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Recommended Procedures for the Disposal or PCB-Contalnlng Wastes (industrial Facilities) On December 22, 1975 the Administrator of the Environmental Protection Agency announced an action plan of regulatory and administrative actions to help ensure that polychlorinated biphenyls currently in service do not enter the environment. One portion of that program includes investigation and recommendation of appropriate disposal procedures for industrial users of this family of chemicals. The Agency is also evaluating ' the consumer waste disposal problem and may issue further guidance on that subject at a later time. General Background Polychlorinated biphenyls (PCBs) are chlorinated aromatic organic compounds which give rise to concern because of their toxicity coupled with their pervasiveness and persistence in the environment and their tendency to accumulate in food chains. It is this bloaccumulatlve characteristic which manifests Itself by possible adverse effects on animals, including man, that causes the present and continuing concern over the disposition of PCBs to the environment. PCBs have been used both in "closed" systems, or sealed as dielectric fluids in transformers and capacitors, and in "open" applications, where the PCBs are used in and consumed with the product. Uses of PCBs in "open" applications Included Impregnation of cotton and asbestos for braided Insulation of electrical wiring; a plasticizer in wire and cable coatings; in plasticizers of MONS 045619 2 vinyl chloride polymer films; In high-pressure hydraulic fluids; specialized lubricants and gasket sealers; heat trans fer qgents; and machine tool cutting oils. Former open appli cations also include: formulation into some epoxy paints; protective coatings for wood, metal, and concrete; adhesives; and in carbonless reproducing paper. Today PCBs are supplied by Monsanto only to the electrical power distribution industry where they are marketed as dielectric fluids in "closed" or sealed systems such as transformers and capacitors. The sole producer of PCBs in the United States is the Monsanto Company, under the trade name of Aroclor. PCBs have also been marketed and used by manufacturers in their products under various trade names. Appendix A .provides a listing of the trade names used by domestic and foreign manufacturers. Cumu lative sales in the U.S. since the introduction of PCBs are estimated to be 1.5 billion pounds. In 1970 Monsanto volun tarily restricted sales only to the electrical power distribu tion industry where^they are marketed as dielectric fluids in "dosed" or sealed systems such as transformers and capacitors. As a result, current production is down more than 50# from the peak years before 1970, but still amounts to about 30 mil lion pounds per year. Monsanto has Introduced Aroclor 1016 which is reported to have lower toxicity and higher biodegra dation rates. Most capacitors HONS 045620 3 (using PCBs) produced in the past two years use Aroclor 1016. Almost all of the PCBs ever produced still present a serious threat to the environment because of their toxicity, bioaccumulative characteristic in the food chain and slow degradation. An estimated 750 million pounds of PCBs produced are still in use; 300 million pounds are estimated to be present in landfills. It is estimated that less than half the PCBs ever produced have entered the environment; of this amount, only about 10$ (50 million pounds) are estimated to have degraded or been incinerated. The recommendations of this document are directed only at the PCBs presently in service (or which will enter service as a result of future production). Purpose Pursuant to Sect..on 204 (b) (1) of the Solid Waste Disposal Act, as amended, the Administrator may issue advisory guidance and recommendations related to the disposal of waste materials. These recommended procedures do not have standard-setting -r regulatory status, butsrepresent the best information available on preferable disposal options for PCB-contaminated waste materials. In addition, the Agency plans to conduct studies to determine other options for treatment and disposal of PCB-containing wastes (including incineration of capacitors containing PCB liquids) during calendar 1976. The Agency is also aware that the American National Standards Institute is in the process of revising its guideline for disposal of askarels containing PCBs MUNS 045621 4 (ANSI CI07.1-1974). As