PCBs: Consolidated Reporting and Recordkeeping Requirements - 3rd Party Disclosure

GUIDANCE FOR APPLICANTS REQUESTING
TO TREAT/DISPOSE OF PCBS USING
INCINERATION OR AN ALTERNATIVE
METHOD
A WALK-THROUGH OF THE APPLICATION PROCESS

Office of Resource Conservation and Recovery
Office of Land and Emergency Management
U.S. Environmental Protection Agency

October 2019
EPA530-R-19-005

OEPA

Disclaimer
This document is intended to be used as an informal reference, and as such, is not a complete statement
of all applicable polychlorinated biphenyl (PCB) requirements. This document does not replace or
supplant the requirements of the Toxic Substances Control Act (TSCA) PCB regulations. Please refer to
the PCB regulations at 40 CFR part 761 for specific regulatory requirements. Also, as indicated by the
use of non‐mandatory language such as “guidance,” “may,” “should,” and “can,” these materials
identify policies and provide suggestions and do not create any new legal obligations or limit or expand
obligations under any federal, state, tribal, or local law.
Paperwork Reduction Act Notice
The public burden for using this guidance when applying to treat/dispose of PCB waste using
incineration or an alternative method, which is approved under OMB Control No. 2070-0211, is
estimated to average 40 hours per applicant. This average is the combination of reading this guidance
(estimated to be 27.5 hours per applicant) and filling out the checklists in the appendices of this
guidance (estimated to be 12.5 hours per applicant). However, the overall burden on those applying to
treat/dispose of PCB waste using incineration or an alternative method is expected to be reduced
significantly because this guidance will streamline the approval process. This is captured in a separate
ICR, EPA ICR No. 1446.12 (PCBs, Consolidated Reporting and Recordkeeping Requirements found in
docket EPA-HQ-OPPT-2017-0647). This document may be useful for those applying to treat/dispose of
PCB waste using incineration or an alternative method under 40 CFR 761.70 or 40 CFR 761.60(e).
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number.
Those treating/disposing of PCB waste using incineration or an alternative method may submit
documentation in accordance with this guidance, or as specified in the corresponding regulation.
Comments may be submitted to EPA electronically through http://www.regulations.gov or by mail to:
EPA Docket Center, Environmental Protection Agency, Mail Code 28221T, 1200 Pennsylvania Ave.,
NW, Washington, DC 20460. You can also send comments to OMB, addressed to “OMB Desk Officer
for EPA” and referencing OMB Control No. 2070-0211 (EPA ICR No. 2596.01) via email to
oira_submission@omb.eop.gov. Include docket ID No. EPA-HQ-OLEM-2018-0305 and OMB control
number 2070-0211 (EPA ICR No. 2596.01) in any correspondence, but do not submit any other
information (e.g., forms, reports, etc.) to these addresses.
Privacy Act Statement
None of the information collected for the PCB Program regarding this guidance is considered
Personally Identifiable Information (PII) or Confidential Business Information (CBI).

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

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Notice
This guidance document was developed by the U.S. Environmental Protection Agency’s (EPA) Office
of Resource Conservation and Recovery (ORCR) and was funded under EPA Contract No. EP-W-09024 to update and combine two guidance documents (Draft Guidelines for Permit Applications and
Demonstration Test Plans for PCB Incinerators, and Draft Guidelines for Permit Applications and
Demonstration Test Plans for PCB Disposal by Non-Thermal Alternative Methods). For questions about
this guidance document, please contact ORCRPCBs@epa.gov or refer to EPA’s Regional and
Headquarters PCB contact information on EPA’s PCB website at www.epa.gov/pcbs/program-contacts.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

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Section

TABLE OF CONTENTS

Page

List of Figures .................................................................................................................................... vii
List of Tables ...................................................................................................................................... vii
Acronyms and Abbreviations ............................................................................................................. ix
Glossary .............................................................................................................................................. xii
1 Introduction ......................................................................................................................................1
1.1
Benefits of this Guidance ........................................................................................... 1
1.2
Organization and How to Use .................................................................................... 2
2 Summary of Relevant 40 CFR part 761 Regulations ....................................................................4
2.1
General ......................................................................................................................... 4
2.2
Approval Authority ..................................................................................................... 4
2.3
Incinerators .................................................................................................................. 6
2.3.1
Liquid PCBs ................................................................................................................ 6
2.3.2
Non-liquid PCBs ......................................................................................................... 7
2.3.3
Maintenance of Data and Records ............................................................................. 8
2.3.4
Approval of Incinerators ............................................................................................. 8
2.4
Alternative Methods of Disposal ............................................................................... 8
2.4.1
Alternative Thermal Destruction Technologies ........................................................ 9
2.4.2
Alternative Non-Thermal Destruction/Removal Technologies ............................... 9
2.5
Other Regulations ....................................................................................................... 9
2.5.1
High Efficiency Boilers .............................................................................................. 9
2.5.2
Scrap Metal Recovery Ovens and Smelters ............................................................ 10
3 Basic Approval Procedures for the Treatment/Disposal of PCBs Using Incineration or
an Alternative Technology ............................................................................................................11
3.1
Establish Communications with the EPA Approval Writer ................................... 11
3.2
Research and Development ...................................................................................... 11
3.3
Submittal of Operating Approval Application and Test Plan ................................ 13
3.4
EPA Review of Operating Approval Application and Test Plan ........................... 13
3.5
EPA Approval of Test Plan ...................................................................................... 14
3.6
Conducting a Test ..................................................................................................... 14
3.7
Submittal of Test Report........................................................................................... 14
3.8
EPA Review of the Test Report ............................................................................... 14
3.9
EPA Issues an Operating Approval ......................................................................... 15
4 Contents of Operating Approval Application ..............................................................................16
4.1
Preliminary Steps to an Approval Application ....................................................... 16
4.1.1
Early Communication ............................................................................................... 16
4.1.2
Criteria ....................................................................................................................... 16
4.1.3
Other Important Information for Development of an Approval Application........ 18
4.1.4
Research and Development Applications ................................................................ 19
4.1.5
Submitting Confidential Business Information (CBI) ............................................ 20
4.1.6
Mobile Treatment Applications ............................................................................... 21
4.2
Contents of an Operating Approval Application .................................................... 21
4.2.1
Transmittal Letter...................................................................................................... 21
4.2.2
Cover Page ................................................................................................................ 22
4.2.3
Approval Application Section I - Summary ............................................................ 24
4.2.4
Approval Application Section II - Company
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Organization/Structure/Personnel ....................................................................... 24
Approval Application Section III - Waste Description .......................................... 25
Approval Application Section IV - Process Engineering Description .................. 25
General Information .................................................................................................. 25
Waste Feed System ................................................................................................... 26
Automatic Waste Feed Cutoff System .................................................................... 26
PCB Destruction/Removal System .......................................................................... 27
Pollution Control System ......................................................................................... 29
Compendium of All Process Operating Parameters ............................................... 30
Approval Application Section V - Monitoring and Sampling Plan ....................... 30
Monitoring and Sampling Plan for Incineration and Alternative Thermal
Destruction Technologies .................................................................................... 32
4.2.7.2 Monitoring and Sampling Plan for Alternative Non-Thermal
Destruction/Removal Technologies .................................................................... 41
4.2.8
Approval Application Section VI - Monitoring Procedures .................................. 45
4.2.9
Approval Application Section VII - Sampling and Analysis Procedures ............. 45
4.2.10
Approval Application Section VIII - Data Recordkeeping and Reporting ........... 46
4.2.11
Approval Application Section IX - By-Product Waste Handling and
Treatment/Disposal .............................................................................................. 47
4.2.12
Approval Application Section X - Inspection Procedures ..................................... 47
4.2.13
Approval Application Section XI - Spill Prevention, Control, and
Countermeasures Plan .......................................................................................... 47
4.2.14
Approval Application Section XII - Safety Plan .................................................... 48
4.2.15
Approval Application Section XIII - Training Plan ............................................... 49
4.2.16
Approval Application Section XIV - Test Plan Summary ..................................... 50
4.2.17
Approval Application Section XV - Test Data or Engineering Performance
Calculations .......................................................................................................... 50
4.2.18
Approval Application Section XVI - Other Permits and Approvals ..................... 50
4.2.19
Approval Application Section XVII - Schedule of Events .................................... 51
4.2.20
Approval Application Section XVIII - Quality Assurance Project Plan ............... 51
4.2.21
Approval Application Section XIX - Standard Operating Procedures .................. 53
4.2.22
Approval Application Section XX - Closure Plan .................................................. 53
4.3
Financial Assurance Documentation ....................................................................... 54
4.3.1
Closure Financial Assurance .................................................................................... 54
4.3.2
Third Party Liability Financial Assurance .............................................................. 56
4.3.3
Maintenance of Financial Assurance ....................................................................... 56
4.3.4
Release of Financial Assurance Obligation............................................................. 56
4.3.5
Transfer of Ownership or Operational Control ....................................................... 57
5 Test Plans.......................................................................................................................................58
5.1
General ....................................................................................................................... 58
5.1.1
The Purpose of the Test and General Approach ..................................................... 59
5.2
Contents of a Test Plan ............................................................................................. 60
5.2.1
Test Plan Section I - Summary................................................................................. 61
5.2.2
Test Plan Section II - Project Organization ............................................................. 63
5.2.3
Test Plan Section III - Treatment Process and Facility Information ..................... 63
5.2.4
Test Plan Section IV - Operating Parameters.......................................................... 63
5.2.5
Test Plan Section V - Monitoring and Sampling Plan ............................................ 66
4.2.5
4.2.6
4.2.6.1
4.2.6.2
4.2.6.3
4.2.6.4
4.2.6.5
4.2.6.6
4.2.7
4.2.7.1

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5.2.5.1

Pollutants and Parameters to be Monitored/Sampled during Tests for
Incinerators or Alternative Thermal Destruction Technologies ........................ 68
5.2.5.2 Pollutants and Parameters to be Monitored/Sampled during Tests for
Alternative Non-Thermal Destruction/Removal Technologies ........................ 69
5.2.6
Test Plan Section VI - Monitoring Procedures ....................................................... 70
5.2.7
Test Plan Section VII - Sampling and Analysis Procedures .................................. 70
5.2.8
Test Plan Section VIII - Emergency Procedures .................................................... 72
5.2.9
Test Plan Section IX - Test Data Reporting ............................................................ 72
5.2.10
Test Plan Section X - Miscellaneous Tests ............................................................. 73
5.2.11
Test Plan Section XI - Waste Handling and Disposal ............................................ 73
5.2.12
Test Plan Section XII - Test Schedule ..................................................................... 73
5.2.13
Test Plan Section XIII - Quality Assurance Project Plan ....................................... 75
5.2.14
Test Plan Section XIV - Standard Operating Procedures ....................................... 76
6 Conducting and Monitoring a Test ...............................................................................................77
6.1
Expected Responsibilities During the Test ............................................................. 77
6.1.1
EPA’s Role ................................................................................................................ 77
6.1.2
The Facility’s Role .................................................................................................... 78
6.2
Preparing for the Test ............................................................................................... 78
6.3
Three Phases of a Test .............................................................................................. 79
6.3.1
Phase I: Start-up of the Treatment/Disposal Unit ................................................... 79
6.3.2
Phase II: Treatment/Disposal of PCB Waste .......................................................... 80
6.3.3
Phase III: Shutdown of the Treatment/Disposal Unit ............................................. 80
6.4
Completed Test ......................................................................................................... 80
6.4.1
An Acceptable Test ................................................................................................... 81
6.4.2
Failed Test ................................................................................................................. 81
7 Test Report .....................................................................................................................................82
7.1
General ....................................................................................................................... 82
7.2
Contents of Test Reports .......................................................................................... 83
7.2.1
Transmittal Letter...................................................................................................... 83
7.2.2
Cover Page ................................................................................................................ 83
7.2.3
Certification Letter .................................................................................................... 84
7.2.4
Test Report Section I - Summary............................................................................. 84
7.2.5
Test Report Section II - Process Operation ............................................................. 84
7.2.5.1 General Process Operation Information .................................................................. 84
7.2.5.2 Pollutants and Parameters Monitored/Sampled during Tests for Incinerators
or Alternative Thermal Destruction Technologies ............................................. 87
7.2.5.3 Pollutants and Parameters Monitored/Sampled during Tests for Alternative
Non-Thermal Destruction/Removal Technologies ............................................ 88
7.2.5.4 Deviations from the Test Plan .................................................................................. 89
7.2.6
Test Report Section III - Test Results...................................................................... 89
7.2.7
Test Report Section IV - Monitoring and Sampling Procedures ........................... 90
7.2.8
Test Report Section V - Analytical Procedures ...................................................... 90
7.2.9
Test Report Section VI - Quality Assurance Summary .......................................... 91
7.2.10
Test Report Section VII - Visits and Audits ........................................................... 91
7.2.11
Test Report Section VIII - Waste Handling and Disposal ..................................... 91
7.2.12
Appendices ................................................................................................................ 91
7.3
EPA Review of the Test Report ............................................................................... 92
7.3.1
Criteria for Evaluating Test Results......................................................................... 92
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7.3.2
Deficiencies in the Test Report ................................................................................ 93
7.3.3
Incomplete or Failed Test ......................................................................................... 93
8 Approval Issuance and Renewal ...................................................................................................95
8.1
Public Comment and Public Participation............................................................... 95
8.2
Operating Approval Contents................................................................................... 95
8.2.1
Mobile vs. Fixed-Site Disposal Approvals.............................................................. 96
8.2.2
Compliance under an Operating Approval .............................................................. 96
8.2.3
Approval Modifications ............................................................................................ 97
8.3
Approval Renewal and Expiration ........................................................................... 97
8.4
Approval Termination .............................................................................................. 98
9 References ......................................................................................................................................99
Appendix A: Sources for Additional Information ......................................................................... 100
Appendix B: Checklists for Completeness of Submittal ............................................................... 111
Appendix C: Monitoring, Sampling, and Analysis Procedures .................................................... 119
Appendix D: Quality Assurance Project Plan Template ............................................................... 133
Appendix E: Cleanup, Extraction, and Determinative Methods for PCB Aroclors,
Homologs, and Congeners ......................................................................................................... 146
Appendix F: Example Checklists for Thermal and Non-Thermal Technologies for Use
During the Test ............................................................................................................................ 150
Appendix G: PCB Aroclors, Homologs, and Congeners .............................................................. 154

Figure
1.
2.
3.
4.
5.
6.
7.

6.
7.
8.
9.

Page

Major Steps in the Operating Approval Process .................................................................... 12
Approval Application Cover Page Example .......................................................................... 23
Example Schematic of Monitoring and Sampling Points for an Incinerator ....................... 34
Example Schematic of Monitoring and Sampling Points for a Thermal Desorber Unit ..... 37
Example Schematic of Monitoring and Sampling Points for a Chemical Dechlorination
Process.................................................................................................................................... 42
Test Plan Cover Page Example ............................................................................................... 62
Test Report Cover Page Example ........................................................................................... 85

Table
1.
2.
3.
4.
5.

LIST OF FIGURES

LIST OF TABLES

Page

Summary of Relevant Approval Authorities ............................................................................ 5
Suggested Format for an Approval Application .................................................................... 22
Example Summary of Monitoring Parameters for Incinerators ............................................ 35
Example Summary of a Sampling Plan for Incinerators ....................................................... 36
Example Summary of Monitoring Parameters for an Alternative Thermal Destruction
Technology ............................................................................................................................ 38
Example Summary of a Sampling Plan for an Alternative Thermal Destruction
Technology ............................................................................................................................ 40
Example Summary of Monitoring Parameters for a Chemical Dechlorination Process ..... 43
Example Summary of a Sampling Plan for a Chemical Dechlorination Process ................ 44
Suggested Format for a Test Plan ........................................................................................... 61

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10.
11.
12.
13.
14.
15.
16.
A-1.
B-1.
B-2.
B-3.
B-4.
C-1.
E-1.
E-2.
E-3.
F-1.
F-2.
G-1.
G-2.
G-3.

Example Summary of Test Parameters for an Incinerator .................................................... 65
Example Summary of Test Parameters for a Batch Chemical Dechlorination Process ...... 66
Example: Proposed Schedule for an Incineration Test .......................................................... 74
Example: Proposed Schedule for an Alternative Method of Treatment/Disposal Test ....... 75
Suggested Format for the Test Report .................................................................................... 83
Example Test Results Summary for Incinerator or Alternative Thermal Destruction
Technology ............................................................................................................................ 86
Example Test Results Summary for an Alternative Non-Thermal Destruction/Removal
Technology ............................................................................................................................ 87
Outline of 40 CFR 761 .......................................................................................................... 101
Example Approval Application Checklist for Thermal and Non-Thermal Methods ........ 113
Example Checklist for a Test Plan ........................................................................................ 116
Example Monitoring and Sampling Parameter Summary to be included in Test Plans
for Incinerators or Alternative Thermal Destruction Process ........................................... 117
Example Monitoring and Sampling Parameter Supplement for an Alternative NonThermal Destruction Process .............................................................................................. 118
Summary of Standard Stack Sampling/Monitoring Methods ............................................. 124
Summary of Extraction Methods for PCB Samples ............................................................ 147
Summary of Cleanup Methods for PCB Samples................................................................ 148
Summary of Analytical Methods for PCB Samples ............................................................ 148
Example Checklist for Thermal Alternative Methods for Use During the Test ................ 151
Example Checklist for Non-Thermal Alternative Methods for Use During the Test........ 153
List of PCB Aroclors ............................................................................................................. 156
List of PCB Homologs........................................................................................................... 157
List of PCB Congeners .......................................................................................................... 158

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ACRONYMS AND ABBREVIATIONS
µg
µg/L
°C
°F
ACFM
ACM
APCD
ASTM
Atm
ATSDR
Btu
CAA
CARB
CASRN
CB
CBI
CCS
CE
CEMS
CFM
CFR
CGC
cm
CO
CO2
CPR
CWA
Demo
DOE
DOI
DOT
DQO
DRE
dscf
dscm
ECD
EIMS
ELCD
EPA
ESA
ESP
FID
g
GC
GC/ECD

Microgram
Micrograms per liter
Degrees Celsius
Degrees Fahrenheit
Actual cubic feet per minute
Actual cubic meter
Air pollution control device
American Society for Testing and Materials
Atmosphere
Agency for Toxic Substances and Disease Registry
British thermal unit
Clean Air Act
California Air Resources Board
Chemical abstracts service registry number
Calibration blank
Confidential business information
Calibrated check standard
Combustion efficiency
Continuous emissions monitoring systems
Cubic feet per minute
Code of Federal Regulations
Capillary gas chromatography
Centimeter
Carbon monoxide
Carbon dioxide
Cardiopulmonary resuscitation
Clean Water Act
Demonstration
Department of Energy
Digital object identifier
Department of Transportation
Data quality objective
Destruction and removal efficiency
Dry standard cubic feet
Dry standard cubic meter
Electron capture detector
Electron impact mass spectrometry
Electrolytic conductivity detector
U.S. Environmental Protection Agency
Endangered Species Act
Electrostatic precipitator
Flame ionization detector
Grams
Gas chromatography
Gas chromatography/Electron capture detector

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GC/FID
GC/MS
GPC
gpm
gr
HAP
HAZWOPER
HCl
HCl/Cl2
HPLC
HQ
HRGC
HRMS
ID
IERL
in H2 O
IR
IRM
IUPAC
kg
L
LCS
LOC
LRMS
m
MACT
MB
mg
mg/L
mm Hg
mm
MODEF
MS
NA
NAA
ND
NDIR
NESHAP
NHPA
NIOSH
NMR
NOx
NPDES
NRC
NTIS
O2
OLEM
ORCR

Gas chromatography/Flame ionization detector
Gas chromatography/Mass spectrometry
Gel permeation chromatography
Gallon per minute
Grains
Hazardous air pollutants
Hazardous Waste Operations and Emergency Response
Hydrochloric acid
Hydrogen chloride/chlorine
High performance liquid chromatography
Headquarters
High resolution gas chromatography, also termed capillary GC
High resolution mass spectrometry
Inner diameter
Industrial Environmental Research Laboratory
Inches of water
Infrared
Information Resource Management
International Union of Pure and Applied Chemistry
Kilogram
Liter
Laboratory control sample
Level of chlorination
Low resolution, electron ionization mass spectrometry
Meter
Maximum Achievable Control Technology
Method blank
Milligram
Milligrams per liter
Millimeters of mercury
Millimeter
Mineral oil dielectric fluid
Mass spectrometry
Not applicable
Neutron activation analysis
Not detected
Nondispersive infrared
National Emission Standards for Hazardous Air Pollutants
National Historic Preservation Act
National Institute for Occupational Safety and Health
Nuclear magnetic resonance
Oxides of nitrogen
National Pollutant Discharge Elimination System
Nuclear Regulatory Commission
National Technical Information Service
Oxygen
Office of Land and Emergency Management
Office of Resource Conservation and Recovery, an office within OLEM

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OSHA
PAH
PCB
PCDD
PCDF
PCS
PD
PDF
PE
PGC
pH
PM
POHC
ppb
PPE
ppm
ppq
ppt
psi
PT
QA
QAPP
QC
R&D
RCRA
RIA
RIS
RPD
RTD
SCFM
SDS
SIM
SIS
SOP
SORS
SPCC
SVOC
SW
TBD
TCDD
TCDF
TEQ
TLC
TSCA
VOC
VOST

Occupational Safety and Health Act
Polycyclic aromatic hydrocarbons
Polychlorinated biphenyl(s)
Polychlorinated dibenzo-p-dioxin
Polychlorinated dibenzofuran
Pollution control system
Percent difference
Portable document format
Performance evaluation
Packed column gas chromatography
Measure of acidity or alkalinity
Particulate matter
Principal organic hazardous constituent
Parts per billion
Personal protective equipment
Parts per million
Parts per quadrillion
Parts per trillion
Pounds per square inch
Proficiency testing
Quality assurance
Quality assurance project plan
Quality control
Research and development
Resource Conservation and Recovery Act
Radioimmunoassay
Recovery internal standards
Relative percent difference
Resistance-thermal detector
Standard cubic feet per minute
Safety data sheet
Selective ion monitoring
Surrogate internal standard
Standard operating procedures
Stop operations/repair system
Spill prevention, control, and countermeasure
Semi-volatile organic compound
Solid waste
To be determined
Tetrachlorodibenzodioxin
Tetrachlorodibenzofuran
Toxic equivalent
Thin layer chromatography
Toxic Substances Control Act
Volatile organic compounds
Volatile organic sampling train

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GLOSSARY
As used in this document, all terms not defined herein have the meaning given to them in the Toxic
Substances Control Act (TSCA), 15 U.S.C. 2601 et seq., and 40 Code of Federal Regulations (CFR) part
761.
Accuracy
The degree of agreement between an observed value and an accepted reference value. Accuracy
includes a combination of random error (precision) and systematic error (bias) components that are
due to sampling and analytical operations. Accuracy is monitored through the analysis of quality
control (QC) samples.
Administrator
See definition in 40 CFR 761.3.
Agency
See definition in 40 CFR 761.3.
Analyte
Chemical compound or element that is the subject of an analysis.
Approval
A written authorization issued by Environmental Protection Agency (EPA) to implement the
requirements of 40 CFR part 761. An approval incorporates applicable requirements in TSCA and
the polychlorinated biphenyl (PCB) regulations, 40 CFR part 761, and establishes specific
administrative, safety, and technical standards to which owners and operators of a treatment unit
must adhere in order to legally treat PCB waste. An approval may be a test plan approval or an
operating approval. This term is synonymous with “permit.”
Aroclor
A commercial mixture of PCBs previously manufactured by Monsanto. Aroclor is one of the most
commonly known trade names for PCB mixtures. There are many types of Aroclors and each has a
distinguishing suffix number that indicates the degree of chlorination. The numbering standard for
the different Aroclors is as follows: The first two digits are usually “12,” which represents a
1200 series product as designated by Monsanto. A 1200 series PCB product is a refined PCB
product usually derived from the 1100 series crude PCBs. The second two numbers indicate the
percentage of chlorine by mass in the mixture. For example, the name Aroclor 1254 means that the
mixture contains approximately 54% chlorine by weight. See Appendix G for a complete list of
Aroclors.

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Combustion Efficiency (CE)
A ratio of the actual combustion relative to complete combustion of a fuel.

Where,

𝐶𝐶𝐶𝐶 = �

𝐶𝐶𝐶𝐶𝐶𝐶2
� × 100
𝐶𝐶𝐶𝐶𝐶𝐶2 + 𝐶𝐶𝐶𝐶𝐶𝐶

𝐶𝐶𝐶𝐶𝐶𝐶2 = Concentration of carbon dioxide, and 𝐶𝐶𝐶𝐶𝐶𝐶 = Concentration of carbon monoxide.

Comparability
A measure of the confidence with which one data set can be compared to another. This is a
qualitative assessment and is addressed primarily in sampling design through the use of comparable
sampling procedures or, for monitoring programs, through accurate re-sampling of stations over
time. In the laboratory, comparability is assured through the use of comparable analytical procedures
and ensuring that project staff are trained in the proper application of the procedures.
Completeness
The amount of data collected as compared to the amount needed to ensure that the uncertainty or
error is within acceptable limits. The goal for data completeness is 100%.
Congener
For PCBs, any single, unique, well-defined chemical compound in the PCB category. The name of a
congener specifies the total number of chlorine substituents, and the position of each chlorine. For
example, 4,4'-dichlorobiphenyl is a congener comprising the biphenyl structure with two chlorine
substituents, one on each of the #4 carbons of the two rings.
Altogether, there are 209 individual PCB congeners having the molecular formula C12H nCl10-n,
where n = 0-9. This definition includes monochlorobiphenyls. See Appendix G for a complete list of
congeners.
Continuous Emissions Monitor (CEM)
An emissions measurement system that is in continuous operation except for system breakdowns,
repairs, calibration checks, and zero and span adjustments. See 40 CFR part 60, Appendix C for
additional details.
Demonstration (Demo) Test
A trial to evaluate the systems performance and compliance with applicable regulations, and to
establish operating limits; commonly called a trial burn for incinerators. May be referred to simply
as “test.” A complete demonstration test or trial burn typically requires three test runs. See section 6
for more information.

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Destruction and Removal Efficiency (DRE)
EPA's principle measure of incinerator performance. A 99.9999 percent DRE means that one
molecule of an organic compound is released to the air for every million molecules entering the
incinerator. For PCBs, DRE is calculated using the following formula:
𝑊𝑊𝑖𝑖𝑖𝑖 − 𝑊𝑊𝑜𝑜𝑜𝑜𝑜𝑜
� × 100
𝐷𝐷𝐷𝐷𝐷𝐷 = �
𝑊𝑊𝑖𝑖𝑖𝑖
Where,
𝑊𝑊𝑖𝑖𝑖𝑖 = mass feed rate of PCBs in the waste stream feeding the incinerator, and
𝑊𝑊𝑜𝑜𝑜𝑜𝑜𝑜 = mass emission rate of PCBs present in exhaust emissions prior to release to the
atmosphere.

Disposal
See definition in 40 CFR 761.3.

Dioxin
This is the abbreviated or short name for a family of substances that all share a similar chemical
structure; tetra-, penta-, hexa-, hepta-, and octa-chlorinated dibenzo dioxins. During certain PCB
treatment/disposal processes it is possible to form dioxin byproducts.
Facility
See definition in 40 CFR 761.3.
Furan
This is the abbreviated or short name for a family of substances that all share a similar chemical
structure; tetra-, penta-, hexa-, hepta-, and octa-chlorinated dibenzo furans. During certain PCB
treatment/disposal processes it is possible to form furan byproducts.
Gas Residence Time
The time that combustion gas spends in the destruction zone (area of combustion chamber with the
temperature equal to or above that required by the regulations); calculated by dividing the
destruction zone volume by the volumetric flow rate at the exit (actual pressure and temperature
conditions).
High Resolution Gas Chromatography
Gas-liquid chromatography performed using a capillary column, typically 10-50 meters (m) long x
0.2 millimeter (mm) inner diameter (ID), coated on the interior with a liquid phase.
Homolog
Subcategories of PCB congeners that have equal numbers of chlorine substituents. For example, the
tetrachlorobiphenyls are all PCB congeners with exactly 4 chlorine substituents that can be in any
arrangement. Altogether, there are 10 homologs. See Appendix G for competed list of homologs.
Isomer
Any compound that has the same molecular formula, but different positional substitutions. For
example, for PCBs, 2,2’-dichlorobiphenyl and 2,3-dichlorobiphenyl are isomeric; 4-chlorobiphenyl
and 2,3,4-trichlorobiphenyl are not.

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Liquid
A substance that has a melting point less than 20°C and does not pass the structural integrity test
(> 15% free liquid content).
Liquid PCBs
See definition in 40 CFR 761.3.
Mass Spectrometry (MS)
An analytical technique that ionizes chemical species and sorts the ions based on their mass-tocharge ratio. In simpler terms, a mass spectrum measures the masses within a sample.
Matrix(ces)
The component, or components, of a sample other than the analyte of interest. For example, this
includes but is not limited to non-PCB components of dielectric fluid, soil, or sludge.
Method
A series of techniques or procedures that form a specific, well-defined sampling, chemical analysis,
or other procedure for a specified compound(s)/matrix(ces) combination. See SW-846 for EPA
developed test methods.
Method 0010
A method that outlines the emissions sampling procedure used to determine organic concentrations
in stack emissions, including PCBs and Principal Organic Hazardous Constituents (POHCs). These
emission levels can then be used to calculate Destruction and Removal Efficiency (DRE) of semivolatile POHCs, including PCBs, from incineration systems.
Method 23/0023A
A method that outlines the procedure used for determining stack emissions of polychlorinated
dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) from stationary sources.
Method 3540
A method that outlines the procedure used for extracting nonvolatile and semi-volatile organic
compounds from solids such as soils, sludges, and wastes. The Soxhlet extraction process ensures
intimate contact of the sample matrix with extraction solvent.
Method 3550C
A method that outlines the procedure used for extracting nonvolatile and semi-volatile organic
compounds from solids such as soils, sludges, and wastes. The ultrasonic process ensures intimate
contact of the sample matrix with the extraction solvent.
Method 8082A
A method describing the procedure used to determine the concentrations of PCBs as Aroclors or as
individual PCB congeners in extracts using open-tubular, capillary columns with electron capture
detectors (ECDs) or electrolytic conductivity detectors (ELCDs). This method also includes
extraction method recommendations for various sample matrices.

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National Emission Standards for Hazardous Air Pollutants (NESHAP)
National Emission Standards for Hazardous Air Pollutants (NESHAP) for stationary sources of
hazardous air pollutants (HAP) are issued pursuant to Clean Air Act (CAA) Section 112(d). This
provision requires EPA to promulgate regulations establishing emission standards for major sources
and area sources of Hazardous Air Pollutants (HAPs) listed pursuant to CAA Section 112(c). EPA
has identified hazardous waste combustors as major sources of HAP emissions and, consistent with
the requirements of CAA Section 112(d), requires hazardous waste combustors to meet HAP
emission standard reflecting the performance of the maximum available control technology
(MACT). The NESHAP for Hazardous Waste Combustors are codified in 40 CFR Part 63 Subpart
EEE.
Non-liquid PCBs
See definition in 40 CFR 761.3.
Normal Operations / Day-to-Day Operations
Everyday operations of a PCB treatment or disposal unit under specific conditions and processes as
described in the facility’s operating PCB approval. This would not include operating the unit to treat
non-PCB-regulated waste or during the demonstration test or trial burn.
Operator
The person responsible for the operation of a facility, part of a facility, a treatment unit, or the
property the treatment unit stands upon.
Owner
The person who owns a facility, part of a facility, a treatment unit, or the property the treatment unit
stands upon.
Packed Column Gas Chromatography (PGC)
Gas-liquid chromatography performed using a column, typically 180 centimeters (cm) long x 2
millimeters (mm) ID, packed with a liquid phase on a granular solid support material. Review the
method being utilized for more detailed parameters required to conduct gas chromatography (GC).
Parts Per Billion (ppb)
One part per 1,000,000,000 parts. Also see part per million (ppm).
Parts Per Million (ppm)
One part per 1,000,000 parts. For gaseous mixtures, a volume/volume (v/v) basis is typically used
and:
𝑚𝑚𝑚𝑚 𝑅𝑅𝑅𝑅
𝑝𝑝𝑝𝑝𝑝𝑝 = 3 ×
𝑀𝑀𝑀𝑀
𝑚𝑚
Where,
𝑅𝑅𝑅𝑅 (at 0°C and 1 atm) = 22.4 liter/g-mole,
𝑅𝑅𝑅𝑅 (at 25°C and 1 atm) = 24.5 liter/g-mole, and
𝑀𝑀𝑀𝑀 = molecular weight of compound, g/g-mole.

For low concentration aqueous samples, a weight/volume (w/v) basis is most commonly used, where
1 ppm = 1 mg/L. A weight/weight (w/w) basis may also be used for aqueous samples, where
1 ppm = 1 mg/kg (assuming a liquid density of 1 kg/L).

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For nonaqueous liquids and solid materials, a weight/weight (w/w) basis is most commonly used,
where 1 ppm = 1 mg/kg.
PCB(s)
See definition in 40 CFR 761.3.
PCB Item
See definition in 40 CFR 761.3.
Percent Recovery
The percent recovery is a measurement of accuracy, where one value is compared with a
known/certified value. The formula for calculating this value is:
𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 =

𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑
× 100
𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒

Performance Evaluation (PE) Sample
PE samples, also known as proficiency testing (PT) samples, are samples of known concentration
provided to the facility by EPA for analysis. The laboratory is required to analyze the PE samples
according to the appropriate method and report the result of the PE sample analysis. These results
are evaluated by EPA personnel for accuracy of analytical results based on known concentration in
the PE sample. PE samples should be representative of the types of samples that would be routinely
analyzed if an approval is granted to the facility.
Polychlorinated Biphenyl (PCB)
See definition in 40 CFR 761.3.
Precision
A measure of agreement among a set of observations or measurements of the same property,
obtained under similar conditions. Precision is usually expressed as standard deviation, variance,
relative percent difference, or range, in either absolute or relative terms. Precision is monitored
through the analysis of QC samples.
Principal Manager
The person responsible for the overall operation of a PCB treatment/disposal unit and typically the
primary contact for EPA.
Quality Assurance (QA)
A system for integrating the quality planning, quality assessment, and quality improvement efforts to
meet user requirements.
Quality Assurance Project Plan (QAPP)
A document that describes how quality assurance (QA) and quality control (QC) will be conducted
and applied to assure that the results obtained are of the type and quality needed and expected.

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Quality Control (QC)
The routine application of procedures for obtaining prescribed standards of performance in the
monitoring and measurement process.
QC Blank
A sample processed and analyzed to obtain background concentrations of the analyte(s).
Relative Percent Difference
The relative percent difference (RPD) is a measurement of precision; it is a comparison of two
similar samples (matrix spike/matrix spike duplicate pair, field sample duplicates). The formula for
calculating RPD is:

where:

𝑅𝑅𝑅𝑅𝑅𝑅 = �

X1 is concentration in sample 1
X2 is concentration in sample 2

2 × (𝑋𝑋1 − 𝑋𝑋2 )
� × 100
(𝑋𝑋1 + 𝑋𝑋2 )

Representative Sample
A sample which, to the greatest extent possible, exhibits the average characteristics of the whole
population.
Representativeness
The degree to which data accurately and precisely reflects the average characteristics of the whole
population. This is a qualitative assessment and is addressed primarily in the sample design and
procedures that reflect the project goals and processes being sampled. It is ensured in the laboratory
through (1) the proper handling, homogenizing, compositing, and storage of samples and (2) analysis
within the specified holding times so that the material analyzed reflects the material collected as
accurately as possible.
Residence Time
The average amount of time spent in a control volume by the particles of a fluid. In the context of
this document, for total residence time, the control volume is the PCB treatment train. For reactor
residence time, the control volume is the reactor where PCB destruction takes place.
Shakedown
A pre-test or set of pre-tests designed and conducted to achieve a state of operational readiness
necessary to conduct the trial burn or demonstration test. PCBs should not be introduced to the unit
during the shakedown period.
Solid
A substance is a solid if its melting point is greater than 20°C and it passes the structural integrity
test (> 15% free liquid content).
SW-846
See definition in 40 CFR 761.3.
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Test
This is a general term used to refer to a demonstration test, a trial burn or both. For example,
statements that include “trial burn/demonstration test plan” or “trial burn/demonstration test
approval” will be referred to as either “test plan” or “test approval.”
Test Run
A full-scale run-through of a PCB treatment/destruction system where PCB waste is introduced to
the unit and the unit processes the waste at conditions typically specified in a test approval until the
PCBs are either destroyed or removed from the media. A test run demonstrates destruction or
removal of PCBs from the media to an acceptable level in a single run-through. A complete
demonstration test or trial burn typically requires three test runs. An incomplete test run may occur
when unforeseen circumstances, e.g., a power outage, prevents the facility from completing that test
run. This typically would invalidate the run, and likely result in the need to repeat the test run. A
failed test run may occur when the facility is unable to achieve acceptable treatment levels in the
media. See section 6 for more information.
Toxic Equivalency (TEQ)
This is the international method of expressing toxicity equivalence for dioxins and furans as defined
in U.S. EPA, Interim Procedures for Estimating Risks Associated with Exposures to Mixtures of
Chlorinated Dibenzo-p-dioxins and -dibenzofurans (CDDs and CDFs), 1989. See 40 CFR 63.1201.
Treatment
Treatment is a subset of disposal as defined in 40 CFR 761.3. Specifically, treatment falls under the
actions related to destroying, degrading, decontaminating, or confining PCBs and PCB Items.
Trial Burn
A trial to evaluate an incinerator’s performance and compliance with applicable regulations, and to
establish operating limits; commonly called a demonstration test for alternative destruction
technologies. May be referred to simply as “test.” A complete demonstration test or trial burn
typically requires three test runs. See section 6 for more information.
TSCA Non-Thermal Destruction/Removal Technologies
A device which does not use elevated temperatures as the primary means to reduce the concentration
of or remove PCBs from PCB waste. These include, but are not limited to, mechanical-chemical
destruction, catalytic hydrogenation, and chemical dechlorination. These processes are typically
different from thermal destruction technologies. Also, there are a variety of types of non-thermal
destruction technologies and they generally operate differently from each other.
TSCA Thermal Destruction Technologies
A device which uses elevated temperatures as the primary means to reduce the concentration of or
remove PCBs from PCB waste. These include, but are not limited to, incinerators, infrared
incinerators, fluidized beds, fluidized circulating beds, scrap metal recovery ovens, high efficiency
boilers, and thermal desorbers. Since most thermal technologies employ high temperature
destruction of PCBs, these processes typically have similar requirements, such as air emissions
monitoring.

