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' ' <PPA f E B27|o,-6 t Recommended Procedures for the Disposal of PCB-Containing 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 or products containing them. The Agency is also evaluating the consumer waste disposal problem and may issue further guidance on that subject at a later time. General Backgrou*,nd ** . . Polychlorinated biphenyls (PCBs) are chlorinated aromatic organic compounds which give rise to concern .* # ' i . because of their pervasiveness and persistence in the ' environment, their tendency to accumulate in food chains, and their chronic toxicity. The .possible adverse effects on animals (including man), resulting from the bioaccumula tion of PCBs in the food chain, causes the present and continuing concern over the disposition of PCBs tovjthe environmenti PCBs have been used both in closed systems, especially as sealed dielectric fluids in transformers and * capacitors and consumptive (or "open") applications, where the PCBs are used in and consumed and discarded with the product. NPC00026232 753569 . ^ nC w s r i i'575 i Consumptive or "open" uses of PCBs have included: impregnation of cotton and asbestos for braided insulation of electrical wiring; a plasticizer in wire and cable coatings; plasticizers of vinyl chloride polymer films; in high-pressure hydraulic fluids; specialized lubricants and gasket sealers; heat transfer agents; and machine tool cutting oils. Former % "open" applications also include: formulation into some epoxy % paints; protective coatings for wood, metal,.and concrete; adhesives? and in carbonless reproducing paper.. Today domestically produced PCBs are supplied only to "closed" applications in the electrical power distribution industry. PCBs used as dielectric fluids in tranformers and capacitors are referred to generally as askarels. The sole producer of PCBs in the United States is the Monsanto Company, under the trade name of Aroclor. Some domestic manufacturers either modify Aroclor or have Monsanto prepare special formulations for them. These have been marketed and used by manufacturers in their products under "various trade names. Additional quantities of PCBs are imported, both as a raw material and as a substance incorporated into manufactured parts or products. Appendix A v provides a listing of the trade names used by domestic and foreign manufacturers on their products containing PCBs. Cumulative sales in the U.S. since the introduction of PCBs in 1929 are estimated to be 1.5 billion pounds. In 1970 Monsanto voluntarily restricted domestic sales to transformers NPC00026233 753570 Exhibit A-2 and capacitors (closed systems). As a result, current production of PCBs is down about 50% from the peak years before 1970, but still amounts to about 30 million pounds per year. Imports of PCB liquids currently amount to about 0.4 million pounds per year. Monsanto introduced Aroclor 1016 in 1971; although not conclusively proven, it % is reported to have lower toxicity and higher biodegradation rates than other homologs. Most capacitors (using PCBs) produced in the past two years use Aroclor 1016, while transformer applications continue to use Aroclor 1242 and 1254. An estimated 750 million pounds of the PCBs produced are still in service. 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? 300 million pounds -are estimated in landfills. This-distribution of PCBs is illustrated on Figure I. The recommenda tions of this publication are directed only at the PCBs presently in service (or which will enter service as a result of future production). Purpose a Pursuant to Section 204 (b) (1) of the Solid Waite Disposal Act:, as amended, the Administrator may issue 3 * n p c 00026234 753571 Exhibit A-3 . FIGURE I Exhibit A-4 advisory guidance and recommendations related to the disposal of waste materials. These recommended procedures do not have standard-setting or regulatory status, but represent the best information available on preferable disposal options for PCB-contaihing waste materials. The Agency plans to conduct studies to determine other options for treatment and disposal of t PCB-containing wastes (including incineration of capacitors containing PCB liquids) during calendar year 1976. (In addition to Agency activities, the American National Standards Institute is in the process of revising its guideline for disposal of askarels containing PCBs (ANSI C107.1-1974).) As significant new information becomes available -from these and other sources, this .. Federal. Begister issuance ,will be revised. . The purpose; 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^mamifacturing and/or using capacitors and transformers containing PCBs, although / V5 * . the recommended procedures are appropriate to all PCB-containing wastes." Capacitor applications include.power factor correction of both high and low voltage power, ballasting in fluorescent lamps, and motors in air conditioners A ' ' * NPC00026236 753573 E x h i b i t A- and industrial applications. Transformer use of PCBs ^ is primarily in those areas where the non-flammability is the major consideration (largely those applications in proximity to humans). These include transportation applications (electric trains, rapid transit systems) and power supply transformers in commercial and public' buildings. 