimonthly sampling
frequency were suggested for surface streams in the site
vicinity.
Monitoring wells are necessary for the safe operation of a
chemical waste landfill. Prior to the deposition of hazardous wastes, observa-
tion and monitoring wells should be installed around the periphery of the
site. locations should be determined by the appropriate regulatory author-
ities based on the site topography and hydrogeological conditions. A recent
OSW documented case history^ illustrates the importance of monitoring wells.
A company in the north central United States had utilized the same dump site
for laboratory waste disposal since 1953. More than half of the waste dumped
was arsenic. Although the monitoring wells around the site were superficial
in nature, arsenic concentrations greater than 175 ppm were detected. The
U.S. Public Health Service drinking water standard for arsenic is 0.05 ppm.^
The dump site is located above a limestone bedrock aquifer which supplies
about 70 percent of a nearby city's residents with drinking and crop irriga-
tion water. Indications are that this water is in danger of being contaminated
(1) Office of Solid Waste Management Programs. Report to Congress: Disposal
of Hazardous Wastes. CSW-115) Washington: U.S. Environmental Protection
Agency, 1974.
2-10
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by arsenic seepage through, the bedrock. Without monitoring wells, this
waste transport would not have been detected, and serious illness could
have resulted.
2.4.3 Currently Available Chmical waste Landfills
A 1977 Office of Solid Waste survey of hazardous waste
management facilities indicated sixteen with "secured" or chanical waste
landfill sites, m order to assess the capabilities of existing sites to
handle these PCB-contain±ng solid wastes, these facilities were contacted,
disposal costs were updated, and the estimated operating life of each fill
and its willingness to accept PCB-containing solid wastes ware ascertained.
Fifteen of the sixteen landfill sites surveyed indicated a
willingness to accept PCB-containing solid wastes such as capacitors and
transformer internals although many indicated that they have not had re-
quests for disposal of such items. The fifteen sites are scattered through-
out the country: nine Class I landfill sites in California, one in Idaho, one
in Illinois, one in Nevada, two in New York, and one in Texas. The one
secured site which indicated it could not accept PCB-containing solid waste
is located in Missouri. Private companies operate four of the Class I land-
fill sites in California and five others are operated by local jurisdictions.
Hie landfills run by county jurisdictions serve only a limited locale and
this could pose problems in adequate disposal capacity.
The California sites are regulated by the California State
Department of Public Health and must meet the following criteria:^
(a) Geological conditions are naturally capable of preventing
hydraulic continuity between liquids and gases emanating
fran the waste in the site and usable surface or ground
waters.
(!) California State Water Resources Control Board, Disposal Site Design and
Operation Information, Sacramento: March 1975, p. 19-21.
2-11
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(b) Geological conditions are naturally capable of preventing
lateral hydraulic continuity between liquids and gases
emanating fran wastes in the site and usable surface or
ground waters, or the disposal area has been modified to
achieve such capability.
(c) Underlying geological formations which contain rock
fractures or fissures of questionable permeability must be
permanently sealed to provide a competent barrier to the
movement of liquids or gases frcm the disposal site to
usable water.
(d) Inundation of disposal areas shall not occur until the
site is closed in accordance with requirements of the
regional board.
(e) Disposal areas shall not be subject to washout.
(f) Leachate and subsurface flow into the disposal area
shall be contained within the site unless other dis-
position is made in accordance with requirements of the
regional board.
(g) Sites shall not be located over zones of active faulting
or where other forms of geological change vrould impair the
competence of natural features or artificial barriers which
prevent continuity with usable waters.
(h) Sites made suitable for use by man-made physical
barriers shall not be located where improper operation
or maintenance of such structures could permit the
waste, leachate, or gases to contact usable ground or
surface water.
(i) Sites which catply with a,b,c,e,f,g, and h but would be
subject to inundation by a tide or a flood of greater
than 100-year frequency may be considered by the regional
board as a limited Class I disposal site.
2-12
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The other sites ccmply with, the criteria and are licensed by
their individual state or local permitting authorities.
These landfills range in size frcm 32 acres to 1,300 acres.
Howaver, the areas of each site which are currently active range frcm one to
30Q acres. Most of the landfills were indicated to have sufficient operating
capacity for expansion and operating lives in excess of 10 years.
A site-by-site listing of pertinent information is given in
Appendix C. This data was gathered frcm both the 1975 and 1977 Survey of
Hazardous Waste Management Facilities, and frcm phone contacts with know-
ledgeable personnel at each site.
2.4.4 Costs of Chemical Waste Landfill Disposal
Costs for disposal in chemical waste landfills are highly
variable and are dependent on location and area serviced. Landfills in
California are county-operated to service specific nearby locales and have
relatively low charges plus additional state fees.
Sites which service a number of states typically charge from
$1,00 to $10.00 per cubic foot of material disposed including freight and
imposed state fees. The lower costs are largely attributable to California
and the West where climate and geology allow location of Class I landfill
sites close to the counties which are serviced. The facilities in the East
must provide impermeable liners and more stringent monitoring and leachate
controls, thus making disposal more expensive.
A representative average cost of $3.00 per cubic foot is felt
to be a reasonable nationwide average for the disposal of PCBs in chemical
waste landfills. Although the specific requiranents in the proposed regula-
tion may result in one or more of the currently operating landfills not being
able to accept PCBs, no major impacts of the regulation on the availability
or costs of such disposal is anticipated.
2-13
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2.5 Incineration
2.5.1 Existing Incinerator Facilities.
2.5.1.1 Liquid Waste Incinerators
During the performance of Task II under this contract,
it was determined that the facilities listed on Table 2-1 are the existing
ocnroercial scale incinerators which, are capable of handling PCBs liquid wastes.
Monsanto has a John Zink designed, forced draft
incinerator at Sauget, 111. that vaporizes the PCBs liquids and waste oils
and maintains a turbulent burning gas at 2200°F for about 2 seconds. General
Electric at Pittsfield, Mass. uses a John Zink designed, induced draft incin-
erator with a combustion temperature of 1600°F to 1800°F and a residence
time of 3 seconds or longer depending on the concentration of PCBs in the
industrial oil.
Rollins uses specially designed units at three loca-
tions: Bridgeport, N.J., Deer Park, Texas, and Baton Rouge, La. Bollins'
basic incinerator is a Dow design? however, reportedly, since 1972 Bollins
has made significant modifications to the incinerator-scrubber unit. Hie
Rollins unit includes a solids burning rotary kiln that exhausts to an after-
burner plus a liquid turbulent burning chamber which also exhausts to the
afterburner. Liquids can be burned either in the liquid chamber or in the
kiln. The afterburner is 40 feet long and is followed by a hot duct of
about equivalent length that allows further combustion. Rollins claims an
overall residence time of 3 to 4 seconds, at a minimum temperature of about
2400°F at the aft end of the hot duct. The gases then go to a Venturi scrubber
and a tower scrubber for cooling and neutralization.
The Dow Chemical Plant in Midland, Michigan operates
four liquid cambusters to destroy in-house industrial liquids.
Liquid PCB wastes as handled by the commercial dis-
posers are normally diluted with waste solvents to a 5-10 percent by weight
PCB level, prior to incineration. Average heat of combustion of the blended
2-14
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TABLE 2-1
Existing PCBs Liquid Waste Incinerators
tsj
\
M
in
Facility
i-ocat ion
G.E. ,
Pit tr,field,
Mass.
Uwm-Trol
Midfd City,
N.V.
tollins'2'
EnviioniiK\nt;al
services
Midland, Mi.
Monsanto
Sauyot, 111.
Annual,..
, (•>)
(ViprtCity
liters ( 51.5 x 10s ('1)
(13.6 x 10")
2.4 X 10'
(0.61 x I0b)
each
'typical Ojieratincj
TVai^xsrature Range
8/l-1093°C
(1C00--2000°F)
liwc
(2700°F>
ui6-u>o°c
(24OO-2S0QrtK)
982°C
<1800°F)
um-uo-rc
(2000 2200°F)
Residence
time, sec.
1 to 12
1-1
<2
Typical Feed
Rate
Jmi(ijHti)
Up lo 15.1
(4)
(Jp to 52.9
(111)
Up to 60.5
(If.)
31. 1
(-8)
;.6
(2)
Air Pollution
Controls
Packed lower
Scrubber
Si-1 ul in a*
Alt ciiixii ner,
Venturi Scrubber, &
a Park** I
scruiijer
lllqh Pressure
Ventiiri willi
Oemister
Hiqh Pressure
Vantur i Sri ulrt*F?r
foliow&l by a Packed
Tt>w«er r,c:rul^*.*r
Draft
Induct*)
forced
Forced
Forcod
Forced
Af>proximate
System Cost, 5
(gjst basis)
450,000 (1974)
2,500,000 (I 974)
790,000 (1970)
(b>
(1) Industrial oil which is contaminated with approximately 2 wt'i K'Bs.
(2) 'Hiree identical unit"?; (kiln, lkpiid dcsl i urt ion clwiNlmr & an aftrrljtirmu ) loralod on<» each at Bridije^ort, N.J., rXi*r Par k# TV-xa*;
and Daton Rouge, la.
(3) Four conibusters to destroy in-honse industrial liquids.
(4) Rstinut ed oajjaoil.y of the four ctnilnister s.
(5) 'Hiere are differences of opinions as to optirrajn tarperatiire level and residence tin*? for PCBs incineration. Capacities given are
reported values based on incineration ol undefined fcodytocks. Thu capability of ttiesc units for PCBs destnjetion can be only
determined if a given doctored feed arri a specific test plan is used to evaluate and compare the performance of titese units.
(C) An additional $160,000 was spent for modification during 1970-74.
(7) This unit has been shut dowi since 1974. ChenvTrol ships liquid PCBs to the St. Lawrence Cement Co., Mississauqa, Ontario, Canada,
as blends In wast:
-------
material is 9-10,000 BOT/lb. .Monsanto has been burning liquid PCBs on an as-
received basis. General Electric has been burning PCB-waste oil mixtures
(as a supplemental fuel to natural gas), with PCB concentrations as high as
20% by weight. General Electric has been successfully burning 1260 type
Aroclor with 60% chlorine content; this is believed to be the most refractory
material being destroyed by incineration.
The incineration units described above can be
categorized as liquid injection type incinerators. Injection type incinera-
tors increase the rate of vaporization and thus combustion by atanizing the
liquid waste to create a larger heat transfer surface area. Normally, this
is done by means of internal mixing nozzles and steam atomization. Forced
draft and/or induced draft is supplied to the canbustion chamber to provide
the necessary mixing and turbulence.
The General Electric, Monsanto and Rollins facilities
are examples of vortex ccmbusters. Such units typically feature very high
heat release rates e.g., 100,000 BTU/hr - ft3. In operation the ignition
chamber is preheated and the waste and primary air are introduced in such a
manner as to create a vortex which is maintained through the length of the
ocmbuster.
2.5.1.2 Solid Waste Incineration
General Electric*s incinerator at Pittsfield, Mass.
has partial solid waste incineration capability. This facility can handle
PCB soaked transformer internals in a high temperature incapsulator for waste
incineration and copper recovery. This unit destroys paper, rags cardboard
and the like but it does not handle fuller's earth contaminated with PCBs
(used for PCBs filtration), contaminated dirt and similar materials.
Rollins uses their Bartlett-Snow tumble burners (the
rotary kilns) for handling solid wastes of almost all types. For PCBs con-
taminated materials, the kiln is operated at 2200°F. The gases frcm the kiln
pass to the afterburner operating at a temperature of 2500°F. They exit the
2-16
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the afterburner to a long hot duct that completes combustion and maintains
the temperature to 2400°F until the gases enter the Venturi scrubber. Rollins
accepts solid wastes which are packed in 35 or 47 gallon lined fiber packs,
or in standard steel drums. Solid PCB wastes are fed to the tumble burner
only in the fiber packs. The liquid contents of steel drums are mechanically
transferred to a storage tank prior to blending and incineration. Rollins
will not accept impact sensitive, radioactive materials, or heavy metals
concentrations in the PCBs wastes of generally greater than 25 ppn. As a
general rule, Rollins will accept solid wastes which are packed according
to the latest ICC tariff for hazardous materials.
2.5.1.3 Costs of PCBs Incineration
Current toll charges for disposal of PCBs by incin-
eration are as follows:
PCBs
Toll Incineration
Disposal Facility
Waste
Charge(1)
Monsanto, Sauget, Illinois
Liquid
10C/lb(2)
Chem-Trol, Model City, N.Y.
Liquid
7-9 l/2
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2.5.2 Comrents on Draft Liquid PCBs Disposal Regulations
The draft liquid PCB waste incineration regulations
(Sec. 761.40) provide for the. following combustion criteria:
A. 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
B. Maintenance of the introduced liquids for a 1 1/2 second
dwell time at 1600°C (± 100°C) and 2 percent excess oxygen
in the stack gas.
C. Combustion efficiency shall be at least 99 percent based
on:
CCO2 .- Ceo
Combustion Efficiency = x 100
where:
Ceo2 = concentration of carbon dioxide
Ceo = concentration of carbon monoxide
Cc&Tments on these and other parts of this section are presented below:
2.5.2.1 Rollins Environmental Services, Inc.
This ccrrmercial disposer believes that the proposed
temperatures and dwell times, while in the right range, represent a "tight"
condition, i.e., they would rather see a minimum combustion temperature of
1316°C (2400°F) {which their equipment is capable of rraintaining) and 3-4
seconds dwell time as a minimum. They seriously question the availability
of equipment for continuous trouble-free monitoring of oxygen, carbon monoxide
and carbon dioxide. They believe that a suggested 1 ppb PCBs ^ level in
the scrubber waste water is achievable by use of a water cleanup systan such
as activated carbon or ozonolysis. They have never encountered CO in the
incinerator stack gas, so maintenance of at least 99 percent combustion
efficiency is not a problem.
(!) Not in the draft PCB disposal regulations.
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2.5.2,2 General Electric Co., Pittsfield, Mass.
This General Electric.division has been disposing
of waste liquid PCBs by incineration since 1972 both for themselves and for
other divisions of the company. Their experience with liquid PCB incinera-
tion indicates that given the proper incinerator geometry and flame distri-
bution and properly blended PCB-fuel feed, a combustion tarperature of 871-
982°C (1600-1800°F) with a minimum 3 second dwell time will effectively
destroy PCBs. A combustion temperature below 1093°C (2'000°F) would limit
NO generation, permit the use of standard refractory firebrick (rather
X
than the very costly high temperature brick), and result in longer equip-
ment life. This unit has operated 24 hours per day, 7 days per week, for
approximately 5 years at an average feed rate of 60 gallons per hour with a
total replacement of 40 individual firebricks during this time.
Another important consideration in PCB incinerator
operations, according to G.E., is the type of air movement used, e.g.,
induced draft versus forced draft. An inspection of Table 2-1 shows that
only G.E.'s incinerator is of the induced draft type. This mode of operation,
where the incinerator is always under slight negative pressure, prevents
the penetration of HC1 through the firebrick which wDuld otherwise cause
extensive corrosion of the metal incinerator shell. This type of corrosion
was observed on the Chem-Trol incinerator during a recent visit to the
Model City facility by Versar personnel. The shell had becarte so badly pitted
that a steel "bandage" had to be placed around a portion of the unit.
General Electric believes that more realistic
criteria for disposal of liquid PCBs by incineration should include:
a) Limits on PCB level of gaseous enissions
b) Limits on PCB level in scrubber water effluent
In effect these two limits define a "destruction efficiency".
CI) Office of Solid .Waste. Management Programs, U»S,. Environmental Protection
Agency, Hazardous Waste- Management Facilities in the united States
(EPA/53O/SW-146.3), NTCS PB-262 917/8WP, January 1977.
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2.5.3 New Incinerator Facilities
B^spr] on the latest EPA national survey of ccnroercial hazard-
ous waste incineration facilities, there are approximately twenty liquid
waste incineration operations which will not or do not handle PCBs.^ There
are three installations which, presently have the capability of handling
both- solid and liquid PCB wastes and which have the presently required environ-
mental approvals. There are two installations which have liquid PCB inciner-
ation capability and one installation with both solid and liquid PCB waste
incineration capability which are awaiting state operating permits. There is
one facility, presently shut down, which has state authorization (as of 1974)
to dispose of liquid PCB wastes. The two liquid PCB waste incineration
operations carried on by industry - General Electric at Pittsfield, Massa-
chusetts^ and Monsanto at Sauget, Illinois, will be both shut down well
before the proposed disposal regulations take effect. Various technical and
economic factors will affect incinerator design once the proposed new regu-
lations take effect.
2.5.3.1 New PCBs Incinerator Design Bases
The three currently operating incineration facilities
with, both liquid and solid PCB disposal capabilities are all owned by Rollins
Environmental Services, Inc. These units are located in Logan Township, N.J.,
Baton Rouge, Louisiana and Deer Park, Texas, and each serves a five to six
state area. Data from a recent test burn of shredded capacitors at the Deer
Park (Houston) facility indicated that this unit processed approximately 700-
(2)
8Q0 pounds per hour of shredded capacitors containing 20 percent PCBs.
This burn resulted in a PCB destruction efficiency of greater than 99.99 per-
cent. The residue frcm the burn contained approximately 0.1 ppm PCBs. Total
dwell time was 2.5 seconds and combustion temperature ranged from 2,000 to
2,400°F. Number 2 fuel oil was used for a heat supply and 1.3 gallons of
fuel oil was consumed per pound of PCB contaminated waste feed. A test burn
(1) This facility is scheduled to cease PCB incineration as of April 15, 1977.
(2) Personal Conmunication, Mr. Gene Crumpler, USEPA, OSW, March 10, 1977.
2-20
-------
was also conducted on whole capacitors. PCBs level in the gaseous emissions
during this test was less than Q.001 grtyTcg of feed, Howsver, the solid
residues had close to 500 ppn of PCB making this material unacceptable for
disposal in a sanitary landfill according to the proposed EPA disposal regu-
lations. Based on this admittedly limited data, it is believed that the
PCB capacitor disposal operation should be conducted with shredded feed
material. Figure 2-1 presents a schanatic of the Deer Park, test PCB burn.
In order to conform to the proposed incineration
regulation, the Deer Park unit would have to be modified with suitable instru-
mentation to continuously measure the concentration of carbon dioxide, carbon
monoxide, and oxygen in the stack emissions. In addition, suitable milling
equipment would be required to be installed in order to supply the shredded
capacitor feed to the Houston unit.
Rollins personnel believe that an improved shredding
action is needed to break up the capacitors prior to incineration.^ The
Gruender hammer mill used to prepare the Houston feed caused a great deal of
spraying and fragmenting of the PCBs and PCB-bearing material during the
pulverizing operation. Rollins favors a tearing or shredding operation, such
as provided by a finger-like or claw-like action which imposes more torque
and less impact energy in comparison to a harrmer mill. They are evaluating
other shredders, and expect to make a decision on acquisition of a shredding
unit in the near future. Improved shredding is expected to increase incinera-
tion capacity significantly. Estimates are as high as 5,000 #/hr, but tests
are needed to find out just how much of a gain can be made. Kollins is also
considering running two rotary kilns in parallel feeding the rest of the
incinerator train in order to double the capacitor handling capacity.
The scrubber water discharge from the Deer Park test
turn contained 5-10 ppb of PCBs. This concentration range is given as
representative of the three Rollins operations. ^ A 1 ppb PCB level in the
(!) Personal Comiunication, Mr. C. E. Ashby, Rollins Environmental Services,
inc., Logan Township, N.J., March 21, 1977.
2-21
-------
ITA MflllOO s
SAMrilUG
IXA.lt I
vmr —-
Villi
MISI UIMIHAIOft
AAWMiriKHI
It AYS
D
LJJl,
- PCD CAPACITOIIS
IIODIDS, OASIS
VORIEX
111 mi if it
r
soims,
StMl -S( »l ll>S_
I IMF
KOIARY
Kim
u
in(iii uiumy
vi i mini s( nimiim
IIIIXIQD IIRAri IAII5
THIS OPERATION
PRESENTLY DONE
ELSEWHERE
COIIVIYOR
WAS If
llll)
inn KAir/in WAim,
rAiitmiu rAmiriiiAifj
lio roiin)
FIGURE 2-1 SCHEMATIC OF ROLLINS ENVIRONMENTAL SERVICES INCINERATOR AT HOUSTON
SET UP FOR PCB CAPACITORS TEST BURN
Source: TfW Systems Group, Destructing Chemical Wastes ill Conner cial Scale Incinerators,
Facility Teat Plans, Vol II, (tJTIS PB-257 710), July, 1975, page 26.
-------
effluent is believed to be practicably attainable through, the use of activated
carbon treatment. Equipment for this purpose would include a fixed bed
system containing actiyated carbon and suitable filtration equipment to
remove particulate frcm the feed to the carbon bed. The spent carbon would
be incinerated in the rotary kiln unit after suitable dewatering.
2.5.3.2 New PCB Incinerator Facility Cost Estimate
A preliminary estimate for the cost of a complete
shredded capacitor disposal unit based on the Houston design is $5 million,
installed. Such, a unit would be capable of processing 3000 lb/hour of
(2)
shredded capacitors. The same unit could handle 500-1000 lb/hour of
liquid PCB wastes as a blend in the fuel feed to the incinerator. A break-
down of the investment cost for the dual purpose unit is shown in Table 2-2.
The annual costs of operation have been determined based on data frcm the
Houston facility test burn of shredded capacitors and engineering estimates,
and are tabulated in Table 2-3. All costs shown are in 1977 dollars.
The unit cost of 52 C/lb. for solid PCB waste disposal
represents an upper bound for this cost. The major cost item involved - fuel
aost, can be averaged down by using inexpensive waste solvents as fuel. This
(2)
is the current practice of canmercial incineration facilities.
Figure 2-2 is a plot of PCB solid waste incineration
capacity versus total annual operating cost. A 0.6 exponent was used to
adjust the respective plant investment costs. Inspection of Figure 2-2 in-
dicates a rapid rise in total per pound cost above a plant capacity of 2000
lb/hour of solid PCBs. Operating cost becomes relatively insensitive to
plant capacity above a rate of 4000 Ib/hr.
CI) Personal Cteranunication, Mr. Richard Fusco, Calgon.Corp., Pittsburgh, Pa.,
March 30, 1977. This statement is qualified/by the need for experimental
verification using the. actual scrubber water effluent.
(2) Personal Coniuunication, l^r. C. E. Ashby, Rollins Environmental Services,
Inc., Logan Township, N.J,, March. 21, 1977.