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SECTION 1
INTRODUCTION
Part 761 in Title 40 of the Code of Federal Regulations (40 CFR part 761) establishes rules on the
manufacture, processing, distribution in commerce, use, disposal, storage, and marking of
polychlorinated biphenyls (PCBs) and PCB Items. 1 Under these rules, persons (defined at 40 CFR
761.3) disposing of regulated PCBs are required to use approved methods and, in some cases, obtain an
approval. 2
PCB wastes may be disposed of in incinerators that comply with § 761.70 or in facilities approved under
§ 761.60(e) as achieving a level of performance equivalent to an incinerator approved under § 761.70.
Other disposal options are available for many types of PCB waste (e.g., landfills as specified in 40 CFR
761.75), but certain PCB wastes must be disposed of using one of those two options. Alternative
disposal methods such as, but not limited to, thermal desorption and chemical dechlorination, reduction,
or oxidation may be approved for use under § 761.60(e).
This document provides guidance for persons applying to the U.S. Environmental Protection Agency
(EPA) for approval to dispose of PCBs using thermal and non-thermal alternative methods
(§ 761.60(e)), and incineration (§ 761.70).3 This document presents and discusses the format, content,
and suggested level of detail for approval applications, trial burn and demonstration (demo) test plans,
and trial burn and demo test reports. Note that each technology is unique and that some elements
discussed in this guidance document may not be applicable to all technologies.
This guidance only addresses the approval process for the disposal of PCBs under the Toxic Substances
Control Act (TSCA). Other federal laws such as the Resource Conservation and Recovery Act (RCRA),
Clean Water Act (CWA), Clean Air Act (CAA), and Occupational Safety and Health Act (OSHA) as
well as state and local laws may also regulate PCB disposal. Some states have a PCB program with state
specific regulations that differ from federal regulation. Satisfying only state requirements does not
ensure that a facility has met all federal requirements. Facilities should ensure that they comply with
both state and federal requirements.

1.1 Benefits of this Guidance

This guidance benefits both applicants and EPA because it clarifies expectations and promotes
consistency. The previous guidance documents for incineration (§ 761.70) and alternative methods
(§ 761.60(e)) were originally developed in 1986 and decades have passed without any published
U.S. Environmental Protection Agency, 1979. “Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution
in Commerce, and Use Prohibitions,” Federal Register, Volume 44, pp. 31514-31568, May 31, 1979.
2
“Disposal” means intentionally or accidentally to discard, throw away, or otherwise complete or terminate the useful life of
PCBs and PCB Items. Disposal includes spills, leaks, and other uncontrolled discharges of PCBs as well as actions related to
containing, transporting, destroying, degrading, decontaminating, or confining PCBs and PCB Items (40 CFR 761.3).
3
For this document “disposal” includes certain processing activities, as indicated in § 761.20(c)(2)(ii). Under the TSCA
regulations, processing activities associated with and facilitating treatment (as defined in 40 CFR 260.10) require a TSCA
PCB disposal approval unless they are part of an existing approval or self-implementing activity or are otherwise specifically
allowed under the PCB disposal regulations (40 CFR part 761, subpart D), such as through a decontamination activity
covered under § 761.70(b) or (c) [see § 761.20(c)(2)(ii)].
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updates. 4 As a result, applicants sometimes submit incomplete applications, thus delaying the approval
process. The new guidance document combines information from the 1986 guidance documents with
current standard practices, policy, and regulation changes that have occurred since 1986. No new
requirements or interpretations were created in this guidance. EPA believes that incorporating both 1986
guidance documents and current standard practices into one document will reduce the back-and-forth
between the applicant and EPA and reduce the overall time spent on an application.
A few of the benefits of this guidance are:
• Higher quality applications which will reduce revisions to address deficiencies during EPA
review;
• A reduction of the overall time to obtain an operating approval;
• An increase in transparency and expectations by incorporating regulatory changes, guidance
documents, and policy decisions since 1986;
o Topics incorporated into this updated guidance include: financial assurance, safety
requirements, and Quality Assurance Project Plans (QAPP); and
• Easy-to-use, modern format of the guidance (e.g., the document is now word searchable).

1.2 Organization and How to Use

This guidance document is organized such that it walks the applicant through each stage of the approval
process. First, a general overview is provided giving the applicant an understanding of EPA procedures,
relevant regulations and the steps involved in the approval process (Sections 2 and 3). Detailed guidance
is then given regarding preparation and submission of approval applications and test plans (Sections 4
and 5). Section 6 discusses how tests are conducted and, after a completed test, Section 7 helps the
applicant prepare and submit a test report. Section 8 discusses the final operating approval and how to
modify or renew an existing approval. Lastly, a significant amount of supplemental information is
provided in the appendices to help the applicant through various steps of the approval process.
We recommend applicants initially review this entire guidance and then focus on specific sections as
they move through the application process. For example, when an applicant completes their
demonstration test, they would use section 7 as an aid to develop their test report. Each section was
developed with the appropriate information such that individual sections can be read without having to
frequently reference other sections of the guidance, but as a result, some information may appear to be
repetitive between multiple sections.
Some discussions in this guidance are separated into thermal and non-thermal sections to help guide the
reader toward the requirements and suggestions that would apply to their technology. Thermal
destruction technologies generally use high heat (> 500°C) and require air emissions monitoring; this
typically includes incineration, desorption with an afterburner, or vitrification. Non-thermal
destruction/removal technologies destroy/remove PCBs, typically in the absence of high temperatures,
and do not require air emissions monitoring. Non-thermal destruction/removal technologies may include
oxidation, catalytic hydrogenation, solvated electron technology, chemical dechlorination processes (i.e.,
sodium emulsion), or mechanochemical destruction. Applicants should remember that their technology
may not fall exclusively into one category. For example, thermal desorption with a condenser or carbon
The 1986 guidance documents are “Draft Guidelines for Permit Applications and Demonstration Test Plans for PCB
Incinerators,” and “Draft Guidelines for Permit Applications and Demonstration Test Plans for PCB Disposal by NonThermal Alternative Methods.”
4

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filter will use slightly elevated temperatures (relative to an incinerator) to remove PCBs from a medium
but the PCBs are generally not destroyed in the process. In this example, air emissions monitoring will
likely be needed for EPA to determine whether the level of performance is equivalent to an incinerator
approved under § 761.70 and this technology does not present an unreasonable risk of injury to health or
the environment. However, many of the operating conditions may be different from an incinerator and
reviewing only the thermal sections of this guidance may not provide comprehensive guidance. If this is
the case, then it is recommended that applicants review both thermal and non-thermal sections of this
guidance.
Note that when reading this document, “test” is a general term used to refer to a demonstration test, a
trial burn or both. For example, statements that include “trial burn/demonstration test plan” or “trial
burn/demonstration test approval” will be referred to as either “test plan” or “test approval.”

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SECTION 2
SUMMARY OF RELEVANT 40 CFR PART 761 REGULATIONS
This document is intended to provide guidance for obtaining EPA approval for PCB disposal by nonthermal alternative methods (§ 761.60(e)), thermal alternative methods (§ 761.60(e)), and incineration
(§ 761.70).5 This section summarizes pertinent provisions of 40 CFR part 761 related to the disposal of
PCBs. Part 761 establishes requirements for the manufacture, processing, distribution in commerce, use,
disposal, storage, and marking of PCBs.

2.1 General

The storage and disposal of PCBs are addressed in subpart D of 40 CFR 761. In § 761.60 of subpart D,
disposal requirements are generally differentiated according to waste type and PCB concentration. See
40 CFR part 761 for PCB disposal options and requirements. In Appendix A, Table A-1 presents an
outline of the sections of 40 CFR part 761 relevant to this guidance document.
This guidance document only addresses incineration and
M ORE THAN ONE TYPE
alternative to incineration PCB approvals, which are issued under
OF APPROVAL MAY BE
§§ 761.60(e) and 761.70. This document does not address disposal,
NECESSARY DEPENDING
cleanup, or decontamination methods that are allowable without an
ON THE TREATMENT
approval as long as regulatory standards are met, or allowable with
TECHNOLOGY
an approval other than those issued under §§ 761.60(e) and 761.70.
However, in some scenarios, an incinerator or alternative to
incineration PCB approval (§§ 761.60(e) or 761.70) may be issued
along with a second type of approval not discussed in this guidance document, typically a commercial
storage approval (§ 761.65). The applicant should be aware that, while this guidance does not discuss
the requirements for a commercial storage approval or other types of approvals, a second approval may
be necessary depending on the treatment technology and should be discussed with the approval writer.
Furthermore, depending on where the technology will be operated and if a second approval is deemed
necessary, it may require coordination between multiple EPA Regions and/or EPA Headquarters (HQ).

2.2 Approval Authority

The EPA officials with authority to approve PCB disposal methods are stated in § 761.60(e) and (i) and
761.70(a) and (b). The EPA officials granted primary approval authority for PCB disposal activities
under § 761.60(e) and 70 are the Director of the Office of Resource Conservation and Recovery
(ORCR) and the EPA Regional Administrators. Generally, requests for approval of
technologies/methods to be used in more than one EPA Region should be submitted to the Director of
ORCR and requests for approval of methods used in only one EPA Region should be submitted to the
Regional Administrator. Table 1 summarizes the EPA officials with approval authority for relevant PCB
disposal facilities. Addresses and contact information for EPA Headquarters and the 10 EPA Regional
offices are available at https://www.epa.gov/pcbs/program-contacts.

If the treated waste will be sent to a landfill or for further treatment elsewhere, then a different type of approval will likely
be required. Contact EPA for more information.
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Table 1. Summary of Relevant Approval Authorities
Disposal Method Description
Mobile alternative treatment or site-specific stationary
alternative treatment of identical design to be used in
more than one EPA Region

Approval Authority1
Director of ORCR (§ 761.60(e))

Mobile alternative treatment or site-specific stationary
alternative treatment of identical design to be used in
a single EPA Region

EPA Regional Administrators
(§ 761.60(e))

Mobile incinerators or site-specific stationary
incinerators of identical design to be used in more
than one EPA Region

Director of ORCR (§ 761.70(a), (b))

Mobile incinerators or site-specific stationary
incinerators of identical design to be used in a single
EPA Region

EPA Regional Administrators
(§ 761.70(a), (b))

Research and development methods of identical
design to be used in more than one EPA Region
involving < 500 pounds of PCB material, including
activities involving < 500 pounds of PCB material
authorized under § 761.60(j), except for selfimplementing activities authorized under § 761.60(j)

Director of ORCR (§ 761.60(i))

Research and development methods of identical
design to be used within a single EPA Region
involving < 500 pounds of PCB material, including
activities involving < 500 pounds of PCB material
authorized under § 761.60(j), except for selfimplementing activities authorized under § 761.60(j)

EPA Regional Administrators
(§ 761.60(i))

Research and development methods of identical
design involving > 500 pounds of PCB material,
including activities involving > 500 pounds of PCB
material authorized under § 761.60(j), except for selfimplementing activities authorized under § 761.60(j)

Director of ORCR (§ 761.60(i))

Note that the delegated approval authority may change or, in some instances, be delegated to the appropriate division
director. Also, the authority to review and approve any aspect of the disposal system may be allocated to the Office of Land
and Emergency Management (OLEM) Administrator or to a Regional Administrator. It is recommended that prospective
applicants contact the appropriate EPA Region or Headquarters for more information when determining where to submit an
application.
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2.3 Incinerators

Section 761.70 provides performance standards for PCB incinerators. To be approved, incinerators must
meet specific requirements (unless EPA waives a requirement in accordance with § 761.70(d)(5)), and
must not present an unreasonable risk of injury to health or the environment. Incinerator requirements,
including operating parameters, for destruction of liquid and non-liquid PCBs are provided in
§ 761.70(a) and § 761.70(b), respectively. Section 761.70(c) establishes requirements for maintaining
records and § 761.70(d) establishes requirements for obtaining approval of incinerators. Each of these
provisions is discussed in the following subsections. Pursuant to § 761.70(d)(4)(ii), additional operating
parameters may be included as conditions of the operating approval based on the operating parameters
that are observed during any demonstration test. See Table B-3 in Appendix B for a list of such
parameters.

2.3.1 Liquid PCBs

Section 761.70(a) establishes the minimum requirements for the destruction of liquid PCBs by
incineration. These requirements include the following:
• The introduced liquid shall be maintained for a 2-second dwell time at 1200 degrees Celsius (°C)
(± 100°C) and 3 percent excess oxygen (O 2) or a 1.5-second dwell time at 1600°C (± 100°C) and
2 percent excess O2 in the stack gas;
• Combustion efficiency (CE) shall be at least 99.9 percent computed as follows:
𝐶𝐶𝐶𝐶 = �

•
•
•
•

•

•

𝐶𝐶𝐶𝐶𝐶𝐶2
� × 100
𝐶𝐶𝐶𝐶𝐶𝐶2 + 𝐶𝐶𝐶𝐶𝐶𝐶

Where,
𝐶𝐶𝐶𝐶𝐶𝐶2 = Concentration of carbon dioxide, 𝐶𝐶𝐶𝐶𝐶𝐶 = Concentration of carbon monoxide

The rate and quantity of PCBs which are fed to the combustion system shall be measured and
recorded at regular intervals of no longer than 15 minutes;
The temperatures of the incineration process shall be continuously measured and recorded. The
combustion temperature of the incineration process shall be based on either direct (pyrometer) or
indirect (wall thermocouple-pyrometer correlation) temperature readings;
The flow of PCBs to the incinerator shall stop automatically whenever the temperature drops
below the minimum levels required to be maintained for the introduced liquid, specified above;
Stack emission products shall be monitored for O2, CO, CO2, NO x, HCl, total chlorinated organic
content (RCl), PCBs, and total particulate matter, at a minimum, when:
o An incinerator is first used for PCB disposal under § 761.70, and
o An incinerator is first used for PCB disposal after the incinerator has been modified in a
manner which may affect the characteristics of the stack emission products;
Monitoring and recording of combustion products and incineration operations shall be conducted
for O2 (continuously), CO (continuously), and CO2 (periodically at a frequency specified by the
Director of ORCR, Regional Administrator, or delegated official), at a minimum, whenever
PCBs are being fed to the incinerator;
The flow of PCBs to the incinerator shall automatically stop whenever there is a failure of the
monitoring operations for O2, CO, CO2; a failure of the PCB rate and quantity measuring and
recording equipment; or the excess O2 falls below the minimum levels required to be maintained
for the introduced liquid, unless a contingency plan indicating alternative measures the
incinerator owner/operator would take during such conditions is submitted by the owner/operator

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and approved by the EPA Regional Administrator, Director of ORCR, or delegated official; and
Water scrubbers or an EPA-approved alternative method shall be used for HCl control during
PCB incineration and shall meet any performance requirements specified by EPA. The scrubber
effluent shall be monitored and shall comply with any applicable effluent or pretreatment
standard and any other state and federal laws and regulations.

EPA also generally assesses performance of the following criteria to assure adequate destruction of PCB
liquids that is necessary to find no unreasonable risk when reviewing incinerator approval applications:
• Mass air emissions from the incinerator of no greater than 0.001 g PCB/kg of the PCB
introduced to obtain a destruction and removal efficiency (DRE) of at least 99.9999%
(commonly referred to as “six nines”);
• Measurement of the stack emissions for chlorinated dibenzodioxins and dibenzofurans; 6
• Particulate matter emission levels of less than or equal to 0.015 grains (gr) per dry standard cubic
foot (dscf) when corrected to 7 percent O2;
• An hourly rolling average of no greater than 100 ppm CO or an hourly rolling average of no
greater than 10 ppm hydrocarbons; and
• PCB concentrations in fly ash (if applicable) and bottom ash (if applicable) of less than or equal
to 2 parts per million (ppm) and in scrubber water of less than or equal to 0.5 microgram (μg) per
liter (l) for unrestricted use (approximately ≤ 0.5 parts per billion [ppb]).

2.3.2 Non-liquid PCBs

Section 761.70(b) describes requirements, similar to those for liquid PCBs, for the destruction of nonliquid PCBs, PCB Articles, PCB Equipment, and PCB Containers by incineration (see § 761.3 for
definitions). § 761.70(b) requires compliance with § 761.70(a) requirements for the destruction of liquid
PCBs by incineration, except: 1) § 761.70(a)(1) combustion criteria do not apply; 2) § 761.70(b) also
requires the mass air emissions from the incinerator to be no greater than 0.001 g PCB for every kg of
PCB introduced into the incinerator, i.e., the incinerator must achieve a DRE of at least 99.9999%; and
3) the flow of PCBs to the incinerator does not have to automatically stop when the combustion
temperature drops below temperatures specified in § 761.70(a)(1) or when excess oxygen falls below the
percentage specified in § 761.70(a)(1). Regardless, some of these exceptions may be included by the
approval writer to ensure no unreasonable risk of injury to health or the environment for certain sites or
situations.
Destruction of non-liquid PCBs, PCB Articles, PCB Equipment, or PCB Containers should meet the
following criteria:
• Measurement of the stack emissions for chlorinated dibenzodioxins and dibenzofurans; 7
• Particulate matter emission levels of less than or equal to 0.015 gr/dscf when corrected to
7 percent O 2;
• An hourly rolling average of no greater than 100 ppm CO or an hourly rolling average of no
greater than 10 ppm hydrocarbons; and

Dioxins/furans released in a stack should be < 0.2 ng TEQ/dscm for new sources and <0.4 ng TEQ/dscm for existing
sources as specified 40 CFR 63.1219. However, the standards listed for dioxin and furans may differ than what is stated here
based on the treatment and air pollution control devices used. See 40 CFR part 63 for more information.
7
See previous footnote.
6

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PCB concentrations in fly ash (if applicable) and bottom ash (if applicable) of less than or equal
to 2 ppm and in scrubber water for unrestricted use of less than or equal to 0.5 μg/L
(approximately ≤ 0.5 ppb).

2.3.3 Maintenance of Data and Records

Section 761.70(c) establishes requirements for maintenance of data and records for PCB incinerators.
Records shall be maintained according to the provisions established in § 761.180. The required records
and associated retention times are discussed in more detail in section 4.2.10 of this document.

2.3.4 Approval of Incinerators

Section 761.70(d) establishes requirements for an owner or operator to obtain written approval from the
EPA officials with authority to approve incineration of PCBs and PCB Items. These requirements
include submitting the following documents to the appropriate EPA Headquarters or Regional office:
1) an application for an operating approval; and 2) a trial burn 8 plan, if EPA determines that a trial burn
is required following receipt of the operating approval application.
While § 761.70(d)(2) says that EPA will determine if a trial burn is required following receipt of the
application for an operating approval, EPA generally requires a trial burn for all incinerator approvals
issued under § 761.70 to support a no unreasonable risk determination. 9 Also, applicants may submit
their trial burn plan after, with, or before their application but both the application and trial burn plan are
typically required prior to EPA issuing approval to conduct the trial burn. If the applicant does not wish
to conduct a trial burn then EPA recommends that they discuss this with their approval writer (see
section 3.1). EPA generally asks owners/operators to submit trial burn reports describing the results of
trial burns pursuant to § 761.70(d)(3), which enables EPA to “require the owner or operator to submit
any other information that the EPA finds to be reasonably necessary to determine whether an incinerator
shall be approved.”
The contents of an approval application, a test plan, and test report are presented and discussed in detail
in sections 4, 5 and 7 of this document, respectively. Section 761.70(d) also provides procedures for
obtaining waivers from requirements in § 761.70(a) and (b) and for transferring ownership of an
approved incinerator, neither of which are discussed in this guidance document.

2.4 Alternative Methods of Disposal

Under § 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 shall submit
a written request to the Regional Administrator or the Director of the Office of Resource Conservation
and Recovery, for a waiver from the incineration requirements of § 761.70 or § 761.71.”
The request shall be sent to either the Regional Administrator or Director of ORCR in accordance with
Note that throughout the rest of the guidance “trial burn” is generally referred to as “test” (see discussion in section 1.2).
EPA uses the term “trial burn” in this section for clarity and consistency with the PCB regulations.
9
According to § 761.70(d)(4)(ii), EPA “may include in an approval any other requirements that EPA finds are necessary to
ensure that operation of the incinerator does not present an unreasonable risk of injury to health or the environment from
PCBs.”
8

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§§ 761.60(e) and (i). The applicant using a thermal or non-thermal alternative method of disposal must
demonstrate 1) that the method can achieve a level of performance equivalent to an incinerator approved
under § 761.70 or, for liquid PCB wastes between 50-500 ppm, a high efficiency boiler operating in
compliance with § 761.71 and 2) that the method will not present an unreasonable risk of injury to
health or the environment. These two requirements should be taken into consideration by the applicant
and should be appropriately addressed in the approval application and proven during the test. EPA
typically requires a test to be conducted for all alternative technologies to determine there is no
unreasonable risk of injury to health or the environment.

2.4.1 Alternative Thermal Destruction Technologies

Approvals for alternative thermal technologies typically have similar operating requirements as
approvals for incinerators because the measurements of performance are similar. Generally, stack
emissions must demonstrate a DRE of PCBs of at least 99.9999 %, combustion efficiency and oxygen
requirements may apply, and ash, like all other solid process wastes, must contain less than or equal to
2 ppm PCBs (the detection limit) to be unregulated for disposal. Many other conditions may apply
depending on the technology and characteristics of the waste. Any aspect of the process that may pose
risks of injury to health or environment should also be addressed in the approval application.

2.4.2 Alternative Non-Thermal Destruction/Removal Technologies

Alternative non-thermal methods of PCB destruction/removal often differ significantly from incineration
and other thermal treatment processes. For alternative processes that non-thermally destroy/remove
PCBs, EPA generally asks the applicant to show that the concentration of PCBs is no more than 2 ppm
in the product or the process waste. Any aspect of the process that may pose risks of injury to health or
environment should be addressed in the approval application. Examples of such risks include emissions
of toxic solvents to the atmosphere and explosion/fire hazards from sodium exposure to moisture or
hydrogen release.

2.5 Other Regulations

Applicants should also take into consideration other regulations that may be applicable to their process.
For example, states may have more stringent requirements, additional air regulations may apply, water
regulations may apply if there is discharge into a body of water, and treatment of radioactive wastes may
require input from the Nuclear Regulatory Commission (NRC) and others. It is the responsibility of the
applicant to have all the proper permits and approvals prior to operating their treatment or disposal
process.
Furthermore, although an operating approval may reference additional requirements of 40 CFR part 761,
the approval should not be relied upon for all requirements related to PCBs or the disposal of PCB
waste. If the information contained in the approval application or other supporting documents submitted
to EPA differs from the conditions specified in the approval, the conditions of the operating approval
shall govern.

2.5.1 High Efficiency Boilers

High efficiency boilers may be used to burn MODEF (mineral oil dielectric fluid) and other liquids
containing a PCB concentration of ≥ 50 ppm, but < 500 ppm. Any person using a high efficiency boiler
to dispose of such PCB liquids must use a boiler that meets the criteria set forth in § 761.71. The criteria
differ depending on the material being burned.
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Note that when burning liquids other than MODEF with concentrations of ≥ 50 ppm but < 500 ppm
PCBs, approval must be obtained from the EPA Region in which the boiler is located, as required in
§ 761.71(b).

2.5.2 Scrap Metal Recovery Ovens and Smelters

Any person may dispose of residual PCBs associated with PCB-Contaminated articles regulated for
disposal under § 761.60(b), metal surfaces in PCB remediation waste regulated under § 761.61, or metal
surfaces in PCB bulk product waste regulated under §§ 761.62(a)(6) and 761.79(c)(6), from which all
free-flowing liquids have been removed, in a scrap metal recovery oven or smelter that meets the criteria
set forth in § 761.72.
Note that scrap metal recovery ovens and smelters must either have a final permit under RCRA (40 CFR
part 266, subpart H and 40 CFR 270.66) or be operating under a valid state air emissions permit which
includes a standard for PCBs. Alternatively, the EPA official with approval authority for the EPA
Region in which the oven or smelter is located, may make a finding (based on a site-specific risk
assessment) that the oven or smelter does not pose an unreasonable risk of injury to health or the
environment.

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SECTION 3
BASIC APPROVAL PROCEDURES FOR THE
TREATMENT/DISPOSAL OF PCBS USING INCINERATION OR AN
ALTERNATIVE TECHNOLOGY
This section provides an overview of the steps toward obtaining an approval to treat/dispose of PCBs
using incineration or an alternative method. Figure 1 shows the major steps in the operating approval
process.

3.1 Establishing Communications with the EPA Approval Writer

For all approvals covered under this guidance document, the applicant should proactively establish early
communications with the appropriate EPA approval writer. This will shift critical discussions to the
beginning of the process, so that EPA and the applicant can reach an agreement on critical issues and
expectations as early as possible. The applicant and EPA approval writer can discuss any special
circumstances, each party’s expectations, and procedures for the submission of information. EPA may
be able to provide early feedback indicating important considerations, such as public participation or
additional sampling/monitoring requirements. Additionally, EPA will gain a better understanding of the
goals and constraints of the applicant and their treatment process. Advance notice of submissions will
allow the EPA approval writer to schedule the review so that it can be completed in a timely fashion.
Furthermore, early and routine communication throughout the application process should minimize EPA
requests for additional information, reduce the amount of superfluous information submitted by the
facility, and speed up the approval issuance process overall.

3.2 Research and Development

A facility seeking to use an uncommon or novel alternative disposal method should consider doing
Research and Development (R&D). While R&D may not be a required step in obtaining an operating
approval, it may assist in transitioning the treatment/disposal process from conception to commercial
operation. Additionally, information from R&D studies can provide a proof of concept for novel or
uncommon technologies that do not have established operating parameters for treating PCB waste. If the
facility determines that R&D is not needed then they may skip this step. However, it is important to
communicate this to EPA prior to developing the operating approval application.
An approval application for R&D activities that are not self-implementing activities (see discussion in
section 4.1.4) should follow the same format as an operating approval application (see section 4.2 for the
format of an operating approval application). The application also should supply information on the
specific objectives of the R&D activity. Due to the limited scope and duration of R&D activities,
technical details, monitoring and sampling plans, health and safety plans, etc., do not need to be as
extensive as those provided for long-term, full-scale operating approvals. Although the R&D approval
application may not have the level of detail of an operating approval application, it should be sufficient
to demonstrate that the R&D activity will not present an unreasonable risk of injury to health or the
environment.

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E STABLISH COMMUNICATIONS
WITH EPA APPROVAL W RITER

SUBMIT COMPLETE OPERATING
APPROVAL APPLICATION TO EPA

SUBMIT COMPLETE T EST PLAN
TO EPA, IF REQUIRED

EPA REVIEW, DEFICIENCIES
I DENTIFIED/COMMUNICATED

EPA MAY ISSUE TEST APPROVAL

CONDUCT T EST

SUBMIT TEST REPORT TO EPA, UNLESS EPA
SPECIFIES OTHERWISE

EPA REVIEW, DEFICIENCIES
I DENTIFIED/COMMUNICATED

P UBLIC P ARTICIPATION AND/ OR PUBLIC
COMMENT, IF DEEMED NECESSARY

EPA MAY ISSUE OPERATING
APPROVAL

Figure 1. Major Steps in the Operating Approval Process

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3.3 Submittal of Operating Approval Application and Test Plan

Paragraph § 761.70(d)(1) establishes the information that must be included in an approval application to
operate a PCB incinerator. EPA suggests that the same information be included in an approval
application to operate PCB disposal technologies that are alternatives to an incinerator pursuant to
§ 761.60(e), as such information is generally needed for EPA to find that the alternative method can
achieve a level of performance equivalent to disposal in a § 761.70 incinerator or a § 761.71 high
efficiency boiler and will not present an unreasonable risk of injury to health or the environment, as
required under § 761.60(e). Section 4 of this document presents EPA’s suggested content and format for
an application for an operating approval pursuant to § 761.60(e). Table B-1 in Appendix B provides a
checklist to aid the applicant in determining if all requirements and recommendations for an application
have been addressed.
THE APPLICANT SHOULD GIVE CAREFUL CONSIDERATION TO THE DESIGN AND
CONDUCT OF THE TEST. T HE CONDITIONS CHOSEN FOR THE TEST GENERALLY
INFORM THE SELECTION OF REQUIREMENTS IN THE OPERATING APPROVAL.

As discussed in section 1.2, a trial burn or demonstration test, is generally referred to as a test. A test is
typically required prior to issuance of approvals for incinerators or alternative technologies. A test plan
is a document prepared specifically for the test, and provides details of how the test will be conducted.
Section 5 of this document presents the information that is typically needed to prepare a complete test
plan. Table B-2 in Appendix B provides a checklist to aid the applicant in determining if these items
have been addressed in the test plan. Operating approval requirements usually reflect the system’s
operating conditions during the test. Therefore, the applicant should give careful consideration to the
design and conduct of the test. For more information, see discussion in section 5.1.1 regarding the
purpose of the test.
The applicant should submit both an operating approval application and a test plan to receive a test
approval. The operating approval application and test plan should be separate, complete documents. The
operating approval application should be submitted as early as possible. In special circumstances, partial
submissions are acceptable if the submission clearly indicates the portions of the application to be
submitted later, and if the applicant and EPA approval writer agree that a preliminary review of a partial
submission will be productive. The test plan may be submitted
before, with, or after the operating approval application. However, a
THE TEST PLAN MAY BE
test cannot be conducted before a complete application and test plan
SUBMITTED BEFORE THE
are submitted and approved by EPA. While electronic submission
APPROVAL APPLICATION .
of files is preferred, EPA will occasionally request paper copies.
Special consideration should be given to figures included in the application and test plan such that, as
feasible, they are prepared in a manner that is useable and readable by color‐blind people (i.e., figures
should be readable in black and white). Symbols with different shapes and/or shading may be used.

3.4 EPA Review of Operating Approval Application and Test Plan

EPA reviews the operating approval application and test plan for completeness, accuracy, clarity, and
technical viability. If either document is unacceptable, EPA will notify the applicant of any deficiencies,
and request submittal of additional information, or data, as needed. The deficiencies should be corrected
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in a revised application or test plan, and the revised document(s) should be submitted to EPA. In some
cases, this process may need to be repeated more than once. EPA may deny the application if the
deficiencies are not addressed within a reasonable period of time.

3.5 EPA Approval of Test Plan

After EPA confirms that the operating approval application and test plan are complete, accurate, clear,
and technically viable, EPA will issue a test plan approval. A test plan approval is required prior to
destroying any PCBs in the unit. The test plan approval will specify a limited amount of PCB-containing
material that can be destroyed during the test and other conditions based on the applicant’s operating
approval application and test plan. The time period for which the test plan approval is valid normally
ranges from one to four months. There may need to be public notice of the test plan, and timing of the
test should take this into account.

3.6 Conducting a Test

A test is scheduled at a date and time agreeable to both the applicant and EPA. It is desirable that EPA
have at least 60 days notice prior to the test. The relevant state and local government authorities must be
notified at least 30 days prior to conducting the test. 10 Public notice may be required in advance of the
test; review your test approval or ask your approval writer for specific public notice requirements.
If any modifications to the test plan are needed prior to the test, the applicant is requested to notify the
EPA approval writer in writing at least 14 days prior to the test. See section 5 for more information.
The test should be conducted under conditions simulating the most challenging scenarios expected to be
encountered under commercial operations (e.g., highest PCB concentrations expected, highest degree of
chlorination, hardest matrix condition to treat, highest porosity, or most organic matter). Section 6 of
this document provides more details on conducting a test.

3.7 Submittal of Test Report

After a test has been performed, EPA generally asks that a report documenting the test results be
prepared and submitted. As noted above, reports for incinerators are generally sought under the authority
of § 761.70(d)(3). For alternative treatment methods conducted under § 761.60(e), test reports are sought
to evaluate if the level of performance is equivalent to disposal in a § 761.70 incinerator or a § 761.71
high efficiency boiler and will not present an unreasonable risk of injury to health or the environment, as
required under § 761.60(e). A test report should be submitted to EPA regardless of whether the
technology passes or fails the test. Section 7 of this document provides the format and contents of the
report.

3.8 EPA Review of the Test Report

Upon receipt of a test report, EPA will conduct a review of the report. If the test report is incomplete or
unclear, EPA will notify the applicant that the report is deficient and may request submittal of additional
information or data as needed. 11

10
11

40 CFR 761.60(f).
EPA may deny the application if the deficiencies are not addressed within a reasonable period of time.

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After review of the test report, EPA may:
• Move forward with drafting an operating approval;
• Deny the operating approval without further consideration;
• Recommend that the applicant submit a R&D approval application in order to provide an
opportunity to correct operating deficiencies prior to another test;
• Reschedule the test with the same test plan, which is usually done when minor deficiencies in the
operating process cause the problem. The applicant would be requested to provide adequate
assurance to the approval writer that deficiencies have been corrected and subsequent test failure
is unlikely, that the test would be conducted in a manner that will not present an unreasonable
risk of injury to health or the environment, and that no modifications are needed to the treatment
system to assure it will be in full compliance with the performance standards; or
• Reschedule the test with a new test plan, which is usually used when major design changes must
be made or major operating deficiencies must be corrected before another test can be performed.
In such circumstances the facility should submit a revised test plan that reflects design or
operational changes such that there is adequate assurance the treatment unit will achieve relevant
performance standards. EPA will issue another test plan approval, if warranted.

3.9 EPA Issues an Operating Approval

After receipt of the complete operating approval application and of the test results, EPA may issue a
final operating approval that allows the owner/operator to operate the PCB treatment unit(s) in
accordance with the terms and conditions in their approval. At a minimum, the final operating approval
will specify the type of PCB-containing material that can be processed, an upper limit on PCB
concentration in the feed, and an effective period, usually 5 to 10 years from the date of issuance.
Prior to renewal of an operating approval, additional information/testing and/or re-testing of the process
is generally required. The operating approval will typically specify when the facility owner/operator
should submit an operating renewal application if it wishes to continue treating PCB waste after the
expiration date of the approval, and describe the steps to continue the effectiveness of an operating
approval pending EPA action on reissuance. 12 EPA will determine if a re-test is required and, if so, then
the applicant will be asked to develop a test plan.

EPA typically requires a renewal application to be submitted 6 months in advance of the expiration date of the current
approval. See Section 8 of this document for more details.
12

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SECTION 4
CONTENTS OF AN OPERATING APPROVAL APPLICATION
This section describes the information that should be included in operating approval applications for
PCB treatment/disposal activities utilizing incineration or alternative technologies. 13 The minimum
required contents of an operating approval application are covered under 40 CFR 761.70(d)(1) for PCB
incinerators, and 40 CFR 761.60(e) for alternative technologies. The application should be submitted to
the same delegated EPA official as the test plan (see section 2.2 for a more detailed discussion on EPA
delegation of authority). While electronic submission of files is preferred, EPA will occasionally request
paper copies.

4.1 Preliminary Steps to an Approval Application

The subsections below discuss various requirements and suggestions for the applicant to keep in mind
prior to and during the development of their operating approval application.

4.1.1 Early Communication

Early communication and a face-to-face meeting with EPA are highly recommended before the
applicant begins developing their application, since it is beneficial to both EPA and the applicant. This
will shift critical discussions to the front of the process, so that EPA and the applicant communicate and
reach an agreement as early as possible. EPA may be able to provide early feedback indicating potential
considerations, such as public participation and/or additional sampling/monitoring requirements, should
the applicant move forward with the operating approval application. Additionally, EPA will gain a better
understanding of the goals and constraints of the applicant and their treatment process. Following the
initial meeting between EPA and the applicant, the applicant may contact or arrange a meeting with
EPA if help is needed to complete the application.
C OMMUNICATION IS KEY TO A TIMELY REVIEW OF THE APPLICATION AND ISSUANCE OF THE
OPERATING APPROVAL

EPA generally only accepts fully completed applications but may allow the applicant to submit a partial
application if it will help minimize the likelihood of an unnecessary or deficient application. If a partial
application is submitted, the applicant should clearly identify on the cover page that it is, in fact, a
preliminary partial submission of an application. Also, if the document is a partial application, the
applicant should clearly identify in the body of the application and table of contents those sections,
items, figures/tables, etc. that will be provided later (and when, if known).

4.1.2 Criteria

When developing an operating approval application, it is important to keep in mind regulatory standards,
process criteria, and quality assurance/quality control (QA/QC) criteria. The standards listed below will
help EPA ensure the alternate disposal method provides PCB destruction equivalent to disposal in a
§ 761.70 incinerator or a § 761.71 high efficiency boiler and will not present an unreasonable risk of
13

As a reminder, trial burns and demonstration tests are referred to collectively as tests.

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injury to health or the environment, as required under § 761.60(e). Individual approvals may include
additional criteria not listed below, based on the specific nature of those technologies and processes, that
are needed for EPA to make a no unreasonable risk determination.
Regulatory standards include: 14
• ≤ 2 ppm PCBs for all matrices (e.g., clean soil or dielectric fluid) except air and water; 15
• ≥ 99.9999% (six ‘9s’) DREs for PCBs in air emissions; 16
• For incinerators and some thermal destruction technologies, the requirements, including
operating parameters, for destruction of liquid and non-liquid PCBs as specified in § 761.70(a)
and § 761.70(b), respectively; 17
• < 3 ppb for water discharged to a treatment works or to navigable waters unless the discharge is
in accordance with a PCB discharge limit included in a permit issued under the Clean Water
Act; 18
• ≤ 0.5 ppb for water for unrestricted use; 19 and
• Any state regulatory standards that may apply.
Additional criteria may include:
• 90-110% isokinetic sampling; 20
• Limits that may be imposed for other hazardous constituents that may be produced within the
treatment process (e.g., buildup of an explosive gas such as H2);
• Other air quality standards (e.g., dioxins/furan standards adapted from Clean Air Act MACT
standards) may be imposed under TSCA to ensure no unreasonable risk of injury to health or the
environment;
o This may be satisfied through a CAA permit instead, if applicable; and
• Monitoring, sampling, or control of any other aspects of the process that may pose an
unreasonable risk of injury to health or environment. 21
Additional criteria for non-thermal destruction/removal technologies will be dependent on the
technology, and due to the variety of non-thermal technologies that exist, it is difficult to create a list of
criteria that may be applicable to all non-thermal technologies. However, generally, non-thermal
technologies may be requested to meet the criteria discussed above. Air emissions monitoring may not
be required if the approval writer determines that no PCBs will be emitted based on the treatment
All the regulatory standards listed here may not be applicable depending on method of treatment and disposal. For
example, PCB-contaminated solids and liquids may be separated during an approved treatment process where the solids are
sent to a TSCA landfill and the liquids are treated to ≤ 2 ppm.
15
Previous guidance has interpreted that “equivalent level of performance” to an incinerator means less than or equal to
2 ppm. See “Guidelines for Permit Applications and Demonstration Test Plans for PCB Disposal by Non-Thermal
Alternative Methods” (1986).
16
40 CFR 761.70(b)(1).
17
See section 2.3 of this guidance and § 761.70 for more information on regulatory incinerator requirements. An incinerator
must meet all applicable requirements specified in § 761.70(a) and § 761.70(b), unless a waiver from these requirements is
obtained pursuant to paragraph § 761.70 (d)(5).
18
40 CFR 761.50(a)(3).
19
40 CFR 761.30(u)(3).
20
EPA Method 0010.
21
Air emissions monitoring may not be required if the approval writer determines that no PCBs will be emitted based on the
treatment process. Generally, thermal treatment processes will be required to monitor air emissions. However, non-thermal
treatment processes may also be required to monitor air emissions, especially if there is potential for PCBs to volatilize.
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process. However, if there is potential for PCBs to volatilize then air monitoring likely will be required.
Quality assurance criteria that EPA may consider are whether:
• Accuracy, precision, and representativeness of the data have been demonstrated;
• All data fall within the 70-130% range of EPA’s values;
o EPA personnel will typically take samples during the test for analysis;
o EPA may also provide two Performance Evaluation (PE) samples to the applicant which
should be analyzed and presented in the test report. One evaluation sample will generally
contain PCB values near the concentration at which the feed will be demonstrated. The
other evaluation sample will generally be close to the regulatory threshold;
o Results of the samples collected and analyzed by EPA will be provided to the applicant;
and
• Gas chromatograms and QA/QC supporting data validation have been provided.
EPA may also take into consideration other federal requirements, such as:
• National Historic Preservation Act (NHPA);
• Endangered Species Act (ESA); and
• Environmental Justice per Presidential Executive Order 12988.

