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Gossman Consulting, Inc.                  October, 1992

PCB rejection specifications and policies at hazardous waste fuel facilities are areas in which technical realities, government regulations and corporate policies or agreements can easily collide. The following factors may have a significant impact on this issue:

1. Government (EPA) regulations do not specifically indicate that materials containing <50 ppm PCBs are unregulated. Indeed some wastes containing <50 ppm PCBs are regulated as PCB contaminated if the waste was produced by diluting material with 50 ppm PCBs.

2. Laboratory methods are not exact. Methods designed to confidently detect PCBs at 50 ppm will frequently detect PCBs at <50 ppm. This determination may be at virtually any confidence level depending on the Arochlor and potential interferences.

3. Corporate policies or contractor supply limits are frequently vague. Phrases such as "no PCBs" or "none" are common. Such phrases are frequently desirable from a community relations standpoint, but ignore the reality of ambient levels of PCBs all around us.

This issue of HWF Notes presents specific language for specifications on hazardous waste fuel which can be used for both permit and operating specifications. Such a specification would also be suitable for use in a supply contract. There is also a recommended corporate policy designed to provide specific guidance to facility personnel performing PCB determinations on hazardous waste fuel. This combination of specifications and policy can avoid conflict with regulations, meet community relations needs and provide unambiguous guidance to operating facility personnel.

Specification Language

Parameter Limit
PCBs or PCB contaminated Shall not be present as defined in 40CFR761.1, 761.3, 761.20 and 761.60.

ABC Corporation PCB Rejection Policy

ABC Corporation operates a number of hazardous waste fuel facilities at cement plants. These facilities are permitted and designed to handle a wide variety of flammable liquid and solid fuels for use in the cement manufacturing process. These fuels must meet specific quality control criteria in order to be considered acceptable. On-site laboratories at each plant are operated to assure that these specifications are met. ABC Corporation HWF facilities have not sought and do not have a permit to utilize PCBs or PCB contaminated materials as hazardous waste fuel. Each shipment at each facility is tested for PCBs. The laboratory methods have been designed to provide results of a high statistical confidence level for PCB concentrations of  50 ppm and any shipment with  50 ppm PCBs shall be rejected. Because regulations controlling PCB concentrations of < 50 ppm PCBs require careful interpretation, the following steps are followed:

1. The identification of PCBs at < 50 ppm must be clear and unambiguous. Only if the analysis has a high statistical confidence of an Arochlor PCB pattern match will PCBs be considered to be present at < 50 ppm.

2. If PCBs at < 50 ppm have been identified in a shipment, the shipment shall be rejected unless the generator provides a written and signed certification stating that "the PCBs present at < 50 ppm in the waste shipment did not result from any dilution of materials containing  50 ppm PCBs". Furthermore, the generator certification must say that "the waste shipment meets none of the definitions or descriptions of PCBs, PCB items or PCB contaminated materials found in 40CFR 761.1, 761.3 and 761.70".

3. Receipt of wastes containing < 50 ppm PCBs under the above conditions requires the direct approval of the plant manager and any occurrence thereof shall be reported within one working day to the corporate environmental manager.