**Clean Air & Water, Inc.**

# A Non-Profit Citizens Environmental Organization

# (Established 1966)

750 Wade Street

Beaumont, Texas 77706

409-892-4964

June 22, 2008

Mr. Stephen Johnson\
Administrator\
U.S. Environmental Protection Agency\
1200 Pennsylvania Avenue, NW\
Washington, D.C. 20460

Subject: **Veolia's Transportation Exemption (Docket ID No.:
EPA-HQ-RCRA-2008-0123)**

Mr. Johnson:

Clean Air & Water Inc. (CAW) learned of the public hearing for Veolia's
exemption for transporting PCBs from Mexico to their Port Arthur, Texas
facility (Docket ID No.: EPA-HQ-RCRA-2008-0123) on the day of the
hearing, too late to attend due to prior plans.

Clean Air & Water Inc. board-of-directors would like the following
comments and suggestions concerning this request to be part of the
hearing record.

Clean Air & Water, Inc. opposes the exemption for Veolia allowing the
transport of PCBs from Mexico or any other foreign country.

Veolia, has demonstrated by pass violations their lack and inability to
obtain control and proper operation of the incinerator (Appendix A).
Through EPA's TRI reports the Lone Star Chapter of the Sierra Club has
discovered releases of PCBs and inconstancies in reporting correct
release data (Appendices B and C). Under the name Onyx, TCEQ approved
financial penalties for unauthorized discharge of contaminants and other
chemical releases leading to reactions producing toxic air emissions - a
mist threaten human health impacting five workers (Appendix D). Veolia
has tried to maintain the economics of incinerator operation by securing
contracts to maintain an over estimated project life and capital
investment, while not investing in newer technologies providing a more
secure future for their employees and the environment they desire to
protect.

In an EPA published document (Appendix E) *Chemical Dehalogenation or
Dechlorination* is an approved method of destroying PCBs, where the cost
appears to be less, plus treatment takes place onsite. This treatment
process is not available apparently at Veolia, but is offered by others.
EPA has identified four companies providing just such a service
(Appendix F). Another company, Commodore Applied Technologies, Inc. has
on site treatment process for PCBs (Appendix G) a technology a company
looking for future growth should invest in, provided demand for feeding
an over capitalized incinerator was not a problem.

Clean Air & Water, Inc. believes too this exemption will allow Mexico to
become a "funnel for world PCB problems." Instead EPA should be sharing
and promoting technology transfer instead of increasing the chance of a
toxic release. This does not prevent Veolia from becoming more involved
in new technologies or from increasing job opportunities for working
Americans.

Clean Air & Water, Inc. would like to thank EPA for this opportunity to
present this comment and suggestions for alternative actions. Looking
forward to your response.

Richard C. Harrel -- President

Clear Air & Water, Inc.

cc: <Noggle.William@epamail.epa.gov>,

> <Greene.Richard@epa.gov>,
>
> <Edlund.Carl@epa.gov>,
>
> <Blevins.John@epa.gov>,
>
> <Luthans.William@epa.gov>,
>
> <Hook.Jonathan@epa.gov>,
>
> <Augurson.Shirley@epa.gov>,
>
> <rcra-docket@epa.gov>