2-23
-------
Table 2-2
Preliminary Engineering Estimate of a Dual Purpose
PCBs Incineration Facility
Plant Capacity; 3000 Ib/hr shredded PCB capacitors
500 Ib/hr PCB liquids
Equipment
Shredding and Solids Conveying Equipment
Rotary Kiln, Afterburner, Liquid Ccmbustor
and Associated Ducting
Scrubbing Equipment, Tankage, Pumps
Stack, Foundations, Site and Site Preparation
Activated Carbon Treatment System including Activated
Carbon Beds and Filtration System
Settling Pond System
Piping and Valves § 25%
Engineering @7%
Contingency @20%
Sub-Tbtal
Sub-Tbtal
Sub-Total
Total
Say
Installed Cost
100,000
2,000,000
500,000
150,000
250,000
100,000
3,100,000
775,000
3,875,000
270,000
4,145,000
830,000
4,975,000
$5,000,000
2-24
-------
Table 2-3
Annual Operating Costs for PCB Capacitor Incineration
Plant Capacity: 3,000 lb/hr of shredded PCB capacitors
500 lb/hr of PCB liquids
Operating Factor: 7300 hours/yr
Capital Investment: $5,000,000
Variable Costs
Fuel Oil (#2) 21,900,000 gal, @ 40C/gal(1) 3,760,000
Direct Operating Labor, 2 men/shift @ $9/hr 157,000
Supervision and Administrative @ 50% of direct 79,000
operating labor
Activated Carbon System^ 122,000
Maintenance @ 20% of capital investment 1,000,000
Power, 100,000 kwh @ 3<^/>cv^i 3,000
Sampling and Analysis 100,000
Waste Disposal, 9,000 TPY @ $10/ton<3) 90,000
Tbtal Variable Costs 10,311,000
Fixed Costs
Capital Recovery Rate (10 yrs @ 10%) 814,000
Taxes and Insurance 0 4% of capital cost 200,000
Total Fixed Costs 1,014,000
TOTAL ANNUAL COST 11,325,000
Cost/lb of PCB Solid Waste $0.52
(1) Assuming a 1:1 fuel oil/solid PCBs feed ratio. This is
approximately 30% lower than data from recent EPA sponsored
test of incinerating shredded capacitors by Rollins at Houston.
(2) This includes replacement of 43,000 lb/yr of spent activated
carbon and incineration of the spent carbon in the PCBs facility.
(3) Assurances were given by the EPA that the ash disposal
requirements in the draft regulation vrould be revised to
allcw sanitary land-fill disposal of ash having insignifi-
cant levels of PCBs.
2-25
-------
Figure 2-2
PCBs Incineration Cost as a Function of
Plant Capacity'
I
t
\
0.70—
0.60-^
0.50'
0.40-
0.30
1000
2000
3000
4000
5000
6000
1
0
Capacity, Pounds Per Hour
of Solid PCB Waste
2-26
-------
2.5.3.3 Factors Affecting Expansion of Cartnercial Incinera-
RES, Die. (Rollins) appears to be the only coimercial
waste disposer with. currently available incineration capacity and know-how
to handle PCB solid wastes. Rollins is ready to consider building new incin-
eration facilities when market research shows that the economics are favor-
able, that the states are going to enforce hazardous and toxic substance
regulations and restrict landfill uses, and where the local political climate
is favorable to the establishment of a modern waste treatment facility.
Rollins estimates that new facilities could be installed and running at their
existing installations by early to mid 1979 assuming inmediate assurances
from EPA as to the "teeth" in the proposed new PCB disposal regulations.
For any new incineration facility installed anywhere
in the country, approval of an environmental impact statement, and obtaining
of local and state approvals, could cause delays of from one to two years
before orders could be placed for equipment. It would seem probable that the
best course of action for near-term disposal of significant amounts of PCB
solid wastes by incineration would be the expansion of existing facilities
even though this would entail excessive transportation costs for waste genera-
tors located at considerable distances from these sites.
2.5.4 Cement Kiln Operations
15ie possibility of disposing liquid PCBs in existing cement
kiln operations needs to be evaluated as an alternative to incineration in
the relatively few incinerators meeting EPA's proposed disposal requiranents.
Cement kilns normally operate at 3000°F flame temperature and dwell time of
a few seconds to as much as a minute. Preliminary tests at the St. Lawrence
Conent Co., Mississauga, Ontario, Canada, have been conducted during 1975
and 1976 under the sponsorship of the Canadian Environmental Protection
Service, using mixtures of highly chlorinated hydrocarbons (including up to
2-27
-------
(1 2)
50 per cent PCBs) as partial fuel input to the cement kiln. ' These
materials were destroyed in the cement kiln with at least 99.98 per cent ef-
ficiency in all cases. Emissions of high molecular weight chlorinated hydro-
carbons were not detected. Tentative recorrmendations are:
(a) Chlorinated hydrocarbon wastes may be used in cement kilns,
replacing other forms of chloride ion (such as calcium
chloride) used for reduction of alkali content.
(b) A small proportion of fossil fuel required for cement manu-
facture is conserved through use of these materials.
(c) Burning chlorinated hydrocarbon wastes is considered a
valuable means of destroying persistent and toxic forms of
pollutants while recovering useful heat values.
Recent test runs at the Peerless Cement Company, Detroit,
Michigan, have confirmed the St. Lawrence Cement Co. results.^ In the
Peerless tests, waste Aroclor 1260 from the Detroit Edison Co. was injected
directly into the hot zone of a wet process corient kiln. There was no
detectable increase in stack PCB emissions over background levels.
(1) McDonald, L.P., (St. Lawrence Cement Co.), D.J. Skinner (Environmental
Canada), F.J. Hopton and G.H. Thomas (Ontario Research Foundation), Burn-
ing Waste Chlorinated Hydrocarbons in a Cedent Kiln, for the Petroleum
and Industrial Organics Chemicals Division, Water Pollution Control
Directorate, Environments1 Protection Service, Environment Canada, Report
No. EPS 4-WP-77 (unpublished report) 1977.
(2) As a result of the incineration studies at the St. Lawrence Cement Co.,
Chem-Trol Pollution Services (one of the participants in these studies)
has received a U.S. Patent No. 4,001,031 covering the use of chlorinated
hydrocarbons as a blending material in the cement kiln fuel. The basic
claim of this patent is that the potential K2O content of c extent clinker
due to the presnece of potassium compounds in the raw feed mix is sub-
stantially eliminated by introducing a chlorinated organic waste product
into the kiln along with or in conjunction with the fuel used to fire the
kiln. The destruction of the chlorinated material in the kiln liberates
HC1 which is effective converting K2O to KCl.
(3) Personal Gcmnunication, Mr. Myron W. Black, Dir. of Env. Control, Peer-
less Cerent Co., Detroit, Michigan to Mr. Karl Bremer, USEPA Region 5,
Chicago, Illinois, March 7, 1977.
2-28
-------
There are relatively few cenent kiln operations which could
atiploy waste liquid PCBs as a fuel blend in their operations (most cement kilns
are now coal-fired} and which, would benefit from reduction in calcium chloride
requirements. Preliminary discussions with industry representatives indicate
that there could be a problem of handling the highly toxic PCBs (prior to
injection in the cement kiln) by operators not familiar with the hazards of
these materials. Also, there would be a marked increase of volatile alkali
chlorides in the electrostatic precipitator dusts. These dusts are reused in
sane plants and appreciable concentrations of alkali chlorides limit the use
of the recycled material. Some corrosion problems could also develop in
dust collection ductwork and in chain sections. The waste liquid PCBs would
be most advantageously atiployed in those kilns using fuel oil as a source of
heat input.
The measurable benefits of PCB liquid incineration may be
marginal to cement kiln operations, primarily resulting fran slightly reduced
fuel costs. The only clear-cut benefit is in providing additional incineration
capability for the waste liquid PCBs. The potential disposal rate for waste
liquid PCBs is approximately 18,000,000 pounds per year over the next few
years, with a gradual decline thereafter. Current disposal charges are in the
1Q-15 C/lb range. Coirmercial incineration of liquid PCBs is therefore a sub-
stantial potential source of revenue for cement kiln operations.
2.5.5 Power Boilers
Tests have been conducted to determine the feasibility of PCB
destruction in a power boiler. ^ This unit apparently has no flue gas scrub-
bing equipment so that PCBs level in power boiler scrubber water could not be
determined. The PCB concentration in the boiler fuel feed was approximately
4 ppm. Only liquid PCBs were incinerated.
(1) Environmental Science and Engineering, Inc., Report On PCB Bflissions Fran
Sanford Unit No. 4, Florida Power and Light Company, May 1976.
2-29
-------
The PCB incineration results are considered, preliminary as the
various parameters affecting PCB. destruction efficiency, i.e., boiler feed
composition and rate, and ash analysis were not sufficiently evaluated. Com-
bustion temperature and dwell time appear to meet the. proposed EPA disposal
regulations.
2.5.6 Sewage Sludge Incineration of PCBs
(2)
A review of test data indicates that destruction of liquid
PCBs by co-incineration with, sewage sludge is not desirable in that the
average combustion temperatures achieved in this operation (950°-1,150°F) are
sufficient to insure 99.99% destruction efficiency of the PCBs. Criteria for
destruction of PCBs in sewage sludge at levels of ~25 ppm, dry basis, are
(3)
discussed in the Federal Register of Thursday, June 3, 1976, Part IV.
2.5.7 Incinerator Ships
Incinerator ships (as exemplified by the ship M/V Vulcanus
sailing under Dutch registry) can only operate with favorable logistics when
large loads of liquid incinerables are available at one time at a port. The
Vulcanus handles 4,000 metric tons per day. The full charge for a recent burn
of waste chlorinated hydrocarbons for Shell Chemical Co., Deer Park, Texas,
on the Vulcanus was $72/metric ton (~40C/lb). ^
Since the ship's incinerator operations are carried out many
miles from land, there is no need for scrubbing of the gaseous pollutants such
as HC1. The Vulcanus has not yet incinerated any liquid PCBs.
(1) Personal Camiunication, Mr. Torn Fair, Florida Power and Light Company,
Miami, Florida, March 23, 1976.
(2) Versar Inc., Destruction of Polychlorinated Biphenyls in Sewage Sludge
During Incineration, NTIS PB 258 162, 1976.
(3) U.S. Environmental Protection Agency, Municipal Sludge Management;
Environmental Factors, 41 FR 22531 (June 3, 1976), page 22536.
C4) Personal Camiunication, Mr. Neighbors, Universal Shipping, Arlington, Va.,
March. 17, 1977.
2-30
-------
2.6 Transportation Costs
Unit transportation costs depend on mode, region, distance, size of
shipment, type of material or product, and exact city-pair for departure and
arrival.
In this study the wain concern is with, trucking 55 gallon steel
drums of:
PCB liquids from draining transformers
Solvents used to flush drained transformers
Rags, sawdust, etc. used to soak PCB spills
2.6.1 Trucking Posts- '
The American Trucking Association's Classification Board has
assigned the following codes to materials and articles of interest in this
study:
weight (not including the container) of 55 x 11.5 lbs or 632.5 lbs. Shipments
of 500-100 lbs for 0-100 miles cost $4.75 per one hundred pounds in the Mid-
Atlantic Conference. Thus a single drum of PCB liquids weighing 45 lbs empty
and 632.5 + 45 filled or 677.5 lbs gross weight will cost $32.18 for a trip
up to 100 miles. The rates per dran do not increase proportionately with
increasing quantities- or distance of shipment. The rates for various size
shipments of drums of liquid PCBs for distances up to 500 miles are summarized
in Table 2-4 and Figure 2-3.
capacitors
transformers
used electric motors
fluorescent fixtures
electrical oils
155,250 if derived frcm petroleum
43,940 for chemicals not otherwise
indexed
61,400
63,420
62,580
109,830
2.6.1.1 Shipments of Liquid PCBs
Che 55 gallon drum of PCB liquids will have a net
2-31
-------
Table 2-4
Truck. Freight Charges for Sirigle Drums- :
0| ji:ansfQrTner oils
Distances Mid-Atlantic Conference " Tbtal Charge for 677.5 lbs.
?/1QQ
0-100 $4.75 $32,18
100-200 5.16 34.96
200-300 5.51 37.33
300-400 5.87 39.77
400-500 6.24 42.28
Truckload Rates: TL • 30,000 lb Minintum
$/10CF lb $/100 lb
0-100 1.14 1.01
100-200 1.34 1.21
200-300 1.54 1.37
300-400 1.81 1.60
400-500 1.97 1.73
Less than truckload rates for 5000 lb. shipments aix3 up
LTL
$/T50 lb
0-100 2.53
100-200 2.89
200-300 3.23
300-400 3.62
400-500 3.96
Source: S.G. Harold, Exec. V.P., Middle Atlantic Conference
and I.C.C, Statement No. 2C1-75
2-32
-------
IN SINGLE
98 GALLON DRUMS
PUIS $ 0.43 /cwt. PER PLATFORM
HANPL1N0
IN LTL SHIPMENTS
OF 3,000 Ibr AND UP
PLUS t 0.20 /curt PER PLATFORM
HANOUNO
TL LOTS OF 39,000 Ibf.tMAX.)
PLUS $O.I5/ewt PER PLATFORM
HANDLING
TL LOTS OF 30,000 '!«. (Ml N.)
100
200
300
400
SCO
DISTANCE,
SOURCE! 3.3.HAH0L0, EXEC.VP, MIDDLE ATLANTIC CONFERENCE
AND I.C.C. STATEMENT NO. 2CI-7S
Figure 2-3
Trucking Charges for Transformer Oil
by Type of Shipment and Distance
2-33
-------
Even lower shipping costs for liquids 'would result
from shipping 5000 gallon tank, truck, lots. The savings/are achieved both in
the elimination of the. expense of buying (and disposing of) drums, and in
lower transportation and handling charges. The tank truck rates for liquid
PCBs are sunrmarized in Figure 2-4.
2.6.1.2 Shipments of Capacitors and Transformers
The truck transportation rates for shipments of capac-
itors and transformers are summarized in Figure 2-5.
2.6.2 Platform Costs
In addition to charges for intercity hauling, there may be
significant charges for handling at the origin, destination or intermediate
interchange point. Hie latter are more likely to occur when two comnercial
haulers are involved because of limitation on the routes each-may service.
Unit costs for one platform handling for one drum at 677.5 lb
in the Middle Atlantic Region^"' would be 43.2£ per one hundred pounds or
(2)
$2.85 per drum. Thus one conmercial platform handling increases the costs
by 13%, two by 26% and three by 39%. Presumably, similar real costs would
be incurred in private, non-coimarcial loading and unloading, except for
savings possible from use of less expensive non-union or under-utilized labor.
Actually, handling at an interchange involves one unloading and one loading
so the charge is roughly double that of one platform handling.
2.6.3 Other Factors Affecting Transportation Posts
It is significant that platform costs bear heavily on single
drums and especially so if multiple handling is required. On the other hand,
CD This is one of the higher-cost regions and can be considered an upper
bound.
(2} Interstate Oatmerce Commission, Cost of Transporting Freight by Class I
and II Motor Cannon Carriers of General Commodities, 1975, Bureau of
Accounts Statement No. 201-75, December 1976.
2-34
-------
fo
I
u>
<_n
42 00
3900
3600
33 00
3000
2?00
2400
2100
18.00
ISOO
1200
9.00
600
3 00
: i
I..,
I ' !
• • t
I i
I :
111
¦4
LIQUID BULK RATES, PER ICC.
+1
-L
100
200
300
400
500
MILES
600
! I
-L
-T
: I
l.i
700
800
900
1,000
SOURCE- ICC. FREIGHT TARIFF 10050
Figure 2-4
5,000 Gallon Minimum Bulk Shipments Electrical Oil
by Distance
-------
-I h
IN SINGLE
39 3ALL0N DRUMS
PLUS *0.43/ew» PER PLATFORM
HAMOUNO
L _
¦L:
o
a
.1 -
_ !H LTL SHIPMENTS
- OF 5,000 lb«. ANO UP
PLUS * 0 20/ewt. PER PLATFORM
HANDLING
\ --
-|-=rr
PLUS $ 0.15/cwt PER PLATFORM
HAN0LIN8
TL LOTS OF 35,000 lb«. (MAX.)
TL LOTS OF 30,000 lb». (MlN.)
100
200
300 400
DISTANCE ,
500
SOURCE: S.S.HAROLD, EXEC. V.P, MIOOLE ATLANTIC CONFERENCE
AND I.C.C. STATEMENT NO. 2C1-75
Figure 2-5
Trucking Charges for Capacitors and Transformers
Erf Type of Shipment and Distance
2-36
-------
truckloads of drums may involve no intermediate handling beyong exchanging
motor-cabs. Also, the. handling charges that are incurred are smaller. For
example 5000 lb lots would be charged 19.5
-------
The 2000 large storage areas will be required to maintain a perpetual
inventory of all items' or containers in storage. Since the record for each
item must include its weight, origin, and date of entry into the area,
clerical costs of perhaps two dollars per item' might "be expected in addition
to a cost of $200 per area to establish, the record keeping procedure. In
addition, the annual reports will require about one man week per facility
C$400).
In addition, owners of transformers and large capacitors must maintain
records as to their location, estimated date of retiranent, and date of dis-
posal. Costs of establishing such records might be expected to run $5 per
transformer or high voltage capacitor location. Modification of the records
to reflect retiranent of equipment would cost about one dollar per item dis-
posed of.
2-38
-------
3.0 E03NCMIC COSTS OF THE DRAFT DISPOSAL REGULATIONS
3.1 Disposal Demand
The estimated amount (in pounds) of PCB electrical equipment requiring
disposal in 1978 is summarized in Table 3-1.
The proposed regulation requires that all of this material be inciner-
ated with the following exceptions:
• Transformers may be disposed in chemical waste landfills if
they are flushed to remove at least 98 percent of the PCBs
• Capacitors may be disposed in chemical waste landfills until
July 1, 1979
• Small appliance capacitors and fluorescent light ballasts in
private residences may be disposed in sanitary landfills
• Small capacitors (and presumably fluorescent light ballasts
and HID capacitors) need not be removed from equipment which
is disposed in sanitary landfills.
Because of the higher costs of incineration, it may be assumed that few capaci-
tors will be incinerated until after July 1, 1979. The upper bound estimates
of incineration requirements are shown below in option 1 which assumes that all
PCB capacitors are removed fran equipment before it is scrapped. Option 2 is
probably a more realistic estimate of disposal requirements as it assumes that
2/3 of all small appliance capacitors, HID capacitors, and fluorescent light
ballasts are not removed fran the equipment, but are disposed of as municipal
solid wastes with the equipment. Option 2 still results in the requirement to
incinerate large numbers of fluorescent light ballasts from commercial and
industrial buildings. The PCBs in these ballasts are very well contained, and
little migration would be expected in a landfill. Therefore, option 3 is
suggested as a less expensive disposal alternative which differs fran option 2
only in that it allows the continued disposal of fluorescent light ballasts in
chemical waste landfills.
3-1
-------
Table 3-1
Disposal Requirements for PCB Electrical Equipment in 1978,
millions of pounds
TRANSK3KMEKS
CAPACITORS
Source
PCB Liq.
Solvent
Trans.
I^arge
liiyh
Voltaqe
Flu Light
Ballasts
Hi Intensity
Licjht Bal 1.
Large Low
Voltarje
Small
Appliances
Utilities
6.3
4.7
13.6
45.6
-
.3
1.3
-
Large Residential
and Camercial
2.1
1.6
4.6
-
146.0
2
10
1.7
Industrial
2.1
1 .6
4.6
2.4
30.4
7.7
10
-
Private
Fteaidential
-
-
-
-
9.5
Negligible
5.4
15
lY>tal
10.5
7.9
22.8
48
186.7
10
26.7
16.7
-------
The disposal requirements for the year following July 1, 1979, are
surrtriarized in Table 3-2 for each of these three options. As PCB electrical
equipment is removed frcm service, the disposal requirements would be expected
to decrease at a rate of about 7 percent per year.
The effect of the various options on the disposal of PCBs is summa-
rized in Table 3-3.
3.2 Decontamination
We do not see much use of decontamination to reduce the PCB level in
equipment because of the potential liability frcm accidental spills of PCBs.
There will be some initial decontamination, of tank cars, tank trucks,
and production machinery as production of new PCBs is phased out. This will
not have a major effect on requirements for incineration or total economic
impacts. Any decontamination of electrical equipment performed after this
initial period will result in a slight decrease in the costs shown for incin-
eration, but the effect should not be significant.
Effective decontamination has been achieved for drums and small con-
tainers contaminated with pesticides. The decontamination procedure requires
triple rinsing of the containers with solvents which contain less than 0.05
percent of pesticide but have a solubility of 5 percent or more for the pesti-
cide. ^ Each rinsing uses a volume of solvent equal to approximately 10 per-
cent of the volume of the container, and the rinsing is accotplished by sloshing
or otherwise forcing repeated contact of the container internal surfaces with
the solvent. The efficiency of decontamination depends in part on the degree
of solvent contacting and on the condition of the container surfaces being
cleaned. After each rinse, the solvents are collected and incinerated. This
procedure is believed readily adaptable for PCB containers.
(1) Midwest Research Institute, Guidelines for the Disposal of Small Quantities
of Unused Pesticides, EPA-670-2-75-057, Cincinnati, Ohio: National Environ-
mental Research Center, U.S. EPA, June 1975.
3-3
-------
Table 3-2
Annual PCB Equipment Disposal Requirements,
after July 1, 1979: millions of pounds
IRANSPORMliRS
CAPACITORS
Disposal
Disposal
Disposal
Enpty
Cation ll
Option l*
Option 3
3
Source
PCB 1.1 q
Solvent
Trans.
MSW
CWI.F Incin
MSW
CWLF Tncin
MSW
OWIf
Incin
Utilities
6.3
4.7
13.6
-
47.2
0.2
47.0
0.2
-
47.0
large Jtesitiential
2.1
1.6
4.6
-
160. IS
100.3
60.2
100.3
48.9
11.3
and Qiuilji cj 1 al
Industrial
2.1
1.6
4.6
-
50.5
25.4
25.1
25.4
10.1
15.0
Private
_
29.4
0.5"
29.4
0.5"
29.4
-
0.5*
Residential
"lUtul
10.5
7.9
22.B
29.4
258.7
155.3
132.a
155.3
59.0
73.8
(incin)
(incin)
(CWIJ-')
sr.-1 - Sanitary Landfill
CWLF - Qtyideal Waste Landfill
Incin = Incinerate
'incinerate all except for residential. MSW(residential): All except 10ii of large low voltage
capacitors (motor run, air conditioner, etc.) removed for replacement by service shops.
-'MSW = 2/3 of flu light liallasts, Kro, and small applicance capacitors;
Jncin - All IUV and large LV+1/3 (flu lights + KID + aiiull appl.)
3MSW = sains as option 2; tWL = 1/3 of flu light ballasts;
Incin = all HIV and large LV+1/3 (HID t small appl.)
'' 104 of large I.V cap. rennvfid by repair sliops (central air oond., imtors, etc.)
-------
Table 3-3
Disposal of PCB Chemical Substance in PCB Equipment,
after July 1/ 1979: million lb/year
TRANSFORMERS R CAPACITORS
Source
PCB Liq. Solvent
Hnpty
Trans.
Disposal Option 11
SLF CWIF Incin
Disposal Option 22
SLF CWLF Incin
Disposal Option 3J
SLF CWLF Incin
Utilities
4.5
.2
.1
-
-
9.79
0.05
9.74
0.05
-
9.74
Large Residential
and Caunercial
1.5
.1
.05
-
-
6.78
3.35
3.43
3.35
1.40
2.03
Industrial
1.5
.1
.05
-
-
5.04
1.86
3.18
1.86
0.2')
2.89
Private
residential
-
4.12
-
0.01
4.12
0.1
4.12
-
0.1
•it>Lal
8.
.4
.2
4.12
(16%)
21.71
(84%)
9.38
(36*)
16.45
(64%)
9.38
(36%)
1.69
(7%)
14.76
(57%)
SU-' - Sanitary landfill
CWLF - Chemical Waste landfill
Incin = Incinerate
incinerate all except for residential.
SLF (residential): All except 10% of large low voltage capacitors (motor run, air conditioner,
etc.) removed for replnceirent. by service shops.