4.1.3 Other Important Information for Development of an Approval Application

Information provided within the approval application is assumed to be representative of the normal dayto-day operations when treating PCB waste, unless clearly specified otherwise. The applicant may
request certain operating parameters for a test to be at the outer edges of their anticipated operating
envelope (i.e., to test under a worst-case scenario) to ensure they receive an operating approval with
conditions that allow them to operate their system at its optimal parameters, particularly when
considering normal variability of these parameters. Differences between the day-to-day operation
conditions and the test conditions should be discussed either in the application or the test plan. The
applicant should clearly explain whether the operating levels proposed for the test will give them an
adequate “cushion” between their normally anticipated operating levels and the levels demonstrated
during the test which, in most instances, will become levels they cannot exceed during normal
operations. The applicant may reference the test plan, if applicable. A more detailed discussion
regarding this topic can be found in section 5.1.1.
Note that the applicant may use the same unit to treat either TSCA regulated or non-TSCA regulated
materials but the operational parameters specific to treating PCB waste should be provided in the
application. Additionally, the applicant may be required to take certain steps (e.g., tank
decontamination) prior to treating non-TSCA regulated waste in a unit which previously treated TSCA
regulated waste. EPA may request more information on how the unit is used for non-TSCA related
activities in order to make a no unreasonable risk determination.
Applicants should also keep in mind that, while it may be helpful to review and understand the
requirements seen in other approvals, such requirements may not apply to their operating approval even
if they use the same technology. Requirements in operating approvals depend upon many components of
the application and observations during the test. For example, some facilities may choose to have an
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extensive sampling regime and/or continuous monitoring equipment on all effluent sources after
treatment. In such cases, EPA may be more lenient with operating parameter requirements in the
approval. In turn, if the applicant chooses to have tight monitoring and operating parameter control over
their system with “not to exceed” operating levels/limits then the need for effluent PCB sampling
requirements may be reduced, if tested successfully. As an example, an incinerator treating PCBcontaminated oil will not have an effluent stream to sample so their monitoring and operating
parameters may be strictly controlled in an operating approval. Whereas, hydrotreaters that treat PCBcontaminated oil have an effluent stream that can be sampled and EPA may be more lenient regarding
the operating and monitoring parameters in the operating approval. In the end, EPA will consider the
application in its entirety when determining appropriate approval conditions that ensure all regulatory
requirements are met and it does not present an unreasonable risk of injury to health or the environment.
The information provided in this section, and this document in general, may not be comprehensive and
applicants should or, in some instances, may be required to provide additional information when
appropriate. Alternative PCB treatments cover a wide breadth of technologies and attempting to discuss
every detail of every potential technology would make this document overwhelming and unreadable.
However, this document will guide the applicant through the application process regardless of the
technology they use and, at minimum, provide an idea of the information EPA is requesting in the
application.

4.1.4 Research and Development Applications

A facility seeking to use an uncommon or novel alternative disposal method should consider doing
Research and Development (R&D). While R&D may not be a required step in obtaining an operational
approval, it may assist in transitioning the treatment/disposal process from conception to commercial
operation. Additionally, information from R&D studies can provide a proof of concept for novel or
uncommon technologies that do not have established operating parameters for treating PCB waste. If the
facility determines that R&D is not needed then they may skip this step. However, it is important to
communicate this to EPA prior to developing the operating approval application because EPA may have
a limited amount of information on the technology and may request that some information/data to be
submitted prior to approving a test plan or an application.
R&D may be conducted without an approval when following the self-implementing guidelines pursuant
to § 761.60(j). The self-implementing R&D provision allows less than 500 gallons of liquid PCBs or
70 cubic feet of liquid or non-liquid PCBs to be treated without an approval from EPA if the maximum
PCB concentration does not exceed 10,000 ppm (see § 761.60(j)(1)(iii)). Note that there are notification
requirements for self-implementing R&D (see § 761.60(j)(1)). When quantities greater than 500 gallons
or 70 cubic feet, or concentrations greater than 10,000 ppm are to be treated in an R&D activity, either
an approval or a waiver is required (see § 761.60(i) and § 761.60(j) respectively). R&D approvals may
be issued for bench-scale, pilot-scale, and full-scale systems, but may not be used in lieu of a
§ 761.60(e) commercial approval. In other words, the main purpose of treatment operations in an R&D
(see § 761.3) device must be to conduct research on the effectiveness of the process to treat/dispose of
PCBs and PCB Items, as opposed to solely using the treatment device to treat/destroy PCBs and PCB
Items.
Except for activities authorized under the self-implementing provisions for R&D for PCB disposal
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(§ 761.60(j)), R&D activities involving less than 500 pounds of PCB material (regardless of PCB
concentrations) will be reviewed and approved by the Director of ORCR, Regional Administrator, or
delegated official, and R&D activities disposing of 500 pounds or more of PCB material (regardless of
PCB concentrations) will be reviewed and approved by the Director of ORCR. Pursuant to
§ 761.60(j)(3), the authorized EPA official may determine at any time that an R&D PCB disposal
approval is required, to ensure that the R&D for PCB disposal activity does not present an unreasonable
risk of injury to health or the environment. EPA may limit the number of R&D runs for those R&D
activities for which an EPA approval is required.
Approval applications for R&D activities that are not self-implementing activities should consist of all
the applicable elements described below in this section (sections 4.2 and 4.3, except where noted). The
R&D application need not contain the detail required for an operating approval application, but should
be sufficient to demonstrate that the R&D activity will not present an unreasonable risk of injury to
health or the environment. The applicant also should supply information on the specific objectives of the
R&D activity. R&D approval applications can be submitted at any time, even if an application for an
approval to operate commercially already has been submitted. As previously discussed, prior to
developing and submitting an R&D approval application to EPA, the facility should proactively have
discussions with the EPA approval writer to determine what types of information will be expected in the
R&D approval application. In some cases, EPA may recommend that the applicant submit an operating
approval application in lieu of the R&D approval application, depending upon the circumstances
involved.
Upon receipt of an R&D approval application, EPA will review the document. If the application is
incomplete or contains deficiencies, a notice of deficiencies will be sent to the applicant, who should
then revise and resubmit the application. After EPA determines the facility’s R&D approval application
satisfies all applicable requirements, an R&D approval is issued. Alternatively, EPA may deny the
approval application if the application does not satisfy the regulatory requirements, the application’s
deficiencies are not addressed within a reasonable period of time, or the technology presents an
unreasonable risk of injury to health or the environment. In some instances, a draft approval is made
available to the public for public comment. If this occurs, EPA will evaluate public comments and then
determine whether the R&D approval should be issued with or without modifications, or denied.
The R&D results may be appropriate for inclusion in, for example, an application for an operating or test
plan approval for the same technology. To use the results in an operating or test plan approval
application, the R&D information should include process information and operating experience. This
information should support the finding that full-scale operation of the technology will be equivalent to
disposal in a § 761.70 incinerator or a § 761.71 high efficiency boiler and will not present an
unreasonable risk of injury to health or the environment, as required under § 761.60(e). There also could
be situations where the approval writer encourages or requires the facility to conduct R&D activities, or
submit results of R&D activities previously conducted, prior to full scale testing if, for example, the
technology is new or the technology has a limited track record with respect to treating their type/quantity
of PCB waste.

4.1.5 Submitting Confidential Business Information (CBI)

When preparing approval documents for submission to EPA, any information that the facility would like
to be considered confidential business information (CBI) (as defined in 40 CFR part 2) should be clearly
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identified. If a company’s submittal to EPA contains CBI, they should submit one version of the
submittal that contains the proprietary information to EPA, marked clearly as CBI, as well as a redacted
version for the public and EPA personnel that are not certified to access CBI. The redacted version
should not contain the CBI, but rather include a page(s) that clearly states, “Information on the original
version sent to EPA has been claimed as confidential business information, and has been redacted from
these pages.” Contact EPA personnel to receive specific instructions for submitting CBI material.

4.1.6 Mobile Treatment Applications

As stated in Table 1, applications for alternative disposal methods that are mobile and would be used in
more than one EPA Region, must be submitted to the Director of ORCR at EPA Headquarters. Mobile
treatment units present a unique set of challenges, particularly in the areas of public engagement,
decontamination, and closure. Mobile treatment units should follow the same guidance in this document
provided for stationary treatment units except when otherwise noted. Guidance specifically for mobile
treatment units is interspersed throughout this document. For additional guidance, contact the ORCR
PCB team at EPA Headquarters (ORCRPCBs@epa.gov).

4.2 Contents of an Operating Approval Application

Table 2 provides a suggested approval application format for incineration and alternative technologies.
All subsections in this section apply to both incineration and alternative technologies unless otherwise
noted in the subsection headings. Appendix B provides a checklist to aid the applicant in developing a
complete approval application to operate a PCB incinerator or an alternative technology. This checklist
is not required and does not need to be submitted to EPA.
In instances where the applicant is submitting a revised test plan, such changes/revisions should be
summarized as described in section 4.2.3, and if practicable, a redline/strikeout “compare” version that
highlights the revisions should be provided. 22 To help facilitate EPA’s review, the applicant is also
encouraged to provide a standalone response to comments document that briefly explains/summarizes
how each comment was addressed.
In instances where significant deficiencies have been identified by EPA, or the applicant is unclear as to
how to address specific deficiencies, the applicant may find it useful to request a meeting or
teleconference with the approval writer to best assure the revisions adequately address the comments
received. EPA may deny the application if the deficiencies are not addressed within a reasonable period
of time.

4.2.1 Transmittal Letter

All operating approval applications should be accompanied by a transmittal letter, which summarizes the
request for an operating approval and mentions relevant history of the request. If the test plan is being
submitted in conjunction with an operating approval application, this should be briefly discussed in the
transmittal letter. The transmittal letter of an updated application should summarize how it differs from
the previously submitted application.

In instances where significant revisions or rewrites have been made, a redline/strikeout compare version may not be
practicable or useful.
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4.2.2 Cover Page

Each approval application should have a cover page, an example of which is shown in Figure 2. If a
paper copy is requested by EPA and if the application or the appendices are bound separately (i.e.,
multiple volumes), the applicant should number each volume in order in the upper right-hand corner of
the cover (“Volume m of n”). The cover of each volume should also have all information shown in
Figure 2.
Table 2. Suggested Format for an Operating Approval Application
Section No.

Section Title
Approval Application Cover
Table of Contents

I

Summary

II

Company Organization/Structure/Personnel

III

Waste Description and Analysis Plan

IV

Process Engineering Description

V

Monitoring and Sampling Plan

VI

Monitoring Procedures

VII

Sampling and Analysis Procedures

VIII

Data Recordkeeping and Reporting

IX

By-Product Waste Handling and Disposal

X

Inspection Procedures

XI

Spill Prevention Control and Countermeasures Plan

XII

Safety Plan

XIII

Training Plan

XIV

Test Plan Summary1

XV

Test Data or Engineering Performance Calculations

XVI

Other Permits and Approvals

XVII

Schedule of Pre-Operation Events

XVIII

Quality Assurance Project Plan

XIX

Standard Operating Procedures

XX

Closure Plan
Appendices

1

For an R&D approval, this section would present the planned research activities.

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Volume m of n

OPERATING APPROVAL APPLICATION, VERSION #X (IF APPLICABLE) 23
PCB TREATMENT/DISPOSAL UNIT
[Type and location of unit]
[Name and location of company headquarters if different from above]
Operating Approval Application Submission Date: [date]
Test Plan Submission Date/Anticipated Date: [date]

Submitted by:
[Company name and address]
[Principal manager
and phone number]

Submitted to:
Director, Office of Resource Conservation and Recovery
Office of Land and Emergency Management
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Mail Code 5303P
Washington, DC 20460
ORCRPCBs@epa.gov
OR
If submitted to an EPA Regional office, provide the applicable
Region’s address listed at www.epa.gov/pcbs/program-contacts.

Figure 2. Approval Application Cover Page Example.

If the document is revised and resubmitted to EPA, the applicant should clearly indicate on the cover that the report has
been updated (e.g., version 2).
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4.2.3 Approval Application Section I - Summary

The approval application should begin with a short summary presenting the document organization and
any pertinent background information, such as a brief description of the company and the technology for
which approval is requested. Be sure to discuss any unique aspects of the technology being utilized and
point out significant differences, if any, relative to similar processes that are typically used in the
industry. Summarize significant operating parameters that will be monitored and the sampling plan. If
there are any previous application submissions or if a revision was requested by EPA, briefly discuss
any significant changes made. If this is a renewal, briefly discuss past approvals and indicate any
significant changes in the renewal application. In addition, the applicant should give a brief overview of
their company and the operations at the facility requesting the approval, as applicable.

4.2.4 Approval Application Section II - Company Organization/Structure/Personnel

The organizational structure for the facility operation should be briefly described. An organizational
chart identifying key individuals (position titles and actual personnel, if known) should also be provided.
The organizational chart should include the owner, operator, and those personnel directly involved in the
project, as well as the company’s decision maker(s) for PCB treatment/disposal operations, (e.g., plant
manager or superintendent). Relevant contractors should also be included if directly involved with the
project. The corporate structure (e.g., relationship of company officers) is only necessary insofar as it
affects the chain of command for the PCB treatment/disposal facility.
Personnel to be identified may include: 24
• Owner (this may be a corporate entity and not necessarily a single person);
• Principal manager;
• Operations supervisor;
• Environmental compliance manager;
• Reviewing engineer;
• Maintenance supervisor;
• Quality assurance officer;
• Safety officer;
• Laboratory technician;
• Person(s) responsible for training;
• Person(s) responsible for demonstration test;
• Person(s) responsible for operation of monitoring system;
• Person(s) responsible for recordkeeping and reporting; and
• Other relevant personnel involved with the project.

Personnel do not need to be identified for all of these roles, only those applicable to the organization, and one person may
fulfill more than one role.
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4.2.5 Approval Application Section III - Waste Description

A description of the waste(s) the applicant is requesting approval to treat/dispose of in the unit should be
provided. This should indicate the characteristic of the waste(s) (e.g., soil, metal, paint, oil) and its phase
(non-liquid or liquid). Expected PCB concentration in the waste(s) and known Aroclors, congeners, or
homologs should be stated and the applicant should propose PCB feed rates or batch volumes. Include
the composition of the waste(s), and discuss any constituents that may affect the treatment efficiency,
the protectiveness of the treatment device outputs/effluents, and/or create operational hazards; this may
include metals, pH, water, radiation, heating value, viscosity, chlorine concentration, ash, water content,
other hazardous contaminants and potentially more.

4.2.6 Approval Application Section IV - Process Engineering Description

EPA needs sufficient information about the PCB treatment/disposal process to evaluate whether the
operation of the system will: 1) comply with applicable PCB standards/requirements; and 2) not present
an unreasonable risk of injury to health or the environment. EPA will also consider information from the
test plan and the test results when making a decision on an approval.
The operating approval application should include detailed descriptions of the facility, PCB waste/item
handling and storage equipment, treatment system process design, operation and anticipated
performance, and pollution control equipment design and operation. To this end, the information that
may be included in the application is presented in the following subsections as guidance. This is not
necessarily all-inclusive; applicants should provide additional information when appropriate.
4.2.6.1 General Information
The following general information should be presented for the proposed PCB treatment/disposal facility:
• Facility location including site map; this should include a map that clearly shows the proximity
of the facility and treatment unit to the surrounding community, water bodies, schools, local
businesses, as well as stack height and/or emission points/locations. Include population and
census data summaries, ecological receptors, topography maps, elevation of the facility relative
to the 100-year flood water elevation, surface water runoff flow pattern, and locations of sewer
manholes;
• Layout diagram and description of the treatment unit or mobile unit;
• Description of the theoretical basis for the destruction process;
• Detailed engineering drawings; 25
• Process flow diagram (schematic diagram of the system) and narrative description;
• Descriptions and location of measurement devices to be used (e.g., flow meters, temperature and
pressure measurement devices, weightometer);
• Intended operating locations of the mobile unit(s), if applicable (e.g., types of facilities or sites,
specific states and EPA Regions);
• Intended storage location of the mobile unit(s) when not in use, if applicable; and
• Other information necessary for EPA to assess whether the facility or technology poses no
unreasonable risk of injury to health or the environment.

25

Provide a table that defines any labels, if they are not clear, for all drawings and diagrams.

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4.2.6.2 Waste Feed System
Provide a narrative description of the waste feed system (e.g., equipment and procedures for unloading,
storage, and transfer of the PCB materials) and operational controls of the system; specifically, the
secondary containment (e.g., drains, curbs, berms, total volume) and the systems that prevent/detect
leakage and fugitive emissions. Also, describe the waste feed rate measurement method (e.g., pressure
drops, flow meters, calibrated peristaltic pumps, scales, conveyor belts, operator observations).
If applicable, describe the waste preparation system such as filtration, distillation, blending with other
wastes (including PCB wastes) and/or reagents and solvents, crushing, preheating, shredding, or
hammering. Note that § 761.1(b)(5) states that “no person may avoid any provision specifying a PCB
concentration by diluting the PCBs, unless otherwise specifically provided.” Any treatment step that
involves dilution and/or blending should be specifically approved by EPA.
Determine the waste feed storage capacity, the expected average volume of waste feed stored on-site,
and the expected average volume of total waste handled per month. Note that PCB waste storage may
require a commercial storage approval pursuant to § 761.65(d). If required, such storage approval could
be issued together with the treatment/disposal operating approval or as a separate approval. If the
treatment/disposal technology is mobile, provide the waste capacity and average characteristics of waste
stored in the mobile unit(s).
4.2.6.3 Automatic Waste Feed Cutoff System
Describe the automatic waste feed cutoff system when process conditions deviate beyond the required
operational limits that ensure destruction efficiency, compliant emissions, and safe operations, and
discuss any time delay between when process conditions deviate beyond the required operational limits
and when the feed is stopped. In most cases, waste feed should be ceased immediately upon any
operating parameter exceeding allowable limits in the operating approval. The system should detect and
record parameters at a frequency adequate to detect when a parameter is out of range, indicating that the
waste feed should be cut off. Also, provide procedures to cut off the waste feed line and the whole
process in the event of an equipment malfunction, recognizing that, for safety reasons, some process
features (e.g., nitrogen blanket to prevent explosion) may not be appropriate to cut off.
Conditions in which a thermal treatment unit’s waste feed is cut off may include the following:
• Reactor/combustion chamber temperature is less than allowable;
• Excess O2 value is lower than allowable (see requirements in § 761.70 (a)(1)(ii));
• Residence time is lower than allowable;
• Burner flameout occurs;
• CO and CO2 concentration in exhaust gases are different from ranges allowed in the approval;
and
• Other specific process conditions are different from those required by the approval (e.g.,
scrubber water flow rate is less than allowable);
Conditions in which a non-thermal treatment unit’s waste feed is cut off are generally more processspecific, but may include the following:
• Temperature and pressure are outside allowable ranges;
• Reagent flow rate is lower than allowable;
• Residence time in the reactor is lower than allowable or flow rate is higher than allowable; and
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•

Potentially other specific process conditions.

4.2.6.4 PCB Destruction/Removal System
This guidance is separated by thermal and non-thermal destruction/removal technologies to help guide
the reader toward the requirements that would apply to their technology. Thermal destruction
technologies generally use high heat (> 500°C) and require air emissions monitoring and treatment
process/operating parameter monitoring; this typically includes incineration, thermal desorption, or
vitrification. Whereas, non-thermal destruction/thermal technologies destroy/remove PCBs typically in
the absence of high temperatures, and do not require air emissions monitoring. This may include
oxidation, catalytic hydrogenation, solvated electron technology, chemical dechlorination processes (i.e.,
sodium emulsion), or mechanochemical destruction. Applicants should remember that their technology
may not fall exclusively into one category. For example, thermal desorption with a condenser or carbon
filter will use slightly elevated temperatures (relative to an incinerator) to remove PCBs from a medium
but the PCBs are generally not destroyed in the process. In this example, air emissions monitoring will
likely be needed for EPA to determine whether its level of performance is equivalent to disposal in a
§ 761.70 incinerator or a § 761.71 high efficiency boiler and will not present an unreasonable risk of
injury to health or the environment, as required under § 761.60(e). However, many of the operating
conditions may be different from an incinerator and reviewing only the thermal sections of this guidance
may not be comprehensive enough. If this is the case, then it is recommended that applicants review
both thermal and non-thermal sections of this guidance. 26
Information for applications specific to thermal destruction treatment systems may include:
• Detailed narrative description of the treatment/disposal unit. Include engineering data (such as
chamber volume), temperature, flow rates, etc.;
• Engineering diagrams;
• Design capacity of the system;
• Volume of each reactor/combustion chamber(s);
• Target heating values for waste feed and auxiliary fuel to be used;
• Target feed rate for waste feed and auxiliary fuel to be demonstrated during the test;
• Target exit temperature of gases to be demonstrated during the test;
• Calculations showing the minimum residence time at the treatment temperature;
• Description of how flow rates are regulated so that the specified retention time is maintained;
• Normal operating values, target operating levels during the test, and acceptable ranges for
operating parameters for which limits will be established based on levels demonstrated during
the test (e.g., chamber temperature and pressure, volumetric flow rate, waste feed rate, retention
time, air pollution control device [APCD] operating levels, O2 , CO, CO2);
• Discussion of how operating parameters will be measured during the test and during normal
operations (if different). Also, discuss measurement frequencies and averaging periods; 27
• Expected destruction removal efficiency of this unit, based on design criteria or pilot tests;
• PCB mass balance calculation; and

Note that air emissions monitoring may be different during the test compared to normal operations. The applicant should
point out these differences in either the test plan or the application.
27
It is suggested to discuss operating parameter values, ranges, measurement frequencies, and averaging periods with your
approval writer. EPA may have specific requirements to include in the operating approval which will impact how the test is
designed and target operating parameter levels are set.
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•

Information on similarly designed treatment/disposal systems, descriptions/summaries of key
differences (if applicable), and their use for treating waste (with summaries of results, if
available).

Information for applications specific to non-thermal destruction/removal treatment systems may include:
• Detailed narrative description of the treatment/disposal unit. Include a description of the
chemical reactions, stoichiometry, reagents, catalysts, temperature, flow rate, etc.;
• Engineering diagrams;
• Design capacity of the reactor and/or the system;
• List of products and by-products and their expected concentrations;
• Description of reactant/oxidant/fuel/catalyst feed rates and how they are monitored;
• Detailed description of the unique engineering features of the process (e.g., condensers,
residence time, heat transfer);
• Description of any regeneration/recycling processes applied in the system;
• Normal operating values, target operating levels during the test, and acceptable ranges for
operating parameters for which limits will be established based on levels demonstrated during
the test (e.g., chamber temperature and pressure, flow rate, waste feed rate, retention/contact
time) being measured;
• Discussion of how operating parameters will be measured during the test and during normal
operations (if different). Also, discuss measurement frequencies and averaging periods; 28
• Expected destruction removal efficiency of this unit, based on design criteria or pilot tests;
• PCB mass balance calculation; and
• Information on similarly designed treatment/disposal systems, descriptions/summaries of key
differences (if applicable), and their use for treating waste (with summaries of results, if
available).
Remember that the information provided for both thermal and non-thermal destruction/removal
technologies should be based on anticipated normal day-to-day operations for destroying/removing
PCBs. 29 Target operating values should be included and, when applicable, acceptable operating ranges
should also be mentioned. The designed operating parameters of certain components of the system may
also be required, especially if the technology is unique or unfamiliar, to ensure no unreasonable risk of
injury to health or the environment. If the applicant is requesting a renewal, the operating values may be
based on the previous approval unless the applicant is requesting to operate under different operating
values.
The operating limits stated in the operating approval for both thermal and non-thermal
destruction/removal technologies are typically based on the results of the demonstration test. The
applicant should carefully plan their test such that DRE and other standards are met and that the test
operating conditions lead to a set of approval conditions that are workable for anticipated day-to-day
operations. This is discussed in more detail in section 5.1.1. Exceeding the operating limits stated in the
operating approval would result in a violation of the approval, which may result in suspension or
termination of the operating approval.
It is suggested to discuss operating parameter values, ranges, measurement frequencies, and averaging periods with your
approval writer. EPA may have specific requirements to include in the operating approval which will impact how the test is
designed and target operating parameter levels are set.
29
See section 5.1.1 for more information.
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4.2.6.5 Pollution Control System (PCS)
A complete description of the PCS for process effluents (air emissions, liquid effluents, sludge, solid
waste, etc.) should be provided. In addition to providing diagrams of the system, information on the
major design parameters, how they affect performance, and how they will be monitored, should be
included. Include all parameters that are necessary to be monitored and controlled to assure compliance
with regulatory (and subsequent operating approval) requirements. Major design parameters will be
dependent on the PCB treatment/disposal system and may include:
• Total effluent flow rate (may be gas or liquid);
• Pressure drop across the system;
• Exhaust gas or liquid temperature after treatment;
• Type and concentration of pollutants (control system inlet and outlet) if available;
• Design pollution removal efficiency (provide basis, including calculation and/or data/info);
• Expected concentration of PCBs that may be captured (e.g., baghouse material);
• Treatment residence time;
• Minimum reactor/combustion chamber temperatures(s);
• Gas temperature ranges within the dry air pollution device (if equipped with a dry air pollution
control device); and
• Other parameters, as necessary.
Operating parameters for treatment systems, including associated APCDs, will typically be dependent
on the treatment unit design and the APCD used, and may be specific to the target pollutant being
controlled (e.g., PCB, particulate matter [PM], dioxin/furan, or HCl emissions). For example, parameters
assuring proper PCB destruction efficiency may be different from those operating parameters necessary
to control PM emissions. When assessing applicable and appropriate operational parameters, it is
suggested that these parameters be identified up front (in both the operating approval application as well
as the demo test plan) based on the target pollutant to be controlled.
We note that most TSCA incinerators are also permitted to treat hazardous waste in accordance with the
Clean Air Act (CAA) and Resource Conservation and Recovery Act (RCRA) requirements, and the
compliance approach described above is currently required under the Clean Air Act for incinerators that
treat hazardous waste (see § 63.1209(j) thru (p) for CAA requirements and 40 CFR parts 260 through
270 for RCRA requirements). 30
As such, permittees of these incinerators are likely already familiar with the compliance approach
discussed above. Therefore, operating parameters deemed necessary by the TSCA approval writer may
be similar to those already required under RCRA or CAA regulations and would likely not be new or
pose additional burden to the facility.

30
Prior to finalizing the Hazardous Waste Combustion MACT standards, EPA also issued a guidance titled: “Operational
Parameters for Hazardous Waste Combustion Devices” (EPA/625/R-93/008, October 1993”), “Permit Writers Guide to test
Burn Data,” EPA/625/6-86/012, (September 1986), as well as “Guidance on Setting Permit Conditions and Reporting Trial
Burn Results,” EPA/625/6-89/019). These documents may also be useful when assessing applicable operating parameters that
may be necessary to assure compliance with the TSCA PCB emission limitations or to assure the PCB treatment/disposal unit
does not present an unreasonable risk of injury to health or the environment.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 29

Below are a few examples of specific pollution control devices and their respective operating
parameters:
•

Scrubber - Scrubber liquid flow rate, pressure drop across mist eliminator, makeup liquid flow
rate, nozzle operating pressure, pH of scrubbing liquid, liquid discharge rate, lime or other
conditioning agent feed rate, liquid/gas flow rate, and potentially others.

•

Fabric Filter - Differential static pressure between clean and dirty side, dew point of gases,
description of temperature protection device or fabric filter bypass system, air/cloth ratio, bag
material (resistant to chemical and physical properties of the stack gas), description of bag
cleaning system, system for ash removal, and potentially others.

•

Electrostatic Precipitator (ESP) - Number of fields, number of transformer-rectifier sets, total
plate area, primary voltage, primary current, ESP voltage (secondary), ESP current (secondary),
spark rate, description of rapper system, system for ash removal, dust level in hopper indicator,
and potentially others.

Information on the normal operating values and acceptable ranges for significant operating variables
should be included. If information is available in the form of vendor-supplied performance
specifications, it may be substituted. The waste streams of the associated treatment process (e.g., ESP
ash, scrubber liquid, incinerator ash, baghouse dust, carbon) should be discussed, including the method
for disposing of the waste. Also, provide a description of the warning system, if any, used to signal PCS
malfunction.
4.2.6.6 Compendium of All Process Operating Parameters
Provide a table that lists all measured operating parameters, instrument settings, and control equipment
parameters and, for each parameter, provide the target operating value, operating range (i.e., upper and
lower boundaries), and averaging time (or indicate if measured instantaneously). All values should be
reported in common, consistent units. The application also should describe the action to be taken
whenever a parameter deviates outside the control limits. These actions may include adjusting the
operating conditions, stopping the PCB feed, shutting down the process, etc. The time allowable for
corrective action before shutdown or other actions should be specified.

4.2.7 Approval Application Section V - Monitoring and Sampling Plan

This section of the application provides the details of the monitoring and sampling to be conducted
during normal PCB treatment operations. Any monitoring and sampling activities specific to only the
test should be discussed in the test plan (see section 5.2.5). The applicant should develop a monitoring
and sampling plan to monitor process operation and verify that the PCB treatment/disposal achieves the
level of performance equivalent to disposal in a § 761.70 incinerator or a § 761.71 high efficiency boiler
and will not present an unreasonable risk of injury to health or the environment, as required under
§ 761.60(e). These plans should also summarize the monitoring and sampling of the emissions, effluent
parameters, and pollution control equipment for the specific treatment process. The objective should be
to obtain results that are representative of the conditions at which the unit is operating. In cases where
samples may not be representative of the conditions at which the unit is operating, a worst-case result
should be obtained (i.e., sample when the process is least likely to achieve the required treatment
standards). In cases where problems can be anticipated (e.g., instrument failure), contingencies should
be included in the monitoring and sampling plan. A tabular format, with narrative explanation, as
Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 30

necessary, can be used to summarize the monitoring and sampling plan.
Note that information in this section may overlap with information discussed in subsequent sections
(i.e., monitoring procedures and sampling procedures, section 4.2.8 and section 4.2.9, respectively). This
section is intended to discuss what methods will be used and where/how each will be applied in the
treatment process. Discussion of the method itself and how each method is conducted is found in the
subsequent sections. There is some overlap between these sections and the applicant may combine the
monitoring and sampling plan and methods into one section of their application, but should be sure to
review and include applicable information discussed in all three sections within this guidance (sections
4.2.7, 4.2.8, and 4.2.9). Remember that there are some subtleties between each section, for example,
measurement frequency could refer to the frequency used during normal operation, during the
demonstration test, or the measurement frequency capabilities of the instrument; all three may be
different. Furthermore, the recording frequency may differ from the measurement frequency.
Generally, the monitoring and sampling plan for both thermal and non-thermal destruction/removal
technologies should discuss the following basic information:
• Process parameters to be monitored;
• Monitoring locations;
• Monitoring methods;
• Monitoring frequencies;
• Effluent streams to be sampled;
• Sampling locations;
• Sampling methods;
• Sampling frequencies;
• Analysis methods; and
• Acceptable operating limits to meet effluent criteria (see section 4.1.2 for criteria).
There are several parameters that the Agency may require to be monitored and sampled depending on
the treatment/disposal unit, such as: waste feed rates, reactor temperature, residence time, emissions,
pollution control devices, and others. When discussing the parameters to be monitored and sampled, the
application should:
• Present the location and provide a brief description of the system or monitoring/sampling
process;
o Breakdown into discrete activities (e.g., stack emissions, combustion chamber operating
parameters, APCD operating parameters, liquid waste, ash, product);
• Discuss the monitoring/sampling objective for each location (e.g., collect a “representative”
sample; monitor and record combustion zone temperature; establish APCD operating limits;
follow an EPA test protocol; or collect a “worst-case” sample);
• List the substance or property to be monitored/sampled at each location;
o Monitored parameters may include O2, CO, CO2, temperature, or pressure;
o Sampling parameters may include the list of the compounds to be analyzed and media
characteristics;
• List the cleanup, extraction, and analytical methods to be used;
• Discuss the monitoring and sampling design for each location. Include a mathematical design or
a reference to a standard protocol, as needed;
o The monitoring design should include the measurement frequency (e.g., every second,
Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 31

•
•

every 15 minutes), averaging time, recording frequency, and any timing delay (e.g., any
time between reaching steady-state conditions and when monitoring began); 31
 Anticipated operating ranges for these monitored parameters should be specified
in the process engineering information, as described previously in section 4.2.6;
 A justification may be required if the frequency of measurement/recording times
are longer than typical industry standards at the time the application is received by
EPA or if the measurement frequency is longer than what EPA believes is needed
to prevent an unreasonable risk of injury to health or the environment;
o The sampling design should include the frequency (e.g., once per batch), size (e.g.,100
grams), timing (e.g., at the end of each batch run), number of replicates (e.g., duplicates
for 10 percent of the samples or 2 samples, whichever is greater), and the total number of
samples should be listed for each sample type;
 An estimate of the sample representativeness. This may be based on data (e.g.,
historical data on replicates) or scientific/engineering judgment (e.g., a sample
from an actively mixed feed tank could be characterized as representative);
 Indicate if grab or composite sampling is used at each location and describe the
procedure;
 A justification may be required if the frequency of sampling is longer than typical
industry standards at the time the application is received by EPA or if the
sampling is less than what EPA believes is needed to prevent an unreasonable risk
of injury to health or the environment;
Include contingencies for action if monitoring data cannot be collected according to plan (e.g.,
alternative sampling sites or times, an entirely new sampling plan, or repeat tests); and
Discuss any safety considerations to prevent injury to workers or the local community (e.g.,
integrity measurements, pressure control measures, measurement of the buildup of hazardous
constituents, etc.).

The following subsections differentiate the monitoring and sampling requirements specific to thermal
and non-thermal destruction/removal technologies.
4.2.7.1 Monitoring and Sampling Plan for Incineration and Alternative Thermal Destruction
Technologies
Destruction of PCBs by thermal methods should, at a minimum, follow the requirements established in
§ 761.70(a). For example, monitoring and recording should be conducted for O2, CO, and CO2 whenever
the thermal unit is used to destroy PCBs. Provide the frequency that O2, CO, and CO2 measurements are
taken and the interval that a value is recorded. 32
Pursuant to § 761.70, when a thermal unit is first used to destroy PCBs or following a modification to
the incinerator that may affect the characteristics of the stack emission products, monitoring of the stack
emission products should be conducted for O2, CO, CO2, NO x, HCl, RCl (residual chloride compounds),
PCBs, and total particulate matter. The measurement of these parameters is discussed in section 5 (Test
Note that, in some instances there is a difference between a measured value and a recorded value. For example, during
continuous emissions monitoring a measured value may be taken every 15 seconds and a value may be recorded every 60
seconds.
32
See section 2.3 of this guidance for incinerator requirements.
31

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

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Plans) of this document.
In addition to those required by § 761.70, an applicant should propose any additional monitoring and
sampling parameters that are necessary to ensure the operation of the PCB treatment/disposal unit does
not present an unreasonable risk of injury to health or the environment and, for an applicant for an
alternative technology, to verify that PCB destruction is equivalent to disposal by incineration. 33 The
approval writer may determine it necessary for the facility to monitor/sample more parameters during
normal operations to assure compliance with PCB regulatory requirements and/or assure operation of
the incinerator does not present an unreasonable risk of injury to health or the environment. Additional
parameters will vary based on the design of the treatment/disposal unit and associated pollution control
systems, as applicable. Example additional operating parameters include, but may not be limited to:
• PCB concentration in the waste feed to calculate the Destruction and Removal Efficiency (DRE);
• Polychlorinated Dibenzo-p-dioxin (PCDD) and Polychlorinated Dibenzofuran (PCDF) (tetrathrough octachloro homologs, 2,3,7,8-tetrachlorodibenzodioxin, and 2,3,7,8tetrachlorobidenzofuran) in the stack emissions; and
• PCB, PCDD, and PCDF concentrations in any solid or liquid wastes generated.
The monitoring and sampling plan also should identify the appropriate combustion system and pollution
control system operating parameters that will be monitored and recorded during normal operations (e.g.,
minimum residence time, batch feed operating parameters, liquid waste atomization parameters,
scrubber water flow rate, pressure drop).
A schematic diagram can be used to illustrate the monitoring points; Figures 3 and 4 are examples for an
incinerator and a thermal desorber, respectively. The specific location of the sampling point should be
discussed briefly in the narrative (e.g., the liquid waste sample will be collected from the feed line just
prior to the injection nozzle). Other important parameters of the monitoring plan can be concisely
presented in a tabular format; Tables 3 and 4 provide example summary tables of monitoring and
sampling parameters for incinerators. Tables 5 and 6 provide summary examples of monitoring and
sampling plans for an alternative thermal destruction technology.
Note that in the tables below stop operation/repair system (SORS) means to immediately stop feeding
PCB waste into the treatment system and potentially shut the PCB treatment process down for repairs.
Batch processes may need to restart the treatment process for the same batch after repairing. The entire
system may not need to be shut down but treatment of PCB waste should stop until the system is
repaired. Facilities should utilize their automatic waste feed cutoff systems and other standard protocols
developed for shutting down their system and/or making repairs.