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. Unfortunately, some of the characteristics (stability, non-degradability) which make PCBs so * - valuable i n industrial applications also make them 'lghly m persistent in the environment. . * ' . ;- . 5 NPC00026237 Exhibit A-6 753574 In the process of replacing hydrogen atoms with chlorine atoms, a large^number of substitution combina tions arise*. Theoretically 210 PCB compounds can be prepared, but only about 100 homologs and isomers are likely to occur in commerical products. In commercial preparation, PCB compounds contain from 12 to 68 percent chlorine; the typical product is a mixture of several homologs. 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. (Aroclor 1016, with approximately 41 percent chlorine, is an exception to this nomenclature system.) The first two digits indicate the type of material: biphenyl, triphenyl, or mixture of the two. Biphenyls with higher chlorine content are ' non-:flammab*le and have extremely low volatilities. '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 ready solubility of PCBs in nonpolar solvents vv- explains why-they are easily absorbed into fatty tissue and into the liver. Fatty tissue ac.ts as a non- i polar solvent, and PC&s are retained, rather than ( excreted-, as the blood passes through. Their resistance - _ * * NPC00026238 6 753575 _ .t. M . i i. to oxidation or other types of chemical degradation explains their persistence and accumulation in animal tissue. Degradation characteristics are not well under% stood. Some, dibenzofurans, which are extremely t o x i c , may be degradation products of PCBs. The chemical inertness and resistance to metabolism of PCBs account for their low acute toxicity. But as they slowly build up in a living system, their concentration approaches toxicity*, levels--FDA has adopted a safety level for food of 5 ppm. At this point chronic effects make themselves evident* Chronic toxic effects vary in different animal species, but run the gamut from skin, liver, and kidney lesions in rabbits to chloracne and hepatotxjkic effects^ln man. . F ' . *; The low solubility of PCBs in water probably limits ^ the rate at which they are dispersed by water systems. PCBs discharged into a river or lake will accumulate in jj f the sediment in relatively high concentrations* Plants . * and animals can concentrate PCBs above their level in iA * - water aloAe. Some fish species taken from Lake Michigan. in 1970 and 1971 have exhibited FCB concentrations *V?* * ' , greater than 5 ppm. Shrimp and oysters exposed to 10 ppb of Aroclor 1254 have shown bioaccumulations from 130- to 3300-fold; bioaccumulations in some species of 40,000 to 75,000 have been experienced. 7 HPC00026239 Exhibit A-8 753576 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 treat ment 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, were based largely upon the results of DDT research. Recent data indicates that aerial transport plays a major role in the world wide dissemination of PCBs, although dumping and river runoff may contribute more importantly to local contamination of fish, wildlife, and drinking water sources. Disposal of FCB-Containing Wastes The persistence of PCBs necessitates extremely careiful attention to ftinal*dispto;s*ition of PCBs and .* PCB-containing materials. First, the use of PCBs . ' should be reduced. Manufacturers or users may either A 'i use less contaminating substitute materials- or more K .. efficient methods which produce less waste.: However, no matter how many substitutes are developed or how efficient operations may become, there may still remain some applications for which PCBs are the best material, and there still will be waste materials. Spills, damaged *. UPC00026240 8 753577 goods, and housekeeping materials will require disposal. Also, as noted on Figure I, there are approximately 750 million pounds of PCBs, incorporated into products, currently in service. These products will ultimately require disposal. If a capacitor or transformer has a label identifying one of the trade names shown in Appendix A, it should be handled as a PCB, and the options listed below followed. If the contents are unknown, but the manufacturer is one of those listed in Appendix A, an inquiry should elicit information on the contents of the equipment or' product. Effective safeguards should be ,,employed in the handling :and transport .of the PCB-containing wastes. These 3?; ,V; - -include the use of protective clothing, closed'containers for transportation-,'^and adequate labeling to alert disposal personnel or emergency response personnel, in the event .V . of a spill or accident. # Anyone initiating a disposal action should select high- quality firms for thj^ifSnsport.and disposal of their PCB- containing .wastes.