2SI*': 2/3 of flu light ballasts, HID and small applicance capacitors
Incin: All I1IV and large LV+1/3 (fin lights + HID + small applicances
3SLF: Same as option 2
CWLF: 1/3 flu li(£it ballasts
Incin: All fHV and large LV+1/3 (ftID + small appl.)
-------
Complete decontamination of askaxel transformers does not appear
feasible. However, partial decontamination of askarel transformers which are
being taken out of service is required. This can be achieved by thoroughly
draining the askarel fluid frcm the transformer, followed by refilling with a
solvent such as mineral spirits and recirculating for several hours. The
solvent is then drained and incinerated. Preliminary results of a test which
was performed by Westinghouse, sponsored by the Federal Railway Administration,
and based on the above procedure, achieved a 99 percent reduction in the
quantity of PCBs in the transformer. Transformers so treated may then be dis-
posed in a chemical waste landfill.
Hie rinsing of transformers will generate a quantity of contaminated
solvents equal in volume to that of the askarel drained frcm the transformer.
A total of 36,500,000 gallons of solvent will eventually be required to flush
the 140,000 existing askarel transformers. This solvent could cost as much as
$.40 per gallon, but it is likely that waste mineral oil from scrapped oil-
filled transformers would be used. The maximum annual cost for this solvent,
assuming new kerosene is used, would be $365,000 per year. All of this con-
taminated solvent would require special incineration in a chemical waste
incinerator or cement kiln. However, the energy value of the solvent would be
high, and the incineration fuel costs should therefore be negligible.
Askarel transformers which are kept in service, but retrofilled with
a silicone or other oil, should be thoroughly drained of askarel oil prior to
refilling with replacement oil. Subsequent drainings and refill ings of such
transformers will require special disposal of the retro-fill oil. In the case
of silicone oil, Dew Cbrning has reported that treatment with activated carbon
will remove the PCBs and permit reuse of the oil. In the case of mineral oil,
the initial retro-fill must be incinerated. Subsequent mineral oil retro-fills
must also be incinerated unless the level of PCBs less than 500 ppm. The
operation of the askarel transformer with replacement oils would result in the
residual PCBs being leached out of the insulation. If, after draining the
retro-fill oil, the residual levels of PCBs in the transformer veigh less than
3-6
-------
.05 percent of the total weight of the transformer, the transformer need no
longer be considered a PCS item for purposes of labeling or disposal.
3.3 Storage for Disposal
The draft regulation requires that each industrial and oonmercial
facility that disposes of small capacitors such as fluorescent light ballasts
must have a specially designated PCB storage area consisting of a specially
marked steel drum. Hie number of such facilities could conceivably run into
the millions, depending on how strictly EPA enforces the storage requirements.
Undoubtedly, there will be substantial non-carpliance by the smaller facilities.
Therefore, it is probably safe to assume an upper bound estimate of one million
such small storage facilities.
Large storage facilities will be required by electric utilities,
major manufacturing facilities, transformer repair shops, and other concerns
who have large capacitors, significant numbers of askarel transformers, or who
service askarel transformers. The total number of such facilities required by
electric utilities will be about 800 (see Section 4.2.2). There may be as
many as 20 transformer repair shops that will require the large storage areas.
A total number of 2000 such areas, including the utilities, is probably a
realistic estimate.
The total attributable costs of the storage facilities are summarized
in Table 3-4. As expalined in Section 2.3, these costs may be considerably in
excess of the economic opportunity costs as much of the attributable costs nay
be for otherwise under utilized storage space and manpcwer.
3.4 Chemical Waste Landfill
The draft regulation allows the use of chemical waste landfills
as the least expensive disposal alternative only for transformers that have
been drained and partially decontaminated. Demand for such disposal in 1978
may be 22,800,000 lb at 100 lb/cubic foot. The total cost of landfill at
$3.00/cubic foot would then be $684,000/year initially, decreasing thereafter
at 7 percent per year.
3-7
-------
Table 3-4
Eooncmic Costs of Storage Facilities
Size
Small
Large
Type of Cost $
Drum (initial) 25
First Year Administrative 80
Labor 10/year
Equivalent Rent 30/year
First Year Total 145
Replacement Drum 15/year
Continuing Administrative 50/year
Subsequent Year Total 105
Engineering and Construction 2,000
Drum Costs 225/year
Labor Costs 1,000/year
Administrative Costs 300/year
Equivalent Rent 600/year
First Year Total 4,125
Subsequent Year Total 2,125
Number of
Facilities
1,000,000
2,000
Total
$145,000,000
$105,000,000
$ 8,250,000
$ 4,250,000
3-8
-------
For the one year period 7-1-78 through 6-30-79, the regulations would
allow disposal of all capacitors in chemical waste landfills. Depending on the
number of such capacitors removed frcm electrical equipment, the cost of land-
fill for this one year period (assuming 150 lb/cubic foot) would run frcm $5.2
million (option 1) to $2.7 million (optical 2). After 7-1-79, the proposed
regulation would preclude the use of chemical waste landfills for capacitors.
Disposal option #3 proposed in this report would allcw the disposal
of 59,000,000 lb/year of fluorescent light ballasts in chemical waste landfills
following 7-1-79. This would result in a continuing cost of landfills of
$l,180,000/year.
In addition to this electrical equipment, there may be an additional
immediate demand for chemical waste landfill for contaminated rags and other
equipment associated with deoonmissioning present PCB facilities, and for dis-
posal of capacitors presently being stored awaiting the promulgation of the
regulations. This would not be expected to increase the landfill costs by
more than one million dollars in 1978.
Total landfill costs could reach a peak of $7 million in 1978, but
would probably be sorewhat less. Continuing costs would be incurred only if
disposal option #3 is incorporated into the regulation. This would result in
continuing landfill costs of $1,180,000 per year. Not all of these costs can
be attributed to the proposed regulation. Chemical waste landfills are cur-
rently specified as the disposal method for transformers and capacitors in the
ANSI Guidelines for aksarels. ^ As much as 50,000,000 pounds of large capac-
itors and transformers might be disposed of in chemical waste landfills in
1978 even if no disposal regulations were pronulgated. Thus, the peak year
eccnonic costs of chemical waste landfills attributed to the regulations
should not exceed $5,500,000.
(1) American National Standards Institute, Inc. Guidelines for Handling and
and Disposal of Capacitor- and Transformer-Gride Askarels Containing
Polychlorinated Biphenyls, ANSI C 107.1-1974, New York; 1974.
3-9
-------
3.5 Incineration
The greatest demand for incineration will occur in the year starting
July 1, 1979. As summarized in Table 3-2, facilities will be required to in-
cinerate 10.5 million lb of transformer askarel, 7.9 million lb of contaminated
solvent, and (depending on the disposal option promulgated) from 73.8 million
to 258.7 million lb of capacitors. In addition, small amounts of contaminated
solids such, as rags, dirt, etc., will require incineration.
The unit cost estimates developed in Section 2.5.3.2 were based on
existing incinerators having a capacity of 3000 lb/hour of solids. Hie number
of 3000 lb/hour incinerators required for each disposal option and the result-
ing operating cost to incinerate the solids are surrmarized in Table 3-5. The
cost of incinerating the liquids may be an additional 2.5 million to 3 million
dollars per year /"depending on the credit received for the fuel value of the
liquids.
3.6 Transportation Costs
The transportation costs incurred by the controlled disposal of PCBs
will depend both on the locations of the incinerators and chemical waste land-
fills and on the point of origin of the PCB items. Almost all of the PCB
material will consist of transformer oils and solvents, drained transformers,
and capacitors. Both capacitors and transformers are used as an integral part
of electrical distribution systems, and it is expected that the number used in
any geographical area will be highly correlated with the consumption of
electrical power. Table 3-6 suntnarizes the state-by-state PCB disposal re-
quirements for 1978 on the assumption of correlation between PCB usage and 1973
electrical power consunption. Based on this distribution, preliminary assess-
ment has been made of the appropriate locations of the new incineration facil-
ities which would be needed in 1979. These locations are tabluated in Table
3-7.
Incineration costs would be reduced wcmewhat by operating fewer,
larger incineration plants. However, reduction of the nuitber of incinerators
would increase transportation costs of waste PCBs.
3-10
-------
Table 3-5
Total Cost of PCBs Solids Disposal by Incineration^
Total Annual PCB Solids^
to Incineration, Ml lb
Total No. of
Facilities Reqd
Total Annual
Operating Cost
$134,000,000
1
2
3
258
133
74
12
6
4
69,000,000
39,000,000
(1) It is assumed that the waste liquid PCBs would be partly handled in presently
existing incineration facilities, and partly blended in the fuel used in
the new incineration plants.
(2) As given in Table 3-2.
(3) These quantities are the estimated amounts of solids (from Table 3-2) to be
handled in 1979 when the waste capacitors can be no longer placed in chemical
landfills. The amounts to be disposed will decline by approximately 7% per
year thereafter.
3-11
-------
Table 3-6
PCB Disposal Requirements - 1978
1973
Total Elec.
Energy Sales
rrac. or
-1973 Disposals-
Empcy
rotal
KW-Hours x 103
Total
Filled Cap.
Transf.
PCB lie.
Sclv.
Li g.
Total U.S.
1,703.2
288.1
22.4
10.50
7.9
IS.4
ALabana
41.8
0.0245
7.02
0.55
0.26
0.20
0.46
Alaska
1.6
0.0009
.26
0.02
0.01
0.01
0.02
Arizona
18.7
0.0110
3.15
0.2S
0.12
0.09
0.21
Arkansas
16.4
0.0096
2.75
0.22
0.10
0.08
0.18
California
14S.4
0.0854
24.46
1.91
0.90
0.67
1.57
Colorado
13.9
0.C082
2.35
0.18
0.09
0.06
0.15
Connecticut
13.3
0.3113
3.23
0.25
0.12
0.09
0.21
Delaware
5.6
0.3033
.95
0.07
0.03
0.03
0.06
District of Col.
(with Md.)
Florida
66.9
0.0393
11.25
0.88
0.41
0.31
0.72
Georgia
40.6
0.0238
6.32
0.53
0.25
0.19
0.44
Hawaii
4.9
0.0029
.33
0.06
0.03
0.02
0.05
Idaho
11.7
0.0069
1.98
0.15
0.07
0.05
0.12
Illinois
32.9
0.0487
13.95
1.09
0.51
C.38
0.39
Indiana
46.1
0.0271
7.76
0.61
0.23
0.21
0.49
Iowa
18.5
0.0109
3.12
0.24
0.11
0.09
0.20
Kansas
16.7
0.0099
2.34
0.22
0.10
0.08
0.18
Kentucky
43.6
0.0256
7.33
0.57
0.27
0.20
0.47
Louisiana
37.3
0.0222
6.36
0.50
0.23
0.18
0.41
Maine
6.0
0.0035
1.00
0.08
0.04
0.03
0.07
Maryland +¦ D.C.
34.2
0.0201
5.76
0.45
0.21
0.16
0.37
Massachusetts
30.2
0.0177
3.07
0.40
0.19
0.14
0.33
Michigan
66.3
0.0389
11.14
0.87
0.41
0.31
0.72
Minnesota
25.2
0.0148
4.24
0.33
0.15
0.12
0.28
Mississippi
13.5
0.0109
3.12
0.24
0.11
0.09
0.20
Missouri
31.3
0.0134
5.27
0.41
0.19
0.15
0.34
Montana.
3.6
0.0050
1.43
0.11
0.05
0.04
0.09
Nebraska
10.4
0.0061
1.75
0.14
0.06
0.05
0.11
Nevada
7.3
0.0043
1.23
0.10
0.05
0.03
0.08
Mew Hampshire
4.9
0.0029
!s3
0.06
0.03
0.02
0.05
New Jersey
45.5
0.0267
7.65
0.60
0.28
0.21
0.49
New Mexico
6.3
0.0037
1.06
0.08
0.04
0.03
0.07
Mew York
99.6
0.0535
16.75
1.31
0.61
0.46
1.07
North Carolina
49.4
0.0293
3.39
0.66
0.31
0.23
0.54
North. Dakota
3.3
0.0019
.54
0.04
0.02
0.02
0.04
Chic
106.5
0.0625
17.90
1.40
0.66
0.49
1.15
Oklahoma
20.6
0.0121
3.47
0.27
0.13
0.10
0.23
Oregon
30.2
0.0177
5.07
0.40
0.19
0.14
0.33
Pennsylvania
90.2
0.0530
15.18
1.19
0.56
0.42
0.98
Rhode Island
4.3
0.0028
.30
.06
0.03
0.02
0.05
South Carolina
29.2
0.0171
4.90
.38
0.18
0.14
0.32
South Dakota
3.4
0.0020
.57
.04
0.02
0.02
0.04
Tennessee
64.9
0.0381
10.91
.85
0.40
0.30
0.70
Texas
120.3
0.0709
20.30
1.59
0.74
0.56
1.30
Utah
6.7
0.0039
1.12
0.09
0.04
0.03
0.07
Verrent
3.1
0.0018
.52
.04
0.02
0.01
0.03
Virginia
37.1
0.0218
6.24
.49
0.23
0.17
0.40
Washington
54.9
0.0322
9.22
.72
0.34
0.25
0.59
West Virginia
16.7
0.0098
2.81
.22
0.10
0.08
0.18
Wisconsin
30.0
0.0176
5.04
.39
0.13
0.14
0.32
WVaning
3.3
0.0023
.66
.05
0.02
0.02
0.04
Puerto Rico
10.5
0.0C62
1.78
0.14
0.07
0.05
0.12
3-12
-------
Table 3-7
Location of PCBs Incineration Facilities
Disposal Total No. of No. of .... Number of location of
Option Facilities Reqd. Existing Facilities New Facilities
12
New Facilities
No. Calif.
-
1
So. Calif.
-
1
Colorado
-
1
Illinois
-
1
Ohio
-
1
Georgia
-
1
Virginia
-
1
New York
-
1
Arkansas
-
1
California
-
1
Virginia
-
1
Ohio
-
1
California
—
1
(2)
(1) These are the three Rollins facilities located respectively in New Jersey, Texas, and
Louisiana. These will require the addition of shredder facilities and certain monitoring
instrumentation to meet the requirements of the proposed regulations.
(2) This is the proposed kepone incineration facility which would be available upon canpletion
of tiie kepone destruction program.
-------
The total incineration plus transportation charges were evaluated
for several different scenarios to evaluate the sensitivity of the total dis-
posal costs to different nurrbers and sizes of incinerators. Hie scenarios
were based on three different denand levels corresponding to the solid waste
incineration requirements of the disposal options (Table 3-2), and on the in-
cinerator siting locations summarized in Table 3-7. In each case, all solid
wastes frcm each state were assumed to be generated at the center of population
of that state and then transported in truckload lots to the nearest inciner-
ator, the transportation costs being taken frcm Figure 2-5. Ocean shipping
charges frcm Puerto Rioo to Jacksonville or Baton Rouge; Honolulu to San
Francisco; and Anchorage to Seattle were added to the trucking charges frcm the
part of entry to the incinerator for PCBs wastes frcm those three areas. The
total demand on each incinerator was used as a basis for obtaining per pound
incineration costs frcm Figure 2-2.
The results of the analysis of four different incinerator siting/
demand scenarios are sumnarized in Tables 3-8 through 3-11.
Since it was assumed that all shipments were in truckload lots, the
average transportation charges are comparable among the various scenarios. As
expected, an increased number of incinerators results in decreased average
shipping distances and decreased transportation oost. However, as summarized
in Table 3-12, the transportation savings resulting frcm an increase in the
number of incinerators frcm 4 to 12 is only one-half cent per pound.
The increased transportation costs resulting frcm longer shipments
where there are only a few incinerators are more than offset by the economies
of scale achieved by operating larger incinerators. Corparison of Tables 3-9
and 3-10 indicates that a reduction of the number of incinerators frcm 6 to 4
(thereby increasing the size of each remaining incinerator by 50 percent) re-
sults in a decrease of the incineration oosts of 2.6
-------
Table 3-8
Incinerator/Transportation Cost Scenario #1
Disposal Opticn: 1
Number of Incinerators: 12
Incinerator location^
PCB Solids
Million Lb/Year
Incineration Cost
C/Lb(2> Total: Million $
Transportation
Costs(3)
Bridgeport, New Jersey
50.95
47
23.9
$ 859,697
Houston, Texas
18.23
53-1/2
9.8
286,211
Baton Rouge, Louisiana
8.51
61-1/2
5.2
121,045
San Francisco, California
13.81
56
7.7
401,662
Los Angeles, California
25.90
51
13.2
489,258
Denver, Colorado
10.28
59-1/2
6.1
240,293
Chicago, Illinois
23.66
52
12.3
384,689
Sandusky, Ohio
33.04
49-1/2
16.4
501,496
Atlanta, Georgia
44.90
48
21.6
911,418
Richmond, Virginia
15.66
55
8.6
259,650
Niagara Falls, New York
.90
1.30
1.2
22,500
El Dorado, Arkansas
12.86
.57
7.3
286,891
TOTALS
258.7
133.3
$4,764,810
Average incineration cost: .515/lb
(1) Table 3-7 Average transportation cost: .0184/lb
(2) Figure 2-2
(3) Table 2-5, Truckload lots
-------
Table 3-9
Incinerator/Transportation Cost Scenario #2
Disposal Option: 2
Number of Incinerators: 6
m PCB Solids Incineration Cost Transportation
Incinerator location Million Lb/Year Total: Million $ Costs(3)
Bridgeport, New Jersey
24.11
51
12.3
$ 370,124
Houston, Texas
15.19
55
8.4
317,422
Baton Rouge, Louisiana
16.77
54
9.1
342,558
San Francisco, California
22.92
51.5
11.8
510,133
Sandusky, Ohio
35.02
49
17.2
709,565
Richmond, Virginia
20.92
52.5
11.0
473,188
TOTALS
134.93
69.8
$2,722,990
Average incineration cost: .517/lb
Average transportation cost: .0202/lb
(1) Table 3-7
(2) Figure 2-2
(3) Table 2-5, Truckload lota
-------
Table 3-10
Incinerator/Transportation Cost Scenario #3
Disposal Option: 2
Number of Incinerators: 4
Incinerator Location^
Bridgeport, New Jersey
Houston, Texas
Baton Rouge, Louisiana
San Francisco, California
TOTALS
Average incineration cost: .491/lb
Average transportation cost: ,0236/lb
PCB Solids Incineration Cost Transportation
Million Lb/Year C/Lb(2) Total: Million $ Posts(3)
68.39 46 31.5 $1,587,554
14.44 56 8.1 312,796
27.91 50.5 14.1 711,884
22.26 52 11.6 522,981
133.0 65.3 $3,135,215
(1) Table 3-7
(2) Figure 2-2
(3) Table 2-5, truckload lots
-------
Table 3-11
Incinerator/Transportation Cost Scenario #4
Disposal Option: 3
Incinerator Location
(1)
Bridgeport, New Jersey
Houston, Texas
Baton Rouge, Louisiana
San Francisco, California
Nurriber of Incinerators: 4
PCB Solids
Million Lb/Year
38.22
7.98
15.41
12.67
Incineration Cost
^/t^>(2) Tbtal: Million $
48.5
62.5
55
57
18.5
5.0
8.5
7.2
Transportation
Costs(3)
$ 884,039
169,774
377,075
289,324
74.28
39.2
$1,720,212
Average incineration cost: .528/Ib
Average transportation cost: .0232/Ib
(1) Table 3-7
(2) Figure 2-2
(3) Table 2-5, truckload lots
-------
Table 3-12
Average Transportation Costs of Shipping Solid
PCBs Wastes to Incinerators
Number of Incinerators Cost per Pound
4
$.0234
6
.0202
12
.0184
3-19
-------
locations of the incinerators. Review of Table 2-5 shows that transportation
costs for a single drum shipped 400 miles would be $.07/lb, but the cost would
be reduced to $.02/lb if the drum were consolidated with other waste PC3s to
form a truckload shipment. This suggests that the establishment of PCS col-
lection services in large cities that are not near incinerators could result
in savings in transportation and an assured demand for the incinerators.
It is not possible to accurately predict the locations of the
incinerators and chemical waste landfills that will be used to disperse of
PCBs. Hcwever, the transportation costs are relatively insensitive to the
number and locations of such facilities, and may be expected to average no
more than four cents per pound of PCB wastes. This would result in a total
transportation cost of not more than $13.2 million per year (disposal option 1)
and more likely a maximum cost of $7.4 million dollars per year (disposal
options 2 and 3).
3.7 Record Keeping Costs
The record keeping and monitoring costs for incinerators and chemical
waste landfills were implicitly included in the estimated operating costs. The
proposed regulation does not impose any record keeping requirements on the cne
million small storage areas which will handle only small capacitors.
The 2000 large storage areas will be required to maintain a perpetual
inventory of all PCB itens or oontainers in storage. Since the record for each
item must include its weight, origin, and date of entry into the area, clerical
costs of perhaps two dollars per item might be expected in addition to a cost
of $200 per area to establish the record keeping procedure. It would there-
fore be expected that initial costs of 400,000 dollars plus an additional one
miliinn dollars per year associated with large capacitors and transformers and
an additional one million dollars per year associated with containers might be
expected. In addition, the annual reports will require about one man week per
facility ($1,000,000 total). Thus, total record keeping oosts for storage
areas might reasonably be estimated at $400,000 initially, plus $3,000,000 per
year thereafter.
3-20
-------
In addition, owners of transformers and large capacitors must main-
tain records as to the location of the PCB equiprent, estinated date of
retirement, and date of disposal. Based on a current usage of 140,000 trans-
formers and 8,000,000 large high voltage capacitors at 400,000 locations, and
assuming a cost of $5 per transformer or capacitor location, the initial record
keeping costs may be expected to be $2,700,000 the first year, with record
maintenance and reporting costs of perhaps an additional million dollars per
year.
Total record keeping costs are therefore estimated at $3,100,000
initially plus $4,000,000 per year. This will result in an equivalent increase
in clerical employnent of over 200 jobs. The costs will be widely distributed
across utilities and industrial concerns, and should have little inpact on
prices or market structure.
3-21
-------
4-0 MASKING
4.1 Requirements in Draft Regulations
The proposed regulations establish specific requirements for narking
PCB equipment/ containers, storage areas, capacitors, transformers, and other
items. The marking is required to assure prcper clean up action in case of an
accidental spill while the item is in service, and to assure proper disposal of
the items vfoen they are removed from service. The specified compliance dates
are summarized in Table 4-1.
Table 4-1
SUMMARY OF COMPLIANCE DATES
FOR THE DRAFT MARKING PECULATIONS
Regulated Units Compliance Date
New Articles January 1, 1978
New Equipment January 1, 1978
Containers January 1, 1978
Inventory
Transformers January 1, 1978
Large Capacitors January 1, 1978
Storage Areas January 1, 1978
Vehicles March 31, 1978
Large High. Voltage Capacitors July 1, 1978
HID Capacitors March 31, 1978
Transformers July 1, 1978
4.2 Methodology
The costs of complying with the draft marking regulations can be
divided into two areas: (1) the cost of specified labels and (2) the costs
associated with applying the labels. In order to arrive at cost estimates for
these tvro categories, it was necessary to approximate not cnly the demand for
labels by producers and users of PCB transformers and PCB capacitors, but also
the magnitude of their respective operations.