33

40 CFR 761.70(d)(4)(ii), 60(e).

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

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2

Afterburner

Primary
Chamber

3

Quench

1

5

8

9

Venturi
Scrubber

Scrubber
Spray
Tower

7

Stack

12 Make-Up

Demister

6
5

Combustion
Air

4
Waste Feed
Bulk Storage
Tank

Sump

Sump

10

11

Discharge

Discharge

13

Make-Up

# - Sampling/monitoring point as described in Table 5.

Figure 3. Example Schematic of Monitoring and Sampling Points for an Incinerator (see Tables 3 and 4 for monitoring and sampling
parameters)

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 34

Table 3. Example Summary of Monitoring Parameters for Incinerators 1

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed in the table relevant to all technologies.
Furthermore, applicants are not required to use this table or submit it to EPA.
Parameter

Method

Frequency

Location

[To be
determined
(TBD)]

1

Target Value

Backup to Monitoring Instrument

5.5 %

Stop Operation/Repair System
(SORS)

Oxygen

Continuous emissions
monitor (CEM)

Carbon monoxide (CO)

CEM

[TBD]

1

20 parts per million (ppm)

SORS

Carbon dioxide (CO2)

CEM

[TBD]

1

12 %

SORS

Combustion temperature

Shielded thermocouple

[TBD]

2, 3

1250 °C

SORS

Incinerator pressure

Pressure transducer

[TBD]

2, 3

[negative pressure] atm

SORS

Waste feed rate

Volumetric or mass flow
meter

[TBD]2

4

[TBD] kilograms per hour
(kg/hr)

SORS

Residence time

Gas velocity (Annubar®)

[TBD]

5, 6

2.2 seconds

SORS

Combustion efficiency

Automated calculation

[TBD]

NA

99.9%

Manual calculation

Venturi pressure drop

Pressure transducer

[TBD]

7

[TBD] inches of water (in H2 O)

SORS

Venturi scrubber liquid flow

Rotameter

[TBD]

8

[TBD] gallons per minute (gpm)

SORS

Spray tower liquid flow

Rotameter

[TBD]

9

[TBD] gpm

SORS

Quench water discharge

Volumetric flow meter

[TBD]

10

[TBD] gpm

SORS

Scrubber liquid discharge

Volumetric flow meter

[TBD]

11

[TBD] gpm

SORS

Quench water make-up

Volumetric flow meter

[TBD]

12

[TBD] gpm

SORS

[TBD]

13

[TBD] gpm

SORS

[TBD]

NA

99.9999 DRE of PCBs

SORS

[TBD]

NA

[TBD] ppm

SORS

Scrubber liquid make-up
Volumetric flow meter
PCB emissions to ambient
EPA SW-846 Method
air
0010
Dioxin/Furan emissions to
EPA SW-846 Method
ambient air
0023A
1
Location points refers to Figure 3.
2
No less frequent than every 15 minutes. See § 761.70(a)(3).

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 35

Table 4. Example Summary of a Sampling Plan for Incinerators 1

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed in the table relevant to all technologies.
Furthermore, applicants are not required to use this table or submit it to EPA.

Sampling/Extraction
Method

Sampling
Frequency

Waste feed

Composite sample,
Method 3540

Ash/Residue
Quench water
discharge

Parameter

1

Analysis methods

Target Value

Backup Plan for
Sample Collection,
Extraction, or
Analysis

PCB homologs

SW-846 Method
8082

Not applicable
(NA)

Hold batch until
sample obtained

NA

PCB homologs

SW-846 Method
8082

≤ 2 parts per
million (ppm)

Hold batch until
sample obtained

10 and 11

PCB homologs

EPA Method 608

≤ 0.5 parts per
billion (ppb)

Hold batch until
sample obtained

Location

Analysis
parameters

[To be
determined
(TBD)]

1

Composite sample,
Method 3540

[TBD]

Grab sample, Method
3540

[TBD]

Location refers to Figure 3.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 36

2

Afterburner

Primary
Chamber

3

Quench

1

5

8

9

Venturi
Scrubber

Scrubber
Spray
Tower

7

Stack

12 Make-Up

Demister

6
5

Combustion
Air

4
Waste Feed
Bulk Storage
Tank

Sump

Sump

10

11

Discharge

Discharge

13

Make-Up

# - Sampling/monitoring point as described in Table 5.

Figure 4. Example Schematic of Monitoring and Sampling Points for a Thermal Desorber Unit (see Tables 5 and 6 for sampling and
monitoring parameters).

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 37

Table 5. Example Summary of Monitoring Parameters for an Alternative Thermal Destruction Technology 1

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed in the table relevant to all technologies.
Furthermore, applicants are not required to use this table or submit it to EPA.

Parameter

Method

Frequency

Location

Target Value

Backup to Monitoring Instrument

Oxygen

Continuous emissions
monitor (CEM)

[TBD]

9

[TBD] %

Stop Operation/Repair System (SORS)

Carbon monoxide (CO)

CEM

[TBD]

9

[TBD] ppm

SORS

Carbon dioxide (CO2)

CEM

[TBD]

9

[TBD] %

SORS

Waste feed rate

Volumetric or mass flow
meter

[TBD]2

1

[TBD] kg/hr

SORS

Dryer temperature

Thermocouple

[TBD]

2, 3

[TBD] °F

Product temperature

Thermocouple

[TBD]

2, 3

[TBD] °F

Carrier gas temperature

Thermocouple

[TBD]

2, 3

[TBD] °F

Dryer internal pressure

Pressure transducer

[TBD]

2, 3

[TBD] in. WC

Carrier gas temperature

Thermocouple

[TBD]

Carrier gas temperature

Resistance-Temperature
Detector (RTD)

[TBD]

Pressure transducer

[TBD]

Gas System

[TBD] in. WC

Residence time
Bag house pressure
drop
Quench water
discharge
Quench tower liquid
flow

Gas velocity (Annubar®)

[TBD]

2, 3

[TBD] seconds

SORS

Pressure transducer

[TBD]

4

[TBD] in. WC

SORS

Volumetric flow meter

[TBD]

6

[TBD] gpm

SORS

Rotameter

[TBD]

7

[TBD] gpm

SORS

Process vent flow

Flow meter

[TBD]

9

[TBD] cfm

Repair or replace meter. Rely on valve position and
dryer pressure to control flow.

Gas system differential
Pressure

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Condenser system
inlet
Condenser system
outlet

[TBD] °F
[TBD] °F

Rely on redundant thermocouples. Repair/replace
within 1 day or stop operation.
Rely on redundant thermocouples. Repair/replace
within 1 day or stop operation.
Rely on redundant thermocouples. Repair/replace
within 1 day or stop operation.
Rely on local pressure indicator Repair/replace within
1 day or stop operation.
Replace thermocouple. Rely on local temperature
indicator.
Rely on redundant RTD. Repair/replace within 1 day
or stop operation.
Rely on local pressure indicator. Repair/replace
within 1 day or stop operation.

Page 38

Table continued from previous page.
Parameter

Method

Frequency

Location

Nitrogen flow

Flow meter

[TBD]

Nitrogen feed
line

Pre-filter differential
pressure

Press indicator

[TBD]

8

HEPA filter differential
Press indicator
[TBD]
pressure
PCB emissions to
EPA Method 0010
[TBD]
ambient air
1
Location points refers to Figure 4.
2
But no less frequent than every 15 minutes, consistent with § 761.70(a)(3).

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Target Value
[TBD] standard
cubic feet per
minute (SCFM)
[TBD] inches
water column
(in.WC)

Backup to Monitoring Instrument
Repair or replace flow meter. Rely on O2 conc. and
dryer pressure to control N2 flow.
Replace during normal maintenance.

8

[TBD] in.WC

Replace during normal maintenance.

9

[TBD] %

SORS

Page 39

Table 6. Example Summary of a Sampling Plan for an Alternative Thermal Destruction Technology 1

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed in the table relevant to all technologies.
Furthermore, applicants are not required to use this table or submit it to EPA.

Analysis methods

Target Value

[To be
determined
(TBD)]

Backup Plan for
Sample Collection,
Extraction, or
Analysis

1

PCB homologs

EPA Method 8082

Not Applicable
(NA)

Hold batch until
sample obtained

[TBD]

6

PCB homologs

EPA Method 608

≤ 0.5 ppb

[TBD]

10

PCB homologs

EPA Method 8082

≤ 2 ppm

[TBD,
periodically to
check for
breakthrough]

8

PCB homologs

EPA Method 8082

≤ 2 ppm

Parameter

Sampling
Frequency

Waste feed

Grab sample, EPA
Method 3540

Water Discharge
Treated Stockpile
Carbon Breakthrough
1

Location

Analysis
parameters

Sampling/Extraction
Method

Grab sample, EPA
Method 3540
Composite sample,
EPA Method 3540
EPA Method 3540

Location refers to Figure 4.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 40

Hold batch until
sample obtained
Hold batch until
sample obtained
Hold batch until
sample obtained

4.2.7.2 Monitoring and Sampling Plan for Alternative Non-Thermal Destruction/Removal
Technologies
A monitoring and sampling plan for non-thermal processes should verify that the PCB
treatment/disposal unit achieves a level of performance equivalent to disposal in a § 761.70 incinerator
or a § 761.71 high efficiency boiler and will not present an unreasonable risk of injury to health or the
environment, as required under § 761.60(e). This may not be straightforward as it will depend on the
type of non-thermal treatment unit. At a minimum, this will include measurements of PCBs in the final
product and effluent streams (wastewater, filters, vent gas, treated oil, etc.). For separation treatment
processes (e.g., carbon filtration) where PCBs are concentrated into a fraction for subsequent
treatment/disposal by an approved method, the applicant should propose a set of monitoring and
sampling parameters to verify that (a) the residual “clean” fraction contains ≤ 2 ppm PCBs (see section
2.4), (b) levels of PCBs emitted from the system through drains, vents, etc. are within regulatory
standards, and (c) the process does not present an unreasonable risk of injury to health or the
environment. The monitoring and sampling parameters will depend upon the process design and the
waste feed and effluent streams associated with the alternative treatment/disposal method. Process
operating parameters that affect performance of the unit (e.g., feed rate, reaction temperature, and
pressure) should be monitored and recorded. The applicant should describe all the operating parameters
that are necessary to assure compliance with the PCB regulations and to ensure no unreasonable risk of
injury to health or the environment in the monitoring and sampling plan. This would include pollution
control system operating parameters, if applicable.
A schematic diagram can be used to illustrate the monitoring and sampling locations; Figure 5 is an
example. The diagram should depict the specific location of each sampling point and sampling locations
should further be discussed in the narrative. Because each alternative method for treatment/disposal of
PCBs is uniquely different, the applicant should specify the process parameters that will be monitored
and the effluent streams that will be sampled during normal operations. Table 7 is an example of a
tabular summary of monitoring parameters for a chemical dechlorination process. Table 8 provides an
example of a sampling plan for a chemical dechlorination method.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 41

To Atmosphere

9
Vent

Carbon
Adsorption
Unit

Bulk Storage
Tank

4

8

1

6

Reagent

7

Quench

Reaction
Vessel

2
5
Vent

Bulk Storage
for Product
Legend
- Monitoring Location as described in Table 9

3

- Sampling Location as described in Table 9

Figure 5. Example Schematic of Monitoring and Sampling Points for a Chemical Dechlorination
Process (see Tables 7 and 8 for monitoring and sampling parameters).

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 42

Table 7. Example Summary of Monitoring Parameters for a Chemical Dechlorination Process 1

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed in the table relevant to all technologies.
Furthermore, applicants are not required to use this table or submit it to EPA.
Parameter
Waste feed rate
Product flow rate
Reagent feed rate
Quench feed rate

1

Method
Volumetric or mass flow
meter
Volumetric or mass flow
meter
Volumetric or mass flow
meter
Volumetric or mass flow
meter

Target Value

Backup to Monitoring
Instrument

Frequency

Location1

[To Be Determined
(TBD)]

4

[TBD] kg/hr

Stop Operation/Repair
System (SORS)

[TBD]

5

[TBD] kg/hr

SORS

[TBD]

6

[TBD] gpm

SORS

[TBD]

7

[TBD] gpm

SORS

Residence time

Manually calculate

[TBD]

NA

[TBD] minutes

Manually Calculate

Reaction vessel pressure

Pressure transducer

[TBD]

8

[TBD] in. WC

SORS

Reaction vessel temperature

Thermocouple

[TBD]

8

[TBD] °F

SORS

Vent emissions

Total hydrocarbon analyzer

[TBD]

9

[TBD]

SORS

Refers to Figure 5.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 43

Table 8. Example Summary of a Sampling Plan for a Chemical Dechlorination Process 1

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed in the table relevant to all technologies.
Furthermore, applicants are not required to use this table or submit it to EPA.

Parameter

1

Sampling/Extraction
method

Sampling
Frequency

Location1

Analysis
parameters

Analysis
methods

Target
Value

Backup Plan for
Sample Collection,
Extraction, or
Analysis

Waste feed

Grab sample, EPA
Method 3540

[To Be Determined
(TBD)]

1-Storage tank
line tap

PCB homologs

EPA Method
8082

Not
Applicable
(NA)

Hold batch until
sample obtained

Process product

Grab sample from
reactor tap

[TBD]

2-Reactor vessel
line tap

PCB homologs

EPA Method
8082

≤ 2 ppm

Hold batch until
sample obtained

Grab sample from
storage tank

[TBD]

3-Product storage
tank

PCB homologs

EPA Method
8082

≤ 2 ppm

Hold batch until
sample obtained

Location refers to Figure 5.

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4.2.8 Approval Application Section VI - Monitoring Procedures

For facilities using monitoring systems, a detailed discussion of the monitoring methods that will be
used during normal operations should be included in this section of the approval application. The
discussion for each monitor that will be used to measure/track/record each parameter may include:
• Type of instrumentation used during normal operations;
o Manufacturer and model number;
o Monitor/instrument operational specifications (e.g., range, accuracy, and interferences);
o Measurement frequency capabilities;
o Operating temperature range of monitor, if monitor is in-situ type;
o Description of the calibration procedures and frequency;
o Description of the routine and preventive maintenance procedures and frequency;
• Description of monitor operation;
o Parameter/pollutants being monitored for normal operations;
o Monitoring locations, and an explanation why each location was chosen and why it
results in representative samples/parameter measurements;
o Measurement frequency capabilities as compared to the proposed parameter recording
frequencies, including a brief description of how the monitor output will be used to
assure compliance with the levels demonstrated during the performance test;
o Description of the data acquisition and recording system for all operating parameters,
including a description of how the data acquisition system calculates and records
operating parameter levels consistent with the anticipated limitations that will be required
based on the levels demonstrated during the performance test;
o Description of the process to physically extract a sample if the monitor is extractive,
including necessary sample conditioning systems (if applicable);
o Evidence that the monitoring method will generate reliable data (e.g., performance data
from a dry run of the system using non-TSCA-regulated waste);
o Description of the system for triggering automatic feed cutoff, if applicable;
o Contingency for monitor failure (e.g., install and calibrate second monitor); and
o Description of any data processing that will be done such as, data reduction procedures,
calculations, etc.

4.2.9 Approval Application Section VII - Sampling and Analysis Procedures

A detailed discussion of the sampling and analysis methods to be used during normal operations should
be included in this section of the approval application. When “standard methods” will be used, they may
be referenced and included as an appendix. However, any deviations from standard procedures should
be noted. Furthermore, when the standard method allows different procedural variations to be used, the
applicant should be specific as to the procedures that will be followed.
BE AWARE THAT CERTAIN CHEMICALS, SUCH AS PHTHALATES IN PLASTICS, CAN CAUSE
INTERFERENCE IN ANALYSIS. A LSO, SILICONE CAN MAKE PCB S DIFFICULT TO EXTRACT
AND EXTENDED EXTRACTION TIMES MAY BE REQUIRED

A discussion of the sampling and analysis procedure should be provided and may include:
• A summary of the sampling and analytical procedures;
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o This may overlap with the procedures discussed in the monitoring and sampling plan, in
which case it may be referenced. For more information, see section 4.2.7;
o Be sure to include any information regarding the sampling method that may be missed in
the monitoring and sampling plan. For example, the applicant may have indicated they
were taking composite samples from a waste pile after treatment. There are many ways to
take composite samples; therefore, it is important that the compositing method is
discussed in detail in this section;
o Summarize analytical procedures and any procedures used to prepare the sample,
including the EPA method numbers and any deviations from the methods, the applicant’s
method numbers, and whether an on-site laboratory will be used;
o Indicate the sampling locations, and an explanation for why each location was chosen and
results in representative samples/parameter measurements;
o Describe how the samples are stored, preserved, and recovered;
o Discuss how samples are transported and how custody is transferred;
A description of the sampling and analytical equipment/apparatus used to take, transport, extract
and analyze a sample;
o Include the equipment manufacturer and model number;
o Provide sampling and analytical equipment specifications, if applicable (e.g., range,
accuracy, and interferences);
o Describe how the sampling and analytical equipment is calibrated, standards used, and
the frequency with which it is calibrated;
o Describe any reagents used during sampling and analysis, and discuss how the reagents
will be prepared and used;
o Describe the routine and preventive maintenance procedures and frequency;
A description of any data processing that will be done, such as data reduction procedures, data
validation procedures, calculations, etc.

Specific details of some analytical procedures may be referenced (if a standard published procedure) or
included as an appendix (if unpublished or if the publication is not readily available). If needed, include
a description of when it is appropriate to analyze for PCBs as homologs or congeners.
Appendices C and E of this document provide guidance on monitoring, sampling, and analysis
procedures of various matrices and list various sample methods.

4.2.10 Approval Application Section VIII - Data Recordkeeping and Reporting

The approval application should explicitly state what data will be recorded (including units), how it will
be recorded, how it will be handled by the applicable data system to calculate operating levels in the
units/averaging periods that will be established as operating limits based on performance test data, and
how the data records will be maintained. Include example calculations, units of measurement, and
example record reporting forms and/or description of the electronic data recording system. Sections
761.180(b) and 761.180(c) establish the minimum data record requirements for disposers of PCB waste
and incinerator facilities, respectively. Section 761.180(b) requires that each PCB disposal facility
maintain annual records on the disposition of all PCBs and PCB Items and prepare and maintain an
annual document log. The annual document log must be prepared by July 1 for the previous calendar
year. The annual records must include all signed manifests and Certificates of Disposal that have been
generated or received at the facility during the calendar year and all records of inspections and cleanups
performed in accordance with § 761.65(c)(5). The annual records must be maintained at the facility for
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at least three years after the facility is no longer used for the disposal of PCBs and PCB Items. The
annual document log must include the information in § 761.180(b)(2). The annual report must briefly
summarize the records and annual document log required to be maintained under § 761.180(b)(1) and
(b)(2) and must consist of the information in § 761.180(b)(3). (EPA anticipates use of e-Manifest to
maintain these documents, once relevant functionality becomes available.)
Section 761.180(c) requires additional records and monitoring for incineration facilities. The
information specified in § 761.180(c) must be maintained for a period of five years from the date of
collection. (EPA anticipates use of e-Manifest could satisfy the requirements in § 761.180(c), once
relevant functionality becomes available.)

4.2.11 Approval Application Section IX - By-Product Waste Handling and
Treatment/Disposal

The approval application should identify any by-product waste (both PCB and non-PCB) or potential
wastes that would need to be sampled/analyzed to determine if they would be considered waste, that will
be generated (e.g., in-line filters for the PCB waste feed line, process water, or solid residues generated
such as incinerator ash). The application should also discuss how waste that is generated will be
handled/stored/disposed, including whether such waste is subject to state or federal regulations, e.g.,
RCRA.

4.2.12 Approval Application Section X - Inspection Procedures

The approval application should identify the routine inspection procedures used to identify problems and
malfunctions associated with the facility. Also, the frequency of inspections should be discussed.
Inspection procedures should be identified for items such as:
• Waste feed system;
• Destruction system;
• Waste feed cutoff system;
• Pollution control system;
• Process operation alarms;
• Storage areas;
• Secondary containment areas;
• Spill collection systems (e.g., portable booms); and
• Fire suppression equipment/system.

4.2.13 Approval Application Section XI - Spill Prevention, Control, and
Countermeasures Plan

Discuss the procedures at the facility that will be used to prevent PCB spills and how to respond to any
PCB spills that occur. The regulations stated in 40 CFR part 112 can serve as an example for the spill
prevention, control, and countermeasures (SPCC) plan; however, the plan in the approval application
need not be in the format or in the detail specified in 40 CFR part 112. 34 Examples of procedures to
include in the SPCC plan may include, but are not limited to:
• Secondary containment for any stored PCB wastes and PCB-contaminated by-products
(secondary containment of two times the volume of the largest container/article or 25% of the
34

When reading 40 CFR part 112, consider “Oil(s)” to mean “PCB(s)” whenever it appears.

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total volume of PCB articles/containers, whichever is greater);
Spill reporting and cleanup procedures; 35
Procedures for storage and transfer operations;
Information on design elements and inspection procedures used to prevent spills and the planned
response to spills, with responsible individuals identified; and
Reporting requirements, cleanup procedures, and disposal methods for any contaminated residual
materials.

4.2.14 Approval Application Section XII - Safety Plan

The approval application should present a description of a site-specific safety plan that will be initiated
to protect workers and the general population from PCB exposure or other health hazards. A copy of the
site-specific safety plan should be kept on-site where operations will occur.
The following information may be included in each siteSPECIAL SAFETY CONSIDERATIONS
specific safety plan:
SHOULD BE GIVEN TOWARD THE
• Scope of work (general description of the
USE OR BUILDUP OF
treatment process and any hazardous materials to
HAZARDOUS/ REACTIVE
be used);
COMPOUNDS, SUCH AS SODIUM ,
• Project personnel, including roles, responsibilities
and qualifications, name of on-site safety
HYDROGEN , OR HYDROCHLORIC
coordinator, and name(s) of any on-site
ACID
cardiopulmonary resuscitation (CPR)/First-Aid
certified person(s);
• Emergency contact information, including local authorities (e.g., local fire and police
departments) and nearest medical facility that would accept patients contaminated with
chemicals;
• Hazard identification (e.g., potential for reactions/fires) and control/mitigation measures;
• Procedures for handling of dangerous and pyrophoric chemicals;
• Required personal protective equipment (PPE);
• Names of all chemicals used at the facility along with approximate quantities and the
corresponding safety data sheets (SDS);
• Provide any additional precautions that may be needed to ensure adverse reactions/spills do not
occur overnight or during system down/idle times;
• Monitoring methods used such as smoke alarms;
• Discuss the automated fire suppression systems, if applicable;
o Describe how the fire suppression system is compatible to the waste and treatment
system (e.g., sodium fires require specialized equipment);
• Procedures for shutting off equipment in case of an emergency;
• Emergency action plan(s) specifying the following:
o Contact information – project and property management, and the persons responsible for
handling emergencies (with 24-hour a day contact in the event of an emergency),
including both phone numbers and email addresses;
o Plans for coordination with/notification to local emergency responders;
o Evacuation plan(s);
35

See 40 CFR 761.125 for more information.

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o
o
o
o
o
o

First aid location(s);
Eye-wash station location(s);
Fire extinguisher location(s);
Location of SDS;
Flammable storage area(s); and
Smoking/non-smoking areas.

Locate the treatment operations/equipment at an adequate safety distance so that they will not present an
unreasonable risk of injury to health or the environment. For example, a unit with the potential to cause
a fire should maintain a minimum distance away from any storage area for flammable or combustible
materials (e.g., flammable liquid storage tanks or drums) or any sensitive ecosystem if the treatment unit
is operated outdoors. All necessary precautionary measures should be taken to ensure that operations
follow the applicable safety and health standards, as required by federal, state and local laws, regulations
and ordinances.
Note that, as a condition of the PCB approval, the applicant may be required to report any lost-time
injury to the PCB coordinator in the appropriate EPA Regional office by the next business day.
Typically, it is a good practice to also draft a report describing the accident and submit it to the ORCR
Office Director at EPA Headquarters.

4.2.15 Approval Application Section XIII - Training Plan

The approval application should present a description of the training program that will be initiated to
assure workers are trained in items appropriate to their jobs. The training plan will ensure that personnel
directly involved with operations are familiar with the requirements of the approval.
The following documents should be included in the training plan and made accessible to personnel:
• The operating approval;
• The operating approval application;
• The test approval request and associated test approval issued by EPA;
• The Site-Specific Safety Plan;
• The Spill Prevention, Control and Countermeasure Plan; and
• Sampling and analytical procedures. 36
Personnel should be trained on the following items:
• The type of PCBs treated and the upper PCB concentration limits which may be treated,
including the dangers PCBs present;
• The recordkeeping, notification and reporting requirements, and the location of records and
retention times;
• Equipment operation and emergency shutdown procedures and standard operating procedures
(all employees should sign and date a statement indicating the employee has read and understood
SOPs);
• The handling and/or PCB waste disposal requirements as described in the approval for process
waste, and other materials generated during operations;
• The handling of dangerous and pyrophoric chemicals (e.g., sodium or potassium);
36

The sampling and analytical procedures should also be maintained in the laboratory conducting the analyses.

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The safety, operating, and maintenance procedures;
The procedures for using, inspecting, repairing, and replacing emergency and monitoring
equipment, with an emphasis on the fire suppression equipment;
PCB Spill Cleanup Policy 40 CFR 761 subpart G;
Sampling and analytical procedures (as needed); and
The Spill Prevention, Control and Countermeasure Plan.

4.2.16 Approval Application Section XIV –Test Plan Summary

This section of the approval application should briefly summarize the applicant’s plans for conducting a
test; a separate detailed plan is required prior to conducting a test (see section 5 of this document).
However, summary information that should be presented in this section includes:
• Tentative date (month/year) for the test;
• Tentative location for the test;
• Parameters to be tested;
• Planned duration of each run;
• Number of runs;
• Type and quantity of waste to be used in each run; and
• Expected/actual submittal date of the detailed test plan.
If possible, please display the major operating parameters to be tested in a table, organized by run. This
provides a quick reference table that can also be used in the test plan.

4.2.17 Approval Application Section XV - Test Data or Engineering Performance
Calculations

The applicant should summarize any relevant data from R&D activities, previous tests using either
TSCA regulated or non-TSCA regulated waste, or other relevant testing/data, and engineering
calculations that support the ability of the system to comply with applicable PCB requirements. Detailed
test results need not be presented in this section, but instead may be summarized and provided as an
appendix or referenced if already on file with EPA.

4.2.18 Approval Application Section XVI - Other Permits and Approvals

Provide a list of other regulatory requirements the treatment/disposal unit is, or will be, subject to and
include brief discussions of the permits/approvals, that have been or will be obtained for the disposal
unit. Also, identify the permitting agency and the person to contact for additional information (permit
writer). Some regulations are self-implementing and, if applicable to the treatment unit, then they should
also be mentioned in this section. Relevant approvals/permits/requirements include, but are not limited
to:
• Prior or current PCB approvals issued by EPA (Region or Headquarters);
• State or local permits to operate;
• RCRA permits;
• Clean Air Act permits (e.g., Title V permits) or other requirements (e.g., hazardous waste
combustion National Emission Standards for Hazardous Air Pollutants (NESHAP));
• National Pollutant Discharge Elimination System (NPDES) permits;
• Nuclear Regulatory Commission (NRC) permits;
• Department of Energy (DOE) permits; and
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Department of Transportation (DOT) permits and/or requirements.

4.2.19 Approval Application Section XVII - Schedule of Events

Provide a proposed schedule (month and year) for complying with the regulatory requirements
associated with approval of the facility. Scheduled items to be addressed may include: beginning
construction date and completion date, submittal of test plan, equipment shakedown period, initiation of
test, submittal of test results, and initial operating date. A Gantt chart is a useful tool for displaying the
proposed schedule of events.

4.2.20 Approval Application Section XVIII - Quality Assurance Project Plan

Each approval application should include a quality assurance project plan (QAPP) and the plan should
be included in the application’s appendix. An example template for a QAPP is provided in
Appendix D. 37 The QAPP should address all measurement (e.g., monitoring) parameters and datagenerating activities (e.g., process monitors and controllers), not just chemical laboratory analysis. This
plan should conform to the specifications established in “Guidance for Quality Assurance Project Plans,
EPA QA/G-5” (U.S. EPA, 2002). Additional guidance in the preparation of a QAPP is available in
“EPA Requirements for Quality Assurance Project Plans” (U.S. EPA, 2001). Note that every technology
is different and may require different testing or monitoring. As such, some elements of a QAPP may not
be applicable to all technologies, therefore, EPA may require some elements to be included in one
QAPP but not another. Where the QAPP repeats information in other submitted documents, a reference
to the applicable document and section is sufficient. If the applicant will be using their own on-site
laboratory, SOPs for laboratory procedures should be included in the QAPP.
The purpose of the QAPP is to establish a specific program to: (a) help assure that the monitoring data
meet specific quality objectives, and (b) routinely assess the quality of the monitoring data. Appropriate
quality assurance (QA) is imperative. If the data (physical or chemical measurement) are of unknown
quality, then the data are unacceptable and cannot be used to demonstrate that a facility is operating
within approval requirements.
A QAPP should include the following content, as applicable: 38
• Distribution List: includes a list of individuals and organizations who play a role in the
development or implementation of the QAPP and will receive a copy of the approved QAPP.
• Problem Definition/Background: includes a statement of specific problem to be solved, decision
to be made or outcome to be achieved; background information.
• Quality Objectives and Criteria: includes outputs from the systematic planning process (e.g.,
data quality objectives [DQOs]); measurement performance or acceptance criteria established
(e.g., precision, bias, accuracy, representativeness, comparability, completeness, sensitivity).
DQOs are defined using a systematic planning process that defines the quality objectives and the
performance criteria. These relate the quality of the data needed to the established limits on the
chance of making a decision error.
• Special Training/Certification: includes any specialized training certifications needed by
personnel; plans for providing, documenting, and assuring this training.
It is suggested to check with EPA approval writers in the appropriate region for additional details not included in this
QAPP example.
38
See the following document for more details: “Guidance for Quality Assurance Project Plans, EPA QA/G-5” (U.S. EPA,
2002).
37

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Documentation and Records: includes a list of records to be included in the data report package;
list of any other project documents to be produced; information on the final disposition of
records and documents, including location and retention schedule.
Sampling Process Design (Experimental Design): includes a description of the project’s
experimental design.
Sampling and Analytical Methods: includes a description of sample/data collection procedures
and analytical methods; list of equipment needed; identification of performance requirements;
description of corrective actions to be taken if problems arise.
Sample Handling and Custody: includes a description of sample handling and transfer
requirements for ultimate disposal.
Quality Control (QC): includes a list of QC activities needed for sampling, analytical or
measurement techniques, along with their frequency (e.g., blanks, spikes, calibration check
samples, replicates, splits); description of control limits for each QC activity and corrective
actions when these are exceeded; and identification of any applicable statistics to be used.
Quantitative data quality indicators (DQIs) include accuracy, precision, and completeness.
Qualitative DQIs include comparability and representativeness. Definitions of these DQIs are
presented in the glossary at the beginning of this document.
Instrument/Equipment Testing, Inspection, and Maintenance: includes a list of equipment and/or
systems needing periodic maintenance, testing or inspection, and the schedule for such;
description of how inspections and periodic preventive maintenance procedures will be
performed and documented; discussion of how critical spare parts will be supplied and stocked;
description of how re-inspections will be performed and effectiveness of corrective actions.
Instrument/Equipment Calibration and Frequency: includes a list of all project tools, gauges,
instruments, and other sampling, measuring, and test equipment which should be calibrated;
description of calibration method and identification of any certified equipment and/or standards
to be used; and details of how calibration records will be maintained and traceable to the
instrument/equipment.
Inspection/Acceptance for Supplies and Consumables: includes a list of project supplies and
consumables that may directly or indirectly affect the quality of the results; the acceptance
criteria for them; and identification of those responsible.
Non-direct Measurements: includes identification of any existing data that will be obtained from
non-measurement sources, such as literature files and historical databases; description of how
you intend to use the data; your acceptance criteria and any limitations for using such data.
Data Management: includes a description of the project data management process; description of
or reference to the office’s standard record-keeping procedures and document control, data
storage, retrieval, and security systems; identification of data handling equipment and procedures
to process, compile, and analyze project data; discussion of data handling procedures to detect
and correct errors and loss during data processing; examples of any forms or checklists to be
used; identification of any specific computer hardware/software performance requirements and
how configuration acceptability will be determined; and description of how applicable
information resource management (IRM) requirements will be satisfied.
Assessments and Response Actions: includes a description of project assessments planned and a
brief discussion of the information expected; approximate schedule for these assessments and
their reports; for any self-assessments, identification of potential participants and their
relationship within the project organization; for independent assessments, identification of the

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organizations and person(s) that will conduct the assessments; and identification of how, when,
and to whom the results of each assessment will be reported.
Reports to Management: includes frequency and distribution of reports to inform management of
the project’s status; and identification of report preparer and recipients, as well as any specific
actions or recommendations recipients are expected to make.

4.2.21 Approval Application Section XIX - Standard Operating Procedures

Standard operating procedures (SOP) under this guidance refers to general procedures used by the
facility when operating their PCB treatment system. SOPs should be a step-by-step guide for:
• starting up and shutting down the treatment system;
• maintaining automated control;
• mobile unit shutdown and decontamination of the unit at each site prior to moving to a new site,
if applicable;
• switching to manual operation if automated controls fail;
• emergency shutdown if parameters are out of normal ranges or a leak is detected; and
• other SOPs that may be required.
A summary of the SOPs should be included in this section. Complete SOPs should be included as an
appendix to the application and made available to facility operators. Applicants may submit a copy of
the process operating manual to satisfy this requirement. SOPs should include sufficient information to
replicate the process, but it is not necessary to include every minute detail, such as the use of specific
equipment.
Divergence from the SOP during tests or commercial runs should be documented and permanent
modifications should be submitted to EPA. For convenience of use, lab procedures should be separate
from system operational procedures.
Instructions on SOPs should be part of the applicant’s training plan. Each employee should sign and date
a statement indicating that the employee has read and understood the SOPs. These signed statements
should be kept on-site.

4.2.22 Approval Application Section XX - Closure Plan

The TSCA provisions promulgated in § 761.65 require owners and operators of commercial storage
facilities to develop a written closure plan identifying steps that shall be taken to close facilities in a
manner that eliminates the potential for post-closure releases of PCBs that may present an unreasonable
risk of injury to health or the environment. Generally, applicants for PCB treatment/disposal approvals
are required to develop a written closure plan. In cases where EPA has determined closure financial
assurance is necessary, the Agency recommends applicants look to the PCB commercial storage closure
financial assurance provisions at § 761.65(g) to determine what types of mechanisms and specifications
are generally acceptable. A closure plan should include provisions for a worst-case scenario closure that
could be carried out by a third party.
For stationary facilities, the closure plan should address permanent closure of the facility. For mobile
treatment units, the closure plan should address permanent closure of the treatment unit. Mobile unit
shutdown at each site prior to moving to a new site is not considered closure, and would be covered in
the application as a standard operating procedure (see section 4.2.21). An acceptable closure plan for
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permanent closure should include the following:
• A description of how the PCB storage and handling areas of the facility will be closed in a
manner that eliminates the potential for post-closure releases of PCBs into the environment;
• An estimate of the maximum inventory of PCB wastes that could be handled at one time at the
facility over its active life and a detailed description of the methods or arrangements to be used
during closure for removing, transporting, storing, and disposing of the facility’s inventory of
PCB waste, including identification of any off-site facilities that will be used (see section 4.3 for
a discussion regarding financial assurance of on-site vs. off-site disposal);
• A detailed description of the steps needed to dispose of PCB waste and decontaminate
contaminated system components, equipment, structures, and soils during closure in accordance
with 40 CFR 761 subpart D;
• A detailed description of other activities necessary during the closure period to ensure that any
post-closure releases of PCBs will not present an unreasonable risk of injury to health or the
environment;
• A schedule for closure of each area of the facility where PCB waste is stored or handled,
including the total time required to close each area of PCB waste storage or handling and the
time required for any intervening closure activities;
• A financial assurance statement (see section 4.3 for a more information); and
• The expected year of closure of disposal units and PCB waste storage areas, if a trust fund is
chosen as the financial mechanism.

4.3 Financial Assurance Documentation

Prior to issuance of the operating approval, the applicant may be required to submit documentation of
financial assurance for closure and third-party liability of the PCB disposal facility. Further, the Agency
has discretion to require financial assurance for incineration and alternative disposal methods as a
condition of the approval. In general, the Agency believes the requirement to obtain financial assurance
for closure and for third party liability is a necessary provision to ensure the operation will not present
an unreasonable risk of injury to health or the environment. In addition to reviewing the guidance
relating to cost estimates and acceptable financial assurance mechanisms in this section, EPA
encourages early consultation with the PCB coordinator prior to obtaining a mechanism to ensure
compliance.

4.3.1 Closure Financial Assurance

If EPA determines that there is a need for financial assurance for closure of the facility, EPA
recommends applicants use the regulations for financial assurance for closure of PCB commercial
storage facilities as a guide for closure provisions and financial assurance mechanisms that are generally
acceptable. These regulations are located at §§ 761.65(d)-(g) and include provisions for acceptable
closure plans, cost estimates, and financial assurance instruments.
As a practical matter, closure financial assurance typically requires a written closure plan. The execution
of the closure plan forms the basis of the cost estimate which in turn determines the amount of financial
assurance needed for closure. In the event EPA determines that closure financial assurance is necessary,
the PCB commercial storage regulations governing acceptable closure plans at § 761.65(e) would be
appropriate. The provisions promulgated in § 761.65(e) require owners and operators to develop a
written closure plan identifying steps that shall be taken to close facilities that eliminate the potential for
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post-closure releases of PCBs that may present an unreasonable risk of injury to health or the
environment.
Generally, the Agency will find a closure cost estimate prepared in accordance with § 761.65(f) to be
acceptable. The provisions in § 761.65(f) require that the closure cost estimate be a detailed estimate, in
current dollars, of the cost of the owner operator hiring a third party to close the facility in accordance
with its approved closure plan. The closure cost estimate shall be in writing and be certified by the
person preparing it using the following certification, as provided in § 761.3:
“Under civil and criminal penalties of law for the making or submission of false or fraudulent
statements or representations (18 U.S.C. 1001 and 15 U.S.C. 2615), I certify that the information
contained in or accompanying this document is true, accurate, and complete. As to the identified
section(s) of this document for which I cannot personally verify truth and accuracy, I certify as
the company official having supervisory responsibility for the persons who, acting under my
direct instructions, made the verification that this information is true, accurate, and complete.”
Note that when calculating the closure cost, the Agency will likely require in the approval that the owner
or operator include in the estimate the current market costs for off-site commercial disposal of the
facility's maximum estimated inventory of PCB wastes, except that on-site disposal costs may be used if
on-site disposal capacity will exist at the facility at all times over the life of the PCB storage facility. 39 If
the on-site disposal exception is allowed and the facility is able to dispose of their maximum inventory
on-site, they must still consider the cost to hire a third party to use the on-site disposal. 40 Additionally, it
is EPA’s position that the availability of a facility’s on-site disposal process that uses a proprietary,
mobile, or technologically complex unit is not guaranteed, and therefore generally should not be used as
an input for the closure cost estimate. 41 Closure costs in the case of a proprietary, mobile, or
technologically complex unit must then include off-site disposal of the facility’s maximum inventory by
a third party.
In cases where EPA has determined closure financial assurance is necessary, the Agency recommends
applicants look to the PCB commercial storage closure financial assurance provisions at § 761.65(g) to
determine what types of mechanisms and specifications are generally acceptable. These provisions
reference subpart H of the RCRA regulations at §§ 264.143 and 151. In general, EPA believes these
instruments are appropriate for demonstrating closure financial assurance for operators of PCB
incinerators and alternative disposal methods and their specifications (including non-cancelation clauses
and irrevocability) are necessary provisions. However, not all provisions will necessarily be appropriate
in the case of approvals to operate PCB alternative disposal methods under TSCA. It is recommended to
consult your PCB approval writer early regarding a facility’s specific financial assurance requirements.

