Document gD2yOxzEp1D0KJdKXj46aBzON

CURRENT REPORT 213 Application No. Applicant Renewal of on Exomptfon Application No. . .Applicant Renewal of an Exemption Application , No. . ,, RanewnJ Exemption 76R4-X......... Eastern Mediterranean (Con- 75H tnlner#) Co,, Ltd., London. England. 7684-X......... OrviVl Tank Container*, F*ri, 7584 Prance. ' 7684-X......... Interox Chemlcota Ltd., Bed 7184 fordshire, England. 7&90-X......... Puerto Rico Marios Manage- , meat. Inc., Filrabelh, R-J. ,,,, 7011-X......- Blehfood, Inc.. Wetmond, V*_ 7M0-X........ MOoourl pacific Hu'lro&d Co,, Et~ lout.*, Mo. 7C21-X......... Great Lakes Chemical Corp., Hi Don* So, Art. 7v 71* ,,a~' ,76" 7632-X......... Enterprise Lorvlc* Co., X!mm> <e53 ton, Tex. , 7033 X......... Rea Containers, London. Eng. land, 7071-X......... Boa Containers, Londoo, Eng* 7671 land. 7690-X......... Trcstcx Products Co., f>t. PauL 70tK> Minn. 7714-X......... Buttons InlcrnnUotvil Limited, 77^4 London, England." . 771ft X......... Turner Co.. Sycamore, JR.......... 77?f)-X......... Economic* laboratory, lac, 7718 7*25 8t. Paul. Minn. 7762-X......... Enrol alner. Paris. lYonc*......... . V753 7763-X...... - Buiuiier Chemical Co., West 7761 port, C'or.n, 7770-X......... Udine Kuhlmann of America, 7770 Inc., Paramus, NJ. 7820-X......... Pcrmal International, Inc., 7620 New York, N.Y. 7C30-X........ Orval Tank Containers, Paris, Prance. 7893-JC......... Orval Tank Containers, Paris, . - France. 722&-X......... A/8 ChemUiov*. LtmvUs, Den- . mark. - 4100-P C <k C Oxygen Co.. Chattanoo- 4JP7-P^.^ RW Mural, LnJd, Okia...-- Mobil Chcralcil Co., Beau- ` ' inonU Tex. 6r>2CLp....... Amchcm Produdn. ` Ambler, Fa. Inc., C234-P--Cltena Lab lYodyots Irvx, Arah.'tjv. Calif. ...... AlrvAck'Industries, Inc., Carl. . - ... ueiNJ. . M14-P.... . T/Ul Brclbrir Chemical Co.! City t.f Industry. Calif. CMS-P......... Olln Chen icclt O.'oup, thorn- ford. Ccrm. C358-P......... Orve.1 Tank Containers, Pails. i-Yftt *7Ci>2*P. . Beech Aimait Carp., Wichlls., K>*ns. 7094-1'.... . P.olun and Haas Co., Philadel phia. I-a. 7M4 .p.,,, 76C7-P.... 7597-P.... .. Compaimle Des Containers HcatTrotrs, Pails, Prance, . WoolfclX CbecoJcol Works. Pwt V alley. Oa. .. Apollo Enterheiscs, Inc., Alllielmer, Art. 7630 7898 792ft 4108 4497 6190 5520 0234 6348 814 C247 8358 7055 7094 7584 7597 7597 757-P._.._ United Roert Co* Bunlde. La..... `7014-P.-.-.. Eurotalner, Paris, Prance.......... 76D7-P ......... Thomptsoii-Hnyward Chemical Co. flan Antonio, Tex. 76^7*I*."bltix-a Chemical Co., Winns- '' tore. La. ' 7597-P......... Cleveland Chemical Co., Cleve- land. Mias. 7833-P_....... Qrval Tank ConUlners, Paris, . Prance. 7654-P ........ Kiitmon Kodak Co...................+ 7507 7014 7597 7ftfl7 . 7507 7633 7664 This notice of receipt of applications for renewal of exemptions end for party to p.n exemption is published In accordance with section 107 of tha IlazardoiLS Materials Transportation Act (49 CPU lbOo; 49 CFTt 1.53(c).) Issued in Washington, D.C., on May 4, 1978. J. R. Ghothe, Chief, Exemptions Branch, Office of Hazardous Materials Operations. - ENVIRONMENTAL PROTECTION AGENCY IMPLEMENTATION PLAN FOR THE PCB MARKING AND DISPOSAL REGULATION: DRAFT FACILITY APPROVAL PROCESS Introduction Implementation of the PCB Marking and Disposal Regula tion can be separated into two major segments: (1) the site approval process and (2) the surveillance and enforcement process. This Plan addresses only the former process. (A draft of the surveillance and enforcement strategy for the PCW Marking ana Disposal Regulation war, distributed to the Regions in Dallas at (he PCB Implementation Meeting for their review and information). The Office of Solid Waste, Hazardous Waste Management Division, has been asked to develop an approach to imple ment tiie site approval process and to provide technical sup port and guidance to the Regions in evaluating requests for the approval of PCB disposal facilities. In this regard, since implementation is basically a regional responsibility, it will be necessary for the Regional Administrators to appoint a Regional PCB Site Approval Coordinator who will organize response to requests for site approval. Site evaluation will be largely a technical activity; to provide technical support and guidance to the Regional Administrators in their decision making, a combined Hcadquartcrs/Laboralory Technical Support Team (TST) has been formed and will be available to the Regions if needed. However, it is intended that the TST will cease to function as the Regions build the needed technical experience base within house. Regional/IIcadquarters primary contacts for coordination will be the ajv- pointed Regional PCB Site Approval Coordinator and the Chairman of the Technical Support Team (Matt Straus, Office of Solid Waste). The most important aspect of the regulation is the fact that sixty (60) days after promulgation of the regulation dis posal becomes illegal except at EPA approved sites. It thus becomes imperative that evaluation and approval of such sites be made as soon as possible to minimize disrup tion of the normal flow of commerce and disposal of these wastes and avoid storage of large stockpiles of PCBs. The remainder of this paper lays out a