4-1
-------
The name and location of all U.S. producers of PCB transformers and
PCB capacitors is found in Tables 4-2 and 4-3 respectively. All such pro-
ducers were contacted in order to establish maximum likelihood estimates for
producers' marking costs. The users of PCB electrical equipment are utility,
industrial, commercial, and residential concerns. Extrapolations were made
fran available information regarding PCB electrical equipment users to arrive
at satisfactory marking cost estimates.
Label costs are based upon manufacturers' retail prices for lots of
1,000. Transportation and labor costs - costs associated with applying the
labels - are maximum estimates; they are costs that would be incurred by a
full-time marking program.
4.2.1 Containers
In order to arrive at a satisfactory approximation of the
total nunber of containers required for the year ending December 31, 1978, it
was necessary to specifically define a PCB container. For marking purposes,
a PCB container is defined as a 55 gallon drum constructed of steel, wood
fiber, or other material. (Note that this definiticxi differs fran that in the
proposed regulations.) Implicit in this definition is the assumption that all
PCB liquids, solid waste, contaminated materials, etc., will be contained in
55 gallon drums when accumulated for disposal. In fact, there have been and
will be other types of containers used for PCB materials. Hcwever, information
obtained fran producers and users of PCB electrical equipment supports the
aforementioned assumption - i.e., 55 gallon drums are the primary containment
employed by most producers and users of PCB electrical equipment.
Given that most producers of PCB electrical equipment have
ceased production of such units already, or will have prior to January 1, 1978,
the number of PCB containers required by producers for the year ending December
31, 1978, will be relatively small. Based on telephone conversations with
U.S. producers of PCB electrical equipment, it is estimated that approximately
10,000 containers will be required by producers in 1978.
4-2
-------
Table 4-2
U.S. Transformer Manufacturing Industry Using PCBs
Canpany Name
Location of the Plant
Westinghouse Electric Corp.
South Boston, Va.
Sharon, Pa.
General Electric Carp any
Bane, Ga.
Pittsfield, Mass.
Research-Cottrell
Finderne, N.J.
Niagara Transformer Gorp.
Buffalo, N.Y.
Standard Transformer Co.
Warren, Ohio
Medford, Oregon
Helena Corp.
Helena, Alabama
Hevi-Duty Electric
Goldsboro, N.C.
Kuhlman Electric Co.
Crystal Springs, Miss
Electro Engineering Works
San Leandro, Calif.
Envirotech Buell
Lebanon, Pa.
R.E. Uptegraff Mfg. Co.
Soottsdale, Pa.
H.K. Porter
Belmont, Calif.
Lynchburgh, Va.
Van Tran Electric Co.
Vandalia, 111.
Waco, Texas
Source: Versar Inc., PCBs in the United States: Industrial Use and Environ-
mental Distribution, NTIS PB-252 402/3WP, February 25, 1976, p. 89.
4-3
-------
Table 4-3
U.S. Capacitor Manufacturing Industry Using PCBs
Company Name
(In Order of PCBs Usage)
Location of the Plant
General Electric Company
Hudson Falls, N.Y.
Ft. Edward, N.Y.
Westinghouse Electric Oorp.
Bloomington, Ind.
Aerovox (AVX)
New Bedford, Mass.
Universal Manufacturing Corp.
Bridgeport, ODnn.
Totowa, N.J.
Cornell Dubilier
New Bedford, Mass.
P.R. Mai lory & Co., Inc.
Waynesboro, Tenn.
Sangamo Electric CO.
Pickens, S. Carolina
Sprague Electric Co.
North Adams, Mass.
Electric Utility Go.
LaSalle, 111.
Capacitor Specialists, Inc.
Escondido, Calif.
JARD Corp.
Bennington, Vt.
York Electronics
Brooklyn, N.Y.
McGraw-Edison
Greenwood, S. Carolina
KF Intexonics
Bayshore, L.I., N.Y.
Axel Electronics, Inc.
Jamaica, N.Y.
Tobe Deutschmann Labs.
Canton, Mass.
Electro Magnetic Filter Co.
Palo Alto, Calif.
Source: Versar Inc., PCBs in the United States: Industrial Use and Environ-
mental Distribution/ NTIS PB-252 402/3WP, February 25, 1976, p. 69.
4-4
-------
It is expected that residential users of PCB electrical equip-
ment will not require any containers. The underlying assumption is that no
single residential dwelling, in the course of one year, will have accumulated
sufficient PCB related waste to warrant using a 55 gallon drum.
Estimates of the nurrber of containers required by utilities and
industrial and ccnmercial users of PCB electrical equipment for the year ending
December 31, 1978, were arrived at as follows:
A) Small PCB capacitors (i.e., HID units):
Available information
1) Utilities - 1,000,000 units
2) Industrial and commercial concerns - 23,900,000 units
3) Annual disposal rate - 6 percent (approximately)
4) Each 55 gallon drum hold approximately 50 small PCB capacitors
1,000,000
6%
60,000 Number of units disposed of by utilities
23,900,000
6%
1,434,000 Number of units disposed of by industrial and
ccnmercial users
60,000/50 = 1,200 Number of containers required by utilities
for small PCB capacitors
1,434,000/50 = 28,680 Number of containers required by
industrial and caimercial users for
small PCB capacitors
-------
B) Large PCB capacitors (i.e., lew and high voltage units):
Available information
1) Utilities - 3,600,000 units
2) Industrial and commercial users - 19,400,000 units
3) Annual disposal rate - 6 percent (approximately)
4) Each 55 gallon drum holds approximately 3 large PCB capacitors
8,600,000
516,000 Number of units disposed of by utilities
19,400,000
6%
1,164,000 Number of units disposed of by industrial
and ccunnercial users
516,000/3 - 172,000 Number of containers required
by utilities for large PCB
capacitors
I,164,000/3 = 388,000 Number of containers required
by industrial and commercial
users for large PCB capacitors
C) PCB mixtures (i.e., liquids and solvents - transformers) :
Available information
1) Utilities - 11,000,000 lb. of PCB mixtures
2) Industrial and carmercial users - 7,400,000 lb. of PCB mixtures
3) Conversion factor - 11.5 lb. of PCB = 1 gallon
II,000,000/11.5 2 956,522 gallons
956,522/55 = 17,391 Number of containers required by
utilities for PCB mixtures
7,400,000/11.5 s 643,478 gallons
643,478/55 s 11,700 Number of containers required by
industrial and ccnmercial users for
PCB mixtures
4-6
-------
D) Miscellaneous
Based on telephone conversations with producers and users of FCB
electrical equipment, it is estimated that approximately 400,000
55-gallon drums will be required by users of KB electrical equip-
ment, for the year ending December 31, 1978, to contain clean-up
materials, contaminated materials, small appliance capacitors,
and fluorescent lighting ballasts. In order to safely divide the
additional 400,000 55-gallon drums between utilities and industrial
and commercial users, it is necessary to assume proportionality as
follows:
For utilities:
1,200 + 172,000 + 17,391 _ X
1,200 + 172,000 + 17,391 + 28,680 + 388,000 + 11,700 400,000
X s 123,166 Miscellaneous
containers
attributable
to utilities
For industrial and comrercial users:
28,680 + 388,000 + 11,700 _ X
1,200 + 172,000 + 17,391 + 28,680 + 388,000 + 11,700 400,000
X = 276,834 Miscellaneous
containers
attributable to
industrial and
commercial users
In sunmary, for the year ending December 31, 1978, producers
of PCB electrical equipment will require 10,000 containers, utilities and
industrial and cannercial users will require approximately 314,000 and 705,000
containers respectively, and residential users will not require any.
4-7
-------
4.2.2 Storage Areas
It is estimated that approximately 1,000,100 storage areas
will be required to temporarily house solid and liquid PCB waste prior to
disposal, for the year ending Decenber 31, 1978. This estimate, as well as
its distribution among producers and users of PCB electrical equipment, is
based on telephone interviews with such producers and users, and on extra-
polations frcm existing data. Specifically, it is anticipated that producers
will require approximately 100 storage areas, utilities will need approxi-
mately 100 storage areas, utilities will need approximately 796 storage
areas, industrial and conmercial users will require approximately 999,204
storage areas, and residential users will not require any - i.e., it is
assumed that residential users of PCB electrical equipment do not possess
sufficient quantities of PCB waste articles to require storage areas.
Extrapolations were made from available information to
determine how many of the 1,000,000 estimated storage areas would be allo-
cated to utilities; those remaining are to be distributed to industrial and
ccnuiercial users. The extrapolation procedure is as follows:
Available information
1) PEPCO's total sales of electric power in KWH's represents 1.01% of
total retail sales
2) TVA's total sales of electric power in KWH's represents 37.91% of
total wholesale sales
3) PEPCO has 7 storage areas
4-8
-------
4) TVA has 39 storage areas
.0101 X = 7
X s 693 Number of retail utilities' storage areas
.3791 X = 39
X = 103 Number of wholesale utilities' storage areas
796 Total number of storage areas required by utilities
1,000,000 Estimated total nunfcer of required storage areas
796 required by users
999,204 Number of storage areas allocated to industrial and
carmercial users
4.2.3 Vehicles
The total number of vehicles that will be required to haul
solid and liquid PCB waste to storage and for disposal facilities for the
year ending December 31, 1978, was estimated as follows:
Available information
1) Estimated amount of solid and liquid PCB waste requiring disposal
by primary users (i.e., utilities and industrial and canmercial
entities) - 299,400,000 {Table 3-1)
2) Average minimum acceptable truckload at disposal sites - 40,000 lbs
NUMBER OF TRUCK LOADS = 299'400/000/'40,000 = 7,485
Assuming that each transport vehicle were to carry 40,000
lbs of PCB waste and to make only one trip, the maximum number of trucks
would be required by users - i.e., 7,485 vehicles. Based on telephone
interviews with producers and users of PCB electrical equipment, it is
estimated that actually only 3,000 vehicles will be required by users of PCB
electrical equipment. Note that only utilities and industrial and carmercial
users will require transport vehicles. Residential users will not require
4-9
-------
transport vehicles because it is assumed that such users do not possess
sufficient quantities of PCB waste to warrant trucking operations.
In order to divide the estimated 3,000 vehicles between
utilities and industrial and ccramercial users, it is necessary to assume
proportionality as follows:
Available information
1) Utilities' estimated disposal requirements for PCB electrical
equipment in 1978 - 71,800,000 lbs.
ON al arv^ al neayc' /-li erv>oa1 vivnn'
mJ JJKiU»!)Wii«-IxLL QjlU ULAllltr.fVv. iifwnl Li«3Ci >3 l liillulLJfciU i ^J[ 11 liT^
for PCB electrical equipment in 1978 - 227,600,000 lbs.
71,800,000 _ X
71,800,000 + 227,600,000 3,000
X s 720 Number of vehicles attributable
to utilities
227,600,000 _ X
71,800,000 + 227,600,000 3,000
X = 2,280 Number of vehicles attributable
to industrial and carmercial
users
Based on telephone interviews with producers of PCB elec-
trical equipment, it is estimated that each of the 37 plants in the United
States which produce such equipment will require approximately 2 transport
vehicles.
4.2.4 Transportation and Labor Marking Posts
Estimates of transportation and labor costs associated with
marking for the year aiding December 31, 1978 were derived from information
obtained frcm telephone interviews with producers and users of PCB electrical
equipment and frcm extrapolations of existing data.
4-10
-------
All estimates, except those associated with utilities'
transoprtation and labor (marking) costs concerning large high voltage
capacitors and transformers, are based on the following assumptions:
1) Labor costs are estimated to be approximately $10 per manhour
2) Transportation costs are estimated to be approximately $5 per
location visited for the purposes of applying labels.
Utilities' transportation and labor (narking) costs
associated with large high voltage capacitors and transformers are estimates
derived by extrapolating from data provided to the EPA by the Tennessee Val-
ley Authority. Table 4-4 outlines the existing data, canputations, and
subsequent extrapolations.
4.3 Economic Impact
The economic impact of the proposed marking regulations on manu-
facturers of PCB electrical equipment will be relatively small because most
production of such equipment will have ceased prior to January 1, 1978. It
is anticipated that two PCB capacitor manufacturers will continue production
after January 1, 1978 and hence will be faced with substantial tooling costs -
$25,000 - in order to comply with the proposed regulations. The total
economic impact of the proposed marking regulations on manufacturers of PCB
electrical equipment is expected to be less than $100,000 as calculated and
surtroarized in Tables 4-5 and 4-6 respectively.
The major costs of complying with the proposed marking regulations
will be incurred by the present users of PCB electrical equipment. Tables
4-7 through 4-9 summarize the necessary calculations in determining users'
marking costs. It is estimated that users of PCB electrical equipment will
faoe marking costs totaling approximately $33.2 million, as summarized in
Table 4-10.
The total cost of ccnplying with the proposed marking regulations
for the year ending December 31, 1978, will be approximately $33.3 million,
4-11
-------
Table 4-4
CMCJLAXJCN OF UTILITIES ' TRANSPOREiXICN
AND LABOR -MARKING COSTS
1
1 SUBSTATIONS
DISTRIBUTION
FEEDERS (POLES)
TRSNSFCRGRS
TVA:
Total Units
345
3710
1350
Transportation
Costs
5
10
Labor
costs
70 (approx.)
40 (acprox.)
15
Total Trans-
portation
and Labor Costs
345 x (70 + 5)
3 25,000
3710 x (10 + 40)
3 185,000
1350 x 15
? 20,000
PEPCO:
Total Units
32
1509
64
Total Trans-
portation
and Labor Oosts
32 (70 + 5) =
2400
1509 x (10 - 40)
= 73,450
54 x 15
=» 960
TVA's total transportation and labor nerking coats are apprcxiirately
225,000 (primarily- a wholaaator)
PEPCO's Total transportation and labor marking costs are approxinately
78,800 (primarily a retailer)
Extrapolation Procedure:
Available information
1) Fiscal year 1976: total retail sales of electrical
energy - 1,391,714,575,000 KKH
2) Fxscal year 1976: total wholesale sales of electric
energy - 276,681,665,000 3WE
3) Fiscal year 1976: Pepco's total sales 'retail) - 14,169,412,000 KWH
4) Fiscal year 1976: m's total sales (wholesale) - 104,900,000,000 KKH
14,169,412,000/.
1,391,714,575,000 3 .0101
78,810/,
X =» .0101/
"^.9899
X - 7,724,160.30
7,724,160.30
78,310.00
7,802,970.30 Utilities' (retail) transportation and labor
narking oosts
104,900,000,000/276<681/665000 3 <3791
225,000/
/.6209
X ¦ 368,510.94
368,510.94
225,000.00
593,510.94 Utilities1 (wholesale) transportation and labor
narking oosts
7,802,370.30
593,510.94
8,396,481.24 Utilities total tranaportatim and labor
;narking costs
4-12
-------
Table 4-5
Calculation of Electrical Equiprrent Manufacturers'
Marking Costs for the Year Ending December 31, 1978
Containers
Sloiage Areas
Vehicles
INVENTORY
New Articles
New BquitHiient
'i'raj is f aimers
Large Ca^jacitox.s
1V>te I'CB unit.
"Assuming tliat containers may be found in 100 locations.
-------
Table 4-6
Electrical Equipment Manufacturers1 Total Marking Costs
For the Year Eroding December 31, 1973
(in collars)
Transportation
Label Costs
and Labor Costs
Total
Containers
Storage Areas
Vehicles
Inventory:
2,7C0
27
1,500
1,000
370
4,200
1,027
20
3S0
Transformers
3
20
40,300
23
Large Capacitors
New Articles
New Equipment
T0TAI3
2,700
25,000
25,000
55,452
42,390
42,700
25,000
25,000
98,340
4-14
-------
Table 4-7
Calculation of Utilities' Marking Costs
for the Year Ending December 31, 1978
Containers
Storage Areas
Vehicles
Large Luw
Voltage
Caixacitors
Large High
Voltage
Capacitors
Trans formers
HID Capacitors
TV>tal Units
1114,000
2796
3 740
1,000,000
7,600,000
84,000
1,000,000
IVatal Label Costs
314,000
x 274 ea.
= $84,780
796
x 27C ea.
= $215
740
x 27C ea.
= $200
"100,000
x 27C ea.
= $27,000
'J 380,000
x $2 ea.
= $760,000
04,000
x 27C ea.
- $22,680
4120,000
x 9C ea.
- $10,800
To La 1 Transportation
and Labor Costs
710,000
x $10
= $100,000
796
x $10
= $7960
740
x $5
= $3,700
100,000
x $10
= $1,000,000
°$8,39(
j, 481
120,000
x $1
- §120,000
1 " ' JTotal nun tier ot units will decrease at a rate of 40% per year, assuming a 20 year lite tor PCB units.
** 109, of tlie total, nuntoer of uni ts are available for marking annually.
*KutiinabDd number of locations - i.e., locations nay be marked rather than individual units.
*12% of tiki total number of units are available for marking annually.
'Assuming that containers may be found in 10,000 locations.
"Total transportation and labor costs for narking large high voltage capacitors and trans former a
by both v^iolesalers and retailers of electric power.
-------
Table 4-8
Calculation of Industrial and Commercial Entities' Marking
Oosts for the Year Ending December 31, 1978
Containers
Storage Areas
Vehicles
Farcje low
Voltage
Ca£jacitors
large High
Voltage
Capacitors
Transformers
HID Capacitors
Total Units
'705,000
*999,204
32,260
19,000,000
400,000
56,000
23,900,000
Total Label Ct>sts
705,000
x 2'K ea.
= $190,350
999,20-1
x 27"? ea.
= $269,785
2,260
x 27$ ea.
. $610
"1,900,000
x 27C ea.
= $511,000
400,000
x $2 ea.
- $800,000
56,000
x 27C ea.
- $15,120
''2,868,000
x 9£ ea.
= $258,120
Total Transportation
and Labor Costs
'/0,000
x 55
= $150,000
999,204
x $5
= $4,996,020
2,260
x $5
= $11,100
1,900,000
x $5
- $9,500,000
400,000
x $5
- $2,000,000
56,000
x $15
- $840,000
2,668,000
x $1
- $2,868,000
lumber of units will decrease at a rate of 40* per yeai:, assitmimj a 20 year lilio Cor KJU units.
''104 of the total number oL units are available lor marking annually.
J12'i of t'Jift total number of units are available for nvsrking annually.
"Assuming lhat containers nay be found in 70,000 locations.
-------
Table 4-9
Calculation of Residential Users' Marking Costs
for the Year Ending December 31, 1978
Containers
Storuqe Aruas
Vehicles
large low
Voitayo
Capacitors
Larcje High
voltaije
Capacitors
Transtonners
HID Capacitors
Total Ur.its
-0-
-0-
-0-
-0-
-0-
-0-
100,000
Total Label Coats
-0-
-0-
-0-
-0-
-0-
-0-
'12,000
x ea.
- $1,030
Total Transportation
and Labor Costs
-0-
-0-
-0-
-0-
-0-
-0-
12,000
X $1
- $12,000
'12% of tlie total niurher of units are available for mar.kiiuj annually.
-------
Table 4-10
Electrical Equipment Users' Total Marking Costs
for the Year Ending December 31, 1978
(in dollars)
Label C=sts
Transportation
and Labor Costs
Total
utilities:
Containers
Storage Areas
Vehicles
Large Dow Voltage
Capacitors
Large High Voltage
Capacitors
Transformers
HID Capacitors
TOTALS
Industrial and Ccnmerciai
rnrrai-en;
Storage Areas
Vehicles
Larqe Low Voltage
Capacitors
Large High Voltage
Capacitors
Transformers
HXD Capacitors
TOTALS
Residential:
Containers
Storage Areas
Vehicles
Large Lew Voltage
Capacitors
Large High Voltage
Capacitors
Transformers
HID Capacitors
TOTALS
GSAND TCCALS
34,780
215
200
27,300
76C,000)
22,680j
10,300
505,675
190,350
269,735
610
513,000
800,000
15,120
258,120
2,046,985
-0-
-0-
-o-
-0-
-0-
-0—
1,080
1,030
2,953,740
100,000
7,960
3,700
1,000,000
3,396,481
120,000
9,623,141
350,000
4,996,020
11,300
9,500,000
2,000,000
340,000
2,363,000
20,565,320
-0-
—0~
-0-
-0-
-0-
12,000
12,0C0
30,205,461
184,78C
8,17
3,900
1,027,000
9,179,16'
130,300
10,533,816
540,3S0
5,265,80"
11,910
10,013,000
2,300,000
355,120
3,126,120
22,612,305
-0-
-0-
-0-
-0-
-0-
-0-
13,050
13,030
33,159,20"
4-18
-------
with users' marking costs ccrnprising 99.7 percent of this total. Undoubtedly,
a large percentage o*f total marking costs will be passed along to consumers
as higher prices for final goods and/or services. Hcwever, sane relatively
small percentage will be borne by producers and. users of PCB electrical equip-
ment.
Estimated label costs are based upon manufacturers' retail prices
for lots of 1,000. Unit costs for labels will be extremely small if all
labels are manufactured by a few companies rather than many - i.e., economies
of scale will give rise to decreasing average costs. Costs associated with
applying the labels - transportation and labor costs - are maximum estimates;
they are costs that would be incurred by a full-time labelling program. Such
costs will be greatly reduced if users' PCB electrical equipment is marked
during routine maintenance operations. For example, it would be more eco-
nomical for a utility company to have its crews mark the various units during
their routine visits to substations for periodic checks, servicing, monitoring,
etc., rather than sending crews to substations for the sole purpose of marking
PCB electrical equipment.
Users' transportation and labor (marking) costs comprise 91.1 per-
cent of their total marking costs. Such costs could be greatly reduced if
the proposed regulations were to be changed so that large capacitors and
transformers are labelled only when they are retired from service and hence
gathered for (eventual) disposal. Tables 4-11 and 4-12 summarize the neces-
sary marking oost calculations regarding users, under this scenario; Table
4-13 summarizes total marking costs. This revision of the proposed regu-
lation would reduce users' total marking costs by approximately 48.2 percent,
utilities' marking costs by approxiirately 71.3 percent, industrial and com-
mercial marking costs by approximately 37.5 percent, and leave residential
marking costs unchanged. Uiis revision, having its greatest irrpact on users'
transportation and labor (marking) costs, would reduce that figure by approx-
imately $14.3 million. (Note that users' total marking costs are reduced by
approximtely $16 million.)
4-19
-------
Table 4-11
Calculations for Utilities' Marking Costs
for the Year Ending December 31, 1978*
Containers
Stor&je Areas
Vehicles
l.anje uw
Voltage
Capacitors
L*u~ge High
Voltaye
Capacitors
Transformers
HID Capacitors
Total Units
'314,000
27%
*740
1,000,000
7,600,000
84,000
1,000,000
Total label Costs
314,000
x 21b ea.
- 84,780
7oo
5456,000
x 27"? ea.
- $123,120
65,040
x. 27C ea.
¦j $1,361
'120,000
x
-------
Table 4-12
Calculations for Industrial and Commercial Entities' Marking Costs
for the Year Ending December 31, 1978*
Containers
Storage Areas
Vehicles
Larye Luw
Voltage
Capacitors
Larye lliyh
Voltage
Capacitors
Transformers
HID Capacitors
Total Units
'70S,000
2999,204
'2,260
19,000,000
400,000
56,000
23,900,000
'irii^al latel Onats
705,000
x 27"? ea.
- $190,350
999,20.1
x 27C ea.