See 40 CFR 761.65(f)(1)(iii).
See 40 CFR 761.65(f)(1)(ii).
41
Memorandum: Policy Regarding Use of On-site Disposal Methods When Calculating Financial Assurance Closure Cost
Estimates. Signed by Maria J. Doa. OPPT. May 1, 2007.
39
40

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4.3.2 Third-Party Liability Financial Assurance

In addition, as part of providing adequate financial assurance for an alternative disposal method
approval, the owner or operator may be required to provide financial assurance for the compensation of
others for bodily injury and property damage caused by accidents arising from facility operations. The
provisions governing third party liability that EPA typically would find acceptable for alternative
disposal method approvals can be found at § 264.147 and wording for the corresponding mechanisms
can be found at § 264.151. Consultation with the PCB approval writer may be necessary to determine if
financial assurance for third-party liability is needed.

4.3.3 Maintenance of Financial Assurance

At the time of application, the owner or operator should address future maintenance of the closure cost
estimate and financial assurance mechanisms. In the case of an incinerator or alternative disposal
method approval, EPA believes adjusting the cost estimate for inflation would be necessary to ensure the
value of the financial assurance remains equal to the cost of closing the facility and would generally find
a cost estimate adjusted for inflation in the manner described in § 761.65(f) to be acceptable. Section
761.65(f) requires that during the active life of the facility, the owner or operator shall annually update
the closure cost estimate for inflation 60 days prior to the anniversary date of the establishment of the
financial instruments used to demonstrate closure financial responsibility. In cases where a financial test
or corporate guarantee is used the closure cost estimate shall be updated for inflation within 30 days of
the owner/operator’s fiscal year. The provisions for acceptable inflation adjustments at § 761.65(f)(2)
state that the inflation factor used is to be derived from the most recent Implicit Price Deflator for the
Gross National Product published by the U.S. Department of Commerce. However, EPA recognizes that
since those regulations were written, the Department of Commerce has largely shifted to using the Gross
Domestic Product. Therefore, EPA typically would accept inflation adjustments using either a deflator
based on the Gross National Product or the Gross Domestic Product, as long as the chosen deflator is
consistently used.
The requirements for each financial assurance mechanism, as described in §§ 264.143, 147, and 151,
include mechanism maintenance which EPA generally finds protective for PCB disposal approvals. In
general, maintenance requires the owner or operator to ensure that the face value of financial assurance
mechanisms continues to be a sufficient amount to cover closure cost estimates following inflation
adjustments. Use of financial test or corporate guarantee mechanisms require annual resubmission of the
items demonstrating a firm’s ability to pass the financial test and acceptance by EPA.

4.3.4 Release of Financial Assurance Obligation

Generally, EPA will require the owner/operator to maintain financial assurance until the Agency
receives certifications from the owner or operator and an independent registered professional engineer
that final closure has been completed in accordance with the approved closure plan. After receiving such
certifications, the Regional Administrator or the Director of ORCR will notify the owner or operator in
writing that the owner or operator is no longer required to maintain financial assurance, unless there is
reason to believe that final closure has not been completed in accordance with the approved closure
plan. In such instances, the Regional Administrator or the Director of ORCR will usually provide the
owner or operator with a detailed written statement identifying inconsistencies between closure and the
closure plan. .

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4.3.5 Transfer of Ownership or Operational Control

In cases where EPA determined financial assurance was necessary, prior to transfer in ownership or
operational control of the disposal facility, the transferee will typically also be required to establish
financial assurance as described above. Generally, EPA will approve the transfer under the conditions
laid out in § 761.65(j). The conditions at § 761.65(j) ensure adequate financial assurance remains in
place. Specifically, the date of transfer usually should be the date the Regional Administrator or the
Director of ORCR provides written approval of transfer so that there will be no lapse in financial
assurance for the transferred facility. The Regional Administrator or the Director of ORCR will
normally approve the transfer, if the transferee has established financial assurance effective as of the
date of final approval of the transfer and any deficiencies (e.g., technical operations, closure plans, cost
estimates) that EPA has identified in the application have been resolved. EPA will usually provide a
final written decision within 90 days of receipt of the financial assurance documentation.

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SECTION 5
TEST PLANS
This section presents the suggested format for a test plan and discusses the information that should be
provided. 42 The test plan should be submitted for approval to the delegated EPA official (see section 2.2
for a more detailed discussion on EPA delegation of authority). Contact EPA personnel to receive
specific instructions for submitting CBI material (see section 4.1.5 for more information). Following
receipt of the test plan, EPA will either approve, require additions or modifications to, or disapprove the
test plan. If the test plan is disapproved, EPA will notify the applicant and provide the rationale for the
disapproval. A new test plan may be submitted that satisfies the requirements indicated by EPA’s
comments. Both an application (see section 4) and a test plan are required before EPA can issue a test
approval. The test cannot be conducted until a test approval has been issued by EPA. While the
electronic submission of files is preferred, EPA will occasionally request paper copies of the test report.
The applicant is encouraged to communicate with EPA early and often during this process to ensure that
the approval process is as timely and agreeable as possible.

5.1 General

A test plan is a detailed plan for conducting and monitoring the test. Tests conducted under § 761.60(e)
encompass a variety of technologies such as those that destroy PCBs (e.g., chemical dechlorination) as
well as those that facilitate treatment of PCB waste (e.g., PCBs are captured by carbon filtration which
are later disposed at a different facility). EPA recommends including the same types of information in
test plans for both incineration and alternative to incineration methods to treat/dispose of PCB waste.
The minimum contents required in the test plan, as identified in § 761.70(d)(2)(ii), are as follows:
• Time, date, and location of the test;
• Quantity and type of PCBs and PCB Items to be incinerated or processed during the test;
• Parameters to be monitored and location of sampling points;
• Sampling frequencies, methods, and schedules for sample analyses; and
• Name, address, and qualifications of persons who will review analytical results and other
pertinent data, and who will perform a technical evaluation of the effectiveness of the test.
If the company submitted the test plan and/or operating approval to EPA but needs to make a major
modification prior to testing, the company should submit revised applications to EPA as soon as
possible, but at least 14 days prior to the test or as specified in the test plan approval. Major
modifications are modifications to the test plan that would have an impact to the no unreasonable risk
determination (e.g., change in feed rate, PCB concentration, or residence time in the reactor). Minor
modifications are modifications to the test plan that would have no impact to the no unreasonable risk
determination (e.g., change in disposal of process wastes, or if feed will be pumped from 55-gallon
drums during the test, in lieu of using a bulk feed storage tank that will be used during normal
operation). Minor modifications may only warrant EPA notification prior to implementing the testing
change, and shall be documented. Such documentation should be submitted to EPA either prior to the
test, or with the test report, depending on when such changes were deemed necessary (e.g., before or
after EPA has approved the test plan) or depending on how significant the change is. Also, if events
require that the plan be significantly modified during the test, then the approval writer should be
contacted immediately to discuss the implications of any modifications.
42

As a reminder, trial burns and demonstration tests are referred to collectively as tests.

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Throughout the test, an “event log” should be maintained. This log should be submitted as part of the
test report. Note that, in most cases, the test approval will specify what types of changes need prior
approval from EPA, and the procedures the company should follow when such changes are necessary.
The remainder of this section provides the suggested format of the test plan and its contents. Appendix C
summarizes and discusses appropriate methods for monitoring and sampling process feed streams (e.g.,
PCB waste prior to treatment), treatment process effluents, and emissions. Also, Appendix E provides a
list of methods for cleanup, extraction, and determination. As discussed in section 4, the information
provided in this section may not be comprehensive and applicants should provide additional information
when appropriate.
EPA may provide public notice and comment opportunities on fixed-site disposal test plans. Draft test
approvals for fixed-site disposal activities may be posted on EPA’s website during the public comment
period, along with additional information about the applicant and the proposed test. During the public
notice period, all documents associated with the test approval should be made available to the local
community. The public comment period usually lasts thirty (30) days and comments are accepted by
email and mail. Additionally, a public participation meeting is often held in the community nearest the
facility. This meeting serves to educate the public on the proposed test and provide a listening session to
hear community concerns. Public comments will be reviewed and considered prior to making the final
decision on issuance of the test approval (also see section 8).

5.1.1 The Purpose of the Test and General Approach

The purpose of a test is twofold:
1. To determine whether the proposed unit can meet the applicable standards and operate in a
manner that poses no unreasonable risk of injury to health or the environment, and
2. To determine at what operating conditions that a compliant level of performance can be
maintained over time during day-to-day operations. Those successful operating conditions are
generally set as requirements in the approval.
Thus, it is important for the applicant to understand the relationship between the test and the operating
parameter values that will ultimately be set in their approval, and plan accordingly to achieve a set of
approval conditions that will be workable for the applicant’s planned day-to-day operation. The
applicant should determine which parameters will be set as maximum levels, which will be set as
minimum levels, and which will be set as a range (i.e., both maximum and minimum). The applicant
also should determine which, if any, parameters will be set based on design specifications rather than the
test. The applicant should consider the format of the operating conditions they will have in their
operating approval, e.g., whether conditions will be set as absolute levels or with averaging timeframes.
Furthermore, the applicant should factor in safety, such as reducing the likelihood of a fire, explosion, or
exposure to hazardous substances.
Since the values of most key operating parameters will be set directly from the test, it is advisable for
applicants to anticipate the outer edges of their anticipated operating envelope or worst-case scenarios,
for example, the highest anticipated concentration of PCBs in the incoming feed, and design the test to
achieve those approval conditions. Generally, this entails designating levels of test conditions that are
slightly higher for conditions set as maximums and slightly lower for conditions set as minimums, to
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allow room for fluctuation. 43
A GOOD TEST DESIGN SUPPORTS SMOOTH OPERATIONS AND WORKABLE APPROVAL
CONDITIONS, AND MINIMIZES THE NEED FOR MODIFICATIONS OF THE APPROVAL
Recommended steps for applicants to design test and operating parameters consist of the following:
• Identify key operating parameters that affect the performance of the unit;
• Determine desired approval levels for those parameters, including whether each is a maximum,
minimum, or range;
• Propose a method for setting each parameter (e.g., based on demonstrated test conditions or
manufacturer’s specifications);
• For each parameter, develop proposed test conditions that are likely to achieve compliance as
well as achieve a set of approval operating conditions that support the anticipated operation of
the unit;
• Confer on the design with approval writer; and
• Incorporate the results of this planning into the approval application and test plan.

5.2 Contents of a Test Plan

Table 9 presents a suggested format for a test plan. Suggested contents of the plan are discussed in the
following subsections. Table B-2 of Appendix B provides a checklist to aid the applicant in determining
whether this information has been included in the test plan. This checklist is not required and does not
need to be submitted to EPA.
In instances where the applicant is submitting a revised test plan based on comments received from EPA
or proposed changes to a previously submitted plan, the applicant should summarize such
changes/revisions in section 5.2.1, and if practicable, a redline/strikeout “compare” version that
highlights the revisions should be provided. 44 The applicant is also encouraged to provide EPA with a
standalone response to comments document that briefly explains/summarizes how each comment was
addressed. This may facilitate EPA’s review of the revised plan.
In instances where significant deficiencies have been identified by EPA, or where the applicant is
unclear as to how to address specific deficiencies, the applicant may find it useful to request a meeting
or teleconference with the approval writer to best assure the revisions adequately address the comments
received. EPA may deny the application if the deficiencies are not addressed within a reasonable period
of time.
All test plans should be accompanied by a transmittal letter, which summarizes the request for approval
to conduct a test and mentions relevant history of the request. If the test plan is being submitted in
conjunction with an operating approval renewal application, this should be briefly discussed in the
transmittal letter. In this circumstance, the updated plan should summarize how/whether this plan differs
See tables 10 and 11 for examples.
In instances where significant revisions or rewrites have been made, a redline/strikeout compare version may not be
practicable/useful.
43
44

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from their previously submitted/approved plan. A suggested cover page format for the test plan is shown
in Figure 6. If a paper copy is requested by EPA and if the plan will be bound in multiple volumes, the
applicant should number each volume in order in the upper right-hand corner of the cover (“Volume m
of n”). The cover of each volume should also have all information shown in Figure 6.
Table 9. Suggested Format for a Test Plan
Section No.

Section Title
Test Plan Cover
Table of Contents

I

Summary

II

Project Organization

III

Treatment Process and Facility Information

IV

Operating Parameters

V

Monitoring and Sampling Plan

VI

Monitoring Procedures

VII

Sampling and Analysis Procedures

VIII

Emergency Procedures

IX

Test Data Reporting

X

Miscellaneous Tests

XI

Waste Handling and Disposal

XII

Test Schedule
Quality Assurance Project Plan (addenda to approval application

XIII

QAPP)
Standard Operating Procedures (addenda to approval application

XIV

SOP)
Appendices

5.2.1 Test Plan Section I - Summary

The summary should indicate when, where, and by whom the test will be conducted. A brief background
discussion about the treatment/disposal device to be tested should also be provided (e.g., treatment unit
description, intended waste feeds, summary of previous tests or operations). Summarize any significant
differences in the operation of the treatment unit for the test run relative to day-to-day operations. If
there are any previous test plan submissions or revisions requested by EPA, briefly discuss any
significant changes made.

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Volume m of n

TEST PLAN, VERSION #X (IF APPLICABLE) 45
PCB TREATMENT/DISPOSAL UNIT
[Type and location of unit]
[Name and location of company headquarters if different from above]
Operating Approval Application Submission Date/Anticipated Date: [date]
Test Plan Submission Date: [date]
Proposed Test Dates: [dates]

Submitted by:
[Company name and address]
[Principal manager
and phone number]

Submitted to:
Director, Office of Resource Conservation and Recovery
Office of Land and Emergency Management
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Mail Code 5303P
Washington, DC 20460
ORCRPCBs@epa.gov
OR
If submitted to an EPA Regional office, provide the applicable
Region’s address listed at www.epa.gov/pcbs/program-contacts.

Figure 6. Test Plan Cover Page Example.

If the document is revised and resubmitted to EPA, the applicant should clearly indicate on the cover that the report has
been updated (e.g., version 2).
45

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5.2.2 Test Plan Section II - Project Organization

An organizational chart and narrative description to identify the key personnel for the project should be
provided. Identify personnel who have overall responsibility for conducting the test and their
relationship to key personnel having overall authority for the operating approval (see section 4.2.4). This
section should specify if responsibilities for certain activities are being contracted out, and, if so, to
whom. Key areas of responsibility that should be identified include:
• Facilities manager;
• Principal manager;
• Test coordinator;
• Operations manager;
• Sampling crew chief;
• Monitoring systems operator;
• Analytical manager and key analyst;
• Quality assurance officer; and
• Safety officer.
Qualifications and formal certifications of the key company/contractor personnel who will be operating
the system and conducting the sampling, monitoring, and analyses are to be provided with the test plan.

5.2.3 Test Plan Section III - Treatment Process and Facility Information

This section should provide a general overview of the treatment/disposal process, including a description
and a detailed engineering drawing. Explain the provisions established for storage of the wastes prior to
and during the test if different from the normal procedures identified in the approval application. This
explanation should include a description of the storage facility and any permits that are in place or will
need to be in place for use of the storage facility. Detailed information about the process and facility,
including health and safety plans, employee training schedules, and recordkeeping, should be in the
approval application and may be referenced. An explanation of the PCB waste and/or surrogate material
to be used in the test should also be discussed.

5.2.4 Test Plan Section IV - Operating Parameters

This section presents the operating parameters to be maintained, monitored, and recorded during the test.
The proposed parameters and their operating values/ranges should be carefully considered, as they will
inform allowable operating parameter values/ranges needed to meet DRE and other standards 46 and,
depending on the test results, may be included as limits in the operating approval. 47 If the test plan is
submitted in support of a renewal request for operation, this section should highlight how the proposed
parameter values differ from those specified in the existing/expiring operating approval. Information
that should be presented in the test plan includes:
• Detailed plan for treatment unit operations during the test;
• Process operating parameters (e.g., temperature, pressure) for the treatment unit and associated
pollution control devices, anticipated operating ranges/levels of these parameters, frequency of
measuring/recording these parameters during the test and day-to-day operations, and the
proposed method by which these measurements/recordings will be used to calculate enforceable
operational limits;
46
47

See section 4.1.2 for other standards.
See section 5.1.1 for more information on the purpose of a test.

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•
•
•

Anticipated emissions and/or effluent levels;
Quantity of PCBs or PCB Items to be fed as waste during the test (e.g., waste feed quantities,
concentrations, and feed rate) and a description of the matrix that the PCBs are in (e.g., sediment,
oil); and
Identification of the Aroclor in waste.

A detailed schedule of events that explains the operating parameters that will be maintained during the
start-up, operation, and shutdown phases of the test should be included. Sampling times and locations
should be highlighted in the monitoring and sampling, discussed in section 5.2.5.
The process operating conditions and anticipated emissions can be summarized in a tabular format.
Tables 10 and 11 provide example summaries of test parameters for an incineration system and
dechlorination system, respectively. Note that control limits (i.e., acceptable ranges) would be listed in
the operating approval, and are based on demonstration of successful treatment at the anticipated levels.
Operating limits stated in the operating approval for both thermal and non-thermal systems are typically
based on the results of the demonstration test. The applicant should carefully plan their test such that
DRE and other standards 48 are met and that the test operating conditions lead to a set of approval
conditions that are workable for their anticipated day-to-day operations. 49 Exceeding the operating limits
stated in the operating approval may result in a violation, suspension, or termination of the operating
approval.

48
49

See section 4.1.2 for other standards.
See discussion in section 5.1.1 for more information on the purpose of a test.

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Table 10. Example Summary of Test Parameters for an Incinerator 1,2
Test Plan
Proposed
Value

Demonstrated
Value 3

Fuel/Waste Feed
Waste feed rate (kg/hr)
PCB concentration in feed (mg/kg)
Total chlorine in feed (mg/kg)
PCB feed rate (kg/hr)
Chlorine feed rate (kg/hr)
Auxiliary fuel feed rate (kg/hr)
Total thermal duty (106 Btu/hr)

Operating
Approval
Control
Limits 4

100
3,500
2,500
0.35
0.25
15
4.5

99.7
3,509
2,550
0.348
0.254
15.1
4.55

85 to 115
< 3,500
< 2,500
0.30 to 0.40
0.21 to 0.29
NA
< 5.0

Combustion Conditions
Combustion air flow rate (acm/min)
Residence time (second)
Destruction temperature (°C)
Combustion gas O2 (%)
Combustion gas CO2 (%)
Combustion gas CO (ppm)

60
2.2
1,250
5
12
20

61.1
2.18
1,271
5.05
12.3
19.2

< 65
> 2.2
1,150 to 1,350
>5
NA
< 100

100
8.5
75
25

97
8.45
78
27

> 85
8.0 to 10.0
60 to 100
> 20

Parameter

Pollution Control
Scrubber water flow (gpm)
Scrubber water (pH)
Venturi water flow (gpm)
Venturi pressure drop (in H2 O)

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed
in the table relevant to all technologies. Furthermore, applicants are not required to use this table.
2
NA means not applicable.
3
These values are measured or calculated after the test.
4
Desired values before the test; values can be revised in the test report after the results have been obtained.
1

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Table 11. Example Summary of Test Parameters for a Batch Chemical Dechlorination Process 1
Parameter
Waste Feed
Batch Weight (kg/batch)
Batch Weight (gallons/batch)
PCB concentration in feed (mg/kg)
Total chlorine in feed (mg/kg)
PCB feed rate (kg/batch)
Chlorine feed rate (kg/batch)
Operating Conditions
Batch residence time (hours)
Reactor temperature (oC)
Reactor pressure (millimeter of Mercury
[mm Hg])

Test Plan
Proposed
Value

Demonstrated
Value 2

Operating
Approval
Control
Limit 3

1,000
275
5,000
3,500
5
3.5

1,022
273
5,015
3,512
5.05
3.51

850 to 1,100
250 to 300
< 5,000
< 3,500
4.25 to 5.5
3.0 to 3.9

2
40
800

2
41.3
800

>2
35 to 45
760 to 880

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every
parameter listed in the table relevant to all technologies. Furthermore, applicants are not required to use
this table.
2
These values are measured or calculated after the test.
3
Desired values before the test; values can be revised in the test report after the results have been obtained.
1

This section should identify the waste feed that will be used during the test. Indicate the waste type,
physical state, heat content (if applicable), and composition of the waste feed including the anticipated
PCB concentration. Identify the total quantity of waste feed to be used during the test, and explain how
it compares to the waste that will be processed during routine operation (e.g., the same, worst-case
condition, mixture of anticipated wastes). Waste feed used in the test should be as similar as possible to
the waste feed expected during operation. In situations where the applicant has exhausted all possible
sources of suitable PCB waste, EPA will consider use of PCB surrogates, such as 1,2-dichlorobenzene,
on a case-by-case basis.

5.2.5 Test Plan Section V - Monitoring and Sampling Plan

This section presents the monitoring and sampling plan for the test. The plan should be detailed and
specific to the proposed test to monitor process operation and verify that the PCB treatment/disposal
achieves the level of performance equivalent to disposal in a § 761.70 incinerator or a § 761.71 high
efficiency boiler and will not present an unreasonable risk of injury to health or the environment, as
required under § 761.60(e). The plan should address all monitoring and sampling activities that will be
conducted during the test and identify any monitoring or sampling activities that will not be conducted
during normal operations. Likewise, any monitoring or sampling activities that will be conducted during
normal operations that will not be conducted during the test also should be identified and justified in the
test plan. Monitoring and sampling during normal operations should be discussed in detail in the
application (see section 4.2.7). Monitoring and sampling during the test should replicate that of normal
operations while the conditions of the test should be worst-case or most challenging relative to normal
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operations. 50 A tabular format, with narrative explanation, as necessary, can be used to summarize the
monitoring and sampling plan.
The objective of the monitoring and sampling plan should be to obtain results that are representative of
the conditions at which the unit is operating. In cases where test samples may not be representative of
the conditions at which the unit is operating, a worst-case result should be obtained (i.e., sample when
the process is least likely to achieve the required treatment standards). In cases where problems can be
anticipated (e.g., instrument failure), contingencies should be included in the monitoring and sampling
plan.
Note that information in this section may overlap with information discussed in subsequent sections
(i.e., monitoring procedures and sampling procedures, section 5.2.6 and section 5.2.7, respectively). This
section is intended to discuss what methods will be used and where/how each will be applied in the
treatment process. Discussion of the method itself and how each method is conducted is found in the
subsequent sections. There is some overlap between these sections and the applicant may combine the
monitoring and sampling plan and methods into one section, but be sure to review and include
applicable information discussed in all three sections within this guidance (sections 5.2.5, 5.2.6, and
5.2.7). Remember that there are some subtleties between each section, for example, measurement
frequency could refer to the frequency used during normal operation, during the demonstration test, or
the measurement frequency capabilities of the instrument; all three may be different. Furthermore, the
recording frequency may differ from the measurement frequency.
The monitoring and sampling plan should include the following elements:
• A description of what is being sampled or monitored (including sampling location). This
description should be organized by discrete sampling/monitoring activities (e.g., stack emissions,
combustion chamber operating parameters, air pollution control device operating parameters,
liquid waste, ash, product);
• The number of test runs, the planned duration of each run, quantity of PCB material to be
processed during each run, and overall planned schedule for the entire test for all test conditions.
Generally, a minimum of three tests are conducted for each test scenario;
• The objective of the sampling or monitoring for each unit (e.g., collect a “representative”
sample; monitor and record combustion zone temperature; establish air pollution control device
operating limits; follow an EPA test protocol; or collect a “worst-case” sample);
• The parameters to be tested. List the substance or property being measured, operating
parameters, and media;
• The sample analysis method to be used. List the cleanup, extraction, and analytical methods to be
used; detailed description of the methods may be presented in this section or an appendix, or a
standard protocol may be referenced;
• The sampling or monitoring methodology/approach/criteria for each operating parameter. This
may reference a standard protocol (e.g., EPA Reference Method 3, 40 CFR 60).51 The frequency
(e.g., every 15 minutes), size (e.g., 100 grams), timing (e.g., one hour after reaching steady-state
conditions), number of replicates (e.g., 10 percent of the samples or 2 samples, whichever is
greater, collected in triplicate), number of surrogate-spiked samples, and total number of samples
The test is typically designed to be more challenging in order to receive desired operating approval conditions. See section
5.1.1 for more information.
51
See Appendix C for more information regarding EPA methods.
50

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•

•
•
•

should be listed for each sample type. The sample size usually is dictated either by the amount of
sample required to detect the analyte or by convenience (e.g., 1 liter for water);
o A justification may be required if the frequency of measurement/recording times are
longer than typical industry standards at the time the application is received by EPA or if
the measurement frequency is longer than what EPA believes is needed to prevent an
unreasonable risk of injury to health or the environment;
A calibration test protocol for sampling/monitoring devices to be used during the test, including
acceptable margins of error and frequency of calibration;
o Before the test, the facility should certify that its continuous emissions monitors such as
oxygen, carbon monoxide, and carbon dioxide, have passed zero drift and span drift tests.
EPA may choose to provide an audit cylinder for one or more of these monitors for a
performance demonstration during the test;
An estimate of sample representativeness. This may be based on data (e.g., historical data on
replicates) or scientific/engineering judgment (e.g., a sample from an actively mixed feed tank
might be characterized as representative);
Contingencies for action if samples cannot be collected according to the plan (e.g., alternative
sampling sites or times, an entirely new sampling plan, or repeat tests); and
Discussion of safety considerations that prevent the risk of injury to the workers and the local
community (e.g., integrity measurements, pressure control measures, measuring of the buildup of
hazardous constituents, etc.).

The parameters that typically should be included in the monitoring and sampling plan for an incinerator
or alternative method of disposal are discussed in the following subsections.
5.2.5.1 Pollutants and Parameters to be Monitored/Sampled during Tests for Incinerators or
Alternative Thermal Destruction Technologies
40 CFR 761.70 provides the minimum monitoring and recording requirements for normal incinerator
operation, which apply when the unit is tested to demonstrate compliance with the applicable
requirements and establish operating limits. These minimum parameters include the following:
• Rate and quantity of waste feed at no longer than 15-minute intervals;
• Reactor/combustion temperature measured on a continuous basis;
• Concentrations of O2 and CO on a continuous basis, and CO2 on a periodic basis; and
• Concentrations of NO x, HCl, residual Cl, PCBs, and total particulate matter.
In addition to those required by § 761.70, the applicant should propose any additional monitoring and
sampling parameters that are necessary to ensure the operation of the PCB treatment/disposal unit does
not present an unreasonable risk of injury to health or the environment and, for an applicant for an
alternative technology, to verify that PCB destruction is equivalent to disposal by incineration. 52 The
approval writer may determine it necessary for the facility to monitor/sample more parameters during
the test (and subsequently during normal operations) to assure compliance with PCB regulatory
requirements and/or assure operation of the incinerator does not present an unreasonable risk of injury to
health or the environment. EPA may find it necessary to include limitations for these operating
parameters in the operating approval based on the levels demonstrated during the test. Necessary
(additional) parameters will vary based on the design of the treatment/disposal unit and associated
pollution control systems, as applicable. Example additional operating parameters include, but may not
52

40 CFR 761.70(d)(4)(ii), 60(e)

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be limited to:
• PCB content of the waste feed to calculate the Destruction and Removal Efficiency (DRE);
• Polychlorinated Dibenzo-p-dioxin (PCDD) and Polychlorinated Dibenzofuran (PCDF) (tetrathrough octachloro homologs, 2,3,7,8-tetrachlorodibenzodioxin, and 2,3,7,8tetrachlorobidenzofuran) in the stack emissions;
• PCB, PCDD, and PCDF concentrations in any solid or liquid wastes generated; and
• Other parameters that demonstrate no unreasonable risk to the safety of the workers and the local
community from PCBs, other hazardous chemicals/by-products, or other hazards (e.g., fires or
explosions).
The monitoring and sampling plan also should identify the appropriate combustion system and pollution
control system operating parameters that will be monitored and recorded during the test to establish
operating limits that will be required during day-to-day operations (e.g., minimum residence time, batch
feed operating parameters, liquid waste atomization parameters, scrubber water flow rate, pressure
drop).
5.2.5.2 Pollutants and Parameters to be Monitored/Sampled during Tests for Alternative NonThermal Destruction/Removal Technologies
The applicant should propose a set of test monitoring and sampling parameters to verify that the PCB
treatment/destruction process: (a) has a level of performance equivalent to disposal in a § 761.70
incinerator or a § 761.71 high efficiency boiler; and (b) does not present an unreasonable risk of injury
to health or the environment. At a minimum, this will include measurements of PCBs in the final
product and effluent streams (wastewater, filters, vent gas, treated oil, etc.). For separation treatment
processes (e.g., thermal desorption, carbon filtration) where PCBs are concentrated into a fraction for
subsequent treatment/disposal by an approved method, the applicant should propose a set of monitoring
and sampling parameters to verify that (a) the residual “clean” fraction contains < 2 µg/g (ppm) PCBs
(see section 2.4), (b) any detectable levels of PCBs emitted from the system through drains, vents, etc.
are within regulatory requirements (see section 4.1.2), and (c) the process does not present an
unreasonable risk of injury to health or the environment. The monitoring and sampling parameters will
depend upon the process design and the type of waste feed and effluent streams associated with the
alternative treatment/disposal method. Process operating parameters that affect the performance of the
unit (e.g., feed rate, reaction temperature, and pressure) should be monitored and recorded. The
applicant should describe all the operating parameters that are necessary to assure compliance with the
PCB regulations and to ensure no unreasonable risk of injury to health or the environment in the
monitoring and sampling plan. This would include pollution control system operating parameters, if
applicable.
EPA may require applicants to amend the list of pollutants or parameters to be monitored/sampled that
they identified in the test plan. For example, EPA may request that additional pollutants, such as
PCDDs, PCDFs, and other chlorinated organics, be included in the monitoring and sampling plan.

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5.2.6 Test Plan Section VI - Monitoring Procedures

For facilities using monitoring systems, a detailed discussion of the monitoring methods to be used
during the test should be included in the test plan. While these procedures have been described in the
approval application, the procedures should also be described in the test plan. We suggest that, at a
minimum, all monitoring procedures that are specific to the test be included in the test plan. The
following information should be included:
• Type of monitoring instrumentation used for the test;
o Manufacturer and model number;
o Monitor/instrument operational specifications (e.g., range, accuracy, and interferences);
o Measurement frequency capabilities;
o Operating temperature range of monitor, if monitor is in-situ type;
o Description of the calibration procedures and frequency;
o Provide an explanation if a specific instrument used for the test will not be used during
normal operations;
• Description of monitor operation;
o Discuss which pollutants/parameters will be monitored during the test, normal operations,
or both;
o Monitoring locations, and an explanation for why each location was chosen and results in
representative samples/parameter measurements;
o Provide an explanation if specific parameters monitored during the test will not be
monitored during normal operations;
o Frequency that the parameters will be monitored/recorded including a brief description
of how the monitor output will be used to assure compliance;
o Description of the data acquisition and recording system for all operating parameters,
including a description of how the data acquisition system calculates and records
operating parameter levels;
o Description of the process to physically extract a sample if the monitor is extractive,
including necessary sample conditioning systems (if applicable);
• Methodology for translating monitoring test results into the operating approval;
o Proposed methodology to translate monitored test parameters into operating limits, if
applicable (e.g., average of the test run averages);
o Proposed methodology to be used to calculate parameter measurement frequency during
normal operations to comply with operating limits that will be included in the operating
approval, if applicable; and
o Describe any data processing that will be done such as, data reduction procedures,
calculations, etc.
Brief descriptions of some monitoring procedures typically used for PCB treatment/disposal
technologies are presented in Appendix C and Appendix E of this document.

5.2.7 Test Plan Section VII - Sampling and Analysis Procedures

Specific details of the sampling and analysis procedures that will be used during the test and that were
not previously addressed in the approval application should be included, in detail, in the test plan. This
section of the plan should also summarize the methods previously given in the approval application and
any additional details or new information available at the time of the test.

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EPA’s SW-846 methods may be referenced and included as an appendix to the test plan. However, any
deviations from standard procedures should be noted. Any modifications to the published procedures or
selection from several options given in a procedure should be documented. Furthermore, when the
standard method allows different procedural variations to be used, the applicant should be specific as to
the procedures that will be followed (e.g., for the measurement of O2 and CO2 concentrations in the
stack gas by EPA Method 3, will multi-point integrated sampling or single-point grab sampling be
used?).
In some instances, the applicant may be asked to demonstrate equivalence between a method they are
requesting and either a standard method or an EPA method, such as those found in SW-846. If this is the
case, duplicate samples should be collected during the test and analyzed according to both methods (the
proposed method and the standard or EPA method). The applicant should present the results in the test
report (section 7) that compare the two methods and discuss how the two methods are equivalent. The
applicant should also discuss how the proposed method does not present unreasonable risk of injury to
health or the environment.
A discussion of the sampling and analysis procedure should be provided and may include:
• A summary of the sampling and analytical procedures;
o This may overlap with the procedures discussed in the monitoring and sampling plan, in
which case it may be referenced. For more information, see section 4.2.7;
o Be sure to include any information regarding the sampling method that may be missed in
the monitoring and sampling plan. For example, the applicant may have indicated they
were taking composite samples from a waste pile after treatment. There are many ways to
composite samples; therefore, it is important that the compositing method is discussed in
detail in this section;
o Summarize analytical procedures and any procedures used to prepare the sample,
including the EPA method numbers and deviations from the methods, the applicant’s
method numbers, and whether an on-site laboratory will be used;
o Indicate the sampling locations, and an explanation for why each location was chosen and
why it results in representative samples/parameter measurements;
o Describe how the samples are stored, preserved, and recovered;
o Discuss how samples are transported and custody is transferred;
• A description of the sampling and analytical equipment/apparatus used to take, transport, extract
and analyze a sample;
o The equipment manufacturer and model number;
o Provide sampling and analytical equipment specifications, if applicable (e.g., range,
accuracy, and interferences);
o Describe how the sampling and analytical equipment is calibrated, standards used, and
the frequency with which it is calibrated;
o Describe any reagents used during sampling and analysis and discuss how the reagents
will be prepared and used;
o Describe the routine and preventive maintenance procedures and frequency;
• A description of any data processing that will be done, such as data reduction procedures, data
validation procedures, calculations, etc.
Specific details of analytical procedures may be referenced (if standard published procedure) or should
be included as an appendix (if unpublished or if the publication is not readily available). If needed,
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include a description of when it is appropriate to analyze for PCBs as homologs or congeners.
Appendices C and E provide guidance on monitoring, sampling, and analysis procedures for various
matrices and list various sample methods.

5.2.8 Test Plan Section VIII - Emergency Procedures

This section should describe the procedures to follow in the case of emergency situations. The
discussion should explain the potential for release during the test and the potential fire hazards
associated with the test. A list of emergency contacts and the location of the nearest hospital that is able
and willing to treat injuries from hazardous substances should be included along with procedures for
shutdown in case of an emergency.

5.2.9 Test Plan Section IX - Test Data Reporting

Present a summary of the data to be obtained during the test and presented in the final test report.
Example calculations and reporting units should be presented. Include information, if applicable, for
process data; pollution control system operating data; and the PCB concentrations for the waste feed,
effluent waste, product streams, and emissions.
All applicable analytical values should be reported as concentrations, expressed as:
• Percent for O2 and CO2;
• Parts per million for trace gases in air (e.g., CO);
• Micrograms per cubic meter for organics in air (e.g., PCBs);
• Micrograms per liter for water; and
• Micrograms per gram for nonaqueous liquids and solids;
PCB concentrations measured in the stack gas, waste feed, product oil, liquid waste, solids waste and
other streams are to be reported. A breakdown of the PCB value by homolog or congener may be useful
for certain destruction tests, as this will reveal whether destruction was incomplete, or PCB destruction
levels met the performance standards. In many cases for alternative methods of PCB destruction,
destruction equivalence to a § 761.70 incinerator has been defined as a measured effluent stream
concentration of not greater than 2 ppm. 53 The analytical results may not be reported in terms of Aroclor
(or other mixture) concentrations, even if an Aroclor is used to calibrate the instrument (as in the waste
feed), unless prior EPA approval is obtained.
PCDDs and PCDFs are to be reported by homolog (e.g., total octachlorodibenzofurans) for the tetrathrough octachloro homologs and summed to give total PCDD and PCDF values as a minimum.
Concentrations may be calculated on a toxic equivalents (TEQ) basis, which are the units of
measurement for reporting under the Clean Air Act NESHAP regulations in 40 CFR part 63, subpart
EEE. Separate values should be reported for 2,3,7,8- tetrachlorodibenzodioxin (TCDD) and 2,3,7,8tetrachlorodibenzofuran (TCDF).
Other contaminants detected should be reported as quantitated, with the sampling and analytical
methods used to detect the subject compound listed.
Previous guidance has interpreted that “equivalent level of performance” to an incinerator means less than or equal to
2 ppm. See “Guidelines for Permit Applications and Demonstration Test Plans for PCB Disposal by Non-Thermal
Alternative Methods” (1986).
53

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5.2.10 Test Plan Section X - Miscellaneous Tests

The proper operation of the automatic waste feed cutoff and other emergency systems should be
demonstrated upon request. Describe the procedures to be used during the test to check operation of
alarm and emergency systems, including:
• Automatic waste feed cutoff system;
• Alarm systems (e.g., high temperature); and
• Fire extinguisher system.
These operational checks should be included as part of the test schedule described in section 5.2.12
below. The checks should be conducted with non-TSCA regulated feed and may be conducted prior to,
or after testing to minimize downtime during the testing process.
If the facility is permitted under the Resource Conservation and Recovery Act (RCRA), copies of the
most recent RCRA performance test that a state or Region has certified as having passed should be
provided. Additionally, if the facility is required to have a Clean Air Act Title V permit then copies of
the CAA permit should also be provided. EPA will review these permits when evaluating a request for
an approval.