**Appendix A**

FOUR OPENINGS OF THE THERMAL RELIEF VENT/BYPASS DUMP STACK IN 2003 AND
2004 - 11 DATES OF MULTIPLE PERMIT VIOLATIONS AND EXCEEDANCES\
\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 7 - Reportable Emission Event - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator. On]{.mark}\
May 26, 2003 informed the TCEQ of a reportable emissions event lasting
one hour. Onyx did not provide a cause for the one hour event. There was
an automatic opening of the thermal relief vent (TRV) is also a Bypass
Dump Stack) and emissions were released from the TRV).\
\
Hydrogen chloride gas levels exceeded the permitted maximum hourly
allowable emissions rate of 3.21 pounds per hour under TCEQ permit
HW-50212-001 with 247 pounds of hydrogen chloride, or nearly 77 times
above the authorized hourly emissions rate.\
\
Particulate matter levels exceeded the permitted maximum hourly
allowable emissions rate of 9.0 pounds per hour under TCEQ permit
HW-50212-001 with 820 pounds of particulate matter, or more than 91
times above the authorized hourly emissions rate.\
\
Sulfur dioxide levels exceeded the permitted maximum hourly allowable
emissions rate of 49.9 pounds per hour under TCEQ permit HW-50212-001
with 51 pounds of sulfur dioxide.\
\
In a Notice of Enforcement for Compliance Investigation letter from TCEQ
on August 26, 2004, Onyx was cited for violations of TCEQ rules
122.143(4), 382.085(b), and 101.201(a))(1)(B) of the Texas Health &
Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 8 - Reportable Emission Event - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator. On]{.mark}\
July 8, 2003 informed the TCEQ of a reportable emissions event lasting
one hour and six minutes. Onyx did not provide a cause for the one hour
and six minute event. There was an automatic opening of the thermal
relief vent (TRV) is also a Bypass Dump Stack) and emissions were
released from the TRV).\
\
Particulate matter levels exceeded the permitted maximum hourly
allowable emissions rate of 9.0 pounds per hour under TCEQ permit
HW-50212-001 with 1,914 pounds of particulate matter, or nearly 213
times above the authorized hourly emissions rate.\
\
Hydrogen chloride gas levels exceeded the permitted maximum hourly
allowable emissions rate of 3.21 pounds per hour under TCEQ permit
HW-50212-001 with 73.7 pounds of hydrogen chloride, or nearly 23 times
above the authorized hourly emissions rate.\
\
In a Notice of Enforcement for Compliance Investigation letter from TCEQ
on August 26, 2004, Onyx was cited for violations of TCEQ rules
122.143(4), 382.085(b), and 101.201(a))(1)(B) of the Texas Health &
Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 9 - Reportable Emission Event - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator. On]{.mark}\
October 10, 2003 informed the TCEQ of a reportable emissions event
lasting five minutes. Onyx indicated that a fire occurred in the
shredder and conveyor system when a drum ignited during processing.\
\
Incident occurred at night and so no opacity reading was taken, but the
permitted opacity limit is 5%.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001
with 646 pounds of carbon monoxide, or nearly 38 times above the
authorized hourly emissions rate.\
\
Particulate matter levels exceeded the permitted maximum hourly
allowable emissions rate of 9.0 pounds per hour under TCEQ permit
HW-50212-001 with 300 pounds of particulate matter, or more than 33
times above the authorized hourly emissions rate.\
\
Hydrogen chloride gas levels exceeded the permitted maximum hourly
allowable emissions rate of 3.21 pounds per hour under TCEQ permit
HW-50212-001 with 31.0 pounds of hydrogen chloride, or nearly 10 times
above the authorized hourly emissions rate.

Sulfur dioxide levels exceeded the permitted maximum hourly allowable
emissions rate of 49.9 pounds per hour under TCEQ permit HW-50212-001
with 60 pounds of sulfur dioxide.\
\
In a Notice of Enforcement for Compliance Investigation letter from TCEQ
on August 26, 2004, Onyx was cited for violations of TCEQ rules
122.143(4), 382.085(b), and 101.201(a))(1)(B) of the Texas Health &
Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 10 - Reportable Emission Event - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
December 12, 2003 informed the TCEQ of a reportable emissions event
lasting fifty minutes. Onyx stated that a power failure from Entergy,
the electric utility provider, causing the induced draft fan to shutdown
and an automatic opening of the thermal relief vent (TRV) is also a
Bypass Dump Stack).\
\
Particulate matter levels exceeded the permitted maximum hourly
allowable emissions rate of 9.0 pounds per hour under TCEQ permit
HW-50212-001 with 485 pounds of particulate matter, or nearly 54 times
above the authorized hourly emissions rate.\
\
Hydrogen chloride gas levels exceeded the permitted maximum hourly
allowable emissions rate of 3.21 pounds per hour under TCEQ permit
HW-50212-001 with 205 pounds of hydrogen chloride, or nearly 64 times
above the authorized hourly emissions rate.\
\
In a Notice of Enforcement for Compliance Investigation letter from TCEQ
on August 26, 2004, Onyx was cited for violations of TCEQ rules
122.143(4), 382.085(b), and 101.201(a))(1)(B) of the Texas Health &
Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 11 - Reportable Emission Event - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
March 10, 2004 informed the TCEQ of a reportable emissions event lasting
forty-one minutes. Onyx stated that a malfunction occurred from falling
friable ash and slag that fell from the top of the quench tower to the
bottom causing the quench recirculation pumps to shutdown that caused
the temperature to increase to a point that triggered the [automatic
opening of the thermal relief vent (TRV) is also a Bypass Dump
Stack)]{.mark}.\
\
Particulate matter exceeded its permitted maximum hourly allowable
emissions rate of 9.0 pounds per hour under TCEQ permit HW-50212-001
with 780 pounds of particulate matter, or nearly 87 times above the
authorized hourly emissions rate.\
\
[Hydrogen chloride gas levels]{.mark} exceeded the permitted maximum
hourly allowable emissions rate of 3.21 pounds per hour under TCEQ
permit HW-50212-001 with 169 pounds of hydrogen chloride, or nearly 53
times above the authorized hourly emissions rate.\
\
In a Notice of Enforcement for Compliance Investigation letter from TCEQ
on August 26, 2004, Onyx was cited for violations of TCEQ rules
122.143(4), 382.085(b), and 101.201(a))(1)(B) of the Texas Health &
Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 12 - Potential Violations Form - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
November 9, 2002 informed the TCEQ of a reportable emissions event
lasting twenty-two minutes.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001.\
\
Onyx was cited for violations of TCEQ rules 122.143(4) and 382.085(b) of
the Texas Health & Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 12 - Potential Violations Form - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
January 29, 2003 informed the TCEQ of a reportable emissions events
lasting seven minutes and five minutes.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001.