- $269,785
2,260
x 27C ea.
; $610
''950,000
x 27C ea.
= $256,500
b24,000
x 274 ea.
$6,480
°3,360
x 27C ea.
; $907
'2,860,000
x 9C ea.
- $258,120
Total Transportation
and labor Costs
"70,000
x $5
= $150,000
999,204
x $5
- $4,996,020
2,260
x $5
^ $11,300
950,000
x $5
- 4,750,000
24,000
x $5
-= $120,000
3,360
x $15
- $50,400
2,868,000
x $1
- $2,860,000
''¦" 3,it>t.al numbftr of units wi ll, decrease at a rate of 40% per y^a>•, assuming a 20 year life tor PGR units.
''5% of U*j total nuniljei of units ate available Cor iiunkiily annually.
of the total nuiiber ot uniti; are available tor marking annually.
' 12% of the total nuuter of units are avaiTable for marking annually.
flAssuming that containers may be found in 70,000 locations.
*Cost estimates aru baaed ui tlie assumption that large capacitors and transformers are not
required to be labelled until removed Iran service and lienoe gathered for (eventual) disposal.
-------
Table 4-13
Electrical Equipment Users' Total Marking Costs
for the Year Ending December 31, 1973*
(in collars)
Label Costs
Transportation
and Labor Costs
Total
Utilities:
Containers
Storage Areas
Vehicles
Large Lew Voltage
Capacitors
Large High Voltage
Capacitors
Transformers
HID Capacitors
TOTAL
Industrial and Commercial:
Containers
Storage Areas
Vehicles
Large Lew Voltage
Capacitors
Large High Voltage
Capacitors
Transformers
HID Capacitors
totals
Residential:
Containers
Storage Areas
Vehicles
Large Lew Voltsge
Capacitors
Large High Voltage
Capacitors
Transferrers
HID Capacitors
TOTALS
GSAND TOTALS
34,780
21S
200
13,300
123,120
1,361
10,300
233,976
190,350
269,735
610
256,500
6,480
907
253,120
952,752
-0-
_>
-0-
-0-
1,080
1,080
1,217,508
100,000
7,960
3,700
250,000
2,280,000
25,200
120,000
2,736,860
350,000
4,996,020
11,300
4,750,000
120,000
50,400
2,363,000
13,145,720
-0-
-0-
-0-
12,000
12,000
15,944,580
184,780
3,175
3,900
263,500
2,403,120
26,561
130,300
3,020,836
540,350
5,265,305
11,910
5,006,500
126,480
51,307
3,126,120
14,123,472
—0—
-0-
-0-
-0-
-0-
-0-
13,080
13,080
17,162,388
*Cost estimates are based on the assumption that large capacitors sr.d transformers
are not required zc be labelled until rercved frcm servioa ar.d hence for
(eventual) disposal.
4-22
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5.0 ECONOMIC IMPACT ANALYSIS
The demand for PCB disposal depends on the nurrber, size and location of
transformers and capacitors containing PCBs and similarly of appliances and
other equipment containing PCB capacitors, including various lighting equip-
ment - e.g., fluorescent lighting and high-intensity discharge lights. In
the U.S. this inventory has been estimated at about 750 million pounds of
PCBs in a total of nearly 6 billion pounds of PCB capacitors and transformers.
The distribution of these PCBs by size of capacitor and type of owner (resi-
dential, coirmercial and institutional, industrial and utility) is reasonably
well kncwn.
In this study, the total weights of PCBs capacitors and transformers
were allocated to the 50 states and Puerto Rico. For this purpose, Federal
Pcwer Conrnission data on annual sales of electric pcwer by staes were used to
obtain the fraction of the total U.S. electric power consumed in each state.
These fractions were then applied to the total weights of various types of
PCB equipment. Then the average lives of the various types of PCB-containing
units were used to estimate annual disposal needs by year.
Disposal demand derived from capacitors in the non-residential economy
has been estimated at 258.7 million pounds for the first year after July 1,
1979. (Large apartment buildings and complexes including such, residential
use were included in this sector.) This total is expected to decline by
about 7 percent a year and thus would become:
240.6 million lb in 1980-81
223.7 million lb in 1981-82
208.1 million lb in 1982-83
193.5 million lb in 1983-84
180.0 million lb in 1984-85, and so forth
5.1 Incineration Costs
If all of these capacitors must be incinerated, as in option 1, 12
incinerators of the type new operated by Rollins near Houston, Texas, Baton
Rouge, La. and Bridgeport, N.J. will be required, none of them new. If such
5-1
-------
plants can be operated 365 days a year for 20 hours a day at 3000 pounds of
shredded capacitor solid per hour, as Rollins personnel believe, each plant
could incinerate 21.9 million pounds of PCB-containing shredded capacitors
per year while also incinerating as much as 3.65 million pounds of PCB
liquids. Twelve such plants could incinerate 262.8 million pounds of shredded
capacitors and 43.8 million pounds of PCB liquids. Hois exceeds the maximum
demand for solids incineration of 251.5 million pounds and for PCB liquids and
solvent of 18.6 million pounds. The total costs, however, would be consider-
able. Each plant would require $5 million investment and take a year to con-
struct after all approvals have been obtained. Annual capital recovery costs
of 10 percent for 10 years would be $814,000 for each plant. Taxes and in-
surance at 4 percent vould average $200,000, making total fixed costs per
plant $1,014,000 per year. Total variable costs at the assumed operating rate
of 4,300 hours per year would be $10,311,000; hence total annual costs are
estimated at $11,325,000 per plant. For all 12 plants this is a total com-
mitment of $134 million resources per year for incineration.
Cation 2, which, diverts 2/3 of all small capacitors to sanitary
landfills, would require only six incineratorsr of which 3 would be new.
This translates to $69 million total annual incineration costs.
Option 3 goes one step further, and diverts the other 1/3 of
fluorescent light ballasts to chemical waste landfills. This option requires
only one new incinerator and, even if it were completely new, the total com-
mitment would be reduced to $39 million in annual incineration costs.
Before other costs are considered, it is useful to consider how
sensitive these incineration costs are to the assumptions underlying these
cost estimates. Two assuirptions appear to be more critical than others:
(1) the price of #2 Fuel Oil will be 40C per gallon;
(2) each plant can be operated at the rate of 7,300 hours
per year.
5-2
-------
It is probably fruitless to try to improve the estimate for the price of
fuel but it should be rioted that such costs represent slightly more than 77
percent of the total annual incineration costs. A one-cent per gallon in-
crease thus would inflate each plant's annual costs by 2.19 percent and an
increase to 84.6£ per gallon would double the total annual costs. Even at
4QC, imports would increase by 105 million dollars for 12 plants. However,
if other EPA regulations were to result in an increase in the amount of
solvents and waste oils requiring incineration, the use of these liquids as
fuel in the PCB incinerators could substantially reduce total fuel costs.
Two safeguards are built into the estimated costs that could al-
leviate disappointment in ahcieved annual operating factors:
(1) each plant has a "contingency" factor of 20 percent or
$830,000 in its capital costs that could be applied to
maintenance or to improvements if no other problems
intervene and pre-empt these funds;
(2) annual demand for PCB incineration will decline by 7
percent per year. This reduces the required operating
factor by 7 percent each year, and provides more tiine
for maintenance or corrective adjustments in operations.
5.2 Other Costs
Total costs for the system include not only incineration costs but
also oosts of other methods of disposal, transportation costs and storage
costs. These three, disposal, transportation and storage are inter-related
and should be considered together. Finally, there are marking costs and
record costs. Recordkeeping will cost $3 million in 1978 and $4 million a
year thereafter and is discussed elsewhere in this report. Marking oosts
depend upon whether marking can be postponed until scrapping or must be done
immediately. If intnediate marking is required, outlays of $33.3 million will
be required in 1978 (of vfaich. $100,000 is capital) and $5 million a year
thereafter. If marking can be done upon removal frcm service, the 1978
outlay is reduced to $17.3 million but the $5 million per year is unchanged.
5-3
-------
Transportation costs will probably average 4C per pound, and could
be reduced if storage at area collection points is used to consolidate ship-
ments and obtain truckload lots. At 4<= per pound, 335 million pounds of
capacitor solids, transformers, and liquids will require $13.2 million in
transport costs. This would decline by 7 percent a year because of declining
quantities but escalation of transport rates may offset this decrease. The
weight of the steel drums containing PCBs will incorease the total weight and
make $15 million a year a better estimate of total transportation costs.
Option 2 reduces the PCB solids requirements by diverting 2/3 of
the small capacitors to sanitary landfills with negligible transportation
costs, but liquid requirements (from transformers) will not be affected.
With 155.6 million pounds in solids and 18.6 in liquids (including solvents),
transportation costs are reduced to $7.4 million which becomes $8 million a
year after allowance for steel drums.
Option 3 allows chemical waste landfill disposal of 1/3 of the
fluorescent light ballast. This doubles the costs of chemical waste land-
fill operations from 1 to 2 million do liars annually in 1969 and later years,
but does not reduce transportation oosts because these operations are few in
number and, therefore, like incinerators, require transportation. Hence,
transportation oosts are the same as for option 2.
^•3 Annual Attributable Costs of Compliance
The total costs of ccrnplying with the proposed regulation will
depend both on the disposal and marking options adopted and cai the degree of
compliance with (or enforcement of) the regulation. The total capital and
attributable operating costs of complying with the various options are shown
in Table 5-1. These costs are upper bound estimates, and the economic costs
may be significantly less if the storage and marking is accomplished in the
normal course of operations using otherwise idle storage space and manpower.
The major out-of-pocket cost will be fuel for the incinerators, and this may
be reduced if waste solvents and oils are used for fuel.
5-4
-------
TABLE 5-1
Total Attributable Compliance Costs
Millions of Dollars
Disposal Option 1
Incinerator
Chem Waste IF
Incineration
Transportation
Disposal Option 2
Incinerator
Chan Waste LF
Incineration
Transportation
Disposal Option 3
Incinerator
Chan Waste LF
Incineration
Transportation
(1)
(2)
(3)
Capital Costs
Annual Operating Costs
1978 1979 and later
45
5
0
15
1
134
15
(probable response to proposed regulation)
15
5 1
0 69
8 8
5
0
8
2
39
8
Recordkeeping
Madcing
New PCBs 0.1
Existing PCBs
Option l(4) (proposed regulation)
Option 2^
33.3
17.3
5
5
Storage
149
109
(1) Incin. all
(2) 2/3 small cap. to SLF
(3) 1/3 of Fl. Light Ballasts to CWLF
(4) All initially
(5) When removed from service
(6) Costs listed will decrease by 7 percent per year
after 1980
5-5
-------
The total capital requirements may be as great as $45.1 million in
1978, but will more likely be in the range of $10 million to $20 million.
Annual attributable operating costs may be as great as $210.3 million in 1978
and $268 million in 1979, but adoption of the suggested options could reduce
these costs to $187,3 million in 1978 and $167 million in 1979. The actual
economic oosts are expected to be considerably less than these upper bound
estimates of the attributable costs.
5.4 Effect on Prices and Market Structure
The impact of the proposed regulations on any specific industry
will be proportional to the amount of electricity used, except for electrical
equipment service organizations sucii as contractors, transformer repair shops,
and appliance repair shops. Among small business, perhaps as many as 20
transformer repair businesses will either have to step handling askarel
transformers or install special diked work and storage areas. Because most
askarel transformers are handled by GE and Vfestinghouse and because most
transformers are oil filled, there should be little effect on small businesses
even if the small independent repair shops stop servicing askarel transformers.
The regulations may result in the development of collection and
storage services to reduce storage and transportation charges frcm numerous
small generators of PCB wastes. This would result in increased business
opportunities for numerous snail labor intensive service businesses, resulting
in an increase in small business opportunities and employment.
Conceivably the incinerator business could be datiinated by Rollins,
which has a sister business in trucking, Macklin Trucking. Macklin or Rollins
could franchise collector and storage operations in areas that Macklin and
Rjllins could service. This would also increase small business opportunities
by making technical expertise available to small operations. Rollins could
then be more confident of a steady supply for their incinerator business and
would be more willing to undertake the investments required for new incin-
eration capacity.
5-6
-------
The proposed regulations will result in substantial compliance
costs for the electric utilities, as this industrial segment has the most
intensive use of PCB capacitors and transformers. The utilities will
generate about 35 percent of the demand for incineration of capacitors (see
Table 3-2, disposal option 2) resulting in a cost to the utilities of $27
million per year after 1979. In addition, much of the costs of complying
with the record keeping and marking requirements will be incurred by the
utilities. Total attributable costs to the utilities may be in the range
of $30 million per year starting in 1978. These costs will be included as
a oonponent of the cost basis on which the electric rates are established
by state regulatory agencies, and will therefore be recovered from the con-
sumers of electric power. Based on total annual U.S. electrical sales of
$53,462,864,000 in 1976,^ the proposed marking and disposal regulations
will cause an average increase in the price of electricity of about 0.06
percent.
Because the use of PCBs is so universally associated with the use
of electric power, no specific industry or region will be relatively dis-
advantaged by the costs of complying with the proposed regulations. Since
all segments of industry will be impacted to an equal degree, costs can be
recovered from the consumers in the form of higher product prices without
resulting in any significant market shifts or price increases.
The only effects on enployment will be increases in manpower
required to ccmply with the proposed regulations. Small increases in
enployment may occur in several categories including: clerical workers to
canply with record keeping requirements; plant operators and managers to
operate larger or additional incinerators; truck drivers to handle increased
transportation demand, and construction workers during the initial con-
struction of storage facilities.
(1) Personal Communication, Mr. Karl Tobin, Edison Electric Institute,
New York, N.Y., April 21, 1977.
5-7
-------
5.5 Energy Consumption Requirements
The major increased energy requirement resulting from the proposed
regulation will be for fuel oil to operate the incinerators. In addition,
energy in the fom of fuels or solvents will be required to generate the
electric power to operate the incinerators, pcwsr the trucks used to haul
the PCB equipment to disposal sites, and flush transformers prior to disposal.
Total energy consunption requirements are surmarized in Table 5-2
for disposal option 1. The energy requirements are converted into equivalent
barrels of crude oil using a loss factor of 3.7 percent during the refining
of oil to fuels or solvents and an energy requirement of one gallon of fuel
oil per 39.5 kilowatt hours of electricity.
The total energy requirements will probably be considerably less
than the upper bound estimate of 17,700 BBI/day. The actual amount of
material incinerated will be closer to disposal option 2, and waste solvents
and oils will be used to replace part of the incinerator fuel requirements.
5.6 Effect on Supplies of Strategic Materials
The regulations do not directly have any significant affect on the
supply or consunption of any strategic materials. However, strict controls
on the disposal of transformers may discourage develqpnent of reclamation
technology for the copper in transformer windings as the GE incinerator will
shut down soon and there are no others able to handle copper windings. Not
all transformers have copper windings; many of the newer transformers have
used aluminum conductors, so there are perhaps 100,000 copper/askarel trans-
formers in service containing 1,000 pounds of copper each. The disposal of
these transformers over 40 years into chemical waste landfills would result
in the loss of 2,500,000 lbs of copper per year which might otherwise be
reclaimed. This is considerably less than 1 percent of the total amount of
copper reclaimed each year in the U.S. and is an insignificant portion of
the total amount of copper consumed each year.
5-8
-------
TABLE 5-2
Annual Energy Requirements of Disposal Regulations
Disposal Option 1 (Incinerate all Capacitors)
Fuel for Incinerators:
1 gal. fuel oil per lb PCB equipment 258,700,000 gal
1 gal solvent per gallon transformer 1,215,000 gal
askarel drained
Electricity (100,000 kwh x 12/39.5 gal/kwh) 30,379 gal
Transportation (.01 gal/lb PCB equipment) 2,587,000 gal
Total Refined Fuel 262,000,000 gal.
Crude oil equivalent: 262,000,000•_ 271,000,000 gal.
Crude oil equivalent: 2—,Q9P,00Q = 6,452,000 BBL/year
Crude oil equivalent: = 17,700 BBL/day
5-9
-------
APPENDIX A
TOXIC SUBSTANCES CCNTKOL ACT
Public Law 94-469
90 Stat. 2003 et seq
Page A-2; Section 6(e): Polychlorinated
Biphenyls
Page A-3: Section 6(a): Soope of Regulation
A-l
-------
PUBLIC LAW 94-469—OCT. 11, 1976 90 STAT. 2025
(e) Polychlorinated Bephksyxs.—(1) Within six months after Rules,
the effective date of this Act the Administrator shall promulgate
rules to—
(A) prescribe methods for the disposal of polychlorinated
biphenyls, and
(B) require polychlorinated biphenyls to be marked with clear
and adequate warnings, and instructions with respect to their
processing, distribution in commerce, use, or disposal or with
respect to any combination of such activities.
Requirements prescribed by rules under this paragraph shall be con-
sistent with the requirements of paragraphs (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 commerce or use any polychlorinated biphenyl
in any manner other than in a tocally 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 polychlorinated biphenyl in a manner other than
in a totally enclosed manner if the Administrator finds that such manu-
facture, processing, distribution in commerce, or use (or combination
of such activities) will not present an unreasonable risk of injur}- to
health or the environment.
(C) For the purposes of this paragraph, the term "totally enclosed "Totally enclosed
manner" means any manner which will ensure that any exposure of manner."
human beings or the environment to a polychlorinated biphenyl will
be insignificant as determined by the Administrator by rule.
(3) (A) Except as provided in subparagraphs (B) and (C)—
(i) no person may manufacture any polychlorinated biphenvl
after two years after the effective date of this Act, and
(ii) no person may process or distribute m commerce any poly-
chlorinated biphenyl after two and one-half years after such date.
(B) Any person may petition the Administrator for an exemption Petition for
from the requirements of subparagraph (A), and the Administrator exemption,
may grant by rule such an exemption if the Administrator finds
that—
(i) an unreasonable risk of injury to health or environment
would not result, and
(ii) good faith efforts have been made to develop a chemical
substance which does not present an unreasonable risk of injury
to health or the environment and which may be substituted for
su. h polychlorinated biphenyl.
An exemption granted under this subparagraph shall be subject to Terms and
n conditions as the Administrator mav prescribe and conditions,
shall be m effect for such period (but not more than one year from
the date it is granted) as the Administrator may prescribe.
(C) Subparagraph (A) shall not apply to the distribution in com-
merce of any polychlorinated biphenvl if such polvchlorinated
biphenyl was sold for purposes other than resale before two and one
half years after the date of enactment of this Act.
(4) Any rule under paragraph (1), (2)(B), or (3)(B) shall be
promulgated in accordance with paragraphs (2), (3), and (4) of sub-
section (c).
(5) This subsection does not limit the authority of the Adminis-
trator, under any other provision of this Act or any"other Federal law.
to take action respecting any polychlorinated biphenyl.
A-2
-------
SEC. 6. REGULATION OF HAZARDOUS CHEMICAL SUBSTANCES AND
MIXTURES.
15 USC 260S. (a) Scope op Reocxatiox.—If the Administrator finds that there is
a reasonable basis to conclude that the manufacture, processing, dis-
tribution in commerce, use, or disposal of a chemical substance or
mixture, or that any combination of such activities, presents or will
present an unreasonable risk of injury to health or the environment,
the Administrator shall by rule apply one or more of the following
requirements to such substance or mixture to the extent necessary to
protect adequately against such risk using the least burdensome
requirements:
(1) A requirement (A) prohibiting the manufacturing, process-
ing, or distribution in commerce of such substance or mixture, or
(B) limiting the amount of such substance or mixture which may
be manufactured, processed, or distributed in commerce.
(2) A requirement—
(A) prohibiting the manufacture, processing, or distribu-
tion in commerce of such substance or mixture for (i) :i
particular use or (ii) a particular use in a concentration in
excess of a level specified by the Administrator in the rule
imposing the requirement, or
(B) limiting the amount of such substance or mixture
which may be manufactured, processed, or distributed in
commerce for (i) a particular use or (ii) a particular use
in a concentration in excess of a level specified by the
Administrator in the rule imposing the requirement.
(3) A requirement that such substance or mixture or any
article containing 3uch substance or mixture be marked with or
accompanied by clear and adequate warnings and instructions
with respect to its use, distribution in commerce, or disposal or
with respect to any combination of such activities. The form and
content of such warnings and instructions shall be prescribed by
the Administrator.
(4) A requirement that manufacturers and processors of such
substance or mixture make and retain records of the processes
used to manufacture or process such substance or mixture and
monitor or conduct tests which are reasonable and necessary to
assure compliance with the requirements of any rule applicable
under this subsection.
(5) A requirement prohibiting or otherwise regulating any
manner or method of commercial use of such substance or
mixture.
(6) (A) A requirement prohibiting or otherwise regulating any
manner or method of disposal of such substance or mixture, or
of any article containing such substance or mixture, by its manu-
facturer or processor or dv any other person who uses, or disposes
of, it for commercial purposes.
(B) A requirement under subparagraph (A) may not require
any person to take any action which would be in violation of
any law or requirement of, or in erfect for, a State or political
subdivision, and shall require each person subject to it to notify
each State and political subdivision in which a required disposal
may occur of such disposal.
(7) A requirement directing manufacturers or processors of
such substance or mixture (A) to give notice of such unreasonable
risk of injury to distributors in commerce of such substance or
mixture and, to the extent reasonably ascertainable, to other per-
sons in possession of such substance or mixture or exposed to such
substance or mixture, (B) to give public notica of such risk of
injury, and (C) to replace or repurchase such substance or
mixture as elected by the person to which the requirement is
directed.
Any requirement (or combination of requirements) imposed under
this subsection may be limited in application to specified geographic
areas.
A-3
-------
APPENDIX B
DRAFT PCB MASKING AND DISPOSAL BEGULAHONS (4-18-77)
40 CFR 761
B-l
-------
It is proposed to establish a new 40 CFR 761 to read as follows:
PART 751 - POLYCHLORINATED BI PHENYLS (PCS s}
Subpart A - General
Sec. 761.1 Applicability
761.2 Definitions
Subpart B - Disposal of PCBs
Sec. 761.10 Disposal Requirements
Subpart C - Marking of PCBs
Sec. 761.20 Marking Requirements
Subpart D - (Reserved)
Subpart E - List of Annexes
Sec. 761.40 Incineration
761.41 Chemical Waste Landfills
761.42 Storage for Disposal
761.43 Decontamination
761.44 Marking Formats
761.45 Records and Monitoring
Annex No.
I
II
III
IV
V
VI
B-2
-------
Subpart A - General
Sec. 761.1 Applicability
(a) This subpart establishes procedures, methods, and other requirements
for the disposal, storage, and marking of polychlorinated biphenyls
(PCBs).
(b) This subpart applies to all persons who manufacture, process, dis-
tribute in commerce, use, or dispose of PC8s, including mixtures
and manufactured items which contain PCBs.
(c) The basic requirements of these regulations are set forth in Subpart
B - Disposal of PCBs and Subpart C - Marking of PCBs. Subpart E
elaborates the requirements which are referred to in the disposal
and marking sections. Definitions of words used in all of these
sections are found in Subpart A. In particular, Sec. 7S1.2(p}-(v)
of Subpart A define "PCBs" covered by these regulations.
(d) Section 15 of the Toxic Substances Control Act (TSCA) states that
failure to comply with these regulations is unlawful. Section 16
imposes liability for civil penalties upon any person who violates
these regulations. Section 16 also subjects a person to criminal
prosecution for a violation which is knowing or willful.