plan (o accomplish this. Relationship to RCRA Those facilities which will require approval under the PCB Marking and Disposal Regulation are the same as those facilities which will require permits under the Resource Conservation and Recovery Act of 1976 (RCRA), except that RCRA will significantly increase the quantity of wastes that are controlled, as defined in Section 3001 of RCRA, and in crease the requirements (i.e., financial responsibility, con tingency plans, etc.) imposed on these facilities. (Please note that RCRA will not affect the specific criteria cited in the PCB Marking and Disposal Regulation.) An argument might be made then, that the Regions should adopt the basic RCRA procedures for both site approval and surveillance and enforcement. However, the Office of Solid Waste does not think this is practical because: (1) The RCRA procedures have not yet been proposed in the Federal Register, or, in many cases, developed as yet; actual RCRA implementation will not begin until FY 79. Published by THE BUREAU OF NATIONAL AFFAIRS. INC., WASHINGTON, D.C. 20037 C<81C88 214 CHEMICAL REGULATION REPORTER (2} The RCRA procedures are quite formalized and will take significantly more time and effort than can be spared, given the need to approve facilities as soon as possible, Therefore, a streamlined set of procedures must be ' ()' loped to provide for evaluation of those facilities likely U. .ek approval on short notice. If a mistake is made in an effort to expedite this approval, the site will be re-evaluated in more detail, when RCIIA is implemented (a year or so later). To prevent needless duplication, it seems expeditious to fold consideration of the site approval process of the PCB Marking and Disposal Regulation into the whole RCRA im plementation process once the latter is instituted. Thus, the Office of Solid Waste believes that a separate permitting system for PCI] disposal is needed only during this interim period to handle the initial site approval applications. Facility Approval Process The main problem in designing this process is the need to evaluate and grant approvals as soon as possible, due to the fact that sixty (CO) days after promulgation of the regulation disposal of most PCBs becomes illegal except at EPA ap proved sites. In addition, the storage criteria specified in the regulation docs not become effective until July I, 1978, thus the alternative to disposal for up to four months is storage with no special requirements. Therefore, it is suggested (hat the Regional Administrator's first action should be to mail letters to those disposal facilities which might require ap proval under this regulation to notify them of their respon sibilities. This letter should be sent by registered mail as soon as the administrator has signed the PCB Marking and Disposal Regulation. The notification letter should first be s^ut to those facilities identified on the recently generated of PCB waste disposers, with a second set of notification letters going to other hazardous waste facilities which the Region has identified (see latest edition of "Hazardous Waste Management Facilities in the U.S." for the complete list; EPA/530/SW-146.S, January 1977). The Agency's first contact is then likely to be by phone or letter from a facility owner/operator who desires approval, Regardless of who receives these contacts, they should all be funnclcd through the appointed Regional PCB Site Approval Coordinator. A checklist will be provided from Headquarters which would enable the Site Approval Coordinator to deter mine over the telephone some basic information such as; 1. Facility contact (name) 2 Address and location 3. PCBs currently handled types and sources of PCBs amount (total and rate) how long (since when) how managed (landfilled, landspread, road oiled, in cinerated, treated, etc,) 4. Approval sought . types and sources of PCBs --capacitators, etc.) total amount and rate any stored (how much, etc.) management techniques (same as above) 5. Have any State permits or approvals been received for the facility? For PCBs specifically? The Regional PCB Site Approval Coordinator should then 'scuss with the applicant the formal technical report which requiicd in 701.40(d)(1) or 7G1.41(c)(1). Copies of the PCB Marking and Disposal Regulation should be sent if necessary. To save lime, where facilities currently receiving PCBs are involved, the Regional PCB Site Approval Coordinator should proceed to contact other Offices within the EPA Regional Office as well as other Federal Offices to gather any additional information and data on the facility which the Agency(s) may have. For new facilities or facilities which are not currently disposing of PCBs, where time is not so pressing, these offices can be contacted after receipt of the technical report. A similar call should be made to the ap propriate Stale Agency. The puipo.se again would be to gather data and information relative to the site. If the facili ty claims to have a State permit which covers PCBs, the issu ing State Agency should be asked if they are willing to cer tify in writing that the facility meets all the EPA standards which `are identified in Annex I or II of the regulation. (It is suggested that the