significant new information becomes available from these and other sources, this Federal Register issuance will be revised. The purpose of this issuance is to provide guidance for the disposal of PCB-containing wastes. This guidance is addressed primarily to industrial users of PCBs, particularly those manufacturing and/or using capacitors and transformers containing PCBs, although the recommended procedures are appropriate to all PCB-containing wastes. Technical Background . Polychlorinated biphenyls are a class of synthetic compounds which have no known counterpart in the natural environment. PCBs are manufactured by the chlorination of biphenyl with anhydrous chlorine using iron filings or ferric chloride as a catalyst. The three most important physical properties of PCBs are low vapor pressures, low water solubility, and high dielectric constants. They are miscible with most organic solvents. The chemical properties that make PCBs desirable industrial materials are their excellent thermal stability, their strong resistance to both acidic and basic hydrolysis, and their , general inertness. They are quite resistant to oxidation. In the process of replacing hydrogen atoms with chlorine atoms, a large number of substitution combinations arise. HONS 045622 b \ Theoretically, there are 210 possible chlorinated biphenyl compounds but only about 100 are likely to occur In commercial products. In commercial preparation, PCB compounds contain from 12 to 68 percent chlorine; the typical product Is a mix ture of several compounds. Monsanto, the sole U.S. producer of PCBs, has adopted a four-digit designation for its Aroclors; the last two digits represent the approximate chlorine content by percentage weight. The first two digits indicate the type of material: biphenyl, trlphenyl, or mixture of the two. The higher chlorinated biphenyls are non-flammable and have extremely low volatilities. Unfortunately, some of the characteristics (stability, non-degradabllity) which make PCBs so valuable In Industrial applications also make them highly persistent In the environment. The chemical stability, low volatility, high dielectric constant, and compatibility with other chlorinated hydrocarbons have resulted in many and varied industrial applications for the PCBs. The solubility of PCBs in nonpolar solvents ex plains why they are readily absorbed into fatty tissue and into the liver. Their resistance to oxidation or other types of chemical degradation explains their persistence and accumulation in animal tissue. The latter effect is enhanced both by their insolubility in water and solubility in organic solvents. Their chemical Inertness and resistance to metabolism account for their low acute toxicity. But as they MONS 045623 6 slowly build up in a living system, their concentration approache toxicity levels, at which point chronic effects make themselves evident. ..... ~.............. The low solubility of PCBs in water probably limits the rata at which they are dispersed by water systems, but does not seem to limit their.range of dispersion. PCBs discharged into a river or lake will accumulate in the sediment in relatively high concentration. Plants and animals can concentrate PCBs above their level in water alone. Shrimp and oysters exposed to 10 ppb of Aroclor 1254 have been known to bioaccumulate from 130- tO'\3300-ifoldv PCBs are not intended to get into the environment, but they do because their unique chemical properties prevent them from being destroyed by usual waste disposal methods. Thus, they Inadvertently escape and become widely dispersed. Environmental transport models for PCBs have not been developed. Conclusions regarding their behavior, particularly their distribution and transport in the environment, are based largely upon the results of DDT research. Recent data indicates that aerial transport Is the roost efficient route, although dumping and river runoff will contribute more effectively to local contamination. Disposition of PCBs The persistence of PCBs necessitates extremely careful attention to final disposition of PCBs and PCB-contaminated MOMS 045624 '7 materials. Initial attention within the manufacturing or PCB-user facility should be given to reducing the use of PCBs. Manufacturers or users may either use substitute (less contaml nating) materials or more efficient methods which produce less waste. However, no matter how many substitutes are developed and no matter how efficient the operation