-- -'Also, spot-checking to assure that the 1 $ y` materials*are b e i n g vproperly handled, treated,-transported, . and disposed is recommended. The generator of the'jvaste m should take responsibility for proper waste management. UPC00026241 Exhibit A-10 753578 Recommended options for the disposal of PCB-containing wastes (in priority order) are: Reclamation or recycling Incineration Controlled land disposal Recycling - Reclamation or recycling of PCBs is usually feasible 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 should be disposed of by high temperatures incineration. Recycling of transformers is accomplished b y General Electric Co, and several independent companies The tank and inside copper of the transformer is reclaimed; the PCB liquids, if they c a n 't be reused, should be incinerated. PCBs can be leached from solid wastes with a suitable solvent,. e*g., trichloroethylene or acetone. The decontaminated waste can then be disposed. The solution containing PCBs may be separated by distillation into PCB, which may be reclaimed, and the solvent which may be used NPC00026242 Exhibit A-ll 753579 again. Mallory has developed a technique for extracting FCBs from reject capacitors and then reclaiming the PCBs for reuse. The distillation technique is also applicable to remove PCBs from contaminated liguids. This technique (of leaching and reclamation) is especially useful after accidental spills of liquid PCBs. The spills could be absorbed on dry sand', ash, sawdust, or commercial absorbents and then processed as above. Incineration - The proper incineration of waste PCBs must involve a suitable balance among temperature in the incinerator, dwell time* i n the firing chamber, and oxygen availability. Also, suitable scrubber should be provided on.the exhaust stack to remove the-hydrochloric acid mist that' is formed. Exhaust gases should b e monitored Recommended^ requirements ares (1) 2-second dwell time at 1100C (2000F) and 3% excess oxygen in the stack; or (2) 1 1/2 second dwell time at 1500C(2700F) and fir ^ 2% excess oxygen in the stack gas.* Open.hearth and other ^ **' cure not normally suitable; the relatively low operating temperature of these equipment would only volatilise the NPC00026243 * These values are from ANSI C107.1-1974. Guidelines for Handling and Dispoal at Capacitor and Transformer-Grade Askarels Containing Polychlorinated Biphenyls, American National Standard Institute. 11 Exhibit A-12 753580 PCB and pollute the 'atmosphere. In addition, instrumenta tion and handling equipment are usually not sufficient for managing hazardous materials. Therefore, PCB-containing waste should not be sent to such municipal incinerators for disposal. 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 i* sufficient residence times may be satisfactory. As a service, Monsanto will incinerate (for a fee) any * returned liquids in their high temperature incinerator. A technical description of 'the Monsanto incinerator is provided in Appendix B. *. 'EPA publication. Hazardous Waste Management Facilities (EPA/530/SW-146), provides information on some incineration facilities. Use of these facilities * t for incineration *>f PCB-containing waste should be checked with EP A Regional and State representatives^. to \V assure that, the facility has adequate environmentad` controls to meet Federal/State/local regulations. Land Disposal - Wastes containing PCBs should not be disposed.of with other mixed_wastes in a sanitary landfill, (See EPA Guidelines on Thermal Processing and Land NPC00026244 12 . 753581 Exhibit A-13 Disposal of Solid Waste, Federal Register, August 19, 1974). Characteristics of transport of- PCBs through the soil are not definitively established. The interaction V7ith other decomposing wastes is n o t well understood. Some landfills may receive materials that readily leach PCBs. The ubiquity and persistence, of PCBs indicate' that their disposal should be carefully controlled until additional data are developed. While j these data are- being gathered, PCBs (when disposed to the land) should only be placed in a secure chemical waste landfill. *In general terms, a chemical waste landfill provides complete long-term protection for the quality of surface and subsurface\vr`rlwaters< far.o.m hazardous waste deposited . v- therein,v and against.,haiaxds to public health and the 4M$?f environment.. Such.