Regional PCB Site Approval Cooidinator contact the States as soon as possible to discuss the Stale's role with regard to approval. In addition, a copy of the PCB Marking and Disposal Regulation should be sent to each State as soon as it is signed by the Administrator.) It should be noted that unlike other Federal legislation, the Toxic Substances Control Act does not authorize the Ad ministrator to delegate his authority outside the Agency to carry out any parts of the Act or any requirements prescrib ed in any subsequent regulations unless the Administrator is unable or is not likely to take action against a chemical sub stance or mixture under this Act for their prevention or elimination. Therefore, facilities which currently hold a State permit to dispose of PCBs would still require approval Horn Die Federal EPA to dispose of PCBs. However, nothing in (he Toxic Substances Control Act will affect the authority of any State or political subdivision of a Stale to establish or continue in effect any regulation unless the State's authority provides a lesser degree of protection than afforded by the Toxic Substances Control Act or any subsequent regulations. For example, if the State or political subdivision provides the same or a higher degree of protection for PCBs than the ! equipments under the PCB Marking and Disposal Regula tion, the State's standards will remain in effect and not be pre-empted by the Federal standards. If the State is willing to certify the disposal facility or if the State submits information to Ute Regional Administrator which shows that operation of (he disposal site will not pre'nt an unreasonable risk of injury to health or the environment f. om PCBs, when one or more of (he requirements described :> SuW.rtc 7Gi .40(a) and (b) or 701.41(b) arc not met, then ,< decision must he made on whether a certification from ihat particular State obviates the need for any further EPA investigation. The opinion of the Regional Solid Waste Staff hoitld weigh heavily in this decision since they have r .mitored and assisted the development of the State Solid Waste Programs and know intimately the quality of these ;iGgrams. Where an incineration facility is involved, tne Regional PCB Site Approval Coordinator should confirm that the facility has conducted a trial burn or has monitoring data for incinerating PCBs prior to accepting the State's cer tification of the site. (A copy of all such monitoring data shoud be secured from the Stale.) If the decision is to accept the State's certification, then after receipt of the technical report from the facility owner/operator, the Regional Administrator should issue a Idler of approval to the facility which should indicate that revocation of approval is possible for violation of the stan dards, and that this approval will be reconsidered as part of the RCRA permit process. (The Regional PCB Site Approval Coordinator must confirm that the facility owner/opcra'.or had notified Die State and any political subdivision of (he PuMir.lu'd l>y TUP. BUREAU OP NATIONAL AFFAIRS, INC., WASHINGTON, D.C. 20037 CURRENT REPORT 215 facility's desire to dispose of PCBs at least 30 days before Ihc approval can be granted.) Granting approval by accept ing State certification should take approximately four (4) weeks, provided the technical report is forthcoming. Assuming that an EPA evaluation is needed, the next step involves an analysis by the Regional Staff as to whether suf ficient information exists from the technical report and other sources to piocecd. Another checklist will be developed by Headquarters to aid in comparing the available date with the POP standards. Different checklists for in cinerators and land disposal facilities will be developed by Headquarters based on the requirements of 761.40 and 761,41. Another checklist based on the storage requirements of 761.42 will also be developed since the adequacy of on-site storage should be considered before granting approval. If more data and information is needed, the Regional PCD Site Approval Coordinator should bake the necessary steps to ob tain it from one or more of the following: (1) the applicant (2) the State or other Federal Agencies (3) by visit At this point, the Regional Administrator and Ids staff should decide whether the llcadquarters/Laboratory Technical Support Team (TST) should be requested. (The PCM Site Approval Coordinator should evaluate the areas of expertise of Regional personnel to assist the Regional Ad ministrator in making this decision.) If so, the Regional PCB Site Approval Coordinator should phone the Chairman of the TST, and arrange for the TST to conduct the evaluation. The Regional Coordinator will make arrangements for the TST to visit the site with others (e.g., State and local officials, etc.), as may he appropriate, and will assist the TST (along with other Regional personnel) as may be appropriate. The TST will prepare an evaluation report for the Regional Ad ministrator with recommendations on the suitability of the disposal site, The evaluation and preparation of the report should normally take about six weeks. If it is not thought necessary to activate the TST, Die Regional team will proceed directly to do the site evaluation. It