5.2.11 Test Plan Section XI - Waste Handling and Disposal

The test plan should identify any by-product wastes (both PCB and non-PCB) that will be generated
(e.g., in-line filters for the PCB waste feed line, samples of feed material, contaminated PPE) and how
the wastes will be disposed of. This includes PCB wastes that are, for example, treated in tests and are
later determined to not pass the treatment efficiency standards (e.g., oil contaminated with PCBs that
cannot be treated to levels less than or equal to 2 ppm).

5.2.12 Test Plan Section XII - Test Schedule

A detailed schedule of the proposed testing period, including when any shakedown tests will be
conducted, should be provided in the test plan. The schedule should be of sufficient detail to determine
what activities are planned for each phase of the test. Tables 12 and 13 provide examples of test
schedules for incineration and alternative treatment/disposal methods, respectively. The test schedule
should be realistic, including sufficient time to address problems that are likely to occur during operation
of a new process.

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Table 12. Example: Proposed Schedule for an Incinerator Test 1
Day

Tentative Date

-5

xx/yy/zz

-4

xx/yy/zz

-3

xx/yy/zz

-2
-1

xx/yy/zz
xx/yy/zz

0

xx/yy/zz

1

xx/yy/zz

2

xx/yy/zz

AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM

3

xx/yy/zz

AM/PM

Activity
Inventory waste feed
Begin system shakedown using auxiliary fuel
Continue system shakedown
Calibrate continuous emissions monitoring system
Continue system shakedown
Check emergency alarm/cutoff systems
Continue system shakedown
Continue system shakedown
Continue system shakedown2
Test crew arrives on-site
Test equipment set-up
Begin PCB destruction
Emission test No. 13
Emission test No. 23
Emission test No. 3
Test of emergency systems
Shut unit down at completion of test according to
test plan

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed
in the table relevant to all technologies. Furthermore, applicants are not required to use this table.
2
System shakedown should continue until system is able to operate without significant downtime (e.g., a minimum 24 hours
of operating time without significant downtime is suggested).
3
Unit will be returned to auxiliary feed at end of each emission test; unit will be switched to PCB waste, prior to starting the
next test period.
1

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Table 13. Example: Proposed Schedule for an Alternative Method of Treatment/Disposal
Test 1
Day

Tentative
Date

-1

xx/yy/zz

AM/PM
AM/PM
AM/PM
AM/PM

1

0

xx/yy/zz

1
2

xx/yy/zz
xx/yy/zz

AM/PM
AM/PM
AM/PM
AM/PM

3

xx/yy/zz

AM/PM

Activity
Inventory waste feed
Begin system shakedown using non-TSCA
regulated feed
Check emergency alarm/cutoff systems
Continue system shakedown using non-TSCA
regulated feed
Test crew arrives on-site
Test equipment set-up
Destruction test No. 1
Destruction test No. 2
Destruction test No. 3
Test of emergency systems
Shut unit down at completion of test according to
test plan

DISCLAIMER: This table is only an example and may not capture every relevant parameter, nor is every parameter listed
in the table relevant to all technologies. Furthermore, applicants are not required to use this table.

5.2.13 Test Plan Section XIII - Quality Assurance Project Plan

Each test plan should include a QAPP (see Appendix D for an optional QAPP template). The applicant
may want to contact the Regional office for any region-specific considerations. If an adequate QAPP has
been submitted with the approval application (see section 4.2.20), then only addenda to the QAPP
specific to additional sampling, monitoring, and analysis for the test need to be submitted with the test
plan. Those portions of the QAPP that apply to normal operations and those that apply only to the test
should be clearly identified. In any event, the QAPP, with addenda, should address all measurement
parameters (e.g., CO emissions, combustion chamber temperature, destruction vessel temperature,
distillation column temperature), not merely PCB sampling and analysis.
Below is a short list of items that should be included in a QAPP specifically for the test (a complete list
of items to include in a QAPP, with a description of each, can be found in section 4.2.20):
• Distribution list and responsibility for QA;
• Quality objectives and criteria (precision, accuracy, completeness, representativeness, and
compatibility);
• Sample handling and custody;
• Monitoring design and procedures;
• Sample and analytical design and procedures;
• Quality control;
• Instrument/equipment testing, inspection, and calibration procedures and frequency;
• Data reduction, validation, and reporting;
• Performance and system audits and frequency;
• Preventive maintenance procedures and schedules;
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•
•
•

Data management;
o Specific routine procedures to assess data precision, accuracy, and completeness;
Assessments and response actions; and
QA reports to management.

The QAPP should conform to the specifications established in Guidance for Quality Assurance Project
Plans, EPA QA/G-5 (US EPA 2002). Additional guidance in the preparation of QAPPs is available in
“EPA Requirements for Quality Assurance Project Plans” (U.S. EPA, 2001).
For most sampling and analysis plans, a minimum of 10 percent or 2 of the samples, whichever is
greater, should be collected in triplicate; a minimum of 10 percent or 2 of the samples, whichever is
greater, should be quality control (QC) samples; and a minimum of 10 percent or 2 of the samples,
whichever is greater, should be QC blanks.

5.2.14 Test Plan Section XIV - Standard Operating Procedures

Provide any addenda to the standard operating procedures (SOP) submitted with the approval
application (see section 4.2.21), if necessary. Those portions of the SOP that apply to normal operations
and those that apply only to the test should be clearly identified.

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SECTION 6
CONDUCTING AND MONITORING A TEST
Once EPA has determined that the test plan is satisfactory, the agency will issue approval to the
applicant, and a testing date agreeable to both the applicant and EPA will be set. 54 A test approval will
generally contain conditions addressing, for example, advance 30-day notification of the test to other
appropriate authorities (i.e., EPA regional Administrator, state and local agencies), permissible PCBcontaining material(s) to be treated, as well as sampling and analysis, waste disposal, QA,
recordkeeping, and reporting requirements applicable to the testing period. The applicant should check
with the approval writer to determine if other steps, such as public notice, may be needed prior to test
approval. 55 A copy of the test approval should be located on-site and adhered to during the test.
If any modifications to the test plan are needed prior to the test, notify EPA (approval writer) in writing
at least 14 days prior to the test or as specified in the test plan approval. Also, if events warrant that the
plan be significantly modified during the test, then the approval writer should be contacted immediately
to discuss the implications of any modifications.
The test should be conducted under conditions simulating reasonable most challenging operational
conditions (e.g., minimum temperatures or maximum flow rates). Operating approval
limits/requirements usually reflect the operating conditions during the test. Therefore, as discussed in
section 5, the applicant should have given careful consideration to the design and implementation of the
test in the test plan.

6.1 Expected Responsibilities During the Test

The following section discusses the anticipated responsibilities of EPA personnel witnessing the test and
the suggested responsibilities of the facility personnel/applicant conducting the test.

6.1.1 EPA’s Role

When the test begins, EPA’s primary role is to observe the test. This may include looking at gauges,
instrument panels, control center panels, and other various components of the process. EPA officials
may also ask the operators or other facility personnel questions about the process, any sampling to be
conducted, or about various control/instrument panels that are monitoring the PCB disposal unit. EPA
should be notified prior to collecting any samples because EPA personnel may wish to observe the
sample collection. If sampling occurs without EPA knowledge, the sample may be disqualified and the
test run may not count if treatment cannot be verified. Due to liability concerns, EPA will not:
• Give any direction or instruction during the test (e.g., suggesting that the temperature should be
increased or decreased);
• Touch any components of the system (e.g., valves, buttons or other components);
• Help the operators run the treatment unit. For example, if an operator is assigned to monitor
certain gauges and they need to step away temporarily, then the operator should request another
operator or a manager to temporarily step in to monitor the gauges. EPA personnel are not
responsible for any issue that may arise if the unit is left unattended;
• Touch any of the applicant’s sampling equipment or collected samples; or
54
55

As a reminder, trial burns and demonstration tests are referred to collectively as tests.
See section 8 for more information on public engagement.

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•

Collect samples on behalf of the facility (though EPA may request that the facility operators
collect duplicate samples on behalf of EPA).

EPA reserves the right to end the test and leave the facility at any point. Reasons for ending a test may
include:
• Runs cannot be completed after three attempts;
• PCBs are not sufficiently destroyed or removed from the media based on preliminary data after
three attempts;
• Steady-state conditions could not be achieved after two days;
• Equipment failure occurs and it cannot be repaired within two days;
• Unexplained data quality or operational parameter monitoring issues occur during the test;
• Hazardous conditions occur at the facility (e.g., fire or explosion occurs); and/or
• Another disruptive event, such as a natural disaster (e.g., hurricane, earthquake, or tornado) or a
power outage, occurs at the facility.

6.1.2 The Facility’s Role

The primary roles of the facility personnel conducting the test are to ensure they are operating the
treatment unit as stated in the conditions of the test approval issued by EPA and communicating with
EPA personnel witnessing the test. If the facility cannot meet the conditions stated in the approval, then
it is strongly suggested that the facility personnel notify EPA as soon as possible. If significant delays
occur during the test and EPA is not made aware of the issues causing the delay in a timely matter, then
EPA personnel may leave and effectively end the test. Discussing any issues that arise during the test
with EPA in a timely fashion may allow for a quicker resolution so that future test runs have acceptable
results. Also, if needed, EPA personnel may allow for modifications of the test approval during the test.
Important items that the facility operators or personnel should communicate to on-site EPA personnel
during the test are:
• Various stages of the treatment process (e.g., start-up, achieving steady-state, adding PCB
waste);
• Regular reports on the operational performance of the unit;
o Current operational measurements (e.g., temperature, pressure);
o Air emissions monitoring performance (e.g. preliminary isokinetic calculations);
o Sample results, if there is a quick turnaround for results;
• Any sample collection related to the test run (which may be witnessed by EPA personnel);
• Any required notification, as stated in the approved test plan; and
• Any issues that have occurred during the test.
An “event log” should be maintained throughout the test and submitted as part of the test report.

6.2 Preparing for the Test

In advance of the test, the principal manager should ensure that the facility is prepared for testing of the
PCB treatment unit. All instruments, controls, devices, etc., should be in working order and calibrated.
All continuous emissions monitors such as oxygen, carbon monoxide, and carbon dioxide should pass
zero drift and span drift tests. EPA may provide an audit cylinder for one or more of these monitors for a
performance demonstration during the test. Sufficient supplies of PCB waste, fuel, reagents, etc., should
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be on hand. If media will be spiked with PCBs then the concentration of the PCBs should be known and
the target PCB concentration within the media should be calculated. It is suggested that sampling
equipment be prepared, containers labeled accordingly, and the lab prepared to process the samples. The
checklists provided in Appendix F may be helpful when preparing for the test.
Provided that other local, state, and federal regulations allow it, one or more pre-tests, known as
shakedowns, may be conducted using a non-TSCA regulated feed (less than or equal 2 ppm) to practice
operating a unit. EPA may also approve processing a limited quantity of PCBs in an alternative
treatment unit under an R&D approval prior to a full-scale test (see section 4.1.4). EPA encourages
applicants to thoroughly shake down new units before any PCBs are introduced into the
treatment/disposal system. The facility should certify that its continuous emissions monitors (CEMs)
such as oxygen, carbon monoxide, and carbon dioxide, have passed the appropriate tests such as zero
drift and span drift tests. EPA may order an audit cylinder for one or more of these monitors that can be
delivered to the facility for them to demonstrate during the test.
Before starting up the unit, regulatory officials (this may include both EPA and state officials) may
arrive to witness the test. It is suggested that the principal manager provide a brief run-through of the
test plan and discuss any last-minute concerns. It is also suggested that the principal or facility manager
provide a safety briefing on its safety and evacuation plan for emergency and/or mechanical breakdown
situations. EPA personnel are typically required to take 40-hour Hazardous Waste Operations and
Emergency Response (HAZWOPER) training with a refresher every two years, but safety protocols
specific to the facility should also be discussed and any site-specific hazards should be identified. For
example, ear plugs or respirators may be needed in a room where certain samples are taken during the
test. EPA personnel will generally bring steel toe boots, hard hats, and safety vests. If additional safety
equipment is needed during the test, notify EPA prior to arriving at the facility.

6.3 Three Phases of a Test

Each test of a PCB treatment/disposal unit usually consists of three phases: start-up, treatment/disposal,
and shutdown. Each phase is discussed below. 56

6.3.1 Phase I: Start-up of the Treatment/Disposal Unit

Start-up is conducted to ensure that the facility is prepared to begin processing PCB waste. For both
continuous operations and batch operation, the system is typically brought up to steady-state conditions
prior to feeding any PCBs into the system. When the operating parameters reach the planned levels for
the test, the time and conditions should be noted, air emissions sampling should begin, if applicable, and
samples should be collected to characterize background conditions for quality control, if applicable.
PCB waste should not be introduced into the system until all required monitoring devices are operational
and recording necessary parameters. Waste should also not be fed to the treatment unit between test runs
unless provided otherwise in the approval test plan. 57

As discussed previously, be sure to communicate with on-site EPA personnel during each phase. There may be specific
points during the test that EPA personnel will want to observe.
57
Do not confuse start-up with shakedown. A shakedown should occur before the scheduled test and with non-TSCA
regulated waste to practice operating the unit. Practice operating the unit may include all three phases: start-up, treatment,
shutdown.
56

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6.3.2 Phase II: Treatment/Disposal of PCB Waste

At this point the treatment unit should have reached steady-state conditions, sampling/monitoring
procedures should have started, and, for continuous operations, PCB waste should now be introduced
into the unit at expected maximum feed rates and maximum PCB concentrations.
During phase two, samples should be collected and records kept of all operating conditions stated in the
test plan (e.g., continuous monitors, gauges, and meters). Visual observation of the effluent also should
be made, where appropriate. Quick turnaround times for the samples during the test will allow for a
quick assessment of the unit’s performance and for discussion of any identified issues with on-site EPA
personnel. If, after the first run, an issue is identified and remediated or a minor change to the test plan is
made, on-site EPA personnel may allow the test to continue for an additional test run rather than
scheduling a future test so that three successful test runs can be completed during the same test. Any
issues with or changes to the test plan should be documented in the test report.
The length of individual test runs will depend on the specific disposal process. A three to four-hour
emissions test is typical for incinerators or alternative thermal destruction technologies, with three test
runs conducted on successive days. For stack emission testing, the probe should be inserted into the
stack after steady state is reached, usually about 30 minutes after starting the PCB waste feed. This
allows sufficient time for volatilization and destruction of PCBs in the combustion chamber(s) and for
sampling of representative combustion gas emissions during PCB incineration.
Testing a batch type treatment/disposal process might consist of test runs of three separate batches. The
length of time to complete each batch is based on the treatment type and the operational parameters of
the unit, such as PCB concentration, quantity of the PCB waste, temperature, media type, etc. Typically,
it will take several hours to complete a run. If a run will last longer than 12 hours, EPA requests prior
notification, as additional EPA and/or state regulatory personnel will be needed for additional shifts. In
rare occasions when an extremely long test is approved (weeks or months long), then alternative
measures may be needed, such as alternative monitoring measures, restricted access, and evidence tape.

6.3.3 Phase III: Shutdown of the Treatment/Disposal Unit

After testing is complete for the process or paused between individual test runs that occur on separate
days, the waste feed should be terminated and the system shut down per normal procedures. For certain
processes, such as incinerators, the system may be kept running on non-TSCA regulated waste at the
discretion of the operator. This would allow a test run on a subsequent day to begin with minimal time
needed to obtain steady-state conditions during the start-up process.

6.4 Completed Test

A test may conclude once three test runs are completed as described above (section 6.3) or if EPA or the
applicant decides to end the test prematurely. The applicant should review any available results of the
test runs and provide those results before EPA leaves the site (e.g., isokinetic results of each run). As
previously mentioned, test runs can be evaluated using monitoring data and preliminary sampling results
to identify indications of passing. EPA may not accept data collected after EPA leaves the site. If the
applicant is concerned about the results, the applicant can discuss this with EPA before EPA personnel
leave the site in order to find a resolution. EPA may allow the applicant to conduct an additional test
run. For example, if a sampling probe broke during a test run, EPA would likely allow the applicant to
conduct another test run if the facility is able to readily replace the probe. If significant changes are
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needed to the operating conditions then a new test approval may be required.

6.4.1 An Acceptable Test

A test run should meet the criteria stated in section 4.1.2. To determine if a run meets these criteria,
samples should demonstrate destruction or removal of PCBs from the media as stated in the test
approval. Typically, for batch systems, steady-state conditions should be maintained for enough time
such that destruction/removal of PCBs to appropriate levels is achieved. For continuous operations, such
as catalytic hydrogenation, the unit may run for several residence times to complete one test run and
achieve appropriate destruction levels. Furthermore, if applicable, air sampling data must demonstrate at
least 99.9999% destruction of the PCBs. EPA generally asks for three acceptable runs to be completed
prior to issuing an operating approval.

6.4.2 A Failed Test

A test may fail for several reasons (see section 6.1.1 for a more detailed discussion). Typically, a test
may fail if the treatment unit was unable to destroy PCBs to an acceptable level, all three runs could not
be completed, or a run was conducted without EPA approval. Furthermore, it may not be known
whether a unit failed a test until the data are obtained and analyzed. Regardless of whether a test passed
or failed, EPA recommends that a test report be completed and submitted.

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SECTION 7
TEST REPORTS
After a test approval is issued and the test has been completed, a report of the results should be prepared
and submitted to EPA. 58 This section presents the suggested format for a test report and discusses the
information that should be provided. Note that a test report should be submitted to EPA regardless of
whether the technology passes or fails the test. The report should be submitted to the same delegated
EPA official as the test plan (see section 2.2). While electronic submission of files is preferred, EPA will
occasionally request paper copies of the test report. Contact EPA personnel to receive specific
instructions for submitting CBI material (see section 4.1.5 for more information). Following receipt and
review of the test report, EPA will begin drafting an operating approval, ask for more information, or
deny the request for an operating approval. If the technology failed the test, EPA will notify the
applicant and provide the basis for determining the test was failed. If EPA determines the test results
adequately demonstrate that the facility has passed all applicable requirements, then EPA will begin
drafting the operating approval. The applicant is encouraged to communicate with EPA if assistance is
needed when developing the test report.

7.1 General

A test report should discuss the sampling results, monitoring data, and general operation of the
technology observed during the test. Much of the content may have already been identified in the test
plan or approval application. This generally includes:
• Time, date, and location of the test;
• Quantity and type of PCBs and PCB Items treated/removed during the test;
• Summary of methods used to monitor the process operation and for sample analysis;
• Process operation and emission results;
• Sampling test results; and
• Quality assurance report with name, address, and qualifications of persons who reviewed
analytical results and other pertinent data.
To help expedite the review process, EPA suggests including the page number or section number of any
referenced document or data from the test plan or approval application. Additionally, it may be
beneficial for the applicant to review previous sections of the guidance that may help with the
development of the test report, such as criteria (section 4.1.2) and purpose of a test (section 5.1.1)
In instances where the applicant is submitting a revised test report based on comments received from
EPA, or due to proposed changes to a previously submitted report, the applicant should summarize such
changes/revisions up front (see section 7.2.4), and if practicable, provide a redline/strikeout “compare”
version that highlights the revisions that have been made. 59 The applicant is also encouraged to provide
EPA with a standalone response to comments document that briefly explains/summarizes how each EPA
comment was addressed in order to facilitate the EPA review process.
In instances where significant deficiencies have been identified by EPA, or the applicant is unclear as to
As a reminder, trial burns and demonstration tests are referred to collectively as tests.
In instances where significant revisions or rewrites have been made, a redline/strikeout compare version may not be
practicable/useful.
58
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how to address specific deficiencies, the applicant may find it useful to request a meeting or
teleconference with the approval writer to help ensure the revisions adequately address the comments
received. EPA may deny the application if the deficiencies are not addressed within a reasonable period
of time.
Following EPA’s review of the test report and any supplemental information, EPA will either begin to
draft the operating approval or deny the applicant’s request for an operating approval. Specific
conditions will be included in an approval and must be followed when operating under the approval (see
section 8 for more information). Note that the conditions in the operating approval will be based on the
parameters and operating performance observed during the test and, as a result, these conditions may
differ from the conditions in the test plan approval. If an operating approval is denied but the applicant is
still interested in an approval, then a new application and test plan should be submitted to EPA and a
new test will likely be required. Any subsequent test plan and operating approval applications should
directly address the deficiencies that were identified in the operating approval denial.

7.2 Contents of Test Reports

Table 14 presents the suggested format for the test report.
Table 14. Suggested Format for the Test Report
Section No.

Section Title
Test Report Cover
Table of Contents
Certification Letter

I
II
III

Summary
Process Operation
Monitoring and Sampling Procedures

IV
V

Analytical Procedures
Test Results

VI
VII

Quality Assurance Summary
Visits and Audits

VIII

Waste Handling and Disposal
Appendices

7.2.1 Transmittal Letter

All test reports should be accompanied by a transmittal letter which summarizes the test results and any
major modifications to or deviations from the test plan made during the test. If the test was completed
for the purposes of renewing an operating approval, the applicant should briefly summarize
how/whether their operations will differ from their previous operating approval.

7.2.2 Cover Page

A suggested cover page format for the test report is shown in Figure 7. The main cover should reference
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when the applicant submitted the test plan and operating approval application and when EPA approved
the test plan. If a paper copy is requested by EPA and if the report volumes or the appendices are bound
separately, each part of the submission should be numbered in order in the upper right-hand corner of
the cover (“Volume m of n”). The covers of each volume should have the full cover information shown
in Figure 7.

7.2.3 Certification Letter

The test report should include a letter, signed by an authorized official, certifying on behalf of the
applicant that the information contained in or accompanying the document is true, accurate, and
complete. 40 CFR 761.3 provides the necessary language for a certification letter. This may be a signed
statement within the report rather than a separate letter. The signed certification letter may be submitted
via email.

7.2.4 Test Report Section I - Summary

The test report should begin with a narrative that summarizes the overall performance of the technology
during the test. The narrative should highlight important operational parameters and whether the facility
met all performance standards and regulatory requirements. It is recommended that this section include
table(s) summarizing the pertinent test results. Major problems and deviations from the test plan should
also be summarized.

7.2.5 Test Report Section II - Process Operation

The following sections discuss the process operation information suggested for inclusion in the test
report.
7.2.5.1 General Process Operation Information
A general overview of the process operations using simplified flow diagrams and a brief narrative
should be provided. Detailed information on the process operations should have been stated in the
approval application or test plan and may be referenced in the test report. When referencing the
application or test plan, EPA suggests including the page number or section number of where the
information is located.
When providing data, a tabular format with explanatory narrative, as applicable, is preferred. Table 15 is
an example summary table of the results for an incinerator or an alternative thermal destruction
technology test and Table 16 is an example summary table for a non-thermal destruction/removal
technology test. Detailed data such as data logs (e.g., tables of temperature recordings) and the process
operator’s log should be presented in an appendix. Detailed data may be summarized in the narrative or
in a table as an average and/or a min/max range observed during the test. All the results should be
compared to the anticipated operating ranges/levels discussed in the test plan and any results outside the
anticipated levels should be highlighted. A discussion regarding any deviation from the test plan should
be included in the test report; more details regarding deviations are provided in section 7.2.5.4.
Note that, due to the variety of technologies that currently exist, the example tables may not capture
every relevant parameter, nor is every parameter shown in the tables relevant to all technologies. The
applicant should be proactive in identifying and including applicable information so the test report is
thorough, but also clear to the approval writer; otherwise, the operating approval may be delayed or
denied.
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Volume m of n

TEST REPORT, VERSION # X (IF APPLICABLE) 60
PCB TREATMENT/DISPOSAL UNIT
[Type and location of unit]
[Name and location of company headquarters if different from above]
Operating Approval Application Submission Date: [date]
Test Plan Submission Date: [date]
Test Date(s): [date(s)]
Test Report Submission Date: [date]

Submitted by:
[Company name and address]
[Principal manager
and phone number]

Submitted to:
Director, Office of Resource Conservation and Recovery
Office of Land and Emergency Management
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Mail Code 5303P
Washington, DC 20460
ORCRPCBs@epa.gov
OR
If submitted to an EPA Regional office, provide the applicable
Region’s address listed at www.epa.gov/pcbs/program-contacts.

Figure 7. Test Report Cover Page Example.

If the document is revised and resubmitted to EPA, the applicant should clearly indicate on the cover that the report has
been updated (e.g., version 2).
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Table 15. Example Test Results Summary Table for Incinerator or Alternative Thermal
Destruction Technology 1,2
Test Run 1

Test Run 2

Test Run 3

Date
Time test begun
Time test ended
Operating parameters:
Max/Avg. waste feed rate (kg/h)
Min/Avg. treatment unit temperature
Max/Avg. PCB concentration (g/kg)
Max/Avg. PCB feed rate (kg/h)
Auxiliary fuel feed rate (kg/h)
Total thermal load (106 Btu/hr)
Residence time (seconds)
Minimum combustion air flow (acm/min)
Avg. O2 (%)
Avg. CO2 (%)
Avg. CO (ppm)
Combustion efficiency (%)
Min/Avg. scrubber water flow (gpm)
Min/Max scrubber water pH
Min/Avg. Venturi water flow (gpm)
Avg. Venturi pressure drop (inches H2O)
Particulate/HCl emissions:
Total sample time (min)
Total sample volume (dscm)
Stack gas flow rate (dscm/min)
Particulate concentration (mg/dscm)
Chlorine (g/min)
HCl removal (%)
PCB emissions:
Total sample time (min)
Total sample volume (dscm)
PCB feed rate (g/min)
PCB output rate (g/min)
PCB DRE (%)
PCDD/PCDF emissions:
Total sample time (min)
Total sample volume (dscm)
Total PCDD emissions (ng/dscm)
Total PCDF emissions (ng/dscm)
DISCLAIMER: This table is only an example and may not capture every relevant parameter for thermal destruction
technologies, nor is every parameter listed in the table relevant to all technologies. Furthermore, applicants are not required
to use this table.
2
The units may be different depending on the technology.
1

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Table 16. Example Test Results Summary Table for an Alternative Non-Thermal
Destruction/Removal Technology 1,2
Test Run 1

Test Run 2

Test Run 3

Date
Time test begun
Time test ended
Operating parameters:
Max/Avg. waste feed rate (kg/h)
Max/Avg. PCB concentration (g/kg)
Max/Avg. PCB feed rate (kg/h)
Auxiliary fuel feed rate (kg/h)
Residence time (seconds)
Reagent Feed Rate (kg/h)
Flow rate through reactor chamber (l/min)
Pressure in reactor chamber (psi)
Temperature in reactor chamber (ºC)
Product effluent flow rate (kg/hr)
Effluent wastewater flow rate (l/min)
PCB concentration in effluent streams (ppm or ppb)
By-product concentration (ppm)
Vent emissions:
Total sample time (min)
Total sample volume (dscm)
Stack gas flow rate (dscm/min)
Volatile organic compound (VOC) (g/min)
Chlorine (g/min)
HCl removal (%)
Particulate concentration (mg/dscm)
DISCLAIMER: This table is only an example and may not capture every relevant parameter for non-thermal
destruction/removal technologies, nor is every parameter listed in the table relevant to all technologies. Furthermore,
applicants are not required to use this table.
2
The units may be different depending on the technology.
1

7.2.5.2 Pollutants and Parameters Monitored/Sampled during Tests for Incinerators or Alternative
Thermal Destruction Technologies
The applicant should present and discuss the process operating parameters, pollution control system
parameters, and emissions that were recorded during the start-up, operation, and shutdown phases of
thermal tests. 61 These results should be compared to the target values provided in the test plan. The
minimum monitoring and recording requirements for incinerators, as provided in 40 CFR 761.70, to be
discussed in the test report include:
• The waste feed rate, quantity and recording intervals;
• The combustion temperature and recording frequency;
• The concentrations of combustion products (e.g., O2, CO, and CO2 ); and
61

See sections 4.2.7 and 5.2.6 for more information regarding monitoring and sampling plans.

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•

The concentrations of stack emission products that were monitored (e.g., NOx, HCl, residual Cl,
PCBs, and total particulate matter).

Any additional monitoring and sampling parameters beyond those listed in § 761.70 that were applied to
ensure the operation of the PCB treatment/disposal method does not present an unreasonable risk of
injury to health or the environment or, for alternative thermal destruction technology, to achieve a level
of performance equivalent to disposal by an incinerator approved under § 761.70, should be discussed. 62
EPA may include limitations for these operating parameters in the operating approval based on the
levels demonstrated during the test (see section 5.1.1 for more information). Additional parameters to
discuss in the test report will vary based on the design of the treatment/disposal unit but may include:
• The PCB content of the waste feed and Destruction and Removal Efficiency (DRE) calculations;
• The concentrations of dioxins and furans in the stack emissions;
• The PCB, dioxin, and furan concentrations in any solid or liquid wastes generated;
• Observed parameter values that indicate proper treatment performance (e.g., minimum residence
time, batch feed operating parameters, and liquid waste atomization parameters);
• Observed parameter values that indicate proper operation of the pollution control systems (e.g.,
scrubber water flow rate, pH, pressures, and temperatures); and
• Observed safety parameter values that demonstrate no unreasonable risk to workers and the local
community from PCBs, other hazardous chemicals/by-products, or other hazards (e.g., fires or
explosions).
7.2.5.3 Pollutants and Parameters Monitored/Sampled during Tests for Alternative Non-Thermal
Destruction/Removal Technologies
Monitoring and sampling parameters to be included in the test report for non-thermal
destruction/removal technologies should verify that the applicant’s PCB treatment/destruction process
achieved a level of performance equivalent to disposal in a § 761.70 incinerator or a § 761.71 high
efficiency boiler and will not present an unreasonable risk of injury to health or the environment, as
required under § 761.60(e). The applicant should present and discuss the process operating parameters,
pollution control system parameters, and any effluent streams that were recorded during the start-up,
operation, and shutdown phases of non-thermal tests. These results should be compared to the values
reported in the test plan. The monitoring and sampling parameters for non-thermal technologies will
depend upon the process design and the waste feed and effluent streams associated with the non-thermal
alternative treatment/disposal method. The applicant should discuss: 63
• At a minimum, the PCB concentrations in the final product and in all effluent streams
(wastewater, filters, vent gas, treated oil, etc.);
o If using separation treatment (e.g., carbon filtration) then verify the concentration of
PCBs in the clean fraction(s);
o Discuss air emission results if air sampling was required;
• Monitoring results of any reactant/oxidant/fuel/catalyst and their feed rate into the system;
• Observed performance parameter values that indicate effective treatment (e.g., minimum
residence time, batch feed operating parameters, and liquid waste atomization parameters); 64
• Observed pollution control system operating parameter values that indicate proper operation
40 CFR 761.70(d)(4)(ii), 60(e).
See sections 4.2.7 and 5.2.6 for more information regarding monitoring and sampling plans.
64
Remember, as previously discussed in 4.1.3, there will likely be fewer operating process limits for processes where
treatment efficiency can be verified as opposed to treatment systems that rely on indirect parameters to assure compliance.
62
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•
•

(e.g., pressure drop, temperature, flow rate, etc.);
Quantity and concentrations of hazardous by-products produced by the treatment process; and
Observed safety parameter values that demonstrate no unreasonable risk to workers and the local
community from PCBs, other hazardous chemicals/by-products, or other hazards (e.g., fires or
explosions).

7.2.5.4 Deviations from the Test Plan
The applicant should provide a discussion of any modification made to the operating parameters or any
events such as upsets, unplanned shutdowns, or other deviations from the approved test plan that
occurred during the test. The applicant should explain why the event occurred and discuss the effect on
the test results and on the overall ability of the system to routinely operate within expected approval
conditions. Note that control limits (i.e., acceptable ranges) will be listed in the operating approval, and
will be based on the operating parameters of a successful test. If the operating parameters demonstrated
during a successful test differed from the target parameter levels proposed in the test plan, then the
demonstrated parameters rather than the parameters listed in the test plan will likely be used to establish
the operating approval conditions (see section 5.1.1 for more information). A modification to the
approval conditions can be requested after the approval is issued but a new test may be required.
PARAMETER VALUES DEMONSTRATED , NOT THE TARGET PARAMETER VALUES STATED IN
THE TEST PLAN , WILL BE USED TO DEVELOP THE OPERATING APPROVAL CONDITIONS.

The test report should also contain a discussion regarding any non-incident-related changes to the test
plan such as site location, quantity of PCBs treated, or use of an independent laboratory for analysis. The
purpose or reasons for these types of changes should be explained.
EPA requests that deviations from the approved test plan also be verbally reported to the approval writer
during the test and as a separate incident report within 14 days of the incident. Any corrective actions
conducted for each event also should be provided to the approval writer and should be presented in an
appendix of the test report.

7.2.6 Test Report Section III - Test Results

The test report should discuss the test sample results, QA/QC results, and system performance, as
applicable. All analytical test results should be included as an attachment to the report and summarized
in the report narrative. Summary tables showing all analytical results with the dates and times of sample
collection should be included in the report. All results should be traceable to the original test data. At a
minimum, the test report should identify how the results were calculated (formulae and data used).
Detailed sample calculations should be presented in the appendix and referenced. For example, the
equation used to calculate the DRE should be provided as follows:
𝐷𝐷𝐷𝐷𝐷𝐷 = �

𝑊𝑊𝑖𝑖𝑖𝑖 − 𝑊𝑊𝑜𝑜𝑜𝑜𝑜𝑜
� × 100
𝑊𝑊𝑖𝑖𝑖𝑖

The values or location of the values for Win and Wout used in the calculation (e.g., the table or page
number where they appear in the report) along with the calculated result should be clearly identified, so
that the DRE calculation may be confirmed.
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Also identify and discuss any anomalies in the system operation, sampling, monitoring, or analyses that
may have significant impact on the test results. Raw data and raw analytical results (e.g., chromatograms
and mass measurements) also should be presented in the appendices.
The applicant should ensure that the unit of measure is indicated for all numerical data (e.g., ppm, %,
mg, mL) and is consistent throughout the test report. Also, it is suggested that samples have an easily
identifiable label or naming scheme within the report. For example, a duplicate sample taken at the end
of the second test run, located in the feed tank could be labeled as “Demo_R2_FT_End-dup.” At
minimum, the applicant should include a table correlating the sample label to the sample description.

7.2.7 Test Report Section IV - Monitoring and Sampling Procedures

This section of the report should summarize the monitoring and sampling procedures used during the
test. The applicant should discuss the samples collected (type, location, time, volume, and number) and
all monitoring data collected (type, location, and time period). A schematic diagram can be used to
illustrate the monitoring and sampling locations. Describe any data processing that was conducted with
the results, such as, data reduction or calculations. 65 Also, discuss the methodology used to translate the
data into operating parameter ranges. Some of this information should have been discussed in the test
plan (sections 5.2.6 and 5.2.7) and may be duplicated or referenced in the test report, but any significant
deviations from the approved test plan should be noted and the potential effects on the results discussed.
Any “standard methods” used should be referenced, and any deviations from standard procedures, such
as modifications to the published procedures, or selection from several options given in a procedure
should be described. Lengthy descriptions should be placed in an appendix. When the standard method
allows different procedural variations to be used, the applicant should be specific as to the procedures
that were followed (e.g., for the measurement of O 2 and CO2 concentrations in the stack gas by EPA
Method 3, whether multi-point integrated sampling or single-point grab sampling was used).

7.2.8 Test Report Section V - Analytical Procedures

The test report should summarize the analytical procedures used for each parameter (e.g., PCBs in
water). Standard procedures may be referenced, but any deviations from or modifications to referenced
methods should be described. Some of this information may have been discussed in the test plan (section
5.2.7) and may be duplicated or referenced in the test report, but any significant deviations from the
approved test plan should be noted and the potential effects on the results discussed. Lengthy
descriptions of the analytical procedures should be placed in an appendix.
In some instances, the applicant may have been asked to demonstrate equivalence between a method
they are requesting and a standard method or an EPA method, such as those found in SW-846 (i.e.,
Method 8082). If this is the case, duplicate samples should have been taken during the test and analyzed
according to both methods. The applicant should present the results that compare the two methods in
this section and discuss how the two methods are equivalent. The applicant should also discuss how the
proposed method does not present unreasonable risk of injury to health or the environment.

It may be beneficial to show one step-by-step calculation as an example if the calculation is conducted multiple times to
obtain test results.
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7.2.9 Test Report Section VI - Quality Assurance Summary

This section should summarize the QA results (blanks, replicates, audit results including results from
performance evaluation (PE) samples). The applicant should identify any serious problems (e.g.,
unacceptable audit results, failure to calibrate instrumentation) or deviations from QA procedures
identified in the approved test plan.
A complete QA report should be appended to the test report and address all the QA objectives, including
whether precision and accuracy objectives were met, as well as results of QC samples, performance
audit samples, and systems audits. This report should be authored and signed by the project’s QA
officer.
Additional information regarding a QAPP can be found in section 4.2.20 of this guidance document.
Also, other guidance documents may be helpful, such as: “Guidance for Quality Assurance Project
Plans, EPA QA/G-5” (U.S. EPA, 2002) and “EPA Requirements for Quality Assurance Project Plans”
(U.S. EPA, 2001). See Appendix D for a QAPP template, or contact EPA for guidance.

7.2.10 Test Report Section VII - Visits and Audits

This section should contain a list of visitors and auditors and the affiliation, address, and phone number
of those who were on site during the test. The list should include all visitors or auditors from local, state,
or federal agencies and their contractors, applicant management, QA personnel, and independent
consultants. Where possible, the purposes of these visits should be summarized and any significant
results (audit reports, engineering certifications, etc.) issued by any visitors should be appended to the
test report.

7.2.11 Test Report Section VIII - Waste Handling and Disposal

The applicant should be aware that all PCB waste generated during the test should be disposed of or
decontaminated in accordance with the requirements of 40 CFR part 761, subpart D. The test report
should provide documentation that all wastes generated during the test were properly disposed of in
accordance with the applicable requirements of TSCA and any other applicable law, such as RCRA.
Copies of manifests should be included in the test report, where applicable, unless available through
EPA’s e-Manifest system.