Sec. 761.2 Definitions
For the purpose of this part:
(a) "Administrator" means the Administrator of the Environmental Pro-
tection Agency, or any employee of the Agency to whom the Adminis-
trator may either herein or by order delegate his authority to carry
out his functions, or any person who shall by operation of law be
authorized to carry out such functions.
-------
"Agency" means the United States Environmental Protection Agency.
"Capacitor" means a device for accumulating and holding a charge
of electricity, consisting of conducting surfaces separated by a
dielectric. Types of capacitors are as follows:
(1) "Small Capacitor" means a capacitor which contains less than
1.36 kg (3 lbs.) of dielectric, except for a capacitor which
is defined as an "HID Capacitor."
(2) "HID Capacitor" means a capacitor which contains less than
1.36 kg (3 lbs.) of dielectric and which is used as part of the
ballast of a high intensity discharge lighting fixture (e.g.>
sodium vapor and mercury vapor arc lights).
(3) "Large High Voltage Capacitor" means a capacitor which contains
1.36 kg (3 lbs.) or more of dielectric and which operates at
2000 volts a.c. or above.
(4) "Large Low Voltage Capacitor" means a capacitor which contains
1.36 kg (3 lbs.) or more of dielectric ana which operates below
2000 volts a.c.
(1) Except as provided in subparagraph (2), the term "Chemical
Substance" means any organic or inorganic substance of a
particular molecular identity, including:
(A) any combination of such substances occurring in whole or
part as a result of a chemical reaction or occurring in
nature, and
(B) any element or uncombined radical.
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(2) Such term does not include:
(A) any mixture,
(B) any pesticide (as defined in the Federal Insecticide,
Fungicide, and Rodenticide Act) when manufactured,
processed, or distributed in conmerce for use as a
pesticide,
(C) tobacco or any tobacco product,
(0) any source material, special nuclear material, or
byproduct material (as such terms are defined in the
Atomic Energy Act of 1954 and regulations issued under
such Act),
(E) any article the sale of which is subject to the tax
imposed by Section 4181 of the Internal Revenue Code of
1954 (determined without regard to any exemptions from
such tax provided by Section 4132 or 4221 or any other
provisions of such Code), and
(F) any food, food additive, drug, cosmetic, or device (as such
terms are defined in Section 201 of the Federal Food,
Drug, and Cosmetic Act) when manufactured, processed, or
distributed in commerce for use as a food, food additive
drug, cosmetic, or device.
"Chemical Waste' Landfill" means a landfill at which protection is
provided from PCBs deposited therein against risk of injury to
health or the environment by locating, engineering, and operating
such landfill so as to prevent migration of PC8s to land, water, or
the atmosphere.
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(f) "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 clause (1).
(g) "Disposal" means to intentionally or accidentally discard, throw
away, or otherwise complete or terminate the useful life of an
object or substance. Disposal includes actions related to containing,
transporting, destroying, degrading, decontaminating, or confining
those substances, mixtures, or articles that are being disposed.
(h) "Distribute in Commerce" and "Distribution in Commerce" when used
to describe an action taken with respect to a chemical substance or
mixture or article containing a substance or mixture means to sell
or to transfer the ownership of the substance, mixture, or article
in commerce; to introduce or deliver for introduction into commerce,
or the introduction or delivery for introduction into commerce of
the substance, mixture, or article; or to hold, or the holding of,
the substance, mixture, or article after its introduction into
commerce.
(i) "Fluorescent Light Ballast" means a device which electrically
controls fluorescent light fixtures and which includes a capacitor
containing 0.1 kg or less of dielectric.
(j) "Incinerator" means any installation operated for the incineration
of chemical substances, mixtures, or articles.
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(k) "Manufacture" means to produce, manufacture, or import into the
customs territory of the United States.
(1) "Mark" means the descriptive name, instructions, cautions, or other
information applied to chemical substances, mixtures, articles,
containers, equipment, or other objects or activities described in
these regulations.
(m) "Marked" means the permanent application of a legible mark by
painting, fixation of an adhesive label, or other method,
(n) "Mixture" means any combination of two or more chemical substances
if the combination does not occur in nature and is not, in whole
or in part, the result of a chemical reaction. Such term does
include
(1) any combination which occurs, in whole or in part, as a result
of a chemical reaction if none of the chemical substances
comprising the combination is a new chemical substance and if
the combination could have been manufactured for commercial
purposes without a chemical reaction at the time the chemical
substances comprising the combination were combined,
(2) any combination of chemical substances which is the result of
solution or hydration; and
(3) any combination which occurs as a consequence of a reaction
which may take place if a chemical substance which functions as
a stabilizer, colorant, antioxidant, filler, solvent, carrier,
surfactant, or plasticizer is added to another chemical substance
and performs as intended.
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(o) "Municipal Solid Wastes" means garbage, refuse, sludges, wastes,
and other discarded materials resulting from residential and non-
industrial operations and activities.
(p) "PCB" and "PCBs" mean one or more of the following: "PCB Chemical
Substance", "PCB Mixture", "PCB Article", "PCB Equipment", and
"PCB Container."
(q) "PCB Article" means any manufactured item, other than a PCB container,
whose surface(s) has been in direct contact with a PCB chemical
substance or a PC3 mixture, and includes capacitors, transformers,
electric motors, pumps, and pipes.
(r) "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 a
PCB chemical substance or PC3 mixture.
(s) "PCB Chemical Substance" means any chemical substance which is
limited to the biphenyl molecule which has been chlorinated to
varying degrees, and includes substances such as Arochlors.
(t) "PCB Container" means any package, can, bottle, bag, barrel, drum,
tank, or other device used to contain a PCB chemical substance, PCB
mixture, or PCB article, and whose surface(s) has been in direct
contact with a PCB chemical substance or PCB mixture.
(u) "PCB Equipment" means any manufactured item, other than a PCB
container or a PCB article container, which contains a PCB article
or other PCB equipment, and includes microwave ovens, television sets,
and fluorescent light ballasts and fixtures.
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(v) "PCB Mixture" means any mixture, except municipal sewage treatment
sludge, which contains 0.05 percent (on a dry weight basis) or
greater of a PC3 chemical substance, and includes dielectrics,
contaminated solvents and oils, rags, soil, paints, and debris,
(w) "Person" means any natural or juridical person including any
individual, corporation, partnership, or association, any State or
political subdivision thereof, any interstate body and any department,
agency, or instrumentality of the Federal government.
(x) "Process" means the preparation or use of a chemical substance or
mixture, after its manufacture, for distribution in commerce:
(1) in the same form or physical state as, or in a different form
or physical state from, that in which it was received by the
person so preparing such substance or mixture, or
(2) as part of an article containing the chemical substance or
mixture.
(y) "Municipal Sewage Treatment Sludge" means'-the solid residue resulting
from the treatment of municipal sewage.
(z) "Storage for Disposal" means temporary storage of PC3s that have
been designated for disposal.
(aa) "Transport Vehicle" means a motor vehicle or rail car used for the
transportation of cargo by any mode. Each cargo-carrying body
(e.g., trailer, railroad freight car) is & separate transport
vehicle.
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Subpart B - Disposal of PCBs
Sec. 751-10 Disposal Requirements
These regulations do not require removal of PCBs from service and disposal
earlier than would normally be the case. However, when PCBs are removed
from service and disposed of, disposal must be undertaken in accordance
with these regulations. Future regulations will be directed to the
manufacture, use, and distribution in commerce of PCBs and may result in
some cases in disposal at an earlier date than would otherwise occur.
(a) PCB Chemical Substances
(1) A PC3 chemical substance shall be disposed of in an incinerator
which complies with Annex 1.
(2) Prior to disposal, a PC3 chemical substance shall be stored in
a facility which complies with Annex III.
(b) PCB Mixtures
(1) Except as provided in subsections (2) and (3), a PCB mixture
shall be disposed of in an incinerator which complies with
Annex I.
(2) A non-liquid PCB mixture in the form of contaminated soil,
sludge, dredge spoil, rags, or other deoris shall be disposed
of
(A) in an incinerator which complies with Annex I, or
(B) until July 1, 1979, in a chemical waste landfill which
complies with Annex II.
(3) Solid residue from an incinerator used for PC3 disposal in
accordance with Annex I shall be disposed of
B-10
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(A) in an incinerator which complies with Annex I, or
(B) in a chemical waste landfill which complies with Annex II.
(4) Prior to disposal, a PCB mixture shall be stored in a facility
which complies with Annex III.
PCB Articles & PCB Fluorescent Light Ballasts
(1) A PCB transformer shall be disposed of
(A) in an incinerator which complies with Annex I, or
(B) in a chemical waste landfill which complies with Annex
II, provided the transformer is first drained, and flushed
internally if necessary, so that no more than two percent
of the dielectric liquid volume measured to the fill line
remains. PCB chemical substances and PCB mixtures which
are removed shall be disposed of in accordance with sub-
sections (a) and (b).
(2) Unless the manufacturer1s literature, the label, or chemical
analysis indicates that a fluorescent light ballast does not
contain a PCB chemical substance or a PCB mixture, the ballast
shall be disposed of in an incinerator that complies with Annex
I or until July 1, 1979, in a chemical waste landfill that
complies with Annex II except that the occupant of a private
housing unit may dispose of ballasts used in the housing unit
as municipal solid waste.
(3) Other PCB articles shall be disposed of in an incinerator which
complies with Annex I.
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(4) Except for fluorescent light ballasts used in private housing
units, prior to disposal PCB articles shall be stored in a
facility which complies with Annex III.
(d) PCB Equipment Other than PCB Fluorescent Light Ballasts
(1) Except as provided in Subsection (2), PCB equipment other than
PCB fluorescent light ballasts shall be disposed of
(A) in an incinerator which complies with Annex I,
(B) in a chemical waste landfill which complies with Annex
II, or
(C) as municipal solid waste.
(2) Whenever PCB equipment is serviced in a manner which provides
direct access to a PCB article such as a capacitor and a
decision is made to dispose of the PCB equipment, the PCB
article shall be removed from the equipment and disposed of in
accordance with Subsection (c).
(e) PCB Containers
(1) Unless decontaminated in accordance with Annex IV, a PCB
container shall be disposed of
(A) in an incinerator which complies with Annex I, or
(B) in a chemical waste landfill which complies with Annex
II, provided that the PCB container shall first be
drained, and flushed internally if necessary, so that
remaining PCB chemical substances and PCB mixtures
constitute no more than 0.5 percent of the total volume
of the container.
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(2) Prior to disposal, a PCB container shall be stored in a
facility which complies with Annex III.
Spills
(1) Spills and other uncontrolled discharges of PCB chemical
substances or PCB mixtures constitute the disposal of PCB
chemical substances or PCB mixtures and must comply with this
section.
(2) PCB chemical substances and PCB mixtures resulting from spill
incidents shall be stored and disposed of in accordance with
Subsections (a) and (b) respectively.
(3) This subsection does not exempt owners or operators respon-
sible for a spill from any actions or liability under other
statutory authorities, including Section 311 of the Federal
Water Pollution Control Act (Pub. L. 92-500) and the Resource
Conservation and Recovery Act (94-580).
Municipal solid wastes containing PCBs shall be disposed of as
provided in applicable Federal, state, or local laws, regulations,
and policies.
A municipal sewage treatment sludge which contains 0.05 percent
(on a dry weight basis) or greater PCB chemical substances shall
be disposed of'
(1) in an incinerator which complies with Annex I, or
(2) until July, 1, 1979, in a chemical waste landfill which
complies with Annex II.
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Subpart C - Marking of PC3s
Sec. 761.20 Marking Requirements
(a) The following marking requirements shall apply:
(1) Each PCB article manufactured after January 1, 1978, shall
be marked at the time of manufacture with mark as described
in Annex V - Sec. 761.44(a).
(2) Each item of PCB equipment manufactured after January 1, 1978,
shall be marked at the time of manufacture with mark M, .
(3) Each PCS container, whether new or existing, shall be marked
by January 1, 1978, with mark M^.
(4) Each PC3 article, except small PCB capacitors, contained in PCB
equipment in inventory after January 1, 1978, shall be marked
before it is distributed in commerce with mark M^.
(5) Each PCB article container used to contain a PCB article that
shall be marked under the provisions of (1) or (4) above shall
be marked by January 1 , 1978, with mark
(6) Each storage area used to store PC3s for disposal shall be
marked by January 1, 1973, with mark M^.
(7) Each PCB article when removed from use after January 1, 1978,
shall at the time of removal either be marked with mark or
be placed in a PCB container marked with mark except for
PCBs disposed of as municipal solid waste as provided in
Sections 761.10(c)(2), 761.10(d)(1)(c), and 751.10(g).
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(8) Each of the following PCB articles using PCB chemical substances
or PCB mixtures as internal fluids shall be marked by January 1,
1978, with mark
(A) Electric motors using PCB coolants.
(B) Hydraulic machinery using PC3 hydraulic fluid.
(C) Heat transfer systems (other than transformers) using PCB
fluids.
(b) In addition to the requirements of Subsection (a), the following
marking requirements shall apply:
(1) Effective March 31, 1978 each transport vehicle loaded with
PCB containers with more than 45 kc of PCB chemical substances
or PCB mixtures in the liquid phase or with one or more PCB
transformers snail be marked with mark M^.
(2) Each PCB large low voltage capacitor and each PC3 HID capacitor
that is in use after March 31, 1978, shall be marked with mark
M^ as soon after the date as the capacitor is available for
marking because of other servicing of the equipment. A
capacitor is available for marking when other servicing oper-
ations provide the servicing person direct access to the
capacitor.
(c) In addition to the requirements of Subsections (a) and (b), the
following marking requirements shall apply:
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(1) Each PCB transformer shall be marked by July 1, 1978, with
mark M^.
(2) Each PCB large high voltage capacitor shall be identified by
July 1, 1978, by at least one of the following methods:
(A) Each individual capacitor is to be marked with mark
Ml, or
(B) If one or more PCB large high voltage capacitors are
installed in a protected location as on a power pole or
structure or behind a fence, the pole, structure, or
fence is to be marked with mark and a record or
procedure identifying the PCB capacitors is to be main-
tained by the owner or operator at the protected location.
Where mark is specified but the PCB article or PCB equipment is
too small to accommodate the smallest permissible size of mark M^,
mark M<-, as described in Annex V - Sec. 761.44(b), may be used
instead of mark
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Subpart D - (Reserved)
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Annex I
Sec. 761.40 Incineration
(a) Liquid PC3s
An incinerator used for incinerating PCS chemical substances or liq-
uid PCB mixtures shall be approved by the Agency Regional Administrator
pursuant to Subsection (d). Such incinerator shall meet all of the re-
quirements specified in (1) through (9) of this subsection, unless a
waiver from these requirements is obtained pursuant to (d)(5). In addi-
tion, the incinerator shall meet any other requirements which may be
prescribed pursuant to (d)(4).
(1) Combustion criteria shall be either of the following:
(A) 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
(B) maintenance of the introduced liquids for a 1 1/2 dwell
time at 160Q°C (± 100°C) and 2 percent excess oxygen
in the stack gas.
(2) Combustion efficiency shall be at least 9S percent computed as
fol1ows:
Combustion Efficiency = Ceo^ - Ceo x 1 GO
Cco2
where
CCO2 = concentration of carbon dioxide
Ceo = concentration of carbon monoxide
(3) The rate and quantity of PC3s which are fed to the combustion
system shall be measured and recorded at regular intervals of
no longer than 15 minutes.
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The temperatures of the incineration process shall be contin-
uously measured and recorded. The combustion temperature of
the incineration process shall be based on either direct
(pyrometer) or indirect (wall thermocouple-pyrometer correla-
tion) temperature readings.
The flow of PCBs to the incinerator shall stop automatically
whenever the combustion temperature drops below the tempera-
tures specified in (1) above.
Monitoring of stack emission products shall be conducted
(A) when an incinerator is first used for the disposal of
PCBs under the provisions of this regulation, and
(B) When an incinerator is first used for the disposal of
PCBs after the incinerator has been modified in a manner
which may affect the characteristics of the stack emis-
sion products.
(C) At a minimum such monitoring shall be conducted for the
following parameters:
(i) o2
(ii) CO
(i1i) C02
(iv) Oxides of Nitrogen (NQx)
(v) Hydrochloric Acid (HC1)
(vi) Total Chlorinated Organic Content (RC1)
(vii) PCS Chemical Substances
(viii) Total Particulate Matter
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(7) At a minimum, continuous monitoring and recording of combustion
products and incineration operations shall be conducted for the
following parameters whenever the incinerator is incinerating
PCBs.
(A) 02
(B) CO
(C) co2
(8) Incinerator operations shall be immediately suspended when any
one or more of the following conditions occur:
(A) failure of monitoring operations specified in (7) above,
(B) failure of the PC3 rate and quantity measuring and re-
cording equipment specified in (3) above, or
(C) combustion temperature, dwell time, or excess oxygen fall
below those specified in (1) above.
(9) Water scrubbers shall be used for HC1 control during PCB in-
cineration and shall meet any performance requirements speci-
fied by the Regional Administrator. Scrubber effluent shall
comply with applicable water quality standards, EPA Water
Quality Criteria, and any other state and Federal laws and
regulations. An alternate method of HC1 control may be used
if the alternate method has been approved by the Regional
Administrator.
Non-Liquid PCBs
An incinerator used for incinerating non-liquid PCS mixtures, PC3
articles, PCB equipment, or PCB containers shall be approved by the
Agency Regional Administrator pursuant to Subsection (c). Such inciner
tor shall meet all of the requirements specified in (1) through (3) of
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this subsection, unless a waiver from these requirements is obtained
pursuant to (d)(5). In addition, the incinerator shall meet any
other requirements which may be prescribed pursuant to (d)(4).
(1) The mass air emissions from the incinerator shall be no
greater than 0.001g PCB chemical substances/Kg of PC3 chemical
substance introduced into the incinerator.
(2) Such incinerator shall comply with the provisions of Section.
761.40(a) (2),(3),(4),(6),(7),(8)(A) and (B), and (9).
(3) The flow of PCBs to the incinerator shall stop automatically
whenever the combustion temperature falls below the tempera-
tures specified in any approvals issued by the Regional Admin-
istrator pursuant to Subsection (d) below. Incinerator opera-
tions shall stop immediately whenever the excess oxygen
measurements fall below those specified in any approvals
issued by the Regional Administrator pursuant to (d) below.
Maintenance of Data and Records
All data and records required by this section shall be maintained
in accordance with Annex VI - Section 751.45, Records and Monitoring.
Approval of Incinerators
Prior to the incineration of PC3s, the owner or operator of an
incinerator shall receive the written approval of the Agency
Regional Administrator of the Region in which the incinerator is
located. Such approval shall be obtained in the following manner:
(1) Initial Report
The owner or operator shall submit to the Regional Administra-
tor an initial report which contains:
(A) T:ie location of the incinerator.
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(B) A detailed description of the incinerator including gen-
eral site plans and design drawings of the incinerator.
(C) Engineering reports or other information on the antici-
pated performance of the incinerator.
(D) Sampling and monitoring equipment and facilities avail-
able.
(E) Waste volumes expected to be incinerated.
(F) Any local, state, or Federal permits or approvals.
(G) Schedules and plans for complying with the approved re-
quirements of this regulation.
Trial Burn
(A) Following receipt of the report described in (1), the
Regional Administrator shall notify the person who sub-
mitted the report whether a trial burn of PCBs must be
conducted. The Regional Administrator may require the
person who submitted the report described in (1) to sub-
mit such other information as the Regional Administrator
finds to be reasonably necessary to determine the need
for a trial burn.
(B) If the Regional Administrator determines that a trial
burn must be held, the person who submitted the report
described in (1) shall submit to the Regional Administra-
tor a detailed plan for conducting and monitoring the
trial burn. At a minimum, the plan must include:
(i) Date trial burn is to be conducted.
(ii) Quantity and type of PCBs to be incinerated.
(iii) Parameters to be monitored and location of
sampling points.
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(iv) Sampling frequency and methods and schedules for
sample analyses.
(v) Name, address, and qualifications of persons who
will review analytical results and other pertinent
data and perform a technical evaluation of the ef-
fectives of the trial burn.
(C) Following receipt of the plan described in (B), the
Regional Administrator will approve the plan, require
additions or modifications to the plan, or disapprove the
plan. If the plan is disapproved, the Regional Adminis-
trator will notify the person who submitted the plan of
such disapproval, together with the reasons why it was
disapproved. That person may thereafter submit a new
plan in accordance with (B). If the plan is approved
(with any additions or modifications which the Regional
Administrator may prescribe), the Regional Administrator
will notify the person who submitted the plan of such
approval. Thereafter the trial burn shall take place at
a date and time to be agreed upon between the Regional
Administrator and the person who submitted the plan.
Other Information
In addition to the information contained in the report and
plan described in (1) and (2), the Regional Administrator may
require the owner or operator to submit such other information
as the Regional Administrator finds to be reasonably necessary
to determine whether an incinerator shall be approved.
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[Note: The Regional Administrator will have available for review and in-
spection an Agency manual containing information or sampling
methods and analytical procedures for the parameters required
in Section 761.40(a)(3),(4),(6), and (7) plus any other parama-
ters he may determine to be appropriate. Owners or operators
are encouraged to review this manual prior to submitting any
report required in this Annex.]
(4) Contents of Approval
(A) Except as provided in (5), the Regional Administrator may
not approve an incinerator for the disposal of PCBs un-
less he finds that the incinerator meets all of the re-
quirements of (a) and/or (b), whichever is applicable.
(B) In addition to the requirements of (a) and/or (b), the
Regional Administrator may include in an approval such
other requirements as the Regional Administrator finds
are necessary to ensure that operation of the incinerator
does not present an unreasonable risk of injury to health
or the environment from PCBs. Such requirements may in-
clude a fixed period of time for which the approval is
valid.
(5) Waivers
An owner or operator of the incinerator may submit evidence to
the Regional Administrator that operation of the incinerator
will not present an unreasonable risk of injury to health or
the environment from PCBs, when one or more of the require-
ments of (a) and/or (b) are not met. On the basis of such
evidence and any other available information, the Regional
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Administrator may in his discretion find that any such require-
ments are not necessary to protect against such risk and may
waive such requirements in any approval for that incinerator.
Any such finding and waiver must be stated in writing and in-
cluded as part of the approval.
Persons Approved
An approval will designate the persons who own and who are
authorized to operate the incinerator, and will apply only to
such persons.
Final Approval
Approval of an incinerator will be in writing and signed by
the Regional Administrator. The approval will state all re-
quirements applicable to that incinerator.
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Annex II
Sec. 761.41 Chemical Waste Landfills
(a) General
A chemical waste landfill used for the disposal of PCBs shall be
approved by the Agency Regional Administrator pursuant to Subsection
(c). Such landfill shall meet all of the requirements specified in
Subsection (b), unless a waiver from these requirements is obtained
pursuant to (c)(4). In addition, the landfill shall meet any other
requirements which may be prescribed pursuant to (c)(3).