may be necessary for the applicant to gather data which may take additional time, e.g., geology and groundwater information. Approval should not be granted until data exists to compare all facility characteristics with the regulation requirements unless the missing data can be considered immaterial to a decision on public health and environmental acceptability. If an emergency situation should occur (i.e., PCli spill), the EPA On-Scene Coordinator should contact the Regional PCB Site Approval Coordinator as soon as possible to assess the situation and determine what possible action should be taken to minimize any danger to public health and environmental damage, (See Section 761.10 (c) of the Regulation for details on spills.) Public Participation A decision must be made concerning public commcnt/involvement on the granting of approval, As previously dis cussed, for facilities now handling PCBs, it is imperative that approvals (or denial) be granted as soon ns possible to prevent the dangerous buildup on backlogs of waste. Tims, a formal hearing procedure is probably precluded for these facilities. However, written comments should be accepted by the Regional Staff during a 30 day comment period during which the technical evaluation is being conducted, A 30 day comment period should be allowed for all facility evaluations including those in which the State certifies the site. Notice of opportunity for written comments should be sent to the Regional Intergovernmental and Congressional Assistants (RICAs), placed in the Port Office, and in public places of Uie municipality nearest the premises. (The Regional Public Affairs Staff is probably best able to handle this.) The applicant's technical report should also be made available to the public at both the EPA Regional Office and at a location near the disposal facility, if the disposal facility asserts a claim of confidentiality covering all or part of the information in the application, the information covered by the claim will be disclosed by EPA only to Urn' extent, and by means of the procedures set forth in 40 CFR Part 2, Subpart B (41 Federal Register 36906, September 1, 1970). In addi tion, Die FCI3 Marking and Disposal Regulation requires that the facility owncr/operator provide written notice to the Slate and local government(s) at least 30 days before a facility is used for the disposal of PCBs. For new facilities or facilities not yet handling PCBs, the luxury of more time exists, since delays will not interupt the normal flow of commerce and disposal of these wastes. In these cases, the Regional Administrator could provide, in addition to Die above, the opportunity for a public hearing if sufficient interest is shown during the comment period. Such a hearing might be desirable if the approval is likely to be controversial, particularly if litigation is likely to result. Final Approval Once all necessary information has been received, public input has been evaluated, and the technical evaluation is completed, Die decision to approve must be made (where in cinerators are involved, a test burn may be required by the Regional Administrator). This is to be based largely on whether or not Die facility location and design meet the U.S. EPA regulatory criteria, however, other factors will need to be considered in reaching a final decision. (The Regional Ad ministrator does not have the authority to withhold approval of a PCB disposal site on the sole basis that the site does not have State and/or local approval or does not meet the more stringent State or local standards.) Where the facility docs not meet all the regulatory criteria, decisions must be made as to whether the variations of the requirements constitutes a lessening in the degree of protection provided. In some cases, mitigating circumstances of design characteristics may eliminate the need to meet all standards. In these cases, the Regional Administrator may waive specific re quirements. The approval letter will discuss: (1) any waivers and why waivers were granted, (2) any conditions which arc placed on approval, (3) a statement to the effect that approval will be recon sidered as part of the RCRA permit process, and (4) agreement to allow access for purposes of sampling and inspection. Denial will indicate the reasons and suggestions as to what must be done by the applicant before approval can be granted. Where incineration is concerned, a trial burn may be re quired if prior data is not available. Section 761.40(d)(2) sets out the requirements for this, including submittal of a trial burn plan by the applicant. This should be submitted as part of the technical report which is required as part of the application. Regional Staff (and/or the TST) will review the trial burn plan after favorable review of the rest of the evaluation. The lest burn then, wili be Die rest of the evalua tion. The test burn then, will be the last action prior to facili ty approval. Regional (and/or TST) response to the plan may include conditions to be met in conducting the tests. Results of the tests will, of course, determine whether Die applica tion is approved. Published by THE BUREAU OF NATIONAL AFFAIRS, INC., WASHINGTON, D.C. 20037 C<t8lC9G 216 CHEMICAL