7.2.12 Appendices

Supporting information should be included in the appendix. Due to the amount of information expected
to be placed in the appendix, EPA suggests separating the information into multiple appendices. The
applicant should clearly label multiple appendices (e.g., Appendix A – Detailed Procedures, Appendix B
– Off Gas Data Sheets, Appendix C – QA Report).
Supporting information in appendices may include:
• Detailed procedures;
• Detailed analytical results;
• Other detailed data sets such as monitoring parameter logs;
• Sampling calculations;
• QA report;
• Chronological test event log;
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•
•
•

Incident reports;
Chromatograms;
Waste manifests; and
Chain of custody record(s).

7.3 EPA Review of the Test Report

The approval writer will review the report to determine if it contains all the information necessary for
the EPA approval writer to decide whether to issue an operating approval.

7.3.1 Evaluating Test Results

When evaluating results of a test, EPA will generally consider compliance with the criteria listed in
section 4.1.2 (regulatory standards, performance standards, and QA/QC criteria). The criteria will be
compared to the results of the test to determine whether the treatment unit performance was equivalent
to disposal in a § 761.70 incinerator or a § 761.71 high efficiency boiler and will not present an
unreasonable risk of injury to health or the environment, as required under § 761.60(e).
EPA will determine if regulatory standards were met during the test. 66 The PCB concentration for all
treated effluent sources must be ≤ 2 ppm for all matrices (e.g., clean soil or dielectric fluid) except air
and water. 67 Water must contain < 3 ppb PCBs if discharged to treatment works or navigable waters
(unless the discharge is in accordance with a PCB discharge limit included in a permit issued under the
Clean Water Act) or ≤ 0.5 ppb PCBs for unrestricted use. 68,69 Air emissions must be at least 99.9999%
DRE for PCBs 70 and additional air quality standards may apply (e.g., dioxins and furans). 71 An
incinerator must meet all of the requirements specified in § 761.70(a) and § 761.70(b), unless a waiver is
obtained pursuant to § 761.70(d)(5).
EPA will evaluate the operational performance of the treatment unit. This generally involves reviewing
the monitoring and sampling test results to ensure the treatment process operated within the conditions
stated within test plan. EPA will also review the monitoring and sampling data to ensure it was
conducted as planned (e.g., sampling frequency). If the results are out of range or the monitoring and
sampling was not conducted according to plan, then a discussion should be provided explaining the
discrepancy and how it will be addressed in the future. EPA may consider this information when making
a no unreasonable risk determination and may include additional conditions in the operating approval, as
needed.

All the regulatory standards listed here may not be applicable depending on method of treatment and disposal. For
example, PCB-contaminated solids and liquids may be separated during an approved treatment process where the solids are
sent to a TSCA landfill and the liquids are treated to ≤ 2 ppm.
67
Previous guidance has interpreted that “equivalent level of performance” to an incinerator means less than or equal to 2
ppm. See “Guidelines for Permit Applications and Demonstration Test Plans for PCB Disposal by Non-Thermal Alternative
Methods” (1986).
68
40 CFR 761.50(a)(3).
69
40 CFR 761.30(u)(3).
70
40 CFR 761.70(b)(1).
71
These standards may be satisfied through a CAA permit instead, if applicable.
66

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EPA will review the test report with safety considerations in mind. EPA will review any procedures or
operations that may pose a risk to the workers or the local community such as buildup of an
explosive/flammable compound, location of combustible materials, and exposure to PCBs or other
hazardous constituents. It may be beneficial to include a discussion on how the treatment process was
operated safely during the test and point out the safety considerations that will continue to be
implemented during normal operations.
QA/QC data will be reviewed by EPA to determine that the accuracy, precision, and representativeness
of the data have been demonstrated. This includes reviewing the supporting data, gas chromatograms,
and calculations. Data from duplicate samples taken by EPA will be compared to the measured values
provided by the applicant; it is expected that the data falls within 70-130% of EPA’s results. Also, EPA
may provide two performance evaluation (PE) samples to the applicant, which should be analyzed and
presented in the test report.
EPA may take into consideration other federal and state requirements when evaluating the results, such
as:
• National Historic Preservation Act (NHPA);
• Endangered Species Act (ESA);
• Environmental Justice per Presidential Executive Order 12988;
• CAA and MACT standards; and
• Other state or local requirements.

7.3.2 Deficiencies in the Test Report

EPA may request more information if sections of the report are missing, incomplete, unclear, or
deficient. The process of identifying these deficiencies will vary depending on the approval writer but
deficiencies will generally be identified either through email/phone calls with the applicant, or in a list
compiled after reviewing the report in its entirety. If significant deficiencies are found in the report and
the applicant is unclear as to how to address them, it is suggested that the applicant request a meeting or
teleconference with the approval writer to help resolve any
issues. EPA may deny the application if the deficiencies
CLEAR AND COMPREHENSIVE
are not addressed within a reasonable period of time. EPA
REPORTING ARE KEY TO EPA’ S
encourages the applicant to work with EPA approval
ABILITY TO DO TIMELY REVIEWS
writers when developing their report so that deficiencies
AND APPROVALS.
are kept to a minimum and EPA can review the report and
issue an approval in a timely matter.

7.3.3 Incomplete or Failed Test

The applicant should still submit a test report for EPA review even if the test was incomplete or failed
for any reason. After review of the test report, EPA may:
• Move forward with drafting an operating approval;
• Deny the operating approval without further consideration;
• Recommend that the applicant submit a R&D approval application to provide an opportunity to
correct operating deficiencies prior to another test;
• Reschedule the test with the same test plan, which is usually done when minor deficiencies in the
operating process cause the problem. The applicant would be requested to provide adequate
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assurance to the approval writer that deficiencies have been corrected and subsequent test failure
is unlikely, that the test would be conducted in a manner that will not present an unreasonable
risk of injury to health or the environment, and that no modifications are needed to the treatment
system to assure they will be in full compliance with the performance standards; or
Reschedule the test with a new test plan, which is usually used when major design changes are
needed or major operating deficiencies need to be corrected before another test can be
performed. In such circumstances the facility should submit a revised test plan that reflects
design or operational changes such that there is adequate assurance the treatment unit will
achieve relevant performance standards. EPA will issue another test plan approval, if warranted.

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SECTION 8
APPROVAL ISSUANCE AND RENEWAL
Upon review of the test report and a determination that the process has demonstrated compliance with
all pertinent requirements of 40 CFR part 761 when operating pursuant to the proposed conditions of an
operating approval, EPA may issue a final approval to operate the PCB treatment system. This section
presents the general components in an approval, as well as the approval renewal and expiration
processes. Note that an operating approval will not be drafted if EPA determines the facility is not able
to operate in compliance with the relevant requirements in 40 CFR part 761. In this case, EPA will issue
a letter to the facility containing the determination and stating that they may submit a new test plan,
should the applicant choose to continue pursuing an operating approval.

8.1 Public Comment and Public Participation

EPA generally provides public notice and comment opportunities on fixed-site disposal draft approvals
and includes responses to public comments, where applicable, in final approvals or other supporting
documentation. 72 Research and development (R&D) approvals generally do not involve public
participation because of limitations on time and amount of material treated, however, the applicant
should verify this with the EPA. Mobile treatment units are generally required as a condition of the
approval to post a notice of operation where the local community could expect to see a community
notice, since the location where the mobile unit will operate may not be known prior to issuance of the
approval.
Draft approvals for fixed-site disposal activities are generally posted on EPA’s website during the public
comment period, along with additional information about the applicant and the proposed operations.
During the public notice period, all documents associated with the approval should be made available to
the local community. The public comment period usually lasts thirty (30) days and comments are
accepted by email and mail. Additionally, a public participation meeting is often held in the community
nearest the facility. This meeting serves to educate the public on the proposed operations and provide a
listening session to hear community concerns. Public comments will be reviewed and considered prior
to making the final decision on issuance of the final approval. If any material in the approval is CBI then
a redacted version will be provided to the public during the comment period (see section 4.1.5 for
information on submitting CBI material to EPA).

8.2 Operating Approval Contents

The primary conditions of the final operating approval will include select operating levels/ranges, the
type of PCB-containing material that can be processed, an upper limit on PCB concentration in the feed,
other technical requirements or conditions, and an effective period, usually between five and ten years,
from the date of issuance. Note that the conditions in the operating approval are based on the parameters
and operational performance observed during the test and, as a result, these conditions may differ from
the conditions stated in the approved test plan. Furthermore, EPA may find it necessary to include
additional requirements or conditions in the approval to ensure the treatment process will not pose an
unreasonable risk of injury to health or the environment, in accordance with 40 CFR 761.60(e) and
761.70(d)(4)(ii). For example, conditions pertaining to waste disposal, emergency response, site
Memo from Lynn R. Goldman to Jane Saginaw in April 1995 regarding the use of public participation in PCB commercial
storage and disposal approvals.
72

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security, recordkeeping, reporting, closure, and financial assurance may be included in the approval.

8.2.1 Mobile vs. Fixed-Site Disposal Approvals

The Director of ORCR has authority to issue multi-region approvals to mobile units and other PCB
disposal methods that are used in more than one EPA Region.
Mobile units may be subject to different notification requirements than fixed-site disposal units. Prior to
operating at a new location, a mobile unit will usually send non-confidential, written notifications of its
intent to treat PCBs at such location to EPA Headquarters, the appropriate EPA Regional PCB
coordinator, the applicable state environmental agency, and local governmental environmental entities
(if applicable). In some cases, the company may need to send additional advanced notifications to local
fire departments and other applicable local emergency response entities where the unit intends to
operate. Public notices that state when a mobile treatment unit is operating should be made available to
the local community. This may entail signs posted in public view at the facility and/or publication on the
facility’s website for the duration of the mobile treatment unit’s operation.
AN APPROVED MOBILE UNIT IS EXPECTED TO BE MOBILE; OPERATING FOR A SIGNIFICANT
AMOUNT OF TIME AT A SINGLE SITE WILL REQUIRE A FIXED SITE APPROVAL

If an approval is written for mobile operation of a disposal unit, but the company intends to operate the
unit at a facility for more than the period of time (e.g., 60 days) set forth in their approval in any given
year, the company may need to either convert the mobile approval into a fixed-site disposal approval or
obtain a separate, additional fixed-site approval. If a mobile approval and a fixed-site approval are
needed, then both approval processes will be coordinated between EPA Headquarters and the EPA
Region where the site is located.

8.2.2 Compliance under an Operating Approval

The operating approval will describe requirements for treating PCB waste and will likely also contain
recordkeeping, sampling, and notification conditions. Generally, a facility must begin operating under
the approval as soon as the PCB waste is being prepared for treatment or the unit is started up for
treatment of PCB waste, whichever comes first. A facility is usually required to follow the requirements
of their approval until all the TSCA-regulated waste is treated, the PCB waste is stored as required by
the PCB regulations, or the remaining PCB waste is sent off-site. The facility must follow all conditions
of their approval at all times when PCB waste is handled and treated. In some instances, the facility may
also be required to decontaminate their treatment unit following completion of treatment operations. The
facility should initiate closure if, for example the operating approval is terminated, expired, or the
facility will no longer be treating PCB waste. Furthermore, the facility must obtain and follow all other
applicable federal, state, and local permits and regulations.
EPA reserves the right for its employees or agents to inspect approved treatment/disposal units at any
reasonable time. If found to be out of compliance, EPA may:
• Suspend all PCB treatment operations until the facility addresses EPA’s concerns;
• Require a modification to the operating approval;
• Require a new test;
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•

Terminate the operating approval; and/or
Subject the facility to further enforcement action, including fines.

8.2.3 Approval Modifications

Modifications to an existing approval can be initiated by either EPA or the facility. EPA could initiate a
modification any time there is reason to believe the operation of the unit presents an unreasonable risk of
injury to health or the environment. EPA-initiated modifications may result from, for example, future
EPA rulemaking(s) or from new information gathered by the facility or EPA.
The facility also can initiate a major modification to the approval, for example, to increase the flow rate
through the system or change the engineering design, hardware, or capacity. Major modifications
initiated by the facility usually involve a test to ensure that the unit continues to operate in a manner that
does not present unreasonable risk of injury to health or the environment. Tests for modifications are up
to the discretion of the approval writer; for example, changes in ownership, or name changes may not
necessitate a retest. To initiate a modification and inquire about a retest, the facility should contact the
approval writer in writing by email or mail.

8.3 Approval Renewal and Expiration

If a facility would like to continue to operate beyond the expiration date of its approval, the facility must
submit a complete approval renewal application and, if required, a complete test plan to EPA in advance
(usually 180 days) of the expiration date of their approval. The submission period should be specified in
the approval. Generally, if the facility submits this information to EPA in accordance with the conditions
of their existing approval, EPA may allow the existing approval to continue in force until EPA issues a
renewed approval or an approval request denial. During this interim period, the approval is
“administratively continued.” However, the facility cannot begin operating under modified conditions
until EPA issues a renewed approval.
A complete approval renewal application and test plan includes, at a minimum, information that was
submitted in previously approved operating approval applications and test plans, with appropriate
modifications or updates based on proposed revisions to the original approval (i.e., treatment unit design
and operation changes and revised operating and testing procedures). For example, if a facility is
seeking approval to treat another PCB material or the same PCB-containing material at higher PCB
concentrations, the approval application and test plan should reflect those changes.
EPA will generally require the facility to conduct another test to assure its operations continue in
accordance with the applicable performance standards and in a manner that does not present an
unreasonable risk of injury to health or the environment. As a result, the facility is encouraged to contact
the EPA approval writer in advance of submitting an approval renewal application to ascertain whether a
new test is needed. If the facility wants to make changes to its operating parameters, then a test is
typically required. Remember that the facility will not be allowed to operate under revised operating
conditions until EPA issues a fully renewed and revised operating approval. When a test is required, the
approval renewal process is similar to the initial approval application process described in sections 3
through 7 of this document. Note that, if an approved facility is nearing their approval expiration date

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and they have an upcoming job to treat PCBs then they may be able to use that opportunity as a
demonstration test.
If no approval renewal application is submitted within the prescribed time frame, EPA will assume that
the company intends to let their approval expire. Even when an approval is set to expire, the company
may have obligations related to closure and should refer to their closure plan and approval. Early contact
with the approval writer will help the closure process run more smoothly. Once EPA receives
certification of closure (see section 4.3.1), EPA will notify the owner or operator that financial assurance
is no longer required.

8.4 Approval Termination

EPA reserves the right to terminate or revoke an approval at any time. EPA may terminate or revoke an
approval if there is reason to believe the operation of the unit presents an unreasonable risk of injury to
health or the environment. Termination may be initiated, for example, following future EPA
rulemaking(s) with respect to PCBs or new information gathered by the facility or EPA, such as
observed non-compliance with the approval.

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SECTION 9
REFERENCES
Doa, Maria J. “Memorandum: Policy Regarding Use of On-site Disposal Methods When Calculating
Financial Assurance Closure Cost Estimates,” Office of Prevention, Pesticides and Toxic Substances,
U.S. Environmental Protection Agency, Washington, D.C., May 1, 2007.
Goldman, L. R., 1995. “Memo to Jane N. Saginaw,” Office of Prevention, Pesticides and Toxic
Substances, U.S. Environmental Protection Agency, Washington, D.C., April 1995.
U.S. Environmental Protection Agency, 1979. “Polychlorinated Biphenyls (PCBs) Manufacturing,
Processing, Distribution in Commerce, and Use Prohibitions,” Federal Register, Volume 44, pp. 3151431568, May 31, 1979.
U.S. Environmental Protection Agency, 1986. “Draft Guidelines for Permit Applications and
Demonstration Test Plans for PCB Incinerators,” Office of Pollution Prevention and Toxics,
Washington, D.C., May 1986.
U.S. Environmental Protection Agency, 1986. “Guidelines for Permit Applications and Demonstration
Test Plans for PCB Disposal by Alternative Methods,” Office of Pollution Prevention and Toxics,
Washington, D.C., June 1986.
U.S. Environmental Protection Agency, 1986. “Permit Writers Guide to Test Burn Data,” EPA/625/686/012, Office of Research and Development. Washington, D.C., September 1986.
U.S. Environmental Protection Agency, 1989. “Guidance on Setting Permit Conditions and Reporting
Trial Burn Results,” EPA/625/6-89/019, Office of Research and Development. Washington, D.C.,
January 1989.
U.S. Environmental Protection Agency, 1989. “Interim Procedures for Estimating Risks Associated with
Exposures to Mixtures of Chlorinated Dibenzo-p-dioxins and -dibenzofurans (CDDs and CDFs),” EPASAB-EC-87-008. EPA Science Advisory Board. Washington D.C., November 1989.
U.S. Environmental Protection Agency, 1993. “Operational Parameters for Hazardous Waste
Combustion Devices,” EPA/625/R-93/008, Office of Research and Development. Washington, D.C.,
October 1993.
U.S. Environmental Protection Agency, 1998. “Disposal of Polychlorinated Biphenyls (PCBs).” Federal
Register, Volume 63, No. 124, pp. 35384-35474, June 29, 1998.
U.S. Environmental Protection Agency, 2001. “EPA Requirements for Quality Assurance Project Plans,
EPA QA/R-5,” EPA/240/B-01/003, Office of Environmental Information, March 2001.
U.S. Environmental Protection Agency, 2002. “Guidance for Quality Assurance Project Plans, EPA
QA/G-5,” EPA-240/R-02/009, Office of Environmental Information, December 2002.

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APPENDIX A
SOURCES FOR ADDITIONAL INFORMATION

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See 40 CFR part 761 for more information on PCB regulations. An outline of the PCB regulations is
provided in the table below.
Table A-1. Outline of 40 CFR part 761 1

Subpart A - General
761.1
Applicability
761.2
PCB concentration assumptions for use
761.3
Definitions
761.19 References
Subpart B - Manufacturing, Processing, Distribution in Commerce, and Use of PCBs and PCB Items
761.20 Prohibitions
761.30 Authorizations
761.35 Storage for Reuse
Subpart C - Marking of PCBs and PCB Items
761.40 Marking requirements
761.45 Marking formats
Subpart D - Storage and Disposal
761.50 Applicability
761.60 Disposal Requirements
(a) PCB Liquids
(b) PCB Articles
(c) PCB Containers
(d) [Reserved]
(e) Alternative Methods
(f) Written Notice
(g) Testing Procedures for PCB Concentration
(h) Export/Import for Disposal
(i) Approval Authority for Disposal Methods
(j) Self-implementing Requirements for R&D for PCB Disposal
761.61 PCB Remediation Waste
761.62 Disposal of PCB Bulk Product Waste
761.63 PCB Household Waste
761.64 Waste from R&D Activities
761.65 Storage for Disposal
761.70 Incineration
(a) Liquid PCBs
(b) Non-liquid PCBs
(c) Maintenance of Data and Records
(d) Approval of Incinerators
761.71 High Efficiency Boilers
761.72 Scrap Metal Recovery Ovens and Smelters
761.75 Chemical Waste Landfills
761.77 Coordinated Approval
761.79 Decontamination Standards and Procedures
Subpart E - Exemptions
Subpart F - Transboundary Shipments of PCBs for Disposal
Subpart G - PCB Spill Cleanup Policy
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Table A-1. Outline of 40 CFR 761 1 (continued)
Subpart J - General Records and Reports
761.180 Records and Monitoring
Subpart K - PCB Waste Disposal Records and Reports
Subpart M - Determining a PCB Concentration for Purposes of Abandonment or Disposal of Natural
Gas Pipeline
Subpart N - Cleanup Site Characterization Sampling for PCB Remediation Waste in Accordance with
§ 761.61(a)(2)
Subpart O - Sampling to Verify Completion of Self-Implementing Cleanup and On-Site Disposal of
Bulk PCB Remediation Waste and Porous Surfaces in Accordance with § 761.61(a)(6)
Subpart P - Sampling Non-Porous Surface for Measurement-Based Use, Reuse, and On-Site or Off-Site
Disposal Under § 761.61(a)(6) and Determination Under § 761.79(b)(3)
Subpart Q - Self-Implementing Alternative Extraction and Chemical Analysis Procedures for NonLiquid PCB Remediation Waste Samples
Subpart R - Sampling Non-Liquid, Non-Metal PCB Bulk Product Waste for Purposes of
Characterization for PCB Disposal in Accordance with § 761.62, and Sampling PCB
Remediation Waste Destined for Off-Site Disposal in Accordance with § 761.61
Subpart S - Double Wash/Rinse Method for Decontaminating Non-Porous Surfaces
Subpart T - Comparison Study for Validating a New Performance-Based Decontamination Solvent
Under § 761.79(d)(4)
1Some subparts are outlined in greater detail than others. See https://www.epa.gov/pcbs/learnabout-polychlorinated-biphenyls-pcbs#laws for additional details.

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The references below may be helpful for those applying for an operating approval under §§ 761.70 or
761.60(e). Note that some of the references focus on RCRA or CAA requirements. As such, elements of
those compliance regimes would not be applied or required for TSCA incinerator/alternative treatment
facilities unless the requirements are already specified in the PCB regulations, or the approval writer
determines such additional limits are necessary to ensure the PCB treatment/disposal unit does not
present an unreasonable risk of injury to health or the environment.
Literature - Sampling and Analytical Methods
M.D. Erickson, Analytical Chemistry of PCBs, Second Edition, CRC/Lewis Publishers, Boca Raton, FL,
1997.
The book defines and discusses sampling, extraction, cleanup, determination of PCB
concentration by chromatographic and nonchromatographic methods, data reduction, and quality
assurance as six discrete steps in the analysis of PCBs. The final chapter provides a discussion on
collaborative testing. The comprehensive bibliography includes more than 1200 references. Five
appendices detail PCB nomenclature, physical properties, compositions of commercial mixtures,
mass spectra characteristics, and PGC/ECD chromatograms. The book includes extensive critical
reviews of the primary literature.

Manual – PCB Inspections
U.S. Environmental Protection Agency, “Polychlorinated Biphenyl Inspection Manual,” Office of
Pollution, Prevention, and Toxics, Washington, D.C., EPA305-X-04-002, August 2004.
EPA developed this manual to guide inspectors in conducting inspections to ensure compliance
with regulations promulgated under section 6(e) of the Toxic Substances Control Act (TSCA)
pertaining to polychlorinated biphenyls (PCBs). The pertinent regulations are found at Part 761
of Title 40 of the Code of Federal Regulations (CFR). The manual gives inspectors an overview
of the regulations they will use in determining compliance. EPA case development/enforcement
personnel make the ultimate determination of where a violation has occurred. Appendices are
provided to supplement information in the manual, including Appendices I and L that address
specific disposal methods and incinerators and alternative disposal methods, respectively.

Manual - RCRA Incinerator Applications
G. Vogel, K. Brooks, I. Frankel, S. Haus, and W. Jacobsen, “Guidance Manual for Evaluating Permit
Applications for the Operation of Incinerator Units,” Report by The Mitre Corporation, McLean, VA, to
U.S. Environmental Protection Agency, Contract No. 68-01-6092, December 31, 1980, 221 pp.
An EPA or state approval writer is offered guidance for evaluating approval applications
submitted by owners or operators of incinerator facilities as required under mandate of the
Resource Conservation and Recovery Act of 1976. The subject areas requiring evaluation are
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identified and information that should be contained in an application to ensure a thorough
evaluation is listed. Data typical of current, acceptable incineration practices and examples of
computations are offered to assist the approval writer.

Manual - Sampling and Analytical Methods
U.S. Environmental Protection Agency, 2014. “Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, SW-846.” Washington, D.C.: Office of Land and Emergency Management.
http://www.epa.gov/epawaste/hazard/testmethods/sw846/online/index.htm
The SW-846 manual provides test procedures and guidance which are recommended for use in
conducting the evaluations and measurements needed to comply with EPA regulations. These
methods are accepted by the U.S. EPA for obtaining data to satisfy the requirements of the PCB
Regulations under 40 CFR part 761.

Memo - Closure Cost Estimates
Doa, Maria J., 2007. “Policy Regarding Use of On-Site Disposal Methods When Calculating Financial
Assurance Closure Cost Estimates,” National Program Chemicals Division, U.S. Environmental
Protection Agency, Washington, D.C., May 2007.
This memo addresses the issue of using on-site disposal methods when calculating closure cost
estimates of PCB storage approvals. The memo clarifies that if a facility’s on-site disposal
process is proprietary, mobile, or technologically complex, then the facility cannot guarantee that
its treatment process will be available for use by a third party at the time of closure. As a result,
the exception at 40 CFR 761.65(f)(1)(iii) would not apply to closure cost estimates if the on-site
disposal is proprietary, mobile, or technologically complex.

Memo - Public Participation
Goldman, L. R., 1995. “Memo to Jane N. Saginaw,” Office of Prevention, Pesticides and Toxic
Substances, U.S. Environmental Protection Agency, Washington, D.C., April 1995.
The Agency received a citizen's petition under section 21 of the Toxic Substances Control Act
(TSCA). The petition requested that the Agency issue rules for public notice and comment prior
to issuing PCB commercial storage approvals under 40 CFR 761.65(d) or PCB disposal
approvals under 40 CFR 761.60(e).
Agency regulation, policy, and guidance requires notification of the public and inclusion of
public comments, where applicable into final permit approvals (40 CFR 124.10) for public
participation for permits issued under various statutes, and for PCBs (see "Guidance Manual for
Writers of PCB Disposal Permits for Alternative Technologies," October 1, 1988). Since the
Agency is already committed to full public participation, the Acting Director for the Office of
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Pollution Prevention and Toxics decided to deny this petition. Amending the appropriate sections
of 40 CFR part 124 and 40 CFR part 761 to include public participation would have used scarce
resources to formalize existing Agency policy.
To ensure national uniformity and avoid additional rulemaking, staff was directed to abide by
Agency requirements and include public participation in all TSCA approvals for commercial
storage and fixed-site disposal activities.

Authoritative Recommendations - Occupational Exposure to PCBs
Department of Health, Education, and Welfare, Public Health Service, Center for Disease Control,
National Institute for Occupational Safety and Health, “Criteria for a Recommended Standard.
Occupational Exposure to Polychlorinated Biphenyls (PCBs),” September 1977, 224 pp. (available from
U.S. Government Printing Office, Washington, D.C.).
The National Institute for Occupational Safety and Health (NIOSH) recommends that employee
exposure to polychlorinated biphenyls (PCBs) in the workplace be controlled by adherence to
their guidance document. The standard is designed to protect the health and provide for the
safety of employees for up to a 10-hour workday, 40-hour workweek, over a normal working
lifetime. The standard is measurable by techniques that are valid, reproducible, and available to
industry and governmental agencies. NIOSH concluded that compliance with the standard should
substantially reduce any risk of reproductive or tumorigenic effects of PCBs and prevent other
adverse effects of exposure in the workplace. Employees should regard the recommended
workplace environmental limit as the upper boundary for exposure.
NIOSH found evidence that indicates adverse reproductive and tumorigenic effects in
experimental animals exposed to certain commercial PCB preparations. Available information
was not adequate to demonstrate that other commercial PCB preparations do not have these
effects. Should sufficient information become available to indicate that the standard offers
greater or lesser protection from some chlorobiphenyl isomers or commercial preparations than
is needed, NIOSH will consider revising the standard.

Reference Tool - Index of Sampling and Analytical Methods
U.S. Environmental Protection Agency, “Index to EPA Test Methods,” U.S. EPA New England Region
1 Library, Boston, MA, April 2003. http://www.epa.gov/region01/oarm/testmeth.pdf.
To respond to frequent requests for agency test methods, Region 1 library staff developed a
methods index as a tool to help locate copies. Confirming that there was no one volume
containing all Agency methods and no comprehensive list of them, the project commenced and
in 1988 the first printed Index to EPA Test Methods published as EPA 901/3-88-001. It has been
updated periodically to reflect new procedures and revoked methods and the current edition
includes about 1600 method references. The index includes only EPA methods and its primary
goal remains as a reference tool to identify a source from which the actual method can be
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obtained, either free or for a fee. Note that not all EPA Test Methods related to PCBs may be
applicable to incinerators and alternative technologies.

Report - Implementation of PCB Regulations
R.G. McInnes and R. J. Johnson, “Provision of Technical Assistance to Support Regional Office
Implementation of the PCB Regulations - East and West,” Draft Project Summary Report by GCA
Corporation, New Bedford, MA, and TRW, Inc. Redondo Beach, CA, on EPA Contract No. 68-023168, Work Assignment No. 45, and Contract No. 68-02-3174, Work Assignment No. 68, for David C.
Sanchez, U.S. EPA, Office of Research and Development, Industrial Environmental Research
Laboratory, Research Triangle Park, NC, 1982, 186 pp.
This project report documents the work efforts conducted by GCA/Technology Division and
TRW Environmental Division in supporting Regional office implementation of the PCB
regulations, by providing regular bimonthly liaison with the EPA Regional offices and by
providing technical and coordinative assistance on an as-needed basis. The bimonthly contact
resulted in a regular bimonthly newsletter which was mailed to the EPA personnel in all ten
Regions who were directly involved with the implementation of the PCB regulations. The
technical assistance effort produced a series of individual facility evaluations as well as a
separate study regarding alternative definitions of PCB solid/liquid wastes.
The salient points of the two project tasks are discussed in the body of the report and copies of a
bimonthly report and all facility evaluations are included in the appendices. This report covers
the period of April 28 to December 15, 1981, and work was completed as of December 31, 1981.

Report - Production, Use, and Distribution of PCBs
R. L. Durfee, G. Contos, F. D. Whitmore, J. D. Barden, E. E. Hackman, III, and R. A. Westin, “PCBs in
the United States - Industrial Use and Environmental Distributions,” U.S. Environmental Protection
Agency:, Office of Toxic Substances, Washington, DC, Report No. EPA 560/676-005, [National
Technical Information Service (NTIS) No. PB-252O12], 1976, 488 pp.
This document presents the current state of knowledge about the production, usage, and
distribution of polychlorinated biphenyls (PCBs) in the United States. The information presented
is derived from detailed studies on the production and first tier user industries, the past and
present generation and disposition of PCB-containing wastes, environmental transport and
cumulative loads, potential alternatives to PCBs usage, inadvertent losses to and potential
formation in the environment, and current regulatory authorities for PCBs control. These results
indicated that, although PCBs content of industrial wastes can be reduced through various
approaches (treatment, substitution, etc.), there exists a potentially severe future hazard in the
form of large amounts of PCBs currently contained in land disposal sites. Further definition of
this and other aspects of the PCBs problem, and determination of ways to minimize the hazard,
are recommended.
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Report – Thermal (Boilers)
R. G. McInnes, “Technical Assistance in Support of Permitting Activities for the Thermal Destruction of
PCBs,” U.S. Environmental Protection Agency, Office of Research and Development, Industrial
Environmental Research Laboratory (IERL), Research Triangle Park, NC, EPA 600/2-81-240, 1982, 70
pp. (NTIS No. PB82 231 325).
This report describes phased efforts to identify, evaluate, and provide technical approval
assistance to utility boiler owners considering thermally destroying PCB-contaminated mineral
oil. Identification initially concentrated on identifying ideal PCB destruction sites using size, age,
location, and fuel use criteria to evaluate available boilers. This effort then extended to directly
contacting U.S. EPA Regional offices to identify utility boiler owners who had expressed an
interest in the PCB disposal program. Regular bimonthly contacts were initiated with the
Regional offices and the status of all Regional PCB activities was tracked. This contact produced
three potential PCB burn sites operated by: (1) Consolidated Edison of New York, (2) Northeast
Utilities, and (3) Pennsylvania Power and Light. Test plans were received from the first two and
were reviewed and found acceptable; these facilities, however, subsequently withdrew their
involvement with the PCB destruction verification burn program due to local community
opposition. By the end of the technical performance period of this work assignment, a candidate
site had not been identified or approved for testing. Appendices to this report detail the utility
boiler site selection methodology, the status of PCB activities in EPA Regional offices as of May
1, 1981, and the test plan evaluations for the Consolidated Edison and Northeast Utilities
facilities.
The project also required that state and local governments be provided information needed to aid
approval of a PCB verification burn. Under this phase of the project a PCB “white paper” was
prepared which summarized background technical information used in writing the PCB
regulations (40 CFR part 761). A second paper was prepared summarizing comments delivered
at a public meeting entitled “What Should We Be Doing About PCBs?” Both papers are
provided as appendices to the report.

Report - Thermal and Non-Thermal
D.G. Ackerman, L. L. Scinto, P. S. Bakshi, R. G. Delumyea, R. J. Johnson, G. Richard, A. M. Takata,
and E. M. Sworzyn, “Destruction and Disposal of PCBs by Thermal and Non-Thermal Methods,” Noyes
Data Corporation, Park Ridge, NJ, 1983, 417 pp.
This is a verbatim combination of two EPA reports:
1. Sworzyn and Ackerman (1982) [EPA-600/2-82-069], and
2. Ackerman et al., (1981) [EPA-600/2-81-022].

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This report is a resource and guidance document intended to aid EPA Regional offices in
applying the PCB Disposal Regulations to requests for approval of thermal destruction of PCBs.
As background material, this document describes fundamental processes of combustion, thermal
destruction systems, sampling and analysis methodology, and flame chemistry relative to PCB
incineration. Administrative considerations, including public involvement, are discussed.
Detailed guidance on evaluation of Annex I incinerators, high efficiency boilers, and the several
stages of the approval process are presented and discussed.

Report – Toxicological Profile for PCBs
Agency for Toxic Substances and Disease Registry, “Toxicological Profile for Polychlorinated
Biphenyls (PCBs),” and “Addendum to the Toxicological Profile for Polychlorinated Biphenyls,” U.S.
Department of Health and Human Services, Atlanta, GA, November 2000 and April 2011, respectively.
The Agency for Toxic Substances and Disease Registry (ATSDR)’s toxicological profile
succinctly characterizes toxicologic and adverse health effects information for PCBs. The peerreviewed profile identifies and reviews the key literature that describes the properties of PCBs.
Other pertinent literature also is presented. The focus of the profile is on health and toxicologic
information; therefore, the profile begins with a public health statement that describes, in
nontechnical language, the relevant toxicological properties of PCBs. Following the public
health statement is information concerning levels of significant human exposure and significant
health effects. In addition, information concerning available analytical methods for various
matrices is provided, along with a listing of regulations and advisories related to PCBs.

Research Report - Analytical Methods for PCB By-Products
M. D. Erickson, J. S. Stanley, G. Radolovich, K. Turman, K. Bauer, J. Onstot, D. Rose, and
N. Wickham, “Analytical Methods for By-Product PCBs--Initial Validation and Interim Protocols,”
Report by Midwest Research Institute, Kansas City, MO, to David P. Redford, U.S. Environmental
Protection Agency, Office of Toxic Substances., Field Studies Branch, Washington, DC, EPA-560/5-82006, 1982, 243 pp.
This document presents proposed analytical methods for analysis of by-product PCBs in
commercial products, product waste streams, wastewaters, and air. The analytical method for
commercial products and product waste streams consists of a flexible approach for extraction
and cleanup of particular matrices. The 13 C-labeled PCB surrogates are added as part of a strong
quality assurance program to determine levels of recovery. The wastewater method is based on
EPA Methods 608 and 625 with revisions to include use of the 13 C-labeled PCB surrogates. The
air method is a revision of a proposed EPA method for the collection and analysis of PCBs in air
and combustion gas emissions. Capillary or packed column gas chromatography/electron impact
ionization mass spectrometry is proposed as the primary instrumental method. Response factors
and retention times of 77 PCB congeners relative to tetrachlorobiphenyl-d6 are presented in
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addition to statistical analysis to project validity of the data and extrapolation of relative response
factors to all 209 possible congeners. Preliminary studies using the 13C-labeled surrogates to
validate specific cleanup procedures and to analyze several commercial products and product
wastes indicate that the proposed analytical methods are both feasible and practical.

Research Report - Sampling and Analytical Methods
C. L. Haile and E. Baladi, “Methods for Determining the Polychlorinated Biphenyl Emissions from
Incineration and Capacitor and Transformer Filling Plants,” Report by Midwest Research Institute,
Kansas City, MO, to Environmental Monitoring and Support Laboratory, Office of, Research and
Development, U.S. Environmental Protection Agency, Research Triangle Park, NC, EPA-600/4-77-048,
1977, 90 pp. (NTIS No. PB-276 745/761).
This document describes methods to measure the polychlorinated biphenyl (PCB) emissions
from the stacks of municipal waste, industrial waste, and sewage sludge incinerators and from
capacitor and transformer filling plants. The PCB emissions from the incineration plants are
collected by impingement in water and adsorption on Florisil. The samples are extracted with
hexane, concentrated through evaporation of the solvent, perchlorinated, and the polychlorinated
biphenyl content measured as the decachlorinated isomer using a gas chromatograph equipped
with a flame ionization detector. The PCB emissions from the capacitor and transformer filling
plants are collected directly on Florisil, extracted with hexane, and quantified against the
appropriate Aroclor using a gas chromatograph. The methods were developed from laboratory
studies and field tested at nine incineration plants and two transformer filling plants.

Review - PCB By-Products
N. D. Erickson and J. S. Stanley, “Methods of Analysis for By-Product PCBs Literature Review and
Preliminary Recommendations,” Report by Midwest Research Institute, Kansas City, MO, to David P.
Redford, U.S. Environmental Protection Agency, Office of Toxic Substances, Field Studies Branch,
Washington, DC, EPA-560/5-82-005, 1982, 135 pp.
A review of the literature on polychlorinated biphenyl (PCB) analysis and recommendations for
methods to determine by-product PCBs in commercial products and other matrices are presented.
This report was prepared by an EPA contractor to assist EPA in formulating a rule regulating byproduct PCBs. The published literature on PCB analysis is critically reviewed. Several hundred
references are cited in a bibliography. The review is subdivided into extraction, cleanup,
determination, data reduction, confirmation, screening, quality assurance, and by- product
analysis sections. The determination section includes thin layer chromatography (TLC), high
performance liquid chromatography (HPLC), gas chromatography (GC), packed column gas
chromatography (PGC), capillary gas chromatography (CGC), electron impact mass
spectrometry (ECD), flame ionization detector (FID), electron impact mass spectrometry
(EIMS), mass spectrometry (MS) nuclear magnetic resonance (NMR), infrared (IR),
electrochemistry, neutron activation analysis (NAA), radioimmunoassay (RIA). Techniques
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applicable to analysis of commercial products, air, and water for by-product PCBs are discussed.
The final section of this report presents a recommended overall primary analytical scheme.