Onyx was cited for violations of TCEQ rules 122.143(4) and 382.085(b) of
the Texas Health & Safety Code for these two events.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 12 - Potential Violations Form - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
October 21, 2002 informed the TCEQ of a reportable emissions event
lasting several hours.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001.\
\
Onyx was cited for violations of TCEQ rules 117.213(1), 122.143(4) and
382.085(b) of the Texas Health & Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 12 - Potential Violations Form - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
July 18, 2003 informed the TCEQ of a reportable emissions event lasting
thirty-five minutes.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001.\
\
Onyx was cited for violations of TCEQ rules 122.143(4) and 382.085(b) of
the Texas Health & Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 12 - Potential Violations Form - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator.]{.mark} On\
November 15, 2003 informed the TCEQ of a reportable emissions event
lasting fifty-seven minutes.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001.\
\
Onyx was cited for violations of TCEQ rules 122.143(4) and 382.085(b) of
the Texas Health & Safety Code.\
\
==========\
\
Texas Commission on Environmental Quality investigation number 277008 -
Attachment 12 - Potential Violations Form - Investigation date July 14,
2004.\
\
[Onyx Environmental Services, L.L.C. Port Arthur hazardous waste
incinerator. On\
December 29, 2003 informed the TCEQ of a reportable emissions event
lasting ten minutes]{.mark}.\
\
Carbon monoxide levels exceeded the permitted maximum hourly allowable
emissions rate of 17.2 pounds per hour under TCEQ permit HW-50212-001.\
\
Onyx was cited for violations of TCEQ rules 122.143(4) and 382.085(b) of
the Texas Health & Safety Code.\
\
================================================================\
\
\
TCEQ Notice of Enforcement for Compliance Investigation Letter to Onyx
dated August 26, 2004\
\
\
Onyx Environmental Services LLC\
Port Arthur, Jefferson County, Texas 77640\
Investigation \# 277008\
Investigation date July 14, 2004\
\
Pages 1-3\
\
OUTSTANDING ALLEGED VIOLATIONS\
\
Violation Track No. 168616\
30 TAC Chapter 122.143(4) - Texas Administrative Code.\
5C THC Chapter 382.085(b) - Texas Health & Safety Code.\
Permit HW 50212-001\
Permit Condition V.G. of Permit 50212-001 requires that this facility
must not violate Section 382.085(b) of the Texas Health & Safety Code.\
\
Alleged Violation:\
Investigation number: 277008\
Comment date: 08/25/2004\
\
[Failure to maintain an emission rate below the allowable emissions
limit.  The incinerator stack has an emission limit for Carbon Monoxide
(CO) of 17.2 pounds per hour.  Hazardous Waste Permit HW 50212-001
establishes the 17.2 pounds per hour limit in Attachment E of that
permit.]{.mark}\
\
The permit limit was exceeded five times since the Federal Operating
Permit was issued.  On November 9, 2002, the CO emissions exceeded the
permit limit for 22 minutes on an hourly rolling average.\
\
On January 29, 2003, the CO emissions exceeded the permit limit two
incidents.  The first started at 8:15 p.m. and ending of 8:21 p.m. for a
duration of 6 minutes.  The second started at 9:08 p.m. and ending of
9:12 p.m. for a duration of 4 minutes.  The hourly rolling average CO
limit was exceeded.\
\
On September 18, 2003, the CO emissions exceeded the permit limit for 35
minutes on an hourly rolling average. \
\
On November 15, 2003, the CO emissions exceeded the permit limit for 57
minutes on an hourly rolling average.  The highest CO recorded was 57
pounds per hour.