REGULATION REPORTER Resource Estimates Currently, we anticipate that between 20 to 30 facilities will apply to the ten (10) Regional Administrators for ap pr'*val to dispose of PCBs. It is estimated that for each . !ity that applies for approval, each Region will employ between 1 man-week to 20 man-weeks to conduct the evalua tion and approve or disapprove the disposal facility. The ex act level of resources will vary depending upon several fac tors, some of which are: (1) type of facility (2) whether TST is requested to conduct evaluation (3) whether State certified site, and (4) whether test burn is requited by the Regional Ad ministrator Headquarters Laboratory Technical Support Team (TST) Because of the short lead time prior to receipt of applications (March), there is insufficient time for Regional Staff to become intimately familiar with the more complex aspects of facility siting and design. For this reason, a com bined llradqnarters/Laboratory Technical Support Team (TST) has been formed from existing resources as a short lived moans of supplying the necessary expertise. Its func tion will bo to provide support and guidance to the Regions, This guidance may take any of several forms, some of which are: (1) Conduct a complete site evaluation, including review of the technical report with recommendations to the Regional Administrator on the suitability of the site (2) Review trial burn plan and/or monitor trial burn at the i* deration facility *3) Provide expertise to the Region on individual subjects (i.e., hydi('geology, etc.) Activation of the TST will be by telephone request from the Regional PCB Site Approval Coordinator to Die Chairman of the TST. (A letter from the Regional Administrator to the Chairman of the TST should follow.) The Regional PCB Site Approval Coordinator will handle all administrative aspects of appioval and provide the logistical support (arranging meetings, etc.) for the TST. Briefly, participants and their areas of expertise should in clude: ' -- Office of Solid Waste (Hazardous Waste Management Division) Chairman of. TST Incineration design and operation Chemical waste landfill design and operation -- Office of Toxic Substances (Hazard Assessment, Chemical Control and Testing Divisions) Regulation interpretation -- Office of Research and Development (Monitoring and Technical Support Office, and Solid and Hazardous Waste Research Division) Waste incineration technology Ryiliogeology expertise Test methods analysis -- Office of Air Quality Planning and Standards Air pollution monitoring and control from incinerators -- Office of Enforcement. Compliance and enforceability of approval conditions is intended that tire TST will no longer be needed as the lugioir; build the needed technical experience base within house. Further, the need for the TST will be eliminated as the PCB site approval regulatory process is incorporated into the broader RCRA implementation process. At the present lime, we anticipate that between 10 and 30 trips will be necessary by the TST in assisting the Regions in evaluating these disposal facilities, however, the actual number of trips will largely depend on several factors: (1) Number of facilities applying for approval (2) Region's ability to conduct site evaluation in-house If the TST is called upon by the Regions, it is estimated that ap proximately 4 man-days will be required for each individual who is a member of the TST to conduct one site evaluation. The actual number of TST members for each site evaluation will vary depending on the type of site, number of requests received by the Regions and travel limitations on 1ST members. Manual of Sampling Methods and Analytical Procedures This is required to be available under Sections 761.10 (e) (2) and 7G1.40 (d) (3), and is to include sampling methods and analytical procedures for: (1) sampling and analyzing the contamination levels associated with spills, (2) measur ing and recording rate and quantity of PCB combustion, (3) incineration temperatures, and (4) monitoring of stack emissions. An initial draft of this manual has been prepared by the Office of Solid Waste which is a compilation of ERA standard test methods dealing with the above subject tests. This manual has been reviewed by various offices within the Agency and is expected to be issued as an interim document by mid-February. A final version of the manual is expected to be issued, after undergoing further review within the U.S. KPA, by early spring of 1978. Approval Lead Time Depending upon the type and location of the facility, the following estimates may be used by the Regions to estimate Die approximate time it will Dike to approve PCB disposal sites: State Certification for disposal sites -- 4 weeks i- Landfills and incinerators (no trial burn required! i tnrently iteeiving PCBs - 13 weeks * Landfills not currently receiving PCBs (due to public ! urings) - - 17 weeks Incinerators (trial burn required) -- 24 weeks. These esi mates, of course, assume that the Agency will have Die cessary staff available to perform Die site evaluation and "undly, that the applicant has Die necessary data in hand treview. If drilling or complex sarnpling/analysis or . ign work ai*> necessary, the time