(b) Technical Requirements
Requirements for chemical waste landfills used for the disposal of
PCBs are as follows:
(1) Soils
The landfill site shall be located in thick, relatively
impermeable formations such as large-area clay pans. Where
this is not possible, the soil shall have a high clay and
silt content with the following parameters:
(A) In-place soil thickness, or 4'
Compacted soil liner thickness 3'
(B) Permeability (cm/sec) < 1x10"^
(C) Percent soil passing No. 200 Sieve > 30
(D) Liquid Limit ^ 30
(E) Plasticity Index * 15
(F) Artificial Liner Thickness ^ 30 mil
(Note: In the event that an artificial liner is used at a
landfill site, special precautions shall be taken to
insure that its integrity is maintained and that it
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is chemically compatible with PC3s. Soil underlining
shall be provided as well as a soil cover).
Hydrology
The bottom of the landfill shall be substantially above the
historical high groundwater table. Floodplains, shore!ands,
and groundwater recharge areas shall be avoided. There shall
be no hydraulic connection between site and standing or flowing
surface water. The site shall have monitoring wells and
leachate collection and shall be at least fifty feet from
the nearest groundwater.
Flood Protection
(A) If the landfill site is below the 100-year floodwater
elevation, the operator shall provide surface water
diversion dikes around the perimeter of the landfill site
with a minimum height equal to two feet above the 100-
year floodwater elevation.
(B) If the landfill site is above the 100-year floodwater
elevation, the operator shall provide diversion struc-
tures capable of diverting all of the surface water run-
off from a 24-hour, 25-year storm.
Topography
The landfill site shall be located in an area of low to moderate
relief to minimize erosion and to help prevent landslipes or
slumping.
Monitoring Systems
(A) Water Sampling
(i) The ground and surface water from the disposal
site area shall be sampled for use as baseline
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data prior to the conmencement of disposal
operations.
(ii) Defined sources shall be sampled at least monthly
when the landfill is being used for disposal
operations.
(iii) Defined sources shall be sampled indefinitely on
a frequency of no less than once every six months
after final closure of the disposal area.
Groundwater Monitor Wells
(i) If underlying earth materials are homogeneous,
impermeable, and uniformly sloping in one direc-
tion, only three sampling points shall be neces-
sary. These three points shall be equally spaced
on a line through the center of the disposal area
and extending from the area of highest water
table elevation to the area of the lowest water
table elevation on the property.
(ii) All monitor wells shall be cased and the annular
space between the monitor zone (zone of satura-
tion) and the surface shall be completely back-
filled or plugged with Portland cement to effec-
tively prevent percolation of surface water into
the well bore. The well opening at the surface
shall have a removable cap to provide access and
to prevent entrance of rainfall or stormwater run-
off. The well shall be pumped to remove the vol-
ume of liquid initially contained in the well
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before obtaining a sample for analysis. The dis-
charge shall be treated to meet applicable state
or Federal discharge standards or recycled to the
chemical waste landfill.
(C) Water Analysis
As a minimum, all samples shall be analyzed for the fol-
lowing parameters, and all data and records of the
sampling and analysis shall be maintained as required in
Annex VI. Sampling methods and analytical procedures for
these parameters shall be as specified in 40 CFR 136 as
amended in 41 FR 52779 of December 1, 1975.
(i) PCBs
(ii) pH
(iii) Specific Conductance
(iv) Chlorinated Organics
Leachate Collection
A leachate collection monitoring system shall be installed be-
neath the chemical waste landfill. Leachate collection sys-
tems shall be monitored monthly for quantity and quality of
leachate produced. The leachate should be either treated to
acceptable limits for discharge in accordance with a state or
Federal permit or disposed of by another state or Federal ap-
proved method. Water analysis shall be as provided in (5){C)
above. Acceptable leachate collection monitoring/collection
systems include, but are not limited to, the following basic
designs:
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(A) Simple Leachate Collection: This system consists of a
gravity flow drainfield installed under the waste dis-
posal facility liner. This design is recommended for
use when semi-solid or leachable solid wastes are placed
in a lined pit excavated into a relatively thick, un-
saturated, homogeneous layer of low permeability soil.
(B) Compound Leachate Collection: This system consists of a
gravity flow drainfield installed under the waste dis-
posal facility liner and above a secondary installed
liner. This design is recommended for use when semi-
liquid or leachable solid wastes are placed in a lined
pit excavated into relatively permeable soil.
(C) Suction Manometers: This system consists of a network
of porous "stones" connected by hoses/tubing to a vacuum
pump. The porous "stones" or suction manometers are in-
stalled along the sides and under the bottom of the
waste disposal facility liner.'- This type of system
works best when installed in relatively permeable unsat-
urated soil immediately adjacent to the disposal facil-
ity's bottom and/or sides.
Chemical Waste Landfill Operations
(A) PCBs.shall be placed in the landfill in a manner that will
prevent damage to containers or articles. Other wastes
placed in the landfill that are not chemically compatible
with PCBs or PCS containers shall be segregated from the
PCBs throughout the waste handling and disposal process.
B-30
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(B) An operations plan shall be developed and submitted to the
Regional Administrator for approval as required in Sub-
section (c). This plan shall include detailed explana-
tions of the procedures to be used for recordkeeping,
excavation and backfilling, waste segregation, burial co-
ordinates, vehicle and equipment movement, use of road-
ways, leachate collection systems, sampling and monitor-
ing procedures, monitoring wells, and security measures
to protect against vandalism and unauthorized waste
placements. EPA guidelines entitled "Thermal Processing
and Land Disposal of Solid Waste" (39 FR 29337 of
August 14, 1974) are a useful reference in preparation
of this plan.
(C) Records shall be maintained for all PCB disposal opera-
tions and shall include the three dimensional burial
coordinates for PCBs. Additional records shall be devel-
oped and maintained as provided in Annex VI.
Supporting Facilities
(A) A six foot woven mesh fence, wall, or similar device
shall be provided around the site to prevent unauthorized
persons and animals from entering.
(B) Roads shall be maintained to and on the site which are
adequate to operate and maintain the site without caus-
ing safety or nuisance problems or hazardous conditions.
(C) The site shall be operated and maintained in a manner to
prevent safety problems or hazardous conditions resulting
from spilled liquids and windblown materials.
B-31
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Approval of Chemical Waste Landfills
Prior to the disposal of any PCBs in a chemical waste landfill, the
owner or operator of the landfill shall receive written approval of
the Agency Regional Administrator of the Region in which the landfill
is located. Such approval shall be obtained in the following manner:
(1) Initial Report
The owner or operator shall submit to the Regional Administra-
tor an initial report which contains:
(A) The location of the landfill.
(B) A detailed description of the landfill including general
site plans and design drawings.
(C) An engineering report describing the manner in which the
landfill complies with the requirements for chemical
waste landfills in (b) above.
(D) Sampling and monitoring equipment and facilities
available.
(E) Expected waste volumes of PCBs".
(F) General description of waste materials other than PCBs
that are expected to be disposed of in the landfill.
(G) Landfill operations plan as required in Subsection (b).
(H) Any local, state, or Federal permits or approvals.
(I) Any schedules or plans for complying with the approval
requirements of these regulations.
(2) Other Information
In addition to the information contained in the report de-
scribed in (1), the Regional Administrator may require the
B-32
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owner or operator to submit such other Information as the
Regional Administrator finds to be reasonably necessary to de-
termine whether a chemical waste landfill should be approved.
(3) Contents of Approval
(A) Except as provided in (4), the Regional Administrator
may not approve a chemical waste landfill for the dis-
posal of PCBs unless he finds that the landfill meets all
of the requirements of (6) above.
(B) In addition to the requirements of Subsection (b), the
Regional Administrator may include in an approval such
other requirements as the Regional Administrator finds
are necessary to ensure that operation of the chemical
waste landfill does not present an unreasonable risk of
injury to health or the environment from PCBs. Such re-
quirements may include a fixed period of time for which
the approval is valid.
(4) Waivers
An owner or operator of a chemical waste landfill may submit
evidence to the Regional Administrator that operation of the
landfill will not present an unreasonable risk of injury to
health or the environment from PCBs, when one or more of the
requirements of Subsection (b) are not met. On the basis of
such evidence and any other available information, the Re-
gional Administrator may in his discretion find that any such
requirements are not necessary to protect against such risk
and may waive such requirements in any approval for that
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landfill. Such finding and waiver will be stated in writing
and included as part of the approval.
Persons Approved
Any approval will designate the persons who own and who are
authorized to operate the chemical waste landfill, and will
apply only to such persons.
Final Approval
Approval of a chemical waste landfill will be in writing and
will be signed by the Regional Administrator. The approval
will state all requirements applicable to that landfill.
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Annex III
Sec. 761.42 Storage for Disposal
(a) A PCB article or PC8 container stored for disposal before July 1,
1981, shall be removed from storage and disposed of before July lj
1982. Any PCS article or PCB container stored for disposal after
July 1, 1981, shall be removed from storage and disposed of within
one year from the date when it was first placed into storage.
(b) Except as provided in (c) below, after October 1, 1977, owners or
operators of any facilities used for the storage of PCBs designa-
ted for disposal shall comply with the following requirements:
(1) Such facilities shall have:
(A) An adequate roof to prevent rainwater from reaching the
stored PC3s.
(B) An adequate floor which has continuous curbing with a
minimum six inch high curb. Such floor and curbing must
provide a containment volume equal to at least two times
the internal volume of the largest PCB equipment or PC3
container stored therein or twenty-five percent of the
total internal volume of all PCB equipment or containers
stored therein, whichever is greater.
(C) No drain valves, floor drains, sewer lines, or other
openings that would permit liquids to flow from the
curbed area.
(D) Continuous, smooth, and impervious construction for
floors and curbing such as Portland cement concrete.
B-35
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The storage area shall be marked as required in Subpart C -
Sec. 761.20(a)(6).
No items of movable equipment used for handling PCBs in the
storage facilities shall be removed from the areas unless
decontaminated.
All PCB containers shall be checked for leaks at least once
every 30 days. All leaking containers and their contents
shall be transferred immediately to properly marked non-
leaking containers. Any spilled or leaked materials shall be
immediately cleaned up using sorbents or other adequate means,
and the cleaned materials and residues shall be disposed of
in accordance with Subpart B - Sec. 761.10(b).
Any PCB container used for storage of liquid PCB chemical sub-
stances or liquid PCB mixtures shall comply with the specifi-
cations of the Department of Transportation Materials Trans-
portation Bureau Hazardous Materials Regulations, 4-9 CFR
173.346 (41 FR 42544, September 27/ 1976). Any PCB container
used for the storage of PCB articles, PCB equipment, non-
liquid PCB chemical substances, and non-liquid PC3 mixtures
may vary from 49 CFR 173.346 by meeting DOT Spec. 5, Spec. 5B,
or Spec. 17C with removable heads.
PCB articles and PC3 containers shall be dated when they are
placed in storage. The storage shall be managed so that the
PCB articles and PCB containers can be located by the date
they entered storage.
Owners or operators of storage facilities shall establish and
maintain records as provided in Annex VI.
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(c) After October 1, 1977, storage facilities storing only small
capacitors and having an aggregate storage volume not greater
than two fifty-five gallon drums, may limit their compliance
to using sound, non-leaking containers and storage of the
containers within a building.
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Annex IV
Sec. 761.43 Decontamination
(a) A PC3 container may be decontaminated by a triple rinsing operation
which requires the flushing of the internal surfaces of PC3
containers three times with a solvent containing less than
0.05 percent PCB chemical substance in which the solubility
of PCBs is five percent or more by weight. Each rinse shall
use a volume of the normal diluent equal to approximately ten
percent of the PC3 container's capacity. The solvent may be
reused for decontamination until it contains 0.5 percent PC3
chemical substance. The solvent shall then be disposed of
as a PCB mixture.
(b) Movable equipment used in storage areas shall be decontaminated
by swabbing surfaces that have contacted PCB chemical sub-
stances and PCB mixtures with a solvent meeting the criteria
of (a) above.
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Annex V
Sec. 761.44 Marking Formats
The following formats shall be used for marking:
(a) Large PCB Mark -
Mark shall be as shown in Figure 1, with black
letters and striping on a white background, and shall be
sufficiently durable to equal or exceed the life (inclu-
ding storage for disposal) of the equipment or container.
The size of the mark shall be at least 15.25 cm (6 inches)
on each side. If the PC3 equipment is too small to
accommodate this size, the mark may be reduced in size
proportionately down to a minimum of 5 cm (2 inches) on
each side.
(b) Small PCB Mark - Ms
Mark M^ shall be as shown in Figure 2, with black
letters and striping on a white background, and shall be
sufficiently durable to equal or exceed the life (inclu-
ding storage for disposal) of the equipment or container.
The mark shall be a rectangle 2.5 by 5 cm (1 inch by
2 inches). If the PCB equipment is too small to accommo-
date this size, the mark may be reduced in size propor-
tionately down to a minimum of 1 by 2 cm (.4 by .8 inches).
B—39
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¦CONTAINS
|w|| _
It
(Polychlorinatntl Biplronyls)
A toxic environmental contaminant requiring
special handling and disposal in accordance
with U.S. Environmental Protection Agency
Regulations 40 CFR 7(5/
In case of accident or spill or for disposal in ~
formation, call toll free the U.S. Coast Guard
National Response Center: 800-424-8802.
-------
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/
y
y
/ZS/S / / / /////s
CAUTION-CONTAINS y
PCBs
FOR PROPER DISPOSAL
SEE 40 CFR 76/
OR CALL 000-4 2*1-0002
"777-777~/77777"
/
/
y
/
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Annex VI
Sec. 761.45 Records and Monitoring
(a) PC3s in Service or Projected for Disposal
By January 1, 1978, each owner or operator of a facility containing
forty-five kilograms of PCS chemical substances or PC3 mixtures
in the liquid phase or fifty or more PCB large high voltage capacitors
shall develop and maintain records on the location and disposition
of the PCBs. These records shall form the basis of an annual document
prepared for each facility by March 1 covering the previous calendar
year. Owners or operators with more than one facility which contain
PCBs may maintain the records and documents at a single location,
provided the identity of this location is available at each facility
containing PCBs that is normally manned for eight hours a day. The
records and documents shall be maintained for at least five years
after the facility ceases containing PCBs at the prescribed quantities.
The fo11 owing information for each facility shall be included in the
annual document:
(1) The dates when PCBs are removed from service, are placed into
storage for disposal, and are placed into transport for dis-
posal. The quantities of such PCSs shall be indicated using
the following breakdown:
(A) Total weight in kilograms of any PCB chemical substances
or PCB mixtures in PCB containers, including the identi-
fication of container contents, such as liquids, and
capacitors.
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(B) Total number of PCS transformers and total weight in kilo-
grams of any PCB chemical substances and PCB mixtures
contained in the transformers.
(C) Total number of PCB large high voltage capacitors.
(2) For PCBs removed from service, the location of the initial
disposal or storage facility and the name of the owner or
operator of the facility.
(3) Total quantities of PC3s remaining in service at the end of
the calendar year using the following breakdown:
(A) Total weight in kilograms of any PCB chemical substances
and PCB mixtures in PCB containers, including the identi-
fication of container contents such as liquids and cap-
acitors.
(B) Total number of PCB transformers and total weight in
kilograms of any PCB chemical substances and PCB mixtures
contained -in the transformers-,
(C) Total number of PCB large high voltage capacitors.
Disposal and Storage Facilities
Beginning in 1979, each owner or operator of a facility used for
the storage or disposal of PCBs shall by March 1 of each year
prepare and maintain a document which specifies the manner in which
PCBs were handled at the facility during the previous calendar
year. Such document shall be retained at each facility for at
least five years after the facility is no longer used for the
storage or disposal of PCBs, except that in the case of chemical
waste landfills such documents shall be maintained at least twenty
B-43
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years after the chemical waste landfill is no longer used for the
disposal of PCBs. Such documents shall be available at the facility
for inspection by authorized representatives of the Environmental
Protection Agency. If the facility ceases to be used for PCB
storage or disposal, the owner or operator of such facility shall
promptly notify the Agency Regional Administrator of the region in
which the facility is located that the facility has ceased storage
or disposal operations and shall specify where the documents
required to be maintained by this paragraph shall be located. The
following information shall be included in each document:
(1) The date when any PCBs are received by the facility during
the previous calendar year for storage or disposal, and the
identification of the person and facility from whom such PCBs
were received.
(2) The date when any PCBs are disposed of at the disposal facility
or transferred to another disposal or storage facility, in-
cluding the identification of the specific types of PC3 chemi-
cal substances, PCS mixtures, or PCB articles in containers;
PCB transformers; and PCB equipment or PCB articles not in con-
tainers which were stored or disposed of.
(3) Total weight in kilograms of any PCB containers and the total
weight in kilograms of any PCB chemical substances or PCB mix-
tures contained in any PCB transformers, received during the
calendar year, transferred to other storage or disposal facil-
ities during the calendar year, and remaining on the disposal
or storage facility site at the end of the calendar year, re-
B—44
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spectively, including, where applicable, the identification of
PCS container contents such as liquids, capacitors, etc. When
PCB containers or PCB chemical substances or PCB mixtures con-
tained in a transformer are transferred to other storage or
disposal facilities, the identification of the facility to
which such PC8s were transferred shall be included.
(4) Total number of any PC8 articles or PCB equipment, not in PCB
containers, received during the calendar year, transferred to
other storage or disposal facilities during the calendar year,
and remaining on the facility site at the end of the calendar
year, respectively, including the identification of the speci-
fic types of PCB articles and PCB equipment received, trans-
ferred, or remaining on the facility site. When PCB articles
and PCB equipment are transferred to other storage or disposal
facilities, the identification of the facility to which such
PCB articles and PCB equipment were' transferred must be
included.
[Note: Any requirements for weights in kilograms of PCBs may be calcu-
lated values if the internal volume of containers and trans-
formers is known and included in the reports, together with any
assumptions on the density of the PCB chemical substances or
PCB mixtures contained in the containers or transformers.]
B-45
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Incineration Facilities
For each owner or operator of a PCS incinerator facility, the
following information is required in addition to the information
required in Subsection (b):
(1) When PC3s are being incinerated, the following continuous and
short-interval data shall be collected and maintained for a
period of five years from the date of collection:
(A) Rate and quantity of PC3s fed to the combustion system,
as provided in Annex I - Sec. 761.40(a)(3).
(B) Temperature of the combustion process, as provided in
Annex I - Sec. 761.40(a)(4).
(C) Stack emission products to include 09, CO, and CQ^, as
provided in Annex I - Sec. 761.40(a)(7).
(2) When PCBs are being incinerated, data and records resulting
from the monitoring of stack emissions as required in Annex I -
Sec. 761.40(d)(2), shall be collected and maintained for five
years.
(3) Total weight in kilograms of any solid residues generated by
the incineration of PCBs during the calendar year, the total
weight in kilograms of any solid residues disposed of by
such facility in chemical waste landfills, and the total
weight in kilograms of any solid residues remaining on the
facility site shall be retained for five years.
(4) When PC3s are being incinerated, additional periodic data
shall be collected and maintained as specified by the Regional
B-46
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Administrator pursuant to Annex I - Sec. 761.40(d)(4).
(5) A document shall be prepared on any suspension of the opera-
tion of any incinerator by the owner or operator thereof, as
required in Annex I - Sec. 761.40(a)(8). The document shall,
at a minimum, include the date and time of the suspension and
an explanation of the circumstances causing the suspension
of operation.
Retention of Special Records by Storage and Disposal Facilities
In addition to the information required to be maintained by Sub-
sections (b) and (c), each owner or operator of a PCS storage or
disposal facility shall collect and maintain for the time period
required in (c) the following data:
(1) All documents, correspondence, and data provided to the owner
or operator by any state or local government agency that per-
tain to the storage or disposal of PCBs at such facility.
(2) All documents, correspondence, and data provided by the owner
or operator of such facility to any state or local government
agency that pertain to the storage or disposal of PC3s at such
facili ty.
(3) Any applications and related correspondence sent by the owner
or operator of such facility to any local, state, or Federal
authorities in regard to wastewater discharge permits, solid
waste permits, building permits, or other permits or authori-
zations, such as those required by Annex I - Sec. 761.40(d)
or Annex II - Section 761.41(c).
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APPENDIX C
CHEMICAL WASTE LANDFILLS
C-l
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Address: Castalia Disposal Site
P.O. Box 5275
Santa Barbara, CA 93108
(805) 969-4703
Contact: Mr. Hunter or Mr. Cole
Waste Streams: 1. Exclusion: Radioactive waste.
2. Accept: PCB-contaminated solid wastes, primarily oily
wastes, oil field wastes, pesticides, and etchant wastes.
3. Volume: Urtoown.
Site Area: 300 acres with 1,000 acres buffer.
Disposal Price: $ .40/42 gal. barrel - oily wastes
$ .05/gal for special wastes
Estimated Landfill Life: Indefinite
Expansion Potential: Gcod, the firm is interested in expanding service to
handle all hazardous chemical wastes.
Site Information: The site is equipped with monitoring wells and leachate
surveillance facilities.
Licensed By: State of California, Class I site.
Cerrments: Petroleum industry and sane electronics are currently the only
generators of waste chenicals in this area.
Location of Landfill:
Santa Barbara, CA
C-2
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Address: Chancellor & Ogden, Inc./BKK
3031 East I Street
Wilmington, CA 90744
(213) 432-8461
Contact: Mr. William Shearer
Waste Streams: 1. Exclusions: Radioactive wastes.
2. Accept: PCB-contaminated solid wastes, Group I wastes
as defined by the State of California.
3. Voltane: Upwards to 500,000 gals./day.
Site Area: 600 acres
Disposal Price: Variable
Estimated Landfill Life: 45 years
Expansion Potential: None
Site Information: Acids are accepted but discharged in a separate location.
The site meets state requirements for Class I materials.
It has a natural clay strata with three monitoring wells
placed in bed rock to monitor leachate activity.
Licensed By: State of California, Class I site.
Location of Landfill:
City of West Covina, CA
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Address: Chem-trol Pollution Services, Inc. Landfill Location:
Subsidiary of SCA Services, Inc. Model City, N.Y.
P.O. Box 200, 1550 Balner Rd.
Model City, NY 14107
(716) 754-8231
Contact: Dr. Robert Stadelmaier
Area Served: U.S. & Canaca,
chiefly 30 eastern states, Ontario and Quebec
Waste Streams: 1. Exclusions: radioactive wastes, shock-sensitive
explosions
2. Accept: PCB-contaminated solid wastes, most types of
chemical wastes including solvents/cleaners, halogenated
hydrocarbons, paint 7 costing sludges, oils and oily
waste, toxic acids, alkalis, plating/etching wastes,
cyanides, heavy metal solutions & residues, pesticides/
PCBs, carcinogens, sludges and solids, arsenic and
mercury wastes.
3. Volume: Capacity in excess of 100 million gallons
annually at Model City facilities.
Site area: 800 acres, 25 acres in use.
Disposal Prices:
Contract Non-contract
bulk $5.00/ft3 < 50 ft3 $O0/ft3
55 gal drums $28.00/drum $30.00/drum
any PCB capacitor < 1 ft3 can be landfilled as is, any larger must
be drummed.
Estimated landfill Life: 150-200 years
Expansion Potential: Similar facility scheduled to be on stream in 1-2
years in New Jersey. Actively considering sites and
markets in several industrialized states.
Site Information: The site has reinforced mesribrane-lined clay cells that
receive solids, sludges, and chemically fixed wastes.
An internal surrp within each cell collects leachate for
treatment. Three-dimensional inventories of buried
wastes are maintained for possible recovery at later
date.