On December 29, 2003, the CO emissions exceeded the permit limit for 10
minutes on an hourly rolling average.  The highest CO recorded was 17.9
pounds per hour.\
\
Federal Operating Permit (FOP) 1509 requires the facility to comply with
HW-50212-001.  Failure to comply with the requirements of Permit
HW-50212-001 is a violation of 30 TAC 122.143(4) which states:  \"The
permit holder shall comply with all terms and conditions codified in the
permit and any provisional terms and conditions required to be included
with the permit.\"\
\
Failure to comply with the requirements of TAC 122.143(4) is also a
violation of Section 382.085(b) of the Texas Health and Safety Code
which states:  \"A person may not cause, suffer, allow, or permit the
emission of any air contaminant or the performance of any activity in
violation of this chapter or of any commission rule or order.\"\
\
\
==========\
\
\
Violation Track No. 168630\
30 TAC Chapter 101.201(a)(1)(B) - Texas Administrative Code.\
5C THC Chapter 382.085(b) - Texas Health & Safety Code.\
Permit HW 50212-001\
Permit Condition V.G. of Permit 50212-001 requires that this facility
must not violate Section 382.085(b) of the Texas Health & Safety Code.\
\
Alleged Violation:\
Investigation number: 277008\
Comment date: 08/25/2004\
\
[Failure to notify the regional office of reportable emissions events at
the incinerator]{.mark} which occurred on May 26, 2003, July 8, 2003,
October 10, 2003, December 12, 2003, and March 10, 2004.\
\
During each of the emissions events, Onyx released more than 100 pounds
of Particulate Matter (PM) which made the event reportable because the
reportable quality for PM is 100 pounds.\
\
Based on the fact that the emissions events were not reported correctly,
the emissions associated with these events are unauthorized. See
Violation Track Number 168633 for the violations associated with the
unauthorized emissions.\
\
===========\
\
\
Violation Track No. 168626\
30 TAC Chapter 117.213(a)(1)(A)(ii) - Texas Administrative Code.\
30 TAC Chapter 122.143(4) - Texas Administrative Code.\
5C THC Chapter 382.085(b) - Texas Health & Safety Code.\
Permit HW 50212-001\
Permit Condition V.G. of Permit 50212-001 requires that this facility
must not violate Section 382.085(b) of the Texas Health & Safety Code.\
\
Alleged Violation: Numerous permit recordkeeping violations\
Investigation number: 277008\
Comment date: 08/25/2004\
\
Failure to maintain and record the hours of operation of the deep well
emergency\
generator (DWBKUP).\
\
From October 21, 2002, through November 30, 2002, Onyx failed to record
the hours of operation for the deep well emergency generator (DWBKUP).
Provision 11 of Hazardous Waste Permit HW 50212-001 permit states: \"The
permit holder shall comply with the requirements of 30 TAC 117,
Subchapter B, Division 3.\"  Title 30 Section 117.203 applies to the
following units WTBKUP, INCBKUP, DWBKUP, BOILER A, AND BOILER B.\
\
The deep well emergency generator is required to comply with 30 TAC
117.213(a)(1)(A)(ii), which requires the hours of operation be
recorded.  Failure to comply\
with 30 TAC 117.213(a)(1)(A)(ii) is a violation of Provision 11 of
Permit HW 50212-001.   Federal Operating Permit (FOP) 1509 requires the
facility to comply with HW 50212-001.   Failure to comply with 30 TAC
117.213(a)(1)(A)(ii) and 30 TAC 122.143(4) is also a violation of
Section 382.085(b) of the Texas Health & Safety Code.\
\
===========\
\
\
Violation Track No. 168633\
30 TAC Chapter 122.143(4) - Texas Administrative Code.\
5C THC Chapter 382.085(b) - Texas Health & Safety Code.\
Permit HW 50212-001\
Permit Condition V.G. of Permit 50212-001 requires that this facility
must not violate Section 382.085(b) of the Texas Health & Safety Code.\
\
Alleged Violations:  Eleven emissions limit violations\
Investigation number: 277008\
Comment date: 08/25/2004\
\
Failure to maintain an emission rate below the allowable emissions
limit.\
\
Three emission limits violations:  On May 26, 2003, Onyx released 247
pounds of HCL, 820 pounds of PM and 51 pounds of SO2 in a 60 minute
period starting at 1:50 a.m. during an emissions event.\
\
Two emission limits violations:  On July 8, 2003, Onyx released 73.7
pounds of HCL, 1,914 pounds of PM and 30.6 pounds of SO2 in a 66 minute
period during an emissions event.

Four emission limits violations:  On October 10, 2003, Onyx released 31
pounds of HCL, 300 pounds of PM, 60 pounds of SO2, and 646 pounds of CO
in a 5 minute period during an emissions event.\
\
Two emission limits violations:  On December 12, 2003, Onyx released 205
pounds of HCL, 485 pounds of PM and 42 pounds of SO2 in a 50 minute
period starting during an emissions event.\
\
Two emission limits violations:  On March 10, 2004, Onyx released 169
pounds of HCL and 780 pounds of PM in a 41 minute period during an
emissions event. The permitted SO2 limit was not exceeded.\
\
The permit limits of Hazardous Waste Permit HW 50212-001 are 3.21 pounds
per hour of HCL, 9.0 pounds per hour for PM and 49.9 pounds per hour for
SO2.  Federal Operating Permit (FOP) 1509 requires the facility to
comply with HW 50212-001.  Failure to comply with the requirements of
Permit HW 50212-001 is a violation of 30 TAC 122.143(4).\
\
Based on the fact that the emissions events were not reported correctly,
the emissions associated with these events are unauthorized. See
Violation Track Number 168630 for the violations associated with the
reporting requirements.\
\
===========

**Appendix B**

<http://www.texas.sierraclub.org/press/newsreleases/20080619.asp>

Company Revises Reported Figures Veolia does not monitor or measure its
stack PCB emissions since it does not have a stack PCB continuous
emissions monitoring system. The company reported figures in the Toxic
Release Inventory (TRI) for PCB emissions in 2006 which placed them
number 1 for PCB emissions in the United States.\
\
That figure was 1,933 pounds of airborne releases of PCB\'s. In response
to this figure being exposed in the TRI data filed in the docket of
their application to burn more PCB\'s, the company has submitted new
numbers, revising the number downward to 2.25 pounds, the equivalent of
more than 1 billion micrograms.

