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environmental services, INC. REPORT ONE ROLLINS PLAZA. WILMINGTON DELAWARE 1 APRIL T9S3 PCBs: POLLUTION, POLITICS AND PREVENTION by Stem Jeilimk Polychlorinated biphenyl* (PCB*> are the only chemical substance* whole manufacture and diitnbution to com merce it specifically banned by an act of Congress When Congress passed the Toxic Substance * Control Act (TSCA) in 1916 to bring all existing sod new industnil chemicals under a regulatory umbrella, u included severe! special pro visions which focused on PCBs. Secoon 6(e) not only prohibited the making and celling of PCB's after July I, 1979, but it also limned the continued use of existing PCBs io those which sre contained in totally enclosed machinery Opportunity was provided Tor limned cxeepdoo* to the manufacture and use bant, but Con gress' intent to end or plttaa out the bulk of PCB manufacture and use was clear. In addition, section 6(e) directed EPA to strictly regulate the marking, storage, and dispoial ot PCS*. In the past seven yesrs, EPA has issued s senes of regula tions to accomplish these Congressional directives HISTORY, USES The PCB story began in the late 1920's whan the Swann Chemical Company (later acquired by Monsanto Company) developed a family of partially or wholly chlorinated isomers of biphenyl (see figure I). These materials had some re markable properties. They were rela tively insoluble in water, they were able to withstand high temperatures with out degradation, and they would not conduct electricity In short, they were extremely stable compounds and the potential industrial benefits of these materials--particularly as flame retardanis in the electric power industry-- soon became apparent Large electric transformers, for example. use dielectric fluids as insulating mate rials Before the 19)0 s, these dielectric fluids--usually petroleum based-- posed a fire or explosion threat if the transformer overheated. PCBs not only avoided this problem, but were consider ably better as insulators than previously used materials PCBs were alio found lo be an ideal material for insulation io electric capacitors (before manufacture was discontinued transformers and capacitors accounted for 63 percent of all PCBs made in the United Suies) Other uses were discovered Heai ex changers and similar heal lransfer m terns could benefit from the unique properties of PCBs. as could tiulrauiic systems in which iherc *is a mk oi fluids igniting Finally. PCBs found their way into punts, adhesives plasterers paper coatings, ink and cirhonicss copy paper HONS 2X2534 accidental- contamination* of food by PCBs used in heat transfer applications and to prohibit the use of Mere contain tion 6(e) of TSCA* These regulations tur found in Title 40, Part 761 of the Code of Federal Regulations (CFR) ing PCBs in food packaging However, immediate removal of PCBs from "closed" electrical systems--princi pally transformers and capacitors--in the absence of available alternative ma terials or machinery, would have meant a near total shutdown of the etectnc power generating industry in the United States Subpan A of Pan 761 specifies who the regulations apply io. defines die various terms used in die regulations, and gives additional references Subpan B sines specific practices that ire authorized or prohibited Subpan C defines and illus trates how PCB containers, amdes eic must be marked Subpari D si-nes In the fall of 1971. the Federal Govern ment established an Interdepartmental specific requirement* for disposal sior age, incineration, landfilling, and de petjrcMnMptiwvt Ironically, il was precisely the beneficial properties ihai made PCBs such uniquely desirable industrial products which caused their withdrawal from the mar ketplace PCBs are extremely persistent organic chemicals, and degrade very slowly in the environment Their chemi cal structure is similar to that of DDT, they ire insoluble in water but soluble in fat, and thus can be absorbed by hu man uiaue Because of thetr widespread use they are distributed throughout the environment. PCB residues have been found in fish or wildlife all around the world. The first report of possible environmental prob lems with PCBs was published in a British scientific journal in 1966 by a Swedish scientist who discovered that PCBs were btoeccumulating in fish and other wildlife in Scandinavian countries. Task Force on PCBs, chaired by the Council on Environmental Quality and the Office of Science and Technology. The Task Force report of May, 1972 con cluded. among other things that PCBs have been used so widely over such a long period that they are ubiquitous. PCBs should be restricted to essential or nonreplaceable uses which involve minimal direct human exposure, since they can have adverse effects on human health. The major gap in die regulatory sys tem to deal with PCBs is broad Fed eral authority--as would be provided by the (then) proposed Toxic Sub stances Control Act--to restrict use or distribution ofthe chemical, to control imports, and to collect information. The use ofPCBs should not be banned entirely u thesa materials are neces sary in the near future for transformers and capacitors. contamination of PCB containers