PCB 761.60(e) Technologies

1. PCB 761.60(e) Technologies Winston Lue August 9, 2016

2. Please hold your questions until the end of the presentation.

3. PCBs

4. Why are PCBs so Difficult to Destroy? • Chemical tailored to do what it was created to do • Two benzene rings with chlorine atoms • The more chlorine on the molecule, the more stable is the molecule • Aromatic and resonance create stability • High boiling point, melting points, low vapor pressure • Bond energy of C-Cl difficult to break. • PCBs were created to be inflammable, used in flame retardants, dielectric fluid

5. Thermodynamic Data • Need a lot of energy to break C-Cl bonds in PCB molecule, stabilized by resonance of the benzene rings • High heat of reaction • The higher the energy used to destroy PCBs, the more effective is the destruction • The more reactive is the reagent, the more effective is the destruction

6. Approval Authorities • ORCR mobile units, transportable technologies, and non-unique fixed site facilities • RA unique fixed site facilities • Cannot be delegated to the States

7. 40 CFR 761.60(e) • Any person who is required to incinerate any PCBs and PCB items under this subpart and who can demonstrate that an alternative method of destroying PCBs and PCB items exists and that this alternative method can achieve a level of performance equivalent to an incinerator approved under§ 761.70 or a high efficiency boiler operating in compliance with § 761.71, must submit a written request to the Regional Administrator or the Director, Office of Resource Conservation and Recovery, for a waiver from the incineration requirements of § 761.70 or § 761.71. • Technology equivalent to the performance of a TSCA incinerator

8. Technical Review of the Operating Approval and Demonstration Test Plan • Will the process work? • Will it meet the criteria of six 9s DREs? • Will it pose an unreasonable risk? • Will it produce an end product more toxic or hazardous than PCBs? • Is it a totally enclosed process? • Is it ex-situ or in-situ? • Was this process ever demonstrated and witnessed by another EPA office? • What type of chemical reagents were used in the process?

9. The Universe of Disposal and Decontamination Technology • Chemical • Thermal and alternative thermal • Physical Separation • Biological • Landfills including encapsulation and stabilization Some of these technologies are not permitted by 60(e)

10. Chemical Technologies to Dispose of PCBs Chemical • Chemical Dechlorination • Reduction • Oxidation • Exotic types of technologies

11. Chemical Dechlorination • Chlorine atoms from the PCB molecule are removed by a strong alkali (e.g. sodium emulsion, APEG, KPEG process. PEG=Polyethylene Glycol) • Usually operated under moisture-free nitrogen • Very reactive process • Potential for sodium fires • Potential for hydrogen fires

12. Companies with Mobile Chemical Dechlorination Units • EPS – Environmental Protection Services, Wheeling, WV • FTI – Florida Transformer Inc, Defuniak Springs, FL

13. Alternative Technology – 60(e)Chemical DechlorinationEnvironmental Protection Services, Inc. • EPS, Inc., Wheeling, WV • Technology was originally SunOhio PCBX treatment in the early 1980s • One of the first companies to be granted national approval • Operated PCBX as a transformer servicing unit • Bought out by ENSR ca. 1995 • Technology purchased by EPS ca. 2001

16. Solvated Electron Technology (SET) • Commodore Advanced Sciences had a 60(e) approval and had demonstrated to HQ for soils, oils, and debris with PCBs. • Approval expired in 2005 • After several attempts, Commodore was not able to demonstrate destruction to PCBs to less than 2 ppm for three runs during several demonstrations.