**Appendix C**

<http://www.epa.gov/cgi-bin/broker?view=COFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=48&county=48245&chemical=001336363&industry=ALL&year=2006&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro>

![](media/image1.png){width="6.49375in" height="1.625in"}

**Appendix D**

<http://www.einews.com/Subcribers_Only/report/20030828_reportframes.htm>

**An Onyx Mistake?**

The Commission on August 20 approved a penalty of **\$17,600** against
**Onyx Environmental Services, LLC**, for violations at its Port Arthur
hazardous waste incinerator, but Onyx negotiated an agreement under
which it will contribute **\$8,000**, or half, of the penalty to
Jefferson County for its Regional Monitoring Network Program Maintenance
Project. The network includes seven existing air monitoring stations,
three of which monitor ozone and nitrogen oxides (Sabine Pass,
Mauriceville, and the Southeast Texas Regional Airport), and six of
which (West Orange, Beaumont, Port Neches, Cove School, the airport, and
Mauriceville) measure volatile organic compounds.

Onyx was cited for failing to prevent the unauthorized discharge of
contaminates - hydraulic oil from a sweeper - in the parking lot near
the heavy equipment building. Onyx also failed to take precautions at
the bulk feed building during hazardous waste treatment to prevent
reactions and air emissions that produced uncontrolled toxic mist,
fumes, dusts, or gases in sufficient quantities to threaten human health
or the environment. On February 14, 2002, there was an adverse reaction
that produced a vapor cloud and nuisance air condition outside the bulk
feed building and impacted five workers on-site.

**Appendix E**

<http://www.chem.unep.ch/pops/indxhtms/cspcb05.html#Table9>

From:

Management of plychlorinated biphenyls in the US - EPA, Pollution
Prevention and Toxics - 1-30-97

**5.1 Incineration**

Incineration is the standard for PCB destruction, but only where the
system can achieve a 99.9999 percent destruction and removal efficiency
(DRE). Incineration meeting the criteria listed in [Appendix A, Table
A-7](http://www.chem.unep.ch/pops/indxhtms/cspcbapp.html#TableA7) is
considered an established technology for proper disposal of PCBs. The
incineration process treats organic contaminants in solids and liquids,
using high temperatures to volatilize and destroy these compounds. The
incineration process generally consists of waste preparation, a waste
feed mechanism, the combustion stage (e.g., primary and secondary
combustion chambers), bottom and fly ash handling units, air emissions
controls (e.g., wet scrubber), heat exchangers, and exhaust stacks.
Liquid incinerator wastes may require additional wastewater treatment
\[3,22\]. Liquids generally cannot be processed into nonliquid form to
circumvent the high temperature incineration regulatory requirements.

Both stationary and mobile incinerators can be used, and the choice is
often based on cost. Approximately 10 commercial incinerators have been
approved in the U.S. for PCB disposal, and incineration has been used at
approximately 65 hazardous waste sites in the U.S. with PCB-contaminated
soils \[3,22\].

Inorganic constituents (metals) are not destroyed by incinerators, and
thus it is important that the waste stream either not contain metals, or
that wastes containing metals be captured before offgases are released
into the atmosphere. Thus, the metals content of the waste stream must
be adequately characterized when considering incineration systems for
PCB disposal.

*Costs of incineration.* Costs for incineration systems can vary widely,
e.g., from \$200 per ton for a mobile incinerator to as high as \$2,300
for fixed incineration of PCBs \[17\]. Other sources cite incineration
costs for PCBs as approximately \$500 to \$800 per ton for solid waste,
and \$3.25 to \$5.00 per gallon for liquid waste \[22\]. Costs for
incineration used as a PCB remediation (site cleanup) technology may
range from \$280 to \$1,000 per ton \[15\]. Another source cites costs
for remediating PCB-contaminated soils as \$130 to \$600 per ton, and
most commonly costing about \$190 per ton \[22\]. Costs vary depending
on waste characteristics (e.g., heating value, PCB concentration), the
total amount of wastes treated, and moisture. Transportation costs can
add \$100 to \$200 per ton \[17\].

***5.5.2 Chemical Dehalogenation or Dechlorination***

This method uses chemical reactions to remove PCB chlorine atoms from
organic molecules. An example of a chemical dehalogenation process is
\"base-catalyzed decomposition\" (BCD). BCD, usually used as a mobile
technology, is an efficient and relatively inexpensive alternative
technology for treating both PCB-contaminated equipment (e.g.,
transformers) and PCB-contaminated soils and sediments. This method,
properly used and permitted, can be used to declassify PCB-contaminated
electrical equipment \[22\].