The final section, Subpart I (there are no Subparts E through I), prescribes what records must be kept and whai monitor ing activities mull be conducted A summary of the major provisions of ihe regulations followi PCBs cannot be manufactured pro cessed, or distributed in commerce unless specifically exempted hv tPA PCBs may only be used in a tot a II v enclosed manner, defined as a manner that results in no exposure ot humans or the environment io PCBs (Several non-totally enclosed uses were au thorized temporarily, under stringent Two yean later. PCBs made headlines in While TSCA was pending enactment, an the popular media for the first time when agreement was worked out between PCB a number of resident* of Yusho, Japan manufacturers and users and the Envi became seriously ill after eating net oil ronmental Protection Agency to continue All items containing SO ppm PCBs or contaminated with high concentrations the use of PCBs in closed systems until greater must be specially labeled and of PCBs Soon after sampling, and as alternative materials were developed, at stored Storage facilities or methods monitoring began to expand usd inten- which time PCBs would begin to be must be capable of preventing any re . sify, PCBs were discovered ut oysters phased out Subsequently, on October 31. lease to the environment should PCBs and other shellfish in Florida, in Great 1977, Monsanto Company--the only leak from containers or articles Fur Lakes fish, and throughout the United remaining U S producer--shut down all thermore, PCBs that have been taken States in human fat tissuo By 1970, sci its PCB production facilities, a year and a out of service for disposal can only be entists in the United States were report half before the Congressional ban on stored for one year ing that PCBs seemed ubiquitous in the environment in very small quantities, and that they were accumulating in the food chain manufacturing was to go into effect REGULATORY REQUIREMENTS With so much of the dispersive and re All PCBs in concentrations greater than $0 ppm and all PCB-coniatnmg items mutt be disposed of in incinerators, in chemicil wane PHASE-OUT AND BAN lated uses of PCBt ended, and with man landfilli. in high efficiency boilers, or The first response of the PCB producing ufacturing no longer underwiy. EPA's by alternative methods approved by industry 10 the disclosures of environ TSCA regulation focused on the PCBs an EPA Regional Administrator mental accumulation was to eliminate voluntarily in 1970 major dispersive uses that were still being used, primarily in various electrical devices, and on the Liquid PCBs in concentrations above 500 ppm and PCB capacitors must be such as in inks and paints The following disposal of PCBs that had been, and disposed of m approved incinerators yen. PCB use was ended in plasticizers, would continue io be. taken out of ser The EPA stindards for PCB in hydraulic fluids, and similar "pamally vice In two major regulations in 1978 cinerators are considerably more stnci closed ` systems In 1971, the Fbod and and 1979. EPA implemented the Con than for hazardous waste incinerators Drug Administration acted to prevent the gressional directives contained in Sec The litter must meet a destruction and 2---------- -------------------------- " ROLUNS REPOST HONS 212535 THE ULTIMATE PCB SOLUTION t*CB SOLIDS EXIT OAB-- ' ASH REBIOUE PCB UOINDB BURNER By Robert C. Gregory Vice PreeMent Md TVcbnicnl Director RolHns Environmental Servke*, Inc. This article is a distillation of technical papers presented recently to the Air Pol lution Control Association and the Inter national Hazardous Waste Conference. Incineration it generally accepted to be ihe most efficient and environmentally sound way to dispose of hi|h concentra tion) of polychlorinated biphenyl a (PCBi) Thu was recognised when the Environmental Protection Agency (EPA) issued its PCB regulations. which call for ihe incineration of malenili or articles (hat contain more than 500 puts per Bul lion (ppm) of PCBa. Since the regula tions were originally written, several mobile and in situ treatment systems have been permitted to destroy or treat PCBa up to the several thousand ppm level, bui incineration---which can handle even pure PCBa--still remains (he mosi widely used method of eliminating high concentrations of PCBi from the environment Permittingthe flrst PCB incinerator in the U S was not an easy task, however. On April 5, 1971. Rollins made its original application for approval 10 incinerate PCB compounds and wastes at its Deer Park. Texas, hazardous waste disposal facility, operated by Rollins Environ mental Services (TX) Inc. The applica tion required many months of technical reviews and permit application work It was not until March 4.1981. that EPA granted Rollins approval to proceed with PCB liquid destruction, which began eight days laser, and has continued until the present. In 1979, Rollins submitted an application for pemusiton to incinerate PCB con taminated soltda, principally capacitors A teal bunt was finally conducted two yean later, end a aolida permit was granted to Rollins in January, 1983 During this same tune penod. ENSCO Inc, wae greeted permits lo bum liquid end solid PCBi at its