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Address: County Sanitation Districts of
Los Angeles County
P.O. Box 4998
Whittier, CA 90607
(213) 699-7411
Location of Landfill:
Palos Verdes
City of Rolling Hills
Estates, CA
Contact: Mr. Van Huit
Area Served: Los Angeles Gounty
Waste Streams: 1. Exclusions: Wastes with. pH less than 4 and greater
than 11. Highly odorous, highly flarrmable, explosive
and high temperature wastes. Magnesium. Loads con-
taining a wide variety of chemical wastes, each in
relatively small quantities and separate containers.
2. Accept: PCB-cantaminated solid wastes, all group I
wastes, except as noted.
3. Volume: Palos Verdes landfill - 1,300,000 tons of
solid waste and 280,000 tons of liquids annually.
Site Area: 207 acres
Disposal Price: $3.50/ton with $2.00 minimum charge.
No special fee for loads delivered in drums.
Estimated Landfill Life: January 1981
Expansion Potential: None
Site Information: The site meets geological conditions described for
Class I sites, and it has monitoring wells for leachate
surveillance. At Palos Verdes, wastes are typically
delivered by vacuum tanker truck and discharged into a
diked area of municipal refuse. Front-end loaders are
not used in landfilling operations. The area is covered
at the end of each day.
Licensed By: State of California, Class I site.
C-5
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Address: County Sanitation Districts of
Los Angeles County
P.O. Box 4998
Whittier, CA 90607
(213) 699-7411
Contact: Mr. Van Huit
Area Served: Los Angeles County
Waste Streams: 1. Exclusions: Explosives and magnesium loads containing
highly odorous or highly flairmable wastes, concen-
trated acids and alkalines.
2. Accept: PCs-contaminated solid wastes, all Group I
wastes except as noted.
3. Volume: Calabasas landfill - 320,000 tons of liquid
annually.
Site Area: 416 acres
Disposal Price: $3.50/ton with $2.00 minimum charge.
No special fee for loads delivered in drums.
Estimated Landfill Life: 25-30 years
Expansion Potential: District personnel are investigating various
alternatives for disposing of liquid industrial
wastes.
Site Information: The site meets geological conditions described for
Class I sites. Jfaiitoring wells are provided for
leachate surveillance. Front end loaders are not used
in landfilling operations. The area is covered at the
end of each day.
Licensed By: State of California, Class I Site.
Location of Landfill:
Calabasas Landfill located
near the town of Agoura, CA
C-6
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Address: Fresno County Department of Public Works Location of Landfill:
4499 East Kings Canyon Pd. Fresno, CA
Fresno, CA 93702
(209) 488-3820
Contact: K.D. Swarts
Area Served: Central California, operated by Fresno County.
Waste Streams: 1. Exclusions: Bulk liquid wastes.
2. Accept: PCE-cor.taminated solid wastes, pesticide and
fertilizer containers.
3. Volume: Approximately 11,000 yd3 to date after 3 site
openings.
Site Area: 32 acres
Disposal Price: $0.75/yd3 plus state fee based on $ .60/ton equivalent.
Estimated Landfill Life: 40-50 yrs. ( < 1% of site capacity has been used).
Expansion Potential: No expansion beyond the existing site is anticipated
at this time.
Site Information: The site is located on tightly packed clay in a low
rainfall area (8 to 10 inches/year). The ground water
depth is 400-500 feet and no monitoring is required.
The site is open only twice a year, two weeks in the
spring and two weeks in the fall. Site operators have
been briefed by agricultural inspector to recognize
and handle various agricultural-chemical containers.
Licensed By: State of California, Class I site.
Camients: This site was specifically set up for the disposal of pesticide
containers.
C-7
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Mdress:
Hollister Disposal Site
Hollister, California 95203
(408) 637-4491
Location of Landfill:
Hollister, CA
Contact: Mr. Grimsley
San Benito City Hall
Area Served: Operated by county, customers restricted to San Benito County.
Waste Streams: 1. Exclusions: Unknown
2. Accept: PCB-ccntaminated solid wastes, pesticide
containers, of f—spec nu.ssile propellant #
3. Volume - Unknown
Site Area: 115 acres (section of a sanitary landfill).
Disposal Price: $10. + $ .60/ton
Estimated Landfill Life: 40 years
Expansion Potential: Unknown
Site Information: The hazardous waste site is an isolated section of a
sanitary landfill (115 acres). The water table lies
220 feet under low permeability clay. No special
engineering was incorporated in establishing the area.
Eight feet of fill is used daily to cover the fill site.
All site run off is collected for treatment.
Licensed By: Licensed Class I disposal site by the state of California.
Waste haulers must be approved by City Kail.
C-8
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Address: Nuclear Engineering Co., Inc. Location of Landfill:
P.O. Box 158 Sheffield, IL
Sheffield, IL 61361
(815) 452-2624
Contact: Mr. Bickford
Waste Streams: 1. Exclusions: Highly reactive sodium and potassium.
2. Accept: PCB-contaminated solid wastes, radioactive
wastes, pesticides, organic wastes, miscellaneous
toxic chemicals, heavy metals, (solids primarily,
liquids accepted following state review).
Site Area: 40 acres
Disposal Price: Transportation - $1.00/mi per 40,000 lb. truck
Disposal - $1.25 to 1.75/ft3
Estimated Landfill Life: Newly opened - unlimited
Expansion Potential: Ample land available.
Site Information: The burial sites consist of clay strata of low
permeability and clay liners. The waste drums are
buried in 30 ft. trenches with three times their
volume of dry clay. Monitoring wells for the site
are checked every two weeks.
Licensed By: Licensed by State of Illinois Health and Environmental
Authorities.
C-9
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Address:
Nuclear Engineering Co., Inc.
Beatty, NV 89003
(815) 454-2624
Location of Landfill:
Beatty, NV
Contact: Mr. Bickford
Waste Streams: 1. Exclusions: Highly reactive sodium and potassium.
2. Accept: PCB-contaminated solid wastes, radioactive
wastes, pesticides, organic wastes, miscellaneous
toxic chemicals, heavy metals, (solids primarily,
liquids accepted following state review).
3. Volume: No specific limit - depends on type and
caiposition.
Site Area: Unknown
Disposal Price: Transportation - $1.00/mi per 40,000 lb. truck
Disposal - $1.25 to 1.75/ft3
Estimated Landfill Life: Unlimited
Expansion Potential: Ample land available.
Site Information: The burial sites consist of clay strata of low
permeability and clay liners. The waste dnns are
buried in 30 ft trenches with three-times their
volume of dry clay. At the Beatty site there is
350 feet to ground water with 150 ft of clay below
the trenches. Rainfall is only 2-4 inches per year
and monitoring wells are checked every two weeks.
Licensed By: State of Nevada Health and Environmental Authorities.
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CHEMICAL WASTE LANDFILL INFORMATION
Address: NEWCO Chemical Waste Systems, Inc.
Subsidiary of Niagara Recycling, Inc.
4626 Royal Avenue
Niagara Falls, New York 14303
(716) 285-6944
Location of Landfill:
Niagara Falls, N.Y.
Contact: Mr. Edward Shuster
Waste Streams:
1. Exclusions: No radioactive or shock sensitive explosives.
2. Accept: PC3-contaminated solid wastes, most wastes con-
sidered including hazardous and toxic.
3. Volume: Unknown.
Site Area: 400 acres
5 acres secure
1 acre active
Disposal Price: $52/55 gal or 6.50/ft3
Estimated Landfill Life: 5 year plus
Expansion Potential: Indefinite
Site Information: This site is monitored by three wells, has leachate
collection and treatment facilities as we-1 as liners
to prevent ground water contamination.
Licensed By: New York State Department of Environmental Conservation.
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Address: Richmond Sanitary Service location of Landfill:
1224 Nevin Avenue Richmond, CA
Richmond, CA
(415) 236-8000
Contact: Mr. Nuti
Area Served: Serves San Francisco Bay Area.
Waste Streams: 1. Exclusions: Exceptions as noted in California Class I
landfill regulations and other wastes depending on
analysis.
2. Accept: PCB-contaminated solid wastes, refinery wastes,
acid plating solutions, tetra-ethyl lead sludge, solvents,
pesticide and chemical containers, and other state of
California group I wastes.
3. Volume: Unknown.
Site Area: 890 acres of marshland, tidelands and bay fill
Disposal Price: $18.90 per yd3 or $5.00 per 55 gallon drum
Estimated Landfxll Life: indefinite
Expansion Potential: Space available, long range plans include use of
available space.
Site Information: Drummed wastes are buried as is. Bulk wastes are
discharged into holding ponds and filled. Discharge
of uncontainerized group I wastes is prohibited.
Conditions such as low permeability, confined conditions,
and an upward direction of flow, appear to preclude
leachate migration to useable ground water. In addition,
annual runoff and flooding conditions are controlled.
Licensed By: State of California, Class I site.
Garments: State Department of Public Health has noted a reluctance on the
part of Richmond management to ccnply vdth the letter and spirit
of existing statutes.
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Address: San Diego County Refuse Disposal Location of Landfill:
555 Overland Boad San Diego County, CA
San DiegO/ CA
(714) 565-5703
Contact: Mr. Eric lewis
Area Served: San Diego County
Waste Streams: 1. Exclusions: Cyanide, explosives, and radioactive wastes.
2. Accept: PCB-contaminated solid wastes if containerized,
pesticides and other chemical wastes.
3. Volume - unkncwn.
Site Area: 516 acres
Disposal Price: $0.20/ft3 plus $.60/tan or $1.00 min. proposed to go up as
of July 1, 1977 to $2.50 ft3.
Estimated Landfill Life: indefinite
Expansion Potential: Management plans to seek permission to fill certain
sludges following neutralization or other chemical
degradation treatment. Plan to improve site operations
by employing a site operator that is familiar with
hazardous wastes. An operations manual is also being
prepared.
Site Information: All wastes to be buried are drummed and placed in an
abandoned mine excavation (native bentonite clay)
2-3 ft. of bentonite used as cover on each cell.
Liquid wastes are discharged into 2 large unlined
evaporative ponds (one pond currently full). To date,
it has not been necessary to remove pond residues, but
the issue will have to be addressed in near future since
one pond is nearly full.
Licensed By: State of California, Class I site.
Comnents: Area flood during winter of 73-74 caused the holding ponds to
overflew (oil wastes). Extra material has been added to pond
berm to prevent overflew. Settle leachate migration was noted
the year prior to the flood. Currently drilling a test well
to determine ground water level. Site is located near county
landfill.
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Address: Texas Ecologists, Inc. Location of Landfill:
Subsidiary of Nuclear Engineering Co., Inc. Fobstcwn, TX
Robstown, TX
(512) 387-3518
Contact: Mr. Dowell Buckner, Gen. Mgr.
Waste Streams: 1. Exclusions: Highly reactive sodium and potassium
2. Accept: PCB-contaninated solid wastes, radioactive
wastes, pesticides, organic wastes, miscellaneous toxic
chemicals, heavy metals, (solids primarily, liquids
accepted following state review).
3. Volume: No specific limit - depends on type and
composition.
Site Area: 240 acres
Disposal Price: Transportation - $1.00/mile per 4,000 lb. truck
Disposal - $1.25-1.75/ft3
Estimated Landfill Life: 30-40 years
Expansion Potential: Unkncwn
Site Information: The site meets Class I regulations. It has a natural
clay strata of 35 feet. The landfill has trenches 17-19
feet deep lined with 10-15 feet of natural clay. Three
monitoring wells are provided for leachate surveil^nce.
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Address: Ventura Regional County Sanitation District Location of Landfill:
P.O. Box AB Ventura County, CA
Ventura, CA
(805) 648-2717
Contact: John A. Lambie
Area Served: Ventura County
Los Angeles County
Santa Barbara County
Kern County
Waste Streams: 1. Exclusions: Radioactive materials and materials
considered unsafe through the screening procedure.
2. Accept: PCB-contaminated solid wastes, other wastes
accepted based upon review and screening or clearance
procedure. Accepted wastes include solvent sludges,
pesticide containers, epoxy, chlorinated biphenols,
cyanide, plating wastes, polyester resins, acids, etc.
3. Volume - varies.
Site Area: 80 acres
Disposal Price: $7.70/tm plus $0.60/ton for State Health Department fee
($1 min.) $25.00 application fee charged to hauler for
each new waste received. Lab costs and any additional
disposal costs are extra.
Estimated Landfill Life: 10 years
Expansion Potential: Unknown
Site Information: Waste burial plots are mapped and inventoried. Well
monitoring is practiced. Bulk liquids are spread on
soil in thin layer and allowed to dry off, and highly
toxic wastes are buried in containers that are used to
transport them.
Licensed By: State of California, Class I site. Site geology, hydrology
and monitoring meet all state prerequisites for Class I sites.
C-15
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Address: Wes Con, Inc. location of Landfill:
P.O. Box 546 Grandview, ID
409 Shashonee St. So.
Twin Falls, 3D 83301
(208) 734-7711
Contact: Mr. Rinebolt
Area Served: Northwest and interniountain region
Waste Stream: 1. Exclusions: Radioactive wastes, poison gases (chemical
warfare).
2. Accept: PCB-
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APPENDIX D
PCB INCENEBATION
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Uk
^JL
®CB I .i
WUUT10N SIRYldS, INC = C 3Cx >/OOe
CHEhicav. C'SPQSAl Jp POl vCHLORI HATED SiPHENYLS { ?C 3"S )
(Som« Traa« Naro«s :sec Are Pvrano: lntrt»*n, Ask*r#l, Arochlar ljlij
12S1*. 1260)
ni-W6' 'c:7 • TELEPHONE 7 <6-75*-d23i
GENERAL DESCRIPTipN
Of WASTE PflOOUC"
POR OlSPOSAl.
PACKAGING ANO
Shipping.
0 ISPOSAl:
'RICING.
Conta i"«r
8u I it, T
55 ga' lor -
Drum*. I«ii ;«ar 5= 9a
* - Mini mum ' 5 i r'jns .
3u i k "
Or jt!S . 55 9a ' I or
„ I QUI OS • °OLvCHLOa1MATJO 8 I PHENYLS (PC8'S) AS 1$ OR MIXED
WITH OThSP '-AST? ;ilS and SOLVENTS.
SOLIOS- - ClcAN-'jP ABSORSEN1*: AnO RAGS SATURATED WITH PC3'S:
iARTH OR CRAVE'. rR0- SPILL CLEAN-UP: CAPACITORS
AMD rtl SCELLAnEGUS C/E3R: S INCLUDING VARIOUS ELECTRICAL
QU I PKENT
;»QuHS • IN TANK 'RUCK QuA-iTlTIES AND 55 GALLON OR LESS
NOH-RETURNABLE SrEtL DRUMS.
SOL 1 OS • in 55 GALLON nON-RE~URnA6LE OPEN-HEAD STEEL ORU*
¦JlTX T! QMT ri-TlNU COVERS.
SEE - :UI0E TS PACKAGING ANO 1OENT1rI CAT I ON OF WASTE PRODUCTS
?0R JNUSUAl PACxAGiNG REQUIREMENTS.
in &CCOROANCE WITU STATE ANO f E 0 ERAL POLLUTION
CONTROL REGULATIOnS.
u1QuI 0 PC3 PRICE SCHEDULE
Contract °''ze
!Cser zourc
S52 00 oer arum
j". OC ie-r c
Non-Contract Pr i;
SO.075 per sound
55^ • 00 ser jrun
S37.CC per dr_n
drums or 'jss aas :25.00 -andlirg, Mfnimun" order 5200.OC.
SOLID PC3 'RICE SCHEDULE
S5-00 5«r ccc : '00;
S25.00 ser in-
«C 50 Cu "t. SSoO/Cu.
> 50 Cu Ft. SS.OO/Cu. Et.
S30.00 per drum
* - Minimum !? druns, I- drums or l«ss 3ca S25-00 land ling, Minimum order S200.CC
*¦* - Pricing Pased on Outer -leasuremenr o* overwrao or arrav.
TERMS.
SHIPPING AO ORESS:
E'PECTIVE DATE:
NET 30 SAYS • ' 0.3. nCOi. CiTV, N£v *CRK, PRICES ARE SUBJECT TO CHANGE
CXEM-TRCL POLLUTION SERV'-CES, INC., I 3 50 SALMER ROAD, MOOEL CITY, NY
NOVEMBER 15, 1 ?75
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ROU.IHS €MVlRC.hmSSTAL SERVICES, 'KC.
Bridgeport., New jersey (60S; ^67-jiOO
Baton Rouge, Louisiana (50*tj /73-123^
Houston, Texas (713) 473-ouOl
An Indemnified Oisaosal Service for tne Disposal of
Folyehlorinated Sioher.vls (PCS'3; (Askarels)
General Description of
Waste Product for
Oisposa':
Packaging and
3h f cd i fvs *
PCS PRICE LIST
Liquids: Pol /ch lo ri natsd 3ipheny1s (Askarels) as is or -nixe-i
with other waste oil and solvents.
Solids: Clean-up absorbents and rags saturated with PC3's...
earth or gravel fro^> spill clean-u3, transrorir(irs.
capacitors, and miseal lanecus cebris inducing varioi.
electrical equipment.
Liriui ds: In tank truck quantities and 3: gallon open head, nc-
returr.able Stse! drums with sec-ra i i q$ on-t meeting
DOT specifications.
Sol i ds: ln~30 gallon non-returnable fiber psck drums with
polyethylene liners and secure lids.
Disposal Method:
All combustible material will be high temperature incinerated w
sufficient residence tira -o insure complete destruction of the
PCB's.
LIQUID 3C3 °iUCE SCHEDULE
Container Pri ce
Sulk, T/T S0.1C per pound
Drums, 55 gallon S75-00 per dru.-n
SOLID PCB "RICE SCHESULE
Drums, 30 gallon fiber S^O.OC per drum
Haxinum 2C0 pounds per drum
Palletized loacs $0.25 per sound
Capacitors and other eiectrica! equiprent are to be packaged and Liorriec: to 3*1 lets. ~.arl
are not to sxesad 20C pounds each nor nave a diameter in txcess of 25 incites. :r(Equ i a.-c-r.
in excess of one foot in height is excluded from this category.)
PRICE SCHED'.i'.? r0\ rgCOKTAMiHAT-CM
of kCd"lOhtai >z?i~ i !
Cor, jr-j iner ?r: ce
gallon s tee I drum SzSTOO per <:r .ti
3? col'c:i ; tee ! drji.i $18.00 ¦:zr .jr .,r,
5 ga?:sr, stce! drut' 5 7.5" -""ail
QUA.L I f I CAT i QMS:
1. All arums must se labeled ''CAL'TICN: Contains ' 5 (i'ptych lorfnste j S?prenyls) That Ar.;
Environmental Contamin««iU*s alorij with .3 code tenser provided by ?,ES.
2. RES transportation fleet is available to ssrvice your transportation needs.
3. *(>rices for the disposal of trans formers, capacitors, and various other electrical equie-
nent in excess of one foot ar.-r based upon the specific characteristics of the equipment.
Prices effective tcc.sn,trr I. 1276. Pricas era subject to change without notice.
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REFERENCES
American National Standards Institute, Guidelines for Handling and Disposal of
Capacitor- and Transformer-Grade Askarels Containing Polychlorinated Biphenyls,
MSI C107.1-1974, New York: WIT. ""
B&ttelle Pacific Northwest Laboratories, Program for the Management of Hazard-
ous Wastes, (EPA Contract No. 68-01-0762) , Richland, WA: July 1973.
California State Water Resources Control Board, Disposal Site Design and Oper-
ation Information, Sacremento: March 1975.
Environmental Science and Engineering, Inc., Report on PCB Emissions from
Sanford Unit No. 4, Florida Paver and Light Ccmpany, May 1976.
Interstate Corrmerce Commission, Cost of Transporting Freight by Class I and II
Motor Camion Carriers of General Cairoodities, 1975, Bureau of Accounts State-
ment No. 201-75, Washington, D.C.: December 1976.
McDonald, L.P., (St. Lawrence Cement Co.), D.J. Skinner (Environment Canada) ,
F.J. Hopton and G.H. Thomas (Ctitario Research Foundation), Burning Waste
Chlorinated Hydroc^-rhons in a Cement Kiln for the Petroleum and Industrial
Organics Chemicals Division, Water Pollution Control Directorate, Environmental
Protection Service, Envirorment Canada, Report No. EPS 4-WP-77 (unpublished
report).
Midwest Research Institute, Guidelines for the Disposal of Small Quantities of
Unused Pesticides, EPA-670/2-75-057, Cincinnati, Ohio: National Environmental
Research Center, U.S. EPA, June 1975.
Office of Solid Waste Management Programs. Report to Congress: Disposal of
Hazardous Wastes. (SW-115) Washington: Environmental Protection Agency, 1974.
TW Systems Group, Destructing Chemical Wastes in Ccmmercial Scale Inciner-
ators, (Report No. 27033-6005 W-00) Technical Summary: NTIS PB-257 709
(Vol. I); Facility Test Plans: OTIS PB-257 710 (Vol. II)? July 1, 1975.
U.S. Environmental Protection Agency, Hazardous Waste Management Facilities
in the United States (EPA/530/SW-146.3), NTIS PB-262 917/8WP, January 1977.
Versar Inc. Assessment of the Environmental and Economic Inpacts of the Ban
on Imports of PCBs. EPA 560/6-77-007 (unpublished Draft Report). February"L,
1977.
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Versar Inc. Destruction of Polychlorinated Biphenyls in Sewage Sludge During
Incineration/ NTIS PB-258 162, 1976.
Versar Inc. PCBs in the United States; Industrial Use and Environmental
Distribution. NTIS PB-252 402/3WP. February 1976.
Versar Inc. Usage of PCBs in Open and Semi-Closed Systans and the Resulting
Losses of PCBs to the Envirornvent. EPA 560/6-77-009 (unpublished Draft Report).
September 1, 1976.
E-2
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BIBLIOGRAPHIC DATA
SHEET
1. Report No.
EPA 560/6-77-013
PB 267 833
4. Title and Subtitle
Microecononic Impacts of the Proposed -Marking and
Disposal Regulations for PCBs
X Keport Date
April 2G, 1977
6.
7. Auchor(s)
8. Performing Organization Retrt.
No- 474-7
9. Performing Organization Name and Address
Versar Inc.
6621 Electronic Drive
Springfield, Virginia 22151
10. Project/Task/Work Unit No.
11. Contract/Graoc No.
68-01-3259
12. Sponsoring Organization Name and Address
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D. C.
13. Type of Report 6i Period
Covered
Final Task Report
5 5. Supplementary Notes
EPA Project Officer: Mr. David E. Wagner
16. Abstracts
This report summarizes the estimated economic impacts of the marking and
disposal regulations for PCBs which are being proposed in fulfillment of
the requirements of Section 6(e) of the Toxic Substances Control Act.
17. Key Words and Document Analysts* 17a. Descriptors
PCBs
Capacitors
Transformers
Incinerators
Chemical waste landfills
Disposal costs
17b. Ideatifiecs/Opea-Ended Terms
17e. COSATI Fieic 'Group
18. Availability Statement
Release Unlimited
19.. Security Class (This
Report)
UN'C.T.AS.'sfFTEn
20. Security Class (This
Pag
UNCLASSIFIED
21.
22, Price
KJ&f-ML
FORM ntis-33 (REV. io-73> ENDORSED BY ANSI AND UNESCO.
THIS FORM MAY BE REPRODUCED
USCOMM.OC S2a3-I"7*
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