Diesel fuel or natural gas is used to heat a primary reactor. Either
sodium hydroxide, sodium bicarbonate, or aliphatic hydrocarbons are used
as hydrogen donors. The presence of metals may affect performance (may
increase the needed amounts of hydrogen). BCD can treat PCBs at almost
any concentration, and laboratory research shows that BCD does not
produce, and can significantly reduce, levels of chlorinated dioxins and
furans. Process residuals can generally be discharged to a publicly
owned treatment works (water and condensate) and to a municipal sewage
sludge plant (decontaminated sludge), after analysis.

It should be noted that some other dehalogenation/dechlorination
processes that use polyethylene glycol are not recommended because of
performance concerns and possible formation of dioxins and furans
\[15\].

*Costs of Dehalogenation/Dechlorination.* Costs for dechlorination range
from \$245 to \$800 \[17\]. Costs of chemical dehalogenation as a
remediation technology range from \$225 to \$580 per ton \[15\].

**Appendix F**

<http://www.epa.gov/pcb/pubs/stordisp.htm#ChemDechlor>

  -----------------------------------------------------------------------
  **Chemical Dechlorination**                           
  ---------------------------------- ------------------ -----------------
  **Company**                        **Address**        **Phone Number**

  \*Environmental Protection         4 Industrial Park  301-232-1590\
  Services, Inc. (formerly SunOhio,  Dr.\               Fax:\
  Inc.)                              P.O. Box 710\      304-232-1599
                                     Wheeling, WV       
                                     26003-0091         

  Clean Harbors (PPM), LLC           1875 Forge Street\ 770-934-0902
                                     Tucker, GA 30084   

  Transformer Disposal Specialists,  P.O. Box 428\      580-628-5371\
  Inc.                               Tonkawa, OK 74653  Fax:\
                                                        580-628-2961

  Clean Harbors (PPM), LLC           Route 3, Box 65\   620-251-6380\
                                     Highway 169 North\ 800-248-0442\
                                     Coffeyville, KS    Fax: 620-251-2822
                                     67377              

  Safety Kleen Oil Recovery Co.      601 Riley Road\    219-397-1131
                                     East Chicago, IN   
                                     46312              
  -----------------------------------------------------------------------

**Appendix G**

<http://www.commodore.com/technologies/set_versatile_alternative.htm>

\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\
**SOLVATED ELECTRON CHEMISTRY\
A VERSATILE ALTERNATIVE FOR WASTE DETOXIFICATION**\
\
**Summary**\
\
\"Commodore Solution Technologies, Inc. has developed an innovative
total systems approach to environmental remediation, which utilizes a
patented (Abel, 1992) chemistry called Solvated Electron Technology (SET
^TM^). Solvated electron solutions are some of the most powerful
reducing agents known. Formed by dissolving alkali and alkaline-earth
metals in anhydrous liquid ammonia to produce a solution of metal
cations and free electrons, solvated electron solutions are capable of
providing unique reductants of great activity. They provide a highly
useful mechanism for the reductive destruction of many organic molecules
and are extremely effective in the dehalogenation of halogenated organic
compounds. Commodore has received a nationwide EPA operating permit for
the non-thermal destruction of PCBs in soils, oils, surfaces and solid
materials using this process. The permit further allows for the recycle
of treated PCB containing oils. The SoLV^TM^ process is a total solution
that incorporates pre- and post- treatments, where necessary, for
environmental clean up. It is applicable to a broad range of substrates
including liquids, solids, soils, personnel protective equipment and job
materials. Commodore has successfully commercialized this technology.
Equipment capable of treating 10 tons a day is currently in the field.
This paper provides an overview of the technology and process.
Individual case studies are available for specific examples where the
process has been utilized.\"\
\
**Introduction**\
\
\"Functional organic compounds have proven to be some of the most
difficult and expensive remediation challenges to face the environmental
clean up industry. As a class, they represent some of the most toxic,
environmentally persistent, and difficult-to-destroy compounds known. In
the environment, materials such as pesticides, PCBs, dioxins, furans,
PAHs, BTXs, explosives, chemical warfare agents, chlorofluorocarbons,
and chlorinated solvents are deemed to pose a hazard to health and the
environment, even when present in relatively small quantities. To meet
today\'s stringent cleanup standards, vast quantities of materials such
as soil, job equipment, adsorbents, process liquids, and building
materials must be treated to remove contaminants that may be present in
quantities measurable only in parts-per-million.\"\
\
\"Other than landfill, commercially available remediation technology
options are limited principally to thermal processes such as
incineration; plasma arc, catalytic extraction, gas phase chemical
reduction, and thermal desorption. These are undesirable due to
generation of off gases such as dioxins. There is a need for a total
system and cost effective remediation approach that can destroy
contaminants while rendering the soil or other matrix materials
non-hazardous.\"\
\
\"The SoLV^TM^ process utilizes solvated electron solutions to destroy
hazardous contaminants. In the process, contaminants are destroyed by a
chemical reduction mechanism, whereby the functional organic compounds
are converted to petroleum hydrocarbons and metal salts. In the case of
a PCB molecule, the halogen atoms are stripped from the halogenated
organic compound and converted to sodium chloride and the carbon
skeleton is converted to high molecular weight hydrocarbons. The
resultant remediated soil can be returned to its original location.\"