required for this activit> w'jld extend the necessary lead time by up to 9 months. ICEGIONAL PCB SITE APPROVAL COORDINATORS REGION I -- Mr. Dan Moon, Solid Waste Program REGION IJ -- Mr. Conrad Simon, Air and Hazardous Materials Div. REGION 111 -- Mr. William Schremp, Solid Waste Program REGION IV -- Mr. James Scarbrough, Solid Waste Section REGION V - Mr. Karl Kiepitsch, Jr., Solid Waste Program REGION VI -- Mr. Larry Brnicky, Solid Waste Program REGION VII -- Mr. Morris Tucker, Solid Waste Section Published by THE BUREAU OF NATIONAL AFFAIRS, INC., WASHINGTON. D.C. 20037 0481091 C TOWOLDMONOQ60242 CURRENT REPORT REGION VIII -- Dr. Henry Schroeder, Solid Waste Branch REGION IX Mr. James Channell, Hazardous Materials Branch REGION X -- Mr. Roger Fucntes, Solid Waste Program artial List of Disposal Facilities Which Currently Handle PCDs Region l General Klectric -- Incinerator 100 Woodlawn Ave. Pittsfield, Mass 01201 Repfon II Chemical Control Corp. -- Incinerator 23 South Front St. Elizabeth, N.J. 07201 . (Company is currently in litigation and it is not clear whether they will be allowed to continue operating.) Chem-lrol Pollution Services, Inc. -- Landfill P.O. Box 200 1550 Balner Hoad Model City, N.Y. 14107 Frontier Chemical Wastes Process, Inc. -- Pyrolysis (Questionable) 4626 Royal Ave. Niagara Falls, N.Y. 14303 \'EWCO Chemical Waste Systems, Inc. -- Incinerator, Land fill Subsidiary of Niagara Recycling, Inc. 4626 Royal Ave Niagara Falls, N.Y. 14303 Rollins Environmental Services -- Incinerator Bridgeport, N.J. (Logan Township) Region III NONE Region IV Resource Industries of Alabama, Inc. -- Landfill (Questionable) P.O. Box 1200 ' Livingston, Alabama Region V Earthline Corporation -- Landfill Wilsonville, Illinois Land Reclamation Lmtd. 2300 S. Green Bay Rd. Racine, WI 53406 Metro Disposal Service 10712 124th Street Franklin, WI 63132 Nuclear Engineering Co., Inc. -- Landfill P.O. Box 150 Sheffield, Illinois 61361 Waste Management, Inc. 9050 N. 124 St. Milwaukee, WI 53223 Region VI Clean Land Air Water (CLAW) -- Landfill Plaquimine, Louisiana Energy Systems Co. (ENSCO) -- Incinerator El Dorado, Arkansas Rollins Environmental Services -- Incinerator Baton Rouge, LA Houston, Tx. Sediment Removal Co. -- Landfill Plaquimine, LA Southwest Ecologist Co. -- Landfill Baton Rouge, LA Texas Ecologists, Inc. -- Incinerator, Landfill Itobstown, Texas Region VII Big 3 Enterprises -- Incinerator 10,000 E. Birmingham Rd. Kansas City, MO Bobs Home Service, Inc. -- Landfill Wright City, Missouri Kansas Industrial Environmental Services -- Landfill Furley, Kansas Wheeling Disposal Service Co., Inc -- Landfill Andrew County, MO Repton VIII NONE Repton IX Calabasas Landfill Palos Verdes Landfill (Contact: LA County Sanitation District P.O. Box 4998 Whittier, CA 90607 Casmalia Disposal Site -- Landfill P.O. Box 5275 Santa Barbara, CA 93108 Chancellor and Ogden, Inc./BKK -- Landfill 3031 East I St. Wilmington, CA 90744 Fresno County Dept, of Public Works -- Landfill 4499 East Kings Canyon Rd Fresno. CA 93702 Hollister Disposal Site -- Landfill Hollister, CA 95203 Nuclear Engineering Co., Inc. -- Landfill Beatty, Nevada 89003 Omar Rendering Co. -- Landfill P.O. Box 1235 Chula Vista, CA Pacific Reclamation and Disposal, Inc. -- Landfill P.O. Box 885 Benicia, CA 94510 Richmond Sanitary Service -- Landfill 1224 Nevin Ave. Richmond, CA San Diego County Site -- Landfill 5555 Overland Rd San Diego, CA Ventura Regional County Sanitation District -- Landfill P.O. Box AB Ventura, CA Published by THE BUREAU OR NATIONAL AFFAIRS, INC., WASHINGTON, T C<t81092 TOWOLDMONOQ60243 218 CHEMICAL REGULATION REPORTER Region X Chem-Nuclcar Systems, Inc. -- Landfill Arlington, Oregon \Vr>- Con, Inc. -- Burial . I Box 546 40^ Shoshonec Slrect South Twin Falls, Idaho 83301 ' (List of sites was provided by Regional Solid Waste Manage ment Staff). VCR Disposal Facility Approval: Checklists In evaluating requests for (he approval of PCD disposal facilities, the Regional PCB Site Approval Coordinator will need to make several decisions throughout the site approval process. Attached are several checklists which can he used to assist the Regional Coordinator in making these deter minations, . ' 1) Initial Contact by Facility Oumcr/Operator Who Desires Approval The Agency's first contact is likely to be by phene or letter from the facility owncr/operator who desires approval. Regardless of who receives these contacts within the Region, they should all be funnelcd through the appointed Regional PCB Site Approval Coordinator. In this initial in terview with (he facility owncr/operator, the Regional Coor dinator may find it useful to use (he following checklist to ob tain some basic information which will (1) indicate whether the facility requires KPA' approval and (2) assist the Regional PCB Approval Coordinator to prioritize the re quests that are received. Initial Interview Checklist Name, address and phone number of company (include boi.. headquarters and disposal site). 