facility in El Dorado, Arkansas. The long lapses between permit applica tions and permit approvals are evidence ofthe enormous amount ofwork required both by permit applicants and by EPA. A PCB incineration permit was virgin regulatory and technical territory, and everyone concerned wanted to make certain that the process was conducted properly to insure maximum environ mental protection. Since Rollins was granted its PCB incin eration permn. the company has de stroyed tern of millions of pounds of these materials. In both the initial test bums end ui subsequent monitoring, as 9CRUBBER WATER near total destruction ei is possible has been certified Liquid PCBs usually require no pre treatment before incmerauoo Theytypi cally arrive n the plant in bulk, usually via truck, and ere incinerated in the liquid unit of the incinerator For PCB solids, however, usually the entire device ic g a capacitor) arrives at the plant intact and these devices must be shredded before they can be burned An automated system that shreds capacitors, separating liquids and solids, virtually el tminates human coniact wuh the devices while they are being pro. cessed. All materials ire weighed before and after shredding to cerufy that all materials are accounted for Solids chat result from the shtedding process are burned in (he rotary kjln portion of the incinerator A computerized recordkeeping system keeps track of all Rollins PCB activmes PCB bins, specially constructed lo pro vide for temporary storage of nonleaking PCB articles, are recorded when ihey leave the RoUim facility and when (hev amve at s customer's location These HONS 212536 bint--u well as any other PCBs or PCB articles--are identified and weighed when they tie received by Rolltnt The computer alto keep* track of PCB materials while they are in storage at Rollins or elsewhere to make certain thai mandatory storage limns are not exceeded As mentioned earlier, the shredding process is monuored. and this informal ion also is stored in the com puter When PCBs or PCB articles are in cinerated, the computer is again watching and weighing, thus completing a record that provides customers and regulatory agencies with absolute records regarding receipt hendling, and destruction The PCB incinennon process itself is probably the most highly regulated in dustrial activity m the United States today with the exception of nucleir ac tivities PCB incinerators must meet op erating end performance criteria that go substantially beyond requirements for hazardous waste incinerators For example, destruction efficiency must be at least 99 9999 percent--the most strin gent desiruction efficiency required in the world today 1o insure that regulatory requirements are met, an independent engineering company makes unannounced, random inspections of incinerator and related op erations several umes month During these inspections, 21 separate control parameters are checked, instrument cali bration is verified, records are exam ined. and a variety of other operations re certified The engineering company makes us reports directly to EPA During inspections, the automatic shut down feature of the incinerator also u tested This system immediately shuts down the incinerator if any one of a vari ety of parameters ts violated, including temperature, emissions, and others In tentional upsets may be cauaad to test the shut-down controls. In all tests to date, no PCBt, other chlonnated hydrocarbons, or EPA pnomy pollutants have been found w the exhaust gas Less than 1 ppm PCBt has been found in the incinerator ash, and less thin 1 3 micrograms per liter of PCBs hive been found in the unit's scrubber effluent Other tests have not been able to find tctrachlorodibenxo-p-dtoxin or tetrachlorodibenzo-p-funn at delectable lev els at a result of the inctneranon process It would seem thit all of these controls and preciuiions would make it axiomatic that regulated, controlled disposal facilities using proven technology to de stroy PCBs it preferable to long-term storage et many different industrial loca tions. but this is not necessarily axiom atic with the public Despite the fact lhai ihe Rollins Deer Perk incinerator is in almost miniscule facility in the midst of a vast industrial complex, public opposi tion io the burning of PCBs wis initially strong and hostile However, m the more recent past, much of this opposition has disappeared, and when e hearing was held on (he issuance of the PCB solids perutn in late 1982, only handful of persons inended For over i dec ade ihe popular media have been applying adjectives such as "deadly ioxic" and "carcinogenic" to PCBs With (he possible exception of agent orange and asbestos. PCBs ire probably he best known 'political poliuunt ` This popular atitlude may never be com pletely overcome, but the exceptionally good record of PCB incineration in the U S to date seems to be helping UOUD CATCH TANK PCB capacitor shreMm| lywefli it automated and enclosed, 11 nanmls ere weighed before and alter ihRddma While UU* ankle has necessarily con centrated on Rollins, the principles it include* can be applied to any welloperated PCB incineration facility, and may be useful to those companies that have PCBs which must be disposed of Technical