\"The application of this versatile chemistry to environmental matrices
has been proven by Commodore to be a cost-effective approach for
addressing environmental remediation issues. Further, the chemistry has
been validated by an independent research group (Mackenzie, 1996).\"\
\
**BACKGROUND ON THE CHEMISTRY**\
\
\"Although the discovery was made in 1865 that sodium metal dissolves in
liquid anhydrous ammonia to form a dark blue solution with some rather
unusual properties, solvated electron solutions still remain an under
utilized phenomenon to most chemists. Yet, solvated electron solutions
are one of the more powerful reducing agents known. Solvated electron
solutions, also referred to as dissolving metal solutions, are formed by
dissolving alkali or alkaline-earth metals, including sodium, calcium,
lithium, and potassium, in anhydrous liquid ammonia.\"\
\
\"Formation of the solvated electron is believed to occur as illustrated
in the following\
\
\
**Process Description**

\"The SoLV^TM^ process is modular in nature. Commodore has developed
several process variations depending on the nature of the material being
remediated. The various modules are designed to be tailored to each
particular remediation site in a manner such that the most
cost-effective sequence is utilized. The SET^TM^ treatment module is the
centerpiece of the process and is a critical component of each process.
[All equipment is **mobile** and able to be placed at the site, which
eliminates the expense of transporting hazardous materials. Space does
not allow the]{.mark} description of all the possible combinations of
these modules. However, they generally include front-end modules that
can remove water or extract the contaminants of interest. Next, the
SET^TM^ treatment module is required to destroy the contaminants. Back
end modules are available to recycle ammonia, pH adjust, concentrate or
fix the reaction products depending on the specific needs of the
client.\"\
\
\"Commodore\'s commercial L1200 liquid unit is shown in Figure I. Such a
setup is applicable to materials like PCBs in oil, liquid pesticides or
extracted contaminates.\"\
\
\"This system consists of a sodium transfer station, which warms sodium
cast in shipping drums to a liquid state, and then pumps the liquid to
the solvator tank. This tank is filled with anhydrous ammonia from an
ammonia storage tank. The sodium dissolves in the ammonia creating a
solvated solution. This solution is discharged to a reactor vessel,
where a volume of approximately 65 gallons of the solvated solution is
maintained.\"

\"Contaminated liquid is pumped to the reactor vessel where organics are
instantly destroyed. The conductivity of the solution in the reactor
vessel is continuously monitored, and when it drops to 200 Mhos feed is
stopped. The destruction reaction is very fast and is essentially
diffusion controlled. Removing ammonia vapor controls the temperature
and pressure of the vessel. This results in lowering the temperature of
the vessel. The feed rate for this system is approximately 1,600 pounds
of material per day.\"\
\
\"After the reaction, the solution is then transferred to the separator
tank using the natural vapor pressure of the ammonia as the motive
force. In the separator, the ammonia is heated to approximately 125o F,
and is pumped in vapor form to a condenser for recycling in the process.
This recycling is performed by a commercial refrigeration subsystem.\"\
\
\"The treated material is discharged to a waste storage vessel. At this
point, hazardous organics have been destroyed, and with pH adjustment,
the product is suitable for on site or non-hazardous disposal.\"\
\
\"Solid materials are processed as-is or first extracted followed by
destruction of the extract in the liquid L1200 unit. When it is
desirable to treat solids as-is, they are placed in a solids screw
reactor (Commodore\'s 10 ton per day S-10 unit, Figure II) in which the
contaminated solid materials and liquid ammonia are mixed. The ammonia
washes the contaminate from the substrate. After a brief period of
additional mixing, sodium metal is added to the ammonia slurry by solid
or molten addition. Electrons are freed from the sodium and they
chemically destroy the contaminants. When the process is complete,
ammonia is retained for re-use, and the treated solid is returned to the
environment. Commodore also has a solids handling unit capable of
treating drum quantities of solids or liquids. This treatment unit is
Commodore\'s S/4 treatment vessel. A photograph of the S/4 is given in
Figure III.\"\
\
\"Wet sludges require a water removal step prior to using SET to destroy
the contaminant. Drying or using a pre-wash module accomplishes water
removal. After the water is removed, the soil can be remediated. The
back-end module involves ammonia removal followed by a simple pH
adjustment. At this stage the material can be disposed in a
non-hazardous waste landfill.\"\
**\
**\
**Oils**\
\
\"Oils such as contaminated transformer and cutting fluids can be
readily detoxified using SET^TM^ in Commodore\'s L-1200 system. This is
a liquid unit, which requires the ability to pump the material to be
treated. Oils containing over 20,000 ppm of PCB have been detoxified to
below 0.5 ppm PCB. Table IV lists data for destruction of PCBs in
oils.\"\
            