2. Individual making initial contact and phone number 3. Principal contact within company and phone number 4. PCBs currently handled (a) types of PCBs currently handled (i.o., liquids, sludges, capacitors (whole or shredded), transformers, contaminated soils, etc.) (b) source of PCBs currently handled (i.e., utilities, capacitor or transformer manufacturers, railroads, in dustry, etc.) (c) esiinptp concentration and emptily for each type of FOB currently handled (total and rate) (Note: PCB mixture means any mixture, except municipal sewage treatment sludge, winch contains 0.06 percent (600 ppm) on a dry weight basis or greater of a PCB chemical substance.) (d) management techniques for each type of PCB waste currently handled (i.e., landfill, incineration, landspreading, storage, treatment, etc.) (e) approximately how long has the company been handl ing PCBs. : 5. Approval sought (a) types of PCBs which will be handled (i.e., liquids, sludges, capacitors (whole or shredded), transformers, con taminated soils, etc.) (b) source of PCBs which will be handled (i.e., utilities, capacitor or transformer manufacturers, railroads, in dustry, etc.) (c) estimated concentration and quantity for each type of PHJ which will be handled (total and rate) ) management technique for each type of PCB waste winch will be handled (i.e., landfill, incineration, landspreading, storage, treatment, etc.) (e) are PCBs currently being stored on-silc; if yes, how are they being stored and how much of each type of PCB is being stored . 6. Have any State or local permits or approvals been received for the facility? For PCBs specifically? If yes, which Stale or local Agency(s) issued the approval (prin cipal contact from State or local Agency(s) and phone number). 2) Determination as to Whether Sufficient Informa tion Exists in Technical Report . After receiving the facilities application (technical report) to dispose of PCBs and assuming that an EPA evaluation is to be conducted (State certification is not available or is not accepted by the Regional Administrator), the Regional PCB Site Approval Coordinator will need to conduct n cursory review of the report and determine whether sufficient infor mation exists from the technical report and other sources with which to proceed. The following set of checklists should be used by (he Regional PCB Site Approval Coordinator to assist him in making this determination: I. The technical report that is submitted on incinerators should, at a minimum, contain the following information. a. The technical report should describe the location of the incineration facility with respect to: (1) industiial sites (both manufacturing and commercial), (2) residential areas (3) navigable streams (i.e., rivers, lakes, etc.), and, (4) the nearest city, town or village. b. The technical report should contain a detailed descrip tion of the incinerator including general site plans and design drawings. The description should include at a minimum: -- general description (i.e., rotary kiln, liquid injection, etc.) of the incinerator (indicate manufacturer) -- capacity of the incinerator (include the dimensions of the combuslioin chamber) --type of feed mechanism into the combustion chamber -- type of auxiliary fuel used, if any, and method of feeding the auxiliary fuel into the combustion chamber -- stack height -- type of air pollution control (APC) equipment (i.e., hiyh-energy venturi scrubber, electrostatic precipitator, afierburncr, etc.) - capacity of the APC equipment. - type of instrumentation on the APC equipment - type of residues (i.e., bottom ash, scrubber effluent, - l) generated from incinerator and disposal techniques 1. ., sanitary landfill, etc.) r The technical report should contain any engineering : :ts, test results or other information on the performance icipaled or measured) of the incinerator when PCBs are onyed. The report should include at a minimum: operating temperature of combustion chamber operating temperature of afterburner (if appropriate) dwell time of incinerator (at temperature) -- combustion efficiency -- mass emission rate (for incineration of non-liquid I i Bs) . - quality of stack gases -- quality of residues including scrubber effluent d. The technical report should contain a description of the sampling and monitoring equipment used when PCBs are dr ;troyed and facilities available. The report should include at a minimum: -- description of laboratory facilities on-site (if any) description and frequency of sampling and analytical procedures performed for PCB wastes (description and drawing of sampling train should be included) Published by TUB BUREAU OF NATIONAL AFPAIKS, INC., WASHINGTON, D.C. 20037 0461093 CURRENT REPORT -- description of sampling station at the stack (i.e., portholes, platform, instrumentation) -- description of the monitoring equipment on the in cinerator for the following: temperature flow rale of combustion air flow rate of PCBs being fed into the combustion chamber stack gases (i.e., O^, CO, CO2* NO* ,HCL Total Chlorinated Organic Content, PCD Chemical substance, Total Particulate Matter, etc.) -- water pressure on wet scrubber -- description of the automatic shut-off system for the following: failure of the monitoring operations for combustion products and incineration operations failure of the PCD rate and quantity measuring and recording equipment when the combustion temperature, dwell time, and/or excess oxygen fall below specified