^ites should be located or engineered to avoid direct'* hydraulic continuity with surface and ** subsurface waters. Generated leachates should be contained, and subsupfac^fi* flow into the disposal area eliminated. Monitoring wells should be established and a sampling and analysis program conducted. Additional characteristics of a chemical waste landfill are- V .13 NPC00026245 Exhibit. A-14 753582 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 or solids or sludges. This is usually done by casting the waste in concrete inside a drum prior to deposition in the landfill. .Only those specific sites which have been state-approved for FCB wastes should be used,. The EPA publication, Hazardous Waste Management Facilities, (EPA/5 3O/SW-14 6) provides some information to potential disposers; these data.when used in consultation with State solid waste management officials can assist in a disposal action ** Documents referenced here may be obtained from Solid Waste Information, U.S. Environmental Protection Agency, Cincinnati; Ohio 145283 NPC00026246 14 753583 *_1 S ft-Ol ( Appendix A Listing of Names Used for PCBs by Manufacturers Name Aroclor Abesto1 Askarel Chlorextol Diaclor Dykanol Elemex Hyvol Inerteen * No-Flamol Pyranol S*a f - T - K u h l Manufacturer Monsanto American Corporation * Allis Chalmers Sangamo Electric Cornell Dubilier McGraw Edision . Aerovox WestinghouseElectric Wagner Electric ^General .Electric ; Kuhlsran* Electric ./ * Clophen Fenclor Kennechlor P h e n o c l o r 'v DP Ky c'a l'e n e SarrtS)therm - ' p ?3Wa,J'*' - Bayer (Germany) Caffaro (Haly) Mitsubishi' (Japan) Prodelec (France) Caffaro (Italy) Prodelec (France) Mitsubishi (Japan) . ' # * generic name used for insulating liquids in capacitors and transfamers; may contain PCBs. 14 * 'a!O HPC00026247 753584 V W R - T jssaww?-111'rr^r^s ' Exhibit A f-tB 1 Y Appendix B I 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, j and various chemical intermediates. The plant is t located immediately south of East St. Louis, 111. j 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 m | The large majority of the wastes burned are PCB derivatives* The sources of these wastes are process still bottoms, spoiled batches, and contaminated transformer oils. The heating value of the materials * is about 9000 BTO/lb. Other in-house high BTU liquid wastes are also incinerated* Phosphorous compounds # cannot be burned due to the formation o f .particulates (P2O5 ) which foul the injection system. The system is n o t equipped to handle suspended!solids. Four .9 -15 '* j .* NPC00026248 753585 ( 20/000 gallon tanks are available for storage. The wastes are typically stored for several days before incineration to allow undissolved solids to settle. After the settling period, the wastes are pumped directly from the tanks to the liquid combustor. Incinerator Description The incinerator .is a liquid injection type housed in a horizontal cylinder 20.ft. long and 9.5 ft,, in diameter. High pressure steam is used . to atomize the waste liquid and inject it into the liquid combustor. The feed rate measures 2 gal/min. A n additional gun which burns natural gas is also positioned inside the plenum. The natural gas serves as an auxiliary fuel to supplement the h e a t i n g .value of *a the waste if necessary. The operating temperature varies from 2000 to 2200*P. If the. temperature is too high# wa t e r can be sprayed into the chamber `to act as a heat sink. The cylinder is protected from the heat by a lining of refractory brick. High aluminum brick'.is used I n the plenum chamber. A- blower, supplies 25% excess air forcing the fumes from the plenum and through an oxidizer. T h ^ v< r e s i de'n c e time inside the oxidizer is 2-3 seconds* 16 . NPC00026249 Exhibit A-18 753586 BIBLIOGRAPHY * Polychlorinated biphenyls and- the environment. Inter departmental Task Force on PCB's. Depts. of Agriculture, Interior, HEW, Commerce and EPA, May 1972. m Carnes, R . , Doerger, J . , Spearks, K.L. Polychlorinated biphenyls in solid waste and solid-waste-related materials. Cincinnati. 1973. a American National Standards Institute (ANSI). Guidelines for handling and disposal of capacitor-and transformer-grade j askarel& containing polychlorinated biphenyls. New York, January 1974. , 4. Peaksail, D.B. PCB's and their environmental effects. Critical Reviews in Environmental Control. CRC. 1975. `5, Broadhurst, M. Use and replacebility of polychlorinated biphenyls. Environmental Health Perspectives. Oct. 1972. )W 6 , Versar, Inc. Assessment of wastewater management, treatment technology, and associated costs* for abatement of PCBs concentrations in industrial effluents. Jan. 1976. (Draft repprt)_r_ . ... *7* .... . _ j 7. Bremer, K. State of concerns of the Lake Michigan Toxic Substances Committee related to PB. Chicago. Internal EPA Report. `. 8. Aroclor. Poly chlorinated polyphenyls (biphenyls) Technical Bulletin O-FF/IR. St. Louis: Monsanto Industrial Chemicals Company, Nov. 1971. ' 9. P C B 's-environmental impact. 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. Lesheridok, T. Environmental Protection .Agency SW-146, revised, 1976. NPC00026250 Exhibit A-20 753587 rcJ l The unit is operated 24 hours/day requiring 2 raen/shift. Initial capital costs were $740,000. The disposal cost has averaged lOC/lb. Air Pollution Control The fumes exit the oxidizer and enter a water quench' column. The main purpose of th quench is to reduce the temperature of the hot fumes. Particulates are removed next in a high energy venturi scrubber. Finally, the emissions are cleaned 17 NPC00026251 .Exhibit A-19 753588