reports shout the performance of the Rollins PCB incinerator ere avail able from the company 5_____________________________________ HOPPER & TM noH-tNS ettxiMr HONS 212537 removal efficiency rating of 99 99 percent, incinerators burning PCBs must meet a destruction efficiency of 99 9999 percent 1 tquid PCBs in coneenirationi of 50 to 500 ppm. and other PCB equipmem and containers, properly drained may be disposed of in chemical *Jste landfills Mineral oil from PCB cont.iiiun.itcd transformers and other liquids con taining PCBs in concentrations of <0 500 ppm may be disposed of in high efficiency boilers Ahhough ihe PCB disposal regulations were initially published in 1978, n was not until March, 1981 that Ihe first com mercial incinerator was permitted by EPA for PCB destruction This unit was--and still is--operated by Rollins Environmental Services (TX) Inc near Houston. Texas Shortly thereafter, nioihrr incinerator, operated by ENSCO, Inc , at El Dorado, Arkansas, was also permitted to bum PCBs These two facilities are still the only two large commercial U S incinerators licensed to destroy PCBs A mobile incinerator de veloped and built by EPA is undergoing tests and also may soon be permitted Several companies have received per mission from EPA to incinerate PCBs which are generated as unavoidable byproductsof manufacturing processes, but these facilities are not permitted to burn PCBs from other sources A number of chemical treatment sys tems--many of them portable--have been developed to transform PCBs into nonhazardous chemical substances However, these are useful primarily for materials containing less than 2,000 ppm of PCBs, commercial incinerators bum materials that contain is much as 800.000 ppm of PCBs StiH other systems have been proposed for PCB destruction, and some have proved suecessful in laboratory tesis However, the bulk of materials containing more than 500 ppm of PCBs are incinerated, and most of the materials that contain be tween 50 and 500 ppm of PCBs are dis posed uf in chemical waste landfills RECENT RULE CHANGES As the result of a successful lawsuit challenging pans of the 1979 regulations which concerned totally enclosed and emporanly an'hnrizcd uses EPA was required to nuke several significant changes to the regulation of PCBs These were published on August 25. 1982. and include Prohibition after October t 1985 on ihe use of transformers and eteciromagncis with more than 500 pans per million PCBs tl they pose an exposure risk to food or feed Pan 761 of ihe CFR This article has ined tn provide general informanon on federal rules governing the manufacture, use, and disposal of whi n prob ably the most highly Tegulaied industrial chemical in ihe Lmuj Stales The nory of PCBs is J classic one in (he hi-.iorv of health and safciv regulation It ,lw' how j vubvi.invc t-rye ihouehl lo ly vtuhk and '-ate bcvjniL a hdU'-L hold siyL wordlor ins u. pollution andhiiw stic tel > ih lou^h i he political priKC" tiiovLd lo icstciyt Us re`sa^e .mo ihe environment Weekly inspections of the equipment until then Authorization for the continued use of all other PCB transformers for the re mainder of their lives, but a require ment that they be inspected quarterly for leaks. Authorization for the continued use of large PCB capacitors located in restricted-access electrical substations or restricted-access indoor installa tions, without inspections Prohibition after October I. 1988, on the use of all other PCB capacitors In addition. EPA promulgated ihe first of two regulations dealing with PCBs that an produced as incidental by-products tn chemical processes None of the new PCB role*, however, change the m IIIW '"Lpl piJMP . I -XMWIIJI >m Total PCB Management performs a complete spectrum of PCB management activities, in conformance with recent EPA regulations requiring phase-out of certain PCB uses. Our Texas subsidiary is permitted by federal and state agencies to manage PCB liquids and solids. Ait our subsidiary companies have emergency teams available around the clock to manage PCB spills or to respond to situations requiring immediate action Since receiving the first EPA permit to incinerate PCBs in 1981, millions of pounds of liquid waste containing high concentrations of PCBs have been incinerated by Rollins at our Deer Park, Texas, facility with a destruction efficiency of at least 99.9999 percent. Standard operating procedure is to incinerate PCB liquids within ten days of receipt at our treatment facility. Field services teams specialize in cleanup, flushing, collection and packaging. We transport liquids in our own fleet of specially designed trucks, and provide reusable bins for approved outdoor storage and transportation of solids. For any PCB service, from consultation to destruction, Rollins has the hands-on experience needed to find the best and most cost-effective solutions, and execute them timely. If you want to expand your PCB management and disposal options, call Rollins first. Rollins Environment*! Servian (RES1 Inc AESfNJSHt *0 BnUgnxt *40*014 -tao*i4T-3i0* DftWTMMIIOMeS ngsmome. Q fcutOt onr Port T* rrua I713147MB01 esn ROBaTOIT? talon Roup LA 70I07 (KM|77.|*W COWORATg Offee O* RoAna Flail Wmw^on pCiMtt 13lttl42-nw HONS 212539