criteria flame-out loss of water pressure in scrubber failure of feed mechanism into combustion chamber e. The technical report should contain the estimated quan tity for each type (i.e., liquids, sludges, capacitors (whole or shredded), transformers, contaminated soil, etc.) of PCB to be incinerated. f. The technical report should include any Slate, local or Federal permits or approvals. g. The technical report should include a description of the storage area. h. The technical report should include a description of the recordkeeping and reporting procedures i. The technical report should include a list of schedules and plans for complying with the approved requirements -- compliance schedule (For any requirements outlined in Sections 761.40 (a) and (b) of the regulation which the facility owner/operator re quests a waiver, a detailed discussion shall be included which describes the rcquirernent(s) the facility owner/operator wants waived and the reason for requesting the waiver). II. The technical report that is submitted on chemical waste landfills should, at a minimum, contain the following: a. The technical report should dovribc the location of the landfill with respect to: (1) industrial sites (both manufac turing and commercial), (2) residential area, (3) navigable streams, (i.e,, rivers, lakes, etc.) and (4) the nearest city, town or village. b. The technical report should contain a detailed descrip tion of the chemical waste landfill including general site plans and design drawings. The description should, at a minimum, include: -- discussion of the general geologic profile of the site -- discussion of the general hydrologic profile of the site (should include the maximum/minimum groundwater levels) -- size of the landfill (capacity) -- approximate size of the trenches which will contain PCBs (include the dimensions of the trench) -- narrative discussion of the monitoring system -- both location and construction (include a map indicating place ment of the monitoiing wells) -- description of type of leachate collection and treatment system (if applicable) -- description of the typo of liner installed (if applicable) -- discussion of the security measures taken at the site (i.e., type of fencing surrounding the site, etc.) -- indication of the groundwater drinking sources In the immediate area c. The technical report should contain any engineering reports or other information which describes the manner in which the landfill will comply with the requirements cited in Section 761.41 (b) of the regulations. At a minimum, the report should include: -- in-place soil thickness or compacted soil liner thickness -- permeability -- per cent soil passing No. 200 sieve -- liquid limit -- plasticity index -- artificial liner thickness (if applicable) -- distance from bottom of landfill to the maximum groundwater level -- relative location of landfill to the 100-year floodwatcr elevation d. The technical report should contain a description of the sampling and monitoring equipment when PCBs are land filled and facilities available. The report should include at a minimum: -- description of laboratory facilities on-site (if any) -- baseline analysis of the ground and surface water from the disposal site area -- description and frequency of sampling and analytical procedures performed for PCB wastes (at a minimum, the following parameters shall be analyzed: PCBs, pH, specific conductance and chlorinated organics) c. The technical report should contain the estimated quan tity for each type (i.e., liquids, sludges, capacitors (whole or shredded), transformers, contaminated soils, etc.) of PCB to be landfiiled. f. The technical report should provide a general descrip tion of waste materials other than PCBs that are expected to be disposed of in the landfill. The report should also indicate those wastes that are expected to be placed in the same trench with PCBs in the landfill. g. The technical report should include an operations plan for the chemical waste landfill. In addition to the factors listed in Section 761.41 (b) (7) (ii) and (iii) of the regulations, the operations plan should also include the following: -- procedure for handling surface water run-off from land fill * -- method for handling PCR wastes (i.e., drummed, whole capacitors, etc.) and method for placing PCBs in landfill -- discussion of covering procedures and type of final cover --- approximate schedule for working the landfill h. The technical report should include any Slate, local or Federal permits or approvals i. The technical report should include a description of the storage area. j. The technical report should include a list of schedules and plans for complying with the approved requirements -- compliance schedule (For any requirement which is outlined in Section 761.41 (b) of the regulation which the facility owner/operator re quests a waiver, a detailed discussion shall be included which describes the requirernent(s) llie facility owner/operator wants waived and the reason for requesting the waiver). UP The technical report which is required to be submit! 1 d by the facility owner/operalor under Sections 761.40 (d) )1) Publis-.hcd by THE BUREAU OF NATIONAL AFFAIRS, INO.. WASHINGTON, D.r