17. SET Technology Reduction is essentially adding a reducing agent or source of electrons from a mixture to the PCB feed. Na + NH3-- NaNH2 + H2 + e-

18. SET Process Diagram

19. Catalytic Hydrogenation • Safety Kleen • Hydrodec North America • Other NORA oil recyclers in the future?

20. Hydrodec North America Inc.

21. Oxidation (Limited Success) • Involves adding an oxidizing agent to the PCB feed to destroy it. Examples: • Ozone • Hydrogen peroxide (Low concentration) • Potassium permanganate • Potassium persulfate • Fenton reagent (iron catalyst and hydrogen peroxide)

22. Thermal Technologies to Dispose of PCBs Thermal and alternative thermal Radiant energy Pyrolysis Thermal desorbers Other thermal units High efficiency boilers, 761.71 Scrap metal recovery and smelters, 761.72(a) Incinerators Thermal desorbers with afterburners

23. Incineration

24. Army Chemical Material AgencyNational Approval for M55 Chemical Agent Rocket Incinerator Approval issued June 6, 2002 Approval renewed June 5, 2007 Approval terminated July 10, 2010 Robert Kasper Chemical Management Agency Aberdeen Proving Ground, Maryland

25. PCBs in Shipping/Firing Tubes

26. Locations of Chemical Agent Stockpile & Disposal

27. Status of Army CMA • Two types of chemical agents – GB (Sarin) and VX (nerve agent) • Both have completed GB Rocket incineration • Closure • Facilities have completed TSCA closure for the metal parts furnaces

28. Mobile Incinerators

29. Mobile Incinerators • EPA HQ had several mobile incinerators permitted in the mid 80s-90s. • Ogden bubbling bed • Shirco infrared • ENSR rotary kiln • Most were pilot scale and were never renewed. • ENSR rotary kiln only commercial incinerator and was at BROS Superfund site in New Jersey

30. Thermal Desorbers • High Temperature Thermal Desorption • With chillers • With afterburners

31. Flow Diagram for High Temperature Thermal Desorption

32. Alternative Thermal Destruction • Geosafe Corporation (now called AMEC) • Maxymillian Technologies • Materials and Energy Corporation • DSSI

33. In-Situ Vitrification

34. In-Situ Vitrification

35. In Container Vitrification • AMEC (now called Kurion-Veolia)

38. Technologies that Were Not Permitted

39. Reasons 60(e) Technology was not approved • Reasons why technology applications were never approved: • Incomplete application • No demonstration • Failed demonstration • Insufficient financial assurance • Human error (or stupidity) • After meeting with the company, did not hear from them • Company did not like terms and conditions of the demo or operating approval • But it works in the lab… • Scale up • Material handling problem • Accidents at demonstration • Cost prohibitive for demo and the approval process

41. Leave the site?? • EPA representatives have the authority to leave the site if the company is unable to successfully treat PCBs to less than 2 ppm in the first run (or other runs) within three days.

42. Technologies that did not work • Mechanochemical Destruction • EPA Mobile Incinerator

43. Mechanochemical Destruction

44. White Alice System

45. Granite Mountain Radio Relay Station (GMRRS) Picture taken from road going up to top of mountain.

46. The State Bird of Alaska - Mosquitoes!

47. Air Transport into Granite Mountain We are looking into potentially having regular flights into and out of Granite Mtn. Maybe daily. The flight takes about 1:15 minutes out of Nome. Weather could delay flights.

48. Garage Building at top of mountain MCD equipment will be setup in here.

49. Mechanical component:MCD treatment utilizes the high energy collisions of a ball mill to fracture soil constituents and produce reactive species on mineral surfaces (e.g. quartz sand). Chemical component:The radicals generated react with PCBs and many other organic molecules (pesticides, dioxins) yielding amorphous carbon and inorganic salts. MCD Principles Collisions create reactive sites on quartz. Reactive sites react with organic compounds.

50. Treatability Study Conclusions at Naval Site in California • MCD Process destroyed PCBs from over 100 mg/kg to less than 1 mg/kg in less than 15 minutes • Destruction appears to completely transform PCBs to amorphous carbon and chloride however, some congener shift may occur as well • Organochlorine Pesticides (DDT, Dieldrin) are destroyed in the same process • Preliminary result indicate MCD process is an effective remedial technology for treatment of recalcitrant organic compounds including PCBs and organochlorine pesticides.