may become, there may still remain some applications for which PCBs are the cur rent optimum material and there still will be waste materials. Spills, damaged goods, and housekeeping materials will require disposal. Recommended options for the disposal of PCB-contaln lng wastes (in priority order) are: - Reclamation or recycling Incineration Controlled land disposal Recycling - Reclamation or recycling of PCBs is usually feas ible only with relatively uncontaminated liquids. Monsanto maintains a toll-free telephone number (800/325-3850) for the public for advice on scrap PCBs. If liquids cannot be reused, these liquids needs to be disposed of by high temperature incin eration. Several Incineration services are available such as Rollins Environmental Services, Inc., Chem-Trol Pollution Services, etc. Addresses are given In Appendix B. Monsanto also has a high temperature Incinerator. A technical descrip tion of the Monsanto incinerator Is provided In Appendix C. Recycling of transformers is accomplished by Ceneral Electric Co. ancl several independent companies. The tank and Inside copper of the transformer Is reclaimed; the PCB liquids HONS 045625 8 If they can't be reused, can be drained and incinerated at facilities such as General Electric's Pittsfield, Massachusetts^ plant.,____ _______ _________________________________________________ _ It is quite possible to leach out the PCBs from solid wastes with a suitable solvent, e.g., acetone, and then dispose of the decontaminated waste. The solution containing PCBs may be separated by distillation into PCB, which may be reclaimed, and the solvent which may be used again. This technique (of leaching and reclamation) is especially useful after accidental spills of liquid PCBs. The spills should be absorbed on dry sand, ash, sawdust, or commercial absorbents and then processed as above. . Incineration - Present knowledge indicates that the proper incineration of waste PCBs must involve a suitable balance among temperature in the incinerator, dwell time in the firing chamber, plus oxygen availability. Also, a suitable scrubber must be provided on the exhaust stack to remove the hydrochloric acid mist that is formed. Preferred requirements are: (1) 2-second dwell time at llOCC(2000F) -and 3* excess oxygen in the stack; or (2) 1 1/2 second dwell time at 1500C(2700F) and 2% excess oxygen in the stack gas.* These alternates are recommended. Open hearth incinerators are not considered suitable; the relatively * These values are from ANSI C107.1-1974. Guidelines for Handling and Disposal at Capacitor and Transformer-Grade Askarels Containing Polychlorinated Biphenyls, American National Standard Institute. MQNS 045626 9 low operating temperature of this equipment would only volatilize the PCB and pollute the atmosphere. The above recommendations are suitable for liquids. Incineration of solid wastes containing PCBs has not been demonstrated. However, such destruction does appear feasible. For example, a rotary kiln furnace, with an afterburner and scrubbing system could probably safely incinerate solid wastes containing PCBs. Likewise, other smaller, high temperature incinerators with sufficient residence times may be satisfactory. Land Disposal - Wastes containing PCBs should not be disposed of with other mixed wastes in a sanitary landfill. Characteristics of transport of PCBs through the soil are not definitively established. The interaction with other decomposing wastes is not well understood. The ubiquity and persistence of PCBs indicate that their disposal should be carefully controlled until additional data are developed. While these data are being gathered, PCBs (when disposed to the land) should only be placed in a secure chemical waste landfill. In genetral terms, a chemical waste landfill provides complete long-term protection for the quality of surface and subsurface waters from hazardous waste deposited therein, and against hazards to public health and the environment. Such sites should be located or engineered to avoid direct hydraulic continuity with surface and subsurface waters. Generated leachates should be contained, and subsurface flow into the disposal areaveliminated. Monitoring wells should be MONS 04562 7 10 established and a sampling and analysis program conducted. Additional characteristics of a chemical waste landfill are described in EPA publication. Landfill Disposal of Hazardous Wastes; A Review of Literature and Known Approaches (EPA/530/ SW-165)**. Encapsulation of wastes in cement prior to burial in a sanitary landfill has been used for small quantities of solids or sludges contaminated with PCBs. Only those specific sites which have been state-approved for PCB wastes should be used. The EPA publication. Hazardous Waste Management Facilities, (EPA/530/SW-146) provides some information to potential disposers; this data when used in consultation with State solid waste management officials can assist in planning a disposal action. ** Documents referenced here may be obtained from Solid Waste V( Information, U.S. Environmental Protection Agency, Cincinnati, Ohio 45268 MOMS (H5628 Appendix A Listing of Names Used for PCBs by Manufacturers* Name Aroclor Asbestol Askarel Chlorextol Diaclor Dykanol Elemex Hyvol Inerteen No-Flamol Pyronol 6af-T-Kuhl Manufacturer Monsanto American Corporation * , Allis Chalmers Sangamo Electric Cornell Dubilier McGraw Edison Aerovox Westingholise Electric Wagner Electric General Electric Xuhlman Electric Clophen . Fenclor Kennechlor Phenoclor PK Pyrolene Santotherm Bayer (Germany) Caffaro (Haly) Xenneclor (Japan) Prodelic (France) Caffaro (Italy) Prodelec (France) Mitsubishi (Japan) * generic name used for insulating liquids in capacitors and transfomers; may contain PCBs., MONS 045629 Apponc!i::e e* (These Appendixes *rf not 3 pan of Ameikjn National St.tmhtd Guideline* foi Handlinn *d of 0 Capacitor and rin*fofmcr-Cr.dc AakarcU Containing Polyvlilotinjicd liiphcnylt. Cl07.1-1974, but aie included lot infotiruiion purpose* only.) Appendix B Disposal Services In iddilion to ihc supervised diy landfill sites that ' may be used for the disposal of asUarel-contaming scrap, the following additional known facilities and services have been established, and others may be available.1 Chem-Trol Pollution Services, Inc P.O. Box 200 IS50 Balmcr Road Model City, N.Y. 14107 Phone: 716 754-8231 This organization has facilities and services capable of handling: (1) Liquids. Askarels alone or mixed with solvents or oils. Disposal by hirlwcmperature Incineration. (2) Solids (software). Askarel-soaked compounds, rags cartons, absorbing earths, etc. Disposal by incineratlon or scientific landfill. (3) Solids (hardware). Capacitors, transformer tanks, cores, askarcl-soaked metals. Disposal by scientific landAll. Has solvent extraction capability. Monsanto Company 800 North Lindbergh Boulevard St. Louis, Mo 63166 Phone:314 694-3352 ' This organization has facilities and services capable of handling askatel liquids alone or mixed with other oils or solvents by high-temperature incineration. Liquid Is pumped through a gun with atomizing steam Into incinerator. Temperatures are maintained at 2000*F- 2$00F with auxiliary natural gas. Exit gases are quenched to 180*F by contact with water. Gas is then pasted through a high-energy venturi scrubber for re moval of particulates. Before exhausting to air (110F), gases are passed through a packed column scrubber to remove UC1. Nuclear Engineering Company Eastern Division P.O.Box 146 Morehead, Ky 40351 Phone: 606 784-6611 Nuclei Engineering Company Disposal Division Sheffield, 111. 61361 Phone: 815 454-2624 This organization provides containerization, trans portation, and disposal services of all liquids and solids (including hardware). Disposal is in controlled chemical and scientific landfill area. Licensed by Atomic Energy Commission for radioactive waste disposal. The organi zation also has two West Coast locations, in the states of California and Washington. Rollins Environmental Services, Inc P.O. Box 2349 Wilmington. Del 19899 Phone: 302 658-845U This organization has facilities and services capable of handling: (1) Liquids. Askarel alone or mixed with solvents or oils. Disposal is by high-tcmperature incineration. (2) Solids (software). Askarel-soaked compounds, rags, cartons, absorbing earths, etc. Disposal is by incin eration at combustion temperatures up to 2500aF. In cineration gases are scrubbed, and entrained solids are removed before exhausting to air. Rollins Environmental Services maintains disposal facilities in the following areas: The lilting given herein is representative of some of the sources that provide this service, and is not presumed to be complete. Any other organizations that wish to be lifted should notify the Standards Institute so (hat they may be included in the next edition of this standard. Philadelphia/Camden: Rollins Environmental Services, Inc Route 322 Logan Township Bridgeport, N.J. 08014 19 HONS 0456SO APITNDIX Baton Rouge: Rollins Environmental Services, Inc Scenic Highway & West Cheatham Lane Scotlandvtilc {-last Baton Rouge Parish, U 70807 Houston: Rollins I;.itvijom,om.