**PCBs/ Dioxins**\
\
\"One of the more pressing environmental problems is the remediation of
PCB contaminated soils or sludges. Commodore has completed numerous
treatability studies in house and on site. Only a couple will be
discussed herein.\"\
\
\"A problem at public utilities is that soil can become contaminated
with PCBs near and around transformers. There still are a number of such
sites with this problem in the United States. Table V gives data from a
clean up of soil from a site in New York State. The soil contained
approximately 1200 ppm of PCB (Aroclor 1254) prior to treatment with
SET. After treatment the PCB level was reduced to 1.4 ppm. Small
quantities of PAHs (pyrene, phenanthrene) were also remediated. The
total petroleum hydrocarbons increased, which is what would be expected.
As explained above the major organic product of PCB destruction is high
molecular weight hydrocarbons. After pH adjustment, the soil can be
returned to the site.\"\
            \
**References**\
\
Abel, A. United States Patent 5,110,364, 1992.\
\
Birch, A. J., 1950, Quart. Rev., (London), 4:69\
\
Birch, A. J., Quart. Rev., (London), 12:17.\
\
Chablay, E., 1914, An. Chem., 9:469-519.\
\
Hudson, F. M., 1963, \"A Study of the Reduction of Aromatic Halogenated
Compounds by Alkali Metals in Liquid Ammonia,\" Ph.D. thesis. The
University of Tennessee (University Microfilms 64-7860)\
\
Jolly, W. L., 1965, Advan. Chem. Ser., 50:23.\
\
Kennedy, M. V., Stojanovic, B. J., and Shumman, F. L., 1972, J. Environ.
Qiality, Vol. 1, No. 1, 63-65.\
\
Mackenzie, K., Kopinke, F.K., and Remmier, M., 1996, Chemosphere,
33:1495.\
\
Mohammed, Mohsin1996, \"Solvated Electron Reductions of Aromatic Nitro
Compounds and 2-Chloro ethylsulfide in Ethylenediamine at 116OC,\"
Masters thesis. Mississippi State University.\
\
Vlieger, J. J., Kieboom, P. G., van Bekkum, H., 1986, J.O.C., 51:1389.\
\
Watt, G.W., 1950, Chem. Rev., 46:317.

**\"REPRESENTATIVE EXPERIENCE\"**\
\
\"Commodore has been successful in treating commercial quantities of
mixed waste. For example:\
               \
    \* Treated over 300 tons of PCB-contaminated soils excavated from an
oil-spill site at the Pennsylvania Air National Guard base, located at
the Harrisburg International Airport, utilizing the full-scale S-10
system to reduce PCB levels to \<1ppm.  During the treatment process,
Commodore successfully performed an EPA demonstration of the commercial
system.\
\
    \* Currently treating 20,500 lbs. of mixed radioactive and hazardous
solvent wastes for a contract with American Ecology Recycle Center, Inc.
(AERC), at facilities in Oak Ridge, Tennessee.  The SL-2 SET system is
treating hazardous residues generated during the cleanup of
radioactively contaminated tools, equipment, and other metallic
materials.\
\
    \* Currently working on a contract with the Los Alamos National
Laboratory (LANL) for the destruction of 12,000 lbs. of low-level
contaminated sodium.  Commodore\'s SET process is being used to treat
bulk sodium, converting it to inactive sodium chloride (NaCl).  Trace
amounts of radioactive material, such as Na22, are also being converted
to a salt in the SET process, and the residue can then be land disposed
as low-level radioactive waste.\
\
    \* Treated 10,000 pounds of mixed wastes, everything from sorbent
materials to shredded capacitors, at DOE Weldon Spring Site Remedial
Action Project removing RCRA or TSCA\* regulated materials leaving
low-level radioactive wastes acceptable for on-site disposal.\
\
    \* For a Fortune 500 company, treated drummed material of PCB and
radioactively contaminated hardware, oils, and soils. Removal of the
RCRA contaminants allowed the wastes to be disposed as low level
radioactive wastes.\"

**Clean Air & Water, Inc.**

# A Non-Profit Citizens Environmental Organization

# (Established 1966)

750 Wade Street

Beaumont, Texas 77706

409-892-4964

Mr. Stephen Johnson\
Administrator\
U.S. Environmental Protection Agency\
1200 Pennsylvania Avenue, NW\
Washington, D.C. 20460