[l Services, Inc Tidal Road & Highway 134 Deer Park, Tex 77536 HONS 045631 <?. Appendix S' Description of Monsanto Incineration Facility .................... .......-Sauget, Illinois Background . ......................... The Krummrich Plant is one of Monsanto's large chemical manufacturing plants. The product line includes sulfuric acid, benzene, chlorine, polychlorinated biphenyls, several rubber compounds, and various chemical intermediates. The plant is located immediately south of East St. Louis, 111. near the Mississippi River. Since June 1971, Monsanto has operated a liquid injection incinerator to dispose of in-house liquid wastes and contaminated PCBs from customers. Waste Characteristics The large majority of the wastes burned are PCB derivatives. The sources of these wastes are process still bottoms,--etches, and contaminated transformer oils. The heating value' of the materials is about 9000 BTU/lb. Other in-house high BTU liquid wastes are also incinerated. Phosphorous compounds cannot be burned due to the formation of particulates (P_0 ) which foul the injection system. The system iB not equipped to handle suspended solids. Four HONS 045632 Air Pollution Control The fumes exit the oxidizer and enter a water quench column. The main purpose of the quench is to reduce the temperature of the hot fumes. Particulates are removed next in a high energy venturi. Finally, the emissions are cleaned in a packed bed (polypropylene packing) at the base of the stack. The 40 ft. stack is equipped with a demister. Scrubber liquors are drained to the sewer without treatment. MONS 045633 REFERENCES 1. Polychlorinated biphenyls and the environment. Inter departmental Task Force on PCB's. Depts. of Agriculture, Interior, HEW, Commerce and EPA, May 1972. V 2. Carnes, R., Doerger, J., Spearks, H.L. Polychlorinated biphenyls in solid waste and solid-waste-related materials. Cincinnati. 1973. 3. American National Standards Institute (ANSI). Guidelines for handling and disposal of capacitor-and transformer-grade askarels containing polychlorinated biphenyls. New York, January 1974. 4. Peaksall, D.B. PCB's and their environmental effects. Critical Reviews in Environmental Control. CRC. 1975. 5. Broadhurst, M. Use and replaceability of polychlorinated biphenyls. Environmental Health Perspectives. Oct. 1972. 6. Versar, Inc. Assessment of wastfewater management, treatment technology, and associated costs for abatement of PCBs concentrations in industrial effluents. Jan. 1976. (Draft report). 7. Bremer, C. State of concerns of the Lake Michigan Toxic Substances Committee related to PCB. Chicago. Internal EPA Report. 8. Aroclor.Polychlorinated polyphenyls (biphenyls). Technical Bulletin O-FF/IR. St. Louis: Monsanto Industrial Chemicals Company, Nov. 1971. ' 9. PCB's-environmental itnpact. Environmental Research. 1972. 10. PCB's their use and control. Organization for Economic Cooperation and Development. Paris. 1974. 11. Sewage sludge incineration. Section IV. Effect of incineration on metals, pesticides, and polychlorinated biphenyls. EPA Task Force. March 1972. 12. PCB Conference. National Swedish Environment Protection Board. 1970. pg, 83-86. 13. Hazardous waste management facilities in the United states. Leshendok, T. Environmental Protection Agency SW-146, revised, 1976. HONS 045634 2 14. Scurlock,\A. et al.. .Incineration in hazardous waste , management. Environmental Protection Publication ' SW-141, 1974. 15. Lindsey, F. and Fields, T. Landfill disposal of hazardous wastes: review of literature and known approaches. Environmental Protection Publication SW-165, 1975. 16. Farb, D. information about hazardous waste management facilities. Environmental Protection Publication SW-145, 1975. . 17. Tucker, E., et al. Migration of PCB's in soil induced by percolating water. Monsanto Co. Bulletin of Environmental Contamination and Toxicology, Vol. 13. 1975 18. ASTM. Standard method of test for rapid gas chromatographic estimation of higher boiling homologues of chlorinated biphenyls for capacitor askarels. specification D 1810-63' (1973). '. , 19. HEW. Registry of toxic effects of chemical substances. 1975 Edition NIOSH June 1975. 20. Mitre Corp. Environmental cycling of PCB's. 1975 (unpublished report). HONS 045635