Review – Thermal and Non-Thermal
M.S.M. Mujeebur Rahuman, Luigi Pistone, Ferruccio Trifirò and Stanislav Miertus, “Destruction
Technologies for Polychlorinated Biphenyls (PCBs),” published in the Proceedings of Expert Group
Meetings on POPs and Pesticides Contamination: Remediation Technologies (April 2000) and on Clean
Technologies for the Reduction and Elimination of POPs (May 2000). http://www.cluin.org/download/remed/destruct_tech.pdf
Although the production of PCBs has been banned (excluded manufacturing products and
inadvertently produced PCBs are not included in this ban) all over the world for many years, as
PCBs were and, in many instances, still are used as dielectric fluids and for other industrial uses,
their presence in anthropogenic products/equipment/appliances and their dispersion in the
environment is still relevant. This document contains a non-exhaustive review of destruction
technologies for polychlorinated biphenyls (PCBs). The analysis considers the need for criteria
in assessing performance of already developed PCB destruction technologies and, when
necessary, optimizing or boosting the development of innovative processes.

Review –PCB Remediation Technologies
Lyons, T., D. W. Grosse, and R. A. Parker. Engineering Issue: Technology Alternatives for the
Remediation of PCB Contaminated Soils and Sediments. U.S. Environmental Protection Agency,
Washington, DC, EPA/600/S-13/079, 2013.
This Engineering Issue paper provides an overview of PCB contamination and remediation, and
was developed from peer reviewed literature, scientific documents, EPA reports, web site
sources, input from experts in the field, and other pertinent information.

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APPENDIX B
CHECKLISTS FOR COMPLETENESS OF SUBMITTAL

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Disclaimer: The checklists in Appendix B describe information that EPA suggests be included in the
approval application or test plan. This is based on EPA’s experience with previous operating approvals
at facilities with various levels of complexity. Depending on site‐specific circumstances, certain
information on the checklist may not be applicable.
The checklists in Appendix B are not a substitute for the regulatory requirements in 40 CFR part 761,
including 40 CFR 761.60(e) or 761.70. Additionally, these checklists are not required to be used or
submitted to EPA. Treatment operators and site owners are responsible for complying with all
applicable requirements in 40 CFR part 761. In case of conflict between this document or portion(s)
thereof and any PCB regulatory requirement, the TSCA PCB regulations supersede this document.

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DISCLAIMER: THIS IS ONLY AN EXAMPLE TEMPLATE AND MAY NOT CONTAIN ALL
REQUIREMENTS THAT APPLY. FURTHERMORE, APPLICANTS ARE NOT REQUIRED TO
USE THIS TEMPLATE OR SUBMIT IT TO EPA.
Table B-1. Example Approval Application Checklist for Thermal and Non-Thermal Methods

Item

Approval Cover
Section I – Summary
Section II – Company Organization
A. Organizational Chart
B. Organization Description
Section III - Waste Description
A. Type
B. Total Amount
C. Physical/Chemical Description
Section IV - Process Engineering
A. General Overview
1. Description
2. Flow Diagram
3. Location
4. Site Maps
B. Waste Feed System/Feed Rate
C. Waste Feed Shut-Off System
D. Destruction System
E. Pollution Control System
F. Operating Parameters
Section V - Monitoring and Sampling Plan
A. Parameter List
B. Sampling/Monitoring Frequency
C. Monitoring Plan Design
D. Methods
1. Monitoring
2. Sampling
3. Analytical
E. Equipment
1. Monitoring
2. Sampling
3. Analytical
Section VI - Process Procedures
A. Appropriate Methods
B. Written Protocols
C. Apparatus
D. Data Reduction
E. Data Storage/Logging
F. Calibration
G. Maintenance
Section VII - Sampling and Analysis Procedures
A. Appropriate Methods
B. Written Protocols
C. Apparatus
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Not
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DISCLAIMER: THIS IS ONLY AN EXAMPLE TEMPLATE AND MAY NOT CONTAIN ALL
REQUIREMENTS THAT APPLY. FURTHERMORE, APPLICANTS ARE NOT REQUIRED TO
USE THIS TEMPLATE OR SUBMIT IT TO EPA.

Item

D. Data Reduction
E. Data Storage/Logging
F. Calibration
G. Maintenance
Section VIII - Data Reporting/Recordkeeping
A. Format
B. Example Calculations
C. Units
Section IX - Waste Handling and Disposal
A. List of All Wastes (type and amounts)
B. Disposal Methods
Section X - Inspection Procedures
A. Waste Feed System
B. Destruction System
C. Waste Feed Cutoff System
D. Pollution Control System
E. Alarms
F. Fire Extinguisher Systems
Section XI - Spill Prevention, Control, and Countermeasure
Section XII - Safety Plan
Section XIII - Training Plan
Section XIV –Test Plan Summary
A. Tentative Date
B. Tentative Location
C. Parameters to be Tested
D. Waste Type
Section XV - Test Data or Engineering Performance Calculations
Section XVI - Other Permits or Approvals
A. Regional R&D
B. Regional Full-Scale
C. RCRA
D. State and Local
E. DOT
Section XVII - Schedule of Pre-Operation Events
Section XVIII – Quality Assurance Project Plan (QAPP)
A. Format
B. Organization and Responsibility
C. QA Objectives
1. Precision
2. Accuracy
3. Completeness
4. Representativeness
5. Comparability
D. Monitoring Procedures
E. Sampling Procedures
F. Analytical Procedures
G. Sample Custody
H. Calibration Procedures and Frequency
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Not
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DISCLAIMER: THIS IS ONLY AN EXAMPLE TEMPLATE AND MAY NOT CONTAIN ALL
REQUIREMENTS THAT APPLY. FURTHERMORE, APPLICANTS ARE NOT REQUIRED TO
USE THIS TEMPLATE OR SUBMIT IT TO EPA.

Item
I. Data Reduction, Validation, and Reporting
J. Internal Quality Control Checks
K. Audits
1. Performance
2. System
L. Preventative Maintenance
M. Specific Routine Procedures Used to Assess Data Precision,
Accuracy, and Completeness
N. Corrective Action
O. Quality Assurance Report to Management
Section XIX - Standard Operating Procedures (SOPs)
Section XX - Closure Plan, Closure Cost Estimate & Financial
Assurance
A. Site-to-Site (Mobile)
B. Permanent

Submitted

To Be
Submitted at
Later Date 1

Not
Applicable

Approved OMB No. 2070-0211
Identify sections of the approval to be submitted at a later date and note any missing sections in the application.

1

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DISCLAIMER: THIS IS ONLY AN EXAMPLE TEMPLATE AND MAY NOT CONTAIN ALL
REQUIREMENTS THAT APPLY. FURTHERMORE, APPLICANTS ARE NOT REQUIRED TO
USE THIS TEMPLATE OR SUBMIT IT TO EPA.
Table B-2. Example Checklist for a Test Plan

Item

Test Plan Cover
Section I – Summary
Section II - Company Organization
A. Key Personnel Identified
B. Organization Chart
Section III - Process Engineering Information (new information
from Approval Applications)
Section IV - Process Operation Test Parameters
A. Operational Plan
B. Process Operating Parameters
C. Anticipated Emission Levels
D. Waste Feed Description/Quantity
Section V - Monitoring and Sampling Plan
A. Number of Tests
B. Parameters to be Monitored
C. Parameters to be Sampled
D. Sampling/Monitoring Locations
E. Number/Frequency of Samples
F. Sampling Methods
G. Monitoring Methods
H. Analysis Methods
Section VI - Process Procedures
A. Written Protocol
B. Equipment
C. Calibration
Section VII - Sampling and Analysis Procedures
A. Methods
B. Written Protocol
C. Equipment
D. Calibration
Section VIII - Data Reporting
A. Data to be Reported, Units
B. Example Calculations
Section IX - Miscellaneous Tests
A. Automatic Waste Feed Cutoff
B. Alarm Systems
C. Fire System
Section X - Waste Handling and Disposal
Section XI - Test Schedule
Section XII - Addenda to Quality Assurance Project Plan (QAPP)
Section XIII - Addenda to Standard Operating Procedures (SOPs)

Submitted

To Be
Submitted at
Later Date 1

Not
Applicable

Approved OMB No. 2070-0211
Identify sections of the approval to be submitted at a later date and note any missing sections in the application.

1

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DISCLAIMER: THIS IS ONLY AN EXAMPLE TEMPLATE AND MAY NOT CONTAIN ALL
REQUIREMENTS THAT APPLY. FURTHERMORE, APPLICANTS ARE NOT REQUIRED TO
USE THIS TEMPLATE OR SUBMIT IT TO EPA.

Data Reporting

Data Storage

Data Reduction

Calibration

Analytical Method

Apparatus/Equipment

Written Protocol

Method

Sampling/Monitoring Location

Sampling Frequency

To Be Monitored (Y/N)

Parameter
PCBs in Waste Feed
Feed Composition
Waste Feed Rate
O2
CO
CO2
NOx
Combustion Efficiency
Residence Time
Destruction Temperature
Excess O2
HCl Removal Efficiency
Stack Gas Flow Rate
PCB Feed Rate
PCB Output Rate
DRE
Particulate
RCl (volatile)
RCl (semi-volatile)
PCDDs/PCDFs
Semi-volatile Organic Screen
Pollution Control System
Operation
Ash Composition
Wastewater
Other

To Be Sampled (Y/N)

Table B-3. Example Monitoring and Sampling Parameter Summary to be included in Test Plans
for Incinerators or Alternative Thermal Destruction Processes1,2

Approved OMB No. 2070-0211
This is not an exhaustive list; EPA, at its discretion, may require additional parameters depending on the process.
2
This is not intended to be a checklist; some columns may need to be edited to allow for writing in text.
1

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DISCLAIMER: THIS IS ONLY AN EXAMPLE TEMPLATE AND MAY NOT CONTAIN ALL
REQUIREMENTS THAT APPLY. FURTHERMORE, APPLICANTS ARE NOT REQUIRED TO
USE THIS TEMPLATE OR SUBMIT IT TO EPA.

Maintenance

Calibration

Data Reduction/Storage

Analytical Method

Apparatus

Written Protocol

Method

Monitoring/Sampling Design

Sampling Frequency

Monitoring Frequency

To Be Monitored (Y/N)

Parameter
PCBs in Waste Feed
Feed Composition
Waste Feed Rate
Reagent Feed Rate
Reaction Temperature
Reaction Pressure
pH of Product
Residual Reagent in Product
PCB Concentration in Product
PCBs in Aqueous Effluents
PCBs in Other Wastes
PCBs in Air Emissions
Pollution Control System
Operation
Other

To Be Sampled (Y/N)

Table B-4. Example Monitoring and Sampling Parameter Supplement for an Alternative NonThermal Technology1,2

Approved OMB No. 2070-0211
This is not an exhaustive list; EPA, at its discretion, may require additional parameters depending on the process.
2
This is not intended to be a checklist; some columns may need to be edited to allow for writing in text.
1

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APPENDIX C
MONITORING, SAMPLING, AND ANALYSIS PROCEDURES

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This appendix summarizes suggested monitoring, sampling, and analysis methods for various sample
matrices, including those found in feed materials and final products or effluent streams. The methods
discussed in this section are not required to be used unless specified in the PCB regulations or by the
approval writer in order to make a no unreasonable risk determination. Also, there may be other
applicable methods that are not discussed in this section.
C.1 Monitoring Methods
Monitoring of gaseous components is specifically required by 40 CFR 761.70 for thermal destruction
systems. For thermal destruction units, CO2 from combustion products and incineration operations must
be monitored periodically at intervals set by the approval writer at either HQ or the Regions. O 2 and CO
must be monitored continuously; however, “continuously” is not defined by the regulation. Other
monitoring parameters may be required as stated in § 761.70, or as needed to demonstrate a level of
performance equivalent to an incinerator under § 761.60(e).
Information related to continuous emission monitoring systems, in general, can be found in “Continuous
Emission Monitoring Systems for Non-Criteria Pollutants” (U.S. EPA, 1997). Applicants may find it
helpful to consult 40 CFR part 63 subpart EEE “National Emission Standards for Hazardous Air
Pollutants from Hazardous Waste Combustors” when designing a monitoring plan.
C.2 Sampling Plans
Inadequate sampling can ruin an otherwise acceptable test, and sampling often is the weakest portion of
an application. The applicant and EPA reviewer should work together to develop a detailed sampling
plan that will generate the desired information. In some cases, a “typical” sample may be desired, while
in others a “worst-case” or “most challenging” sample may be desired. The objective should be clearly
spelled out in a sampling plan.
PCB disposal facilities are not ideal sampling sites. Events do not always occur according to plan,
especially during the shakedown periods in which the test generally is held. The sampling plan should
reflect the realities of the disposal unit and be written in such a way as to allow the applicant to make
every attempt to meet the stated objectives. The plan should propose acceptable alternatives to the
optimum samples. In cases where a sampling plan is compromised, the test report should present an
explanation.
Several examples of approaches (not full sampling plans) to sampling situations are presented below.
•

Stack testing generally is conducted over the duration of a test burn (e.g., 4 hours). In the EPA
Method 5 protocol, the probe is traversed across the stack in a prescribed, nonrandom manner to
get a sample representative of all of the stack gases.

•

The waste feed should be sampled from a pipe throughout a test burn. Ideally, a pump would be
used to continuously draw off a portion of the feed to obtain an integrated sample. If use of a
pump is impractical because of the valve design or feed stock viscosity, manual integration may
be an alternative. If manual sampling is employed, the valve should be opened at measured time
intervals (e.g., every 15 minutes), and a measured amount added to the sample. Thus, a sample
would be collected over the burn duration, which would be an integration of the feed at 15minute intervals.

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•

Ideally, an ash bin would be sampled in a random fashion, where every part of the bin has a
finite, known probability of being sampled. However, access ports are not randomly placed. A
plan may specify that the sampling be randomized within the access area available (perhaps
similar to the feed sampling).

•

A chemical dechlorination system should be demonstrated. The batch process vessel should to be
filled from numerous drums. The process vessel should be filled and the mixer activated. After
30 minutes of mixing, a sample should be drawn from the vessel tap; a second sample should be
drawn 10 minutes later.

•

A field of waste drums should be sampled. The drums could be randomly sampled. If the drums
are known to be from several sources and are identifiable, the sampling design should include
stratification of the subsets.

•

The plan should stipulate that if a bung on a drum is frozen, the sampler is to move to the nearest
drum to the north. If more than half of the bungs are frozen, or if the bungs on an apparent set of
drums (in one area or with similar markings) are all frozen, the representativeness of the
sampling may be compromised (these may all contain a corrosive liquid which has frozen the
drums shut), and additional efforts at opening the drums should be employed. These efforts
might include freeing the frozen bungs in the drum.

C.3 Sample Collection Techniques
Guidance on sample collection techniques is available in 40 CFR part 60, Appendix A and 40 CFR part
261, Appendix I. Additional information on sample collection techniques can be found in “Samplers and
Sampling Procedures for Hazardous Waste Streams” (U.S. EPA, 1980) and “Sampling and Analysis
Methods for Hazardous Waste Combustion” (U.S. EPA, 1984a).
C.3.1 Liquids
Liquids may be collected by grab or integrative techniques. Grab sampling may include filling a jar from
a spigot or using an Alpha bottle to collect a water sample from a lagoon. Frequency of sampling and
amount to be collected during each test should be stated in the sampling plan and recorded when the
samples are collected. Integrative sampling entails a pump on an interval timer, a slow flow from a
valve, manually timed interval sampling, or other integrating technique. Additional guidance is available
in U.S. EPA’s guidance document entitled “Handbook for Sampling and Sample Preservation of Water
and Wastewater” (U.S. EPA, 1982a).
C.3.2 Solids
Solid sampling techniques vary with the nature of the solid. Free-flowing powders may behave like a
liquid, while special equipment may be needed to remove a portion of other solids. The equipment to be
used (trowel, auger, grain thief, etc.) and procedures for use should be adequately described in the
sampling plan.
C.3.3 Mixed-Phase Samples
Mixed-phase samples represent a challenge to the sample collector. In tanks and other static systems,
phase separation during sampling is preferable, provided that the total volume or weight of each phase is
measured. Phases collected separately should be analyzed separately. Proportions of each phase in the
system (e.g., in a holding tank) should be measured volumetrically. Examples include skimming solids
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off liquids and drawing off oil and water layers from a tank. Where phase separation is impractical, such
as with a suspended solid, the whole system should be mixed to assure that the sample is representative.
In a flowing pipe, collecting a representative sample of a solid/oil/water mixture may be impossible,
because the valve position is fixed. In this situation, the oil phase probably would contain more PCBs
than the water and should be sampled, as it would represent a maximum concentration (worst case for
waste, best case for feed). The representativeness or lack thereof should be noted.
C.3.4 Particulate Matter in Stack Gas Emissions
EPA Method 5 (Appendix A-3 of 40 CFR part 60) and other methods derived from Method 5 may be
used to collect a particulate matter sample from the stack gas emissions.
C.3.5 Organic Stack Gas Emissions
SW-846 Method 0023A (U.S. EPA, 1996) provides a sampling procedure that can be used for
determining stack emissions of PCDDs and PCDFs from stationary sources. This method may be
modified as specified by the method, to allow simultaneous sampling and analysis for PCDDs, PCDFs,
PCBs, polycyclic aromatic hydrocarbons (PAHs), and semi-volatile organic compounds (SVOCs).
Gaseous and particulate samples are isokinetically withdrawn from the emission source and collected in
a modified EPA Method 5 sampling train (SW-846 Method 0010). The collection components consist of
the front half glassware surfaces (nozzle, probe, and front half filter holder), the glass fiber filter, the
back half glassware surfaces (back half filter holder and condenser coil), and the solid sorbent (XAD-2®)
module. Field sample recovery and laboratory sample preparation steps determine whether Method
0023A can be modified to provide simultaneous determination of PCBs, PCDDs, PCDFs, and SVOCs
emissions. Method 0023A specifies sequential acetone, methylene chloride, and toluene rinses of the
front half and back half portions of the sampling train to recover the train, with all of the solvents
combined in one container for the front half rinse and another for the back half rinse. If PCBs and
SVOCs are being determined simultaneously with the PCDDs and PCDFs, it is appropriate to separate
the toluene rinse from the acetone and methylene chloride rinses because PCBs and SVOCs could be
lost in subsequent laboratory sample preparation steps. Additional information on the combined
measurement techniques for PCBs, PCDDs, PCDFs, and SVOCs can be found in Appendix B of U.S.
EPA’s guidance document entitled Risk Burn Guidance for Hazardous Waste Combustion Facilities
(U.S. EPA, 2001).
SW-846 Method 23 (U.S. EPA, 2017) provides a sampling procedure that is very similar to Method
0023A for determining stack emissions of PCDDs and PCDFs from stationary sources. The primary
difference between Method 23 and Method 0023A is that Method 0023A requires the front half of the
sampling train (nozzle, probe, front half of the filter holder, and filter) to be extracted and analyzed
separately from the back half of the sampling train (back half of the filter holder and condenser coil).
Whereas, in Method 23 the front half and back half of the sampling train can be extracted and analyzed
together.
C.3.6 HCl Stack Gas Emissions
EPA Method 26A (40 CFR part 60, Appendix A) is used to quantify HCl emissions. A modified Method
5 sampling train as specified by EPA Method 26A, is used with an acidic (sulfuric acid) solution in the
first three impingers to solubilize the HCl to form chloride. The chloride recovered from the first three
impingers is then measured by ion chromatography.
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C.3.7 NOx Stack Gas Emissions
Nitrogen oxides (NO x) in stack gases are determined according to EPA Method 7 (40 CFR 60, Appendix
A). Alternate methods, such as instrumental analyzers, may be used if approved by EPA.
C.3.8 RCl
Total chlorinated organics (RCl) should be sampled during the initial destruction test. No specific
method is mandated by EPA in the regulations. As a result, many sampling techniques have been used to
measure RCl. Strictly speaking, an RCl test method should measure volatile, semi-volatile, and
nonvolatile compounds because the collection and analysis techniques for these three categories may
differ. Volatile RCl can be sampled using the Volatile Organic Sampling Train (VOST). The VOST is a
combination of sampling and analytical methods from the SW-846 Compendium (U.S. EPA, 2012).
Sample collection is performed using either Method 0030 or 0031, desorption of the sorbent cartridges is
performed using Method 5041A, and analysis is achieved via GC with mass spectrometry (MS) (SW846 Method 8260). Semi-volatile RCl can be determined from the sampling procedures previously
described in Section C.3.5.
C.4 Sample Analysis Methods
For many alternative technologies, the PCB content of the feed, product, and waste samples should be
determined. This section addresses the analysis of these matrices for PCBs. As discussed elsewhere in
this document, EPA may require additional analyses to demonstrate that an alternative technology has a
level of performance equivalent to an incinerator approved under § 761.70. The applicant is responsible
for presenting detailed methods for these matrices, other matrices, or non-PCB analyses, as required.
PCBs are a complex set of 209 individual chemical compounds. The commercial mixtures for those
commonly found in the feed material generally contain from 20 to 100 of these 209 PCB congeners. In
most cases for final products or effluent samples, however, it can be anticipated that the PCB pattern
will be qualitatively different from that in the feed, unless the PCBs were transmitted through the system
without any chemical alteration by the destruction/removal process. For effluent samples, the analytical
method should identify and quantitate all of the PCBs present in each sample, not just the Aroclors
present in the feed.
C.4.1 Methods for PCBs
This section presents analytical methods for PCBs that should provide acceptable data, please see
Appendix E of this guidance for additional information on analytical methods. This section addresses
PCB analytical methods for feed material, stack gas, ash, scrubber water, and final products and effluent
samples. Methods other than those presented here may be proposed by applicants, but EPA will evaluate
the proposed methods’ adherence to data quality objectives (e.g., analysis for all PCBs in samples with
quantitation limits adequate to meet approval requirements). Applicants should review this guidance and
propose specific extraction, cleanup, and analysis methods in their test plan. Many methods, including
some of those discussed in this section, present one or more options to the analyst. If there is more than
one option, the applicant should state which option is to be used and present the selection criteria in the
test plan. Additional guidance on analytical methods for PCBs is available (Erickson, 1997).

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Table C-1. Summary of Standard Stack Sampling/Monitoring Methods
Method
SW-846 Method
0010

Application
PCBs and semivolatiles in stack
gas emissions

SW-846 Method
0020

Semi-volatiles
and particulates
in stack gas
emissions

EPA SW-846
Method 23 or
0023A

Dioxin/Furan

EPA SW-846
Method 0031

Volatile Organics

Continuous
Emissions
Monitoring
Systems (Tedlar
bags are not
acceptable
alternatives to
CEMS)

CO, O2 CO2, and
NOx stack gas
emissions

Description
Samples of gaseous and particulate pollutants are
withdrawn from an emission source at an isokinetic
sampling rate and are collected in a multicomponent
sampling train. Principal components of the train
include a high-efficiency glass- or quartz-fiber filter
and a packed bed of porous polymeric adsorbent
resin. The filter is used to collect organic-laden
particulate materials and the porous polymeric resin
is used to adsorb semi-volatile organic species.
Semi-volatile species are defined as compounds with
boiling points > 100 ºC. Comprehensive chemical
analyses of the collected sample are conducted to
determine the concentration and identity of the
organic materials.
Samples of particulate and semi-volatile organic
materials are withdrawn from a source at a constant
rate near isokinetic conditions and are collected in a
multicomponent sampling train. Chemical analyses
of the samples are conducted to determine the
concentration and identity of the semi-volatile
organic species and gravimetric determinations are
performed to approximate particulate emissions.
This method describes the sampling procedure to be
used for determining stack emissions of
polychlorinated dibenzo-p-dioxins (PCDDs) and
polychlorinated dibenzofurans (PCDFs) from
stationary sources. Note that, dioxins and furans may
be formed during destruction of PCBs in temperature
ranges 450 to 750 ºF
This method is used to determine volatile organic
compounds in gaseous emissions from a wide
variety of stationary sources including hazardous
waste incinerators. Note that, total organic chlorine
content was determined as the sum of semi-volatile
and volatile organic compounds containing chlorine.
The effluent gas is continuously or intermittently
sampled and the samples are conveyed to a CEM for
measurement of the concentration of O2 by
paramagnetic analysis (or other principles), CO and
CO2 by nondispersive infrared (NDIR) (or other
principles), and NO x by chemiluminescence (or
other principles). Combustion efficiency should
measure to be 99.9%. Method 3A is a procedure for

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EPA Methods 3a,
10, and 7.

EPA Method 26a

HCl

EPA Method 5

Particulates

measuring oxygen (O2) and carbon dioxide (CO2)
and Method 10 for measuring carbon monoxide
(CO) in stationary source emissions using a
continuous instrumental analyzer. Method 7 is the
procedure for measuring Nitrogen oxide (NO x)
This method is applicable for determining emissions
of hydrogen halides and halogens. This is included
in the modified method 5 sampling train.
This method is applicable for the determination of
PM emissions from stationary sources. This is
included in the modified method 5 sampling train.

C.4.1.1 Feed Material Samples
As long as the feed material contains PCBs that qualitatively resemble one of the commercial mixtures,
such as Aroclors, the traditional analytical methods that use Aroclor mixtures for GC calibration should
be acceptable. These methods are discussed below.
C.4.1.1.1 Oils
The EPA procedure for analysis of PCBs in transformer oils and waste oils (U.S. EPA, 1982b) provides
a generalized approach with respect to sample preparation and instrument analysis. Several sample
cleanup techniques are provided as optional approaches in this procedure. For the instrument analysis,
gas chromatography with halogen-specific, electron capture, or mass spectrometry detectors are all
allowed, provided appropriate limits of detection can be achieved. A strong quality control program
including control samples, daily quality control check samples, blanks, standard additions, accuracy and
precision records, and instrument and chromatographic performance criteria should be in place to
support all data generated by the method.
The American Society for Testing and Materials (ASTM, 2000) procedure for electrical insulating
mineral oils and silicones employs solvent dilution and a Florisil slurry cleanup prior to GC/ECD
determination. The procedure may be applied to the determination of PCB concentrations in insulating
liquids contaminated by either individual Aroclors or mixtures of Aroclors. The ASTM procedure notes
that the sensitivity of the ECD is reduced by mineral oil and instructs the analyst that the same amount
of oil must pass through the detector in both calibration and analysis to ensure a meaningful comparison
for quantification.
EPA Method 8082 also provides sample preparation and analysis standards, which may be applied to
PCB-contaminated oil. If it is suspected that sulfur is present in the oil sample, it may be appropriate to
conduct sulfur removal per EPA Method 8082. Sulfur can be removed using Method 3660.
C.4.1.1.2 Soils, Sludges, and Solid Wastes
A variety of standard methods are available for soils, sludges, and solid wastes. Several EPA methods
utilize dichloromethane extraction, followed by cleanup and gas chromatography determination with
different detectors. Soil and other solid wastes may be analyzed by appropriate SW-846 methods (U.S.
EPA, 2012), most commonly Method 8082 and 8082A. Method 8082 employs open-tubular, capillary
columns with ECD to determine the concentrations of PCBs. When compared to packed columns, the
fused-silica, open-tubular columns offer improved resolution, better selectivity, increased sensitivity,
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and faster analysis. The target compounds may be determined by either a single- or dual-column
analysis system. Compound identification based on single-column analysis should be confirmed on a
second column or should be supported by at least one other qualitative technique. In most cases, Method
8270 is not appropriate for the quantitation of multicomponent analytes (i.e., Aroclors) because of
limited sensitivity for those analytes. When these analytes have been identified by another technique,
such as Method 8082, Method 8270 is appropriate for confirmation of the presence of these analytes,
provided the concentration in the extract is above the detection limit.
ASTM Method D6160-98 (ASTM, 2003) is a two-tiered analytical approach to PCB screening and
quantitation of oils, sludges, solid wastes, and other matrices. Tier I is designed to screen samples
rapidly for the presence of PCBs. Tier II is used to determine the concentrations of PCBs, typically in
the range of 2 to 50 mg/kg (ppm). PCB concentrations greater than 50 mg/kg are determined through
analysis of sample dilutions. ASTM Method D6160-98 provides sample cleanup and instrument
conditions necessary for the determination of Aroclors by GC/ECD. This is a pattern-recognition
approach that does not take into account individual congeners that might occur, such as in reaction byproducts.
For sludge, EPA Method 624-S (U.S. EPA, 1984b) provides optional Florisil, silica gel, and gel
permeation chromatography (GPC) cleanups and stipulates electron impact mass spectrometry (EIMS)
as the GC detector. Quantitation is by total areas compared to total areas of Aroclor standards.
C.4.1.1.3 Capacitors and Other Solids
No standard methods exist specifically for these matrices. The sample should be physically prepared by
shredding or grinding and then extracted with an appropriate solvent (e.g., hexane), preferably with a
Soxhlet apparatus over multiple cycles. Cleanup and analysis can then follow one of the methods given
above.
C.4.1.2 Stack Gas Samples
As previously indicated in Section C.3.5, it is possible to make all semi-volatile determinations (PCBs,
PCDDs, PCDFs, and SVOCs) from a single modified EPA Method 5 (SW-846 Method 0010) sampling
train that has been spiked with the SW-846 Method 0023A standards (U.S. EPA, 2001). However,
toluene train rinses from the PCDDs and PCDFs recovery must be stored separately from other train
rinses, the condensate and impinger contents and rinses must be retained and analyzed, and two separate
Soxhlet extractions using different solvents are necessary.
A general combined process is described below:
•
•
•
•
•

Perform a first Soxhlet extraction of Method 0010 train components with methylene chloride.
Remove the methylene chloride from the extraction flask. Split the methylene chloride extract in
half, one half for the PCDD/PCDF analysis and the other half for everything else.
Add the toluene rinse to the remaining contents of the Soxhlet extractor, and perform a second
extraction with toluene.
Remove the toluene extract from the extraction flask. Combine half of the toluene extract with
half of the methylene chloride extract and subject the combined extract to PCDD/PCDF cleanup
and analysis; archive the other half of the toluene extract.
Divide the remaining methylene chloride extract into three portions; perform PAH cleanup and
analysis on one portion, PCB cleanup and analysis on a second portion, and analyze the third

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portion directly for SVOCs and/or chlorobenzenes/chlorophenols.
Analytical methods available for PCB analysis include EPA Method 1668A (U.S. EPA, 1999). EPA
Method 1668A is for determination of chlorinated biphenyl congeners by high resolution gas
chromatography/high resolution mass spectrometry (HRGC/HRMS).
EPA occasionally publishes Federal Register Notices that identify broadly applicable alternative test
methods for air sampling. A list of the alternative methods can be found at
https://www.epa.gov/emc/broadly-applicable-approved-alternative-test-methods. Applicants may
propose to use these broadly applicable alternative test methods in lieu of otherwise specified reference
test methods. For example, ALT 052 is a modified EPA Method 23 that allows the use of only acetone
and toluene as recovery solvents instead of using acetone, methylene chloride, and toluene as specified
by the method. Also, this modified method allows acetone and toluene rinses to be combined into one
sample prior to extraction and analysis instead of analyzing the toluene rinse separately as required by
the method.
C.4.1.3 Ash Samples
Ash samples collected from thermal processes typically will contain significantly altered Aroclor
patterns. If the applicant can demonstrate that the Aroclor patterns were not altered during the disposal
process, methods previously presented in Section C.4.1.1.2 can be employed for the determination of
Aroclors. The methods presented in the following paragraphs can be employed to determine PCB
content of the ash samples based on determination of homologs or congeners.
If the applicant chooses to use GC/ECD as the instrumental method, a mixture of 10 PCB congeners
(one each for the various levels of chlorination) may be used for the calibration. Individual peaks are
quantified versus the appropriate homolog standard based on the homolog window in which it elutes.
Homolog totals are obtained by summing the individual PCB peak amounts for each homolog window.
The total PCB concentration is then calculated from the sum of the individual homolog totals. Sample
preparation (extraction, cleanup, etc.) can be done according to SW-846 (U.S. EPA, 2012). Instrument
analysis can be done according to SW-846 Method 8082 or EPA Method 608 (U.S. EPA, 1984b). To
quantitate the samples, the following protocol (Midwest Research Institute, 1985) may be used:
a. Determine the retention windows. Note: This is an arbitrary demarcation and results in
misidentification of some congeners as either a higher or lower homolog. However, because the
ECD cannot discriminate by homologs, this is the best approach to partitioning the peaks.
(1) Record the retention time for each congener in the standard on a data sheet.
(2) For the mono-, the window extends from the retention time of the standard, which is the
first eluting PCB, to the midpoint between the mono- and di- standards. Start the window
sufficiently ahead of the standard elution time (e.g., 0.1 min) to allow for retention time drift.
(3) The windows for di- through nona- are the midpoints between the retention times of the
standards.
(4) For the deca-, which has only one isomer, the window is the retention time of the
standard, allowing appropriate time (e.g., ± 0.1 min) for retention time drift.
b. Calculate a linear regression curve for each homolog. The minimum correlation coefficient
(e.g., 0.99) should be specified in the QAPP. If this correlation is not obtained, either rerun the
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standard curve or perform corrective action as given in the QAPP.
c. Quantitate the samples. Obtain the concentration in μg/ml of each peak in the sample (as
injected on the gas chromatograph) from the regression equations calculated above.
d. Multiply the concentration obtained by the dilution factor, and divide by the original sample
weight (or volume) to obtain the concentration in µg/g (or µg/ml) of the original sample. Record
this value on the data sheet.
e. Automated quantitation routines incorporating the above principles may be substituted.
For determination of PCB homologs by GC/MS, EPA Method 680 (U.S. EPA, 1985) can be employed.
EPA Method 680 utilizes GC/MS operated in the Selected Ion Monitoring (SIM) mode to identify and
quantify the various PCB homologs. A summation of the individual PCB homologs may then be used to
reliably determine total PCBs.
EPA Method 1668A also allows estimation of homolog totals by level of chlorination (LOC) and
estimation of total PCBs in a sample. An isomer from each of the 10 LOCs is used in quantifying each
PCB isomer group; total PCB concentration in each sample extract is obtained by summing isomer
group concentrations. EPA Method 1668A also is used for congener-specific determination of the 209
chlorinated biphenyls. The determination of total PCBs in a sample is calculated by the summation of
the concentrations of each chlorinated biphenyl congener.
C.4.1.4 Aqueous Samples
Scrubber water and other aqueous samples can be analyzed by EPA Method 608 (U.S. EPA, 1984c),
EPA Method 625 (U.S. EPA, 1984d), EPA Method 8082 (U.S. EPA, 2007), or ASTM Method D517591 (ASTM, 1991) only if the Aroclor pattern has not been altered.
If the Aroclor patterns are significantly altered by the destruction/removal process, or if other PCBs
(e.g., partially dechlorinated homologs) are observed in the samples, then the methods described in
Section C.4.1.3 can be used to determine the total PCB content of the aqueous samples by summation of
individual homologs or congeners.
C.4.1.5 Final Product or Effluent Samples
For processes that do not alter the PCB composition, such as solvent cleaning processes, the methods
previously identified in Section C.4.1.1 for the various feed samples can be adapted to the final product
or effluent samples. With the lower detection limits, additional blanks and other QC measures may be
appropriate.
If the Aroclor pattern is significantly altered by the destruction/removal process, or if other PCBs are
observed in the samples, then the GC/ECD, HRGC/LRMS, or HRGC/HRMS methods described in
Section C.4.1.3 for determination of individual PCB homologs or congeners should be employed to
identify and quantitate all of the PCBs present in the samples.

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C.4.1.5.1 Oils and Other Nonvolatile Organic Liquids
The sample preparation procedures may follow those listed for the feed samples. Samples then may be
analyzed by an appropriate instrumental technique as described above.
C.4.1.5.2 Volatile Organic Liquids
No specific standard procedures are recommended for these matrices. If the matrix is compatible with
the analytical method (e.g., a hydrocarbon and GC/ECD), direct injection or evaporative concentration
may be sufficient. If the matrix is not compatible with the analytical method (e.g., a chlorofluorocarbon
and GC/ECD), then a solvent-exchange should be conducted. A higher boiling hydrocarbon “keeper”
should be added so that the sample is not evaporated to dryness. The samples then may be analyzed by
an appropriate instrument technique.
C.4.1.5.3 Dissolvable Solids (Process Waste, Sludge, etc.)
For samples that readily dissolve in organic solvents such as hexane or methanol/hexane, a weighed
aliquot can be dissolved to a known concentration, mixed thoroughly, and then either analyzed directly,
or cleaned up as oil.
C.4.1.5.4 Insoluble Granular Solids (Soils, Ash, Non-Bulk Solid Wastes, etc.)
The sample preparation for soils, sludges, and solid wastes can follow the same procedures outlined for
the feed samples in Section C.4.1.1.2. If the Aroclor patterns have not been altered by the PCB
destruction/removal process, the analytical methods identified for soils, sludges, and solid wastes in
Section C.4.1.1.2 can be employed. Otherwise the GC/ECD, HRGC/LRMS, or HRGC/HRMS methods
described in Section C.4.1.3 should be used for determination of the total PCB concentration of the
sample.
C.4.1.5.5 Insoluble Bulk Solids
No standard methods exist specifically for filter media and other bulk solids. The entire sample should
be extracted with an appropriate solvent, preferably with a Soxhlet apparatus over multiple cycles. It is
important that the entire sample be extracted because the PCB content is most likely not homogeneous
and, thus, a subsample probably would not be representative. The choice of extraction solvent depends
on the nature of the sample. If the sample is heavily water-laden or hydrophilic, the solvent should wet
the surface (e.g., mixed hexane/acetone or hexane/water/acetonitrile). If the sample is hydrophobic, then
extraction with a nonpolar solvent such as hexane may be appropriate. The sample analysis by GC/ECD
or GC/MS can follow that given in Section C.4.1.3.
C.4.2 Methods for PCDDs and PCDFs
Because of their extreme toxicity, PCDDs and PCDFs are of environmental concern even at low levels.
Therefore, analytical methods should not only be extremely sensitive, but also generate highly reliable
results.

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The standard reference method for the isokinetic
D IOXINS MAY BE FORMED AT
collection of the various PCDD and PCDF
TEMPERATURES GREATER THAN
congeners is SW-846 Method 0023A that utilizes an
450 º F DUE TO INCOMPLETE
XAD-2® sorbent trap. Recovery of the sampling
COMBUSTION OF PCB S. D RY AIR
train involves the use of an acetone/methylene
POLLUTIONS SYSTEMS THAT ARE
chloride rinse followed by a toluene rinse. Analysis
OPERATED WITHIN THIS RANGE
is by HRGC/HRMS as detailed in SW-846 Method
HAVE THE POTENTIAL TO GENERATE
8290. This method provides procedures for the
AND EMIT SIGNIFICANT LEVELS OF
detection and quantitative measurement of PCDDs
DIOXIN .
and PCDFs in a variety of environmental matrices at
parts per trillion (ppt) to parts per quadrillion (ppq)
concentrations. This procedure uses matrix specific
extraction, analyte specific cleanup, and provides selected cleanup procedures to aid the analyst in
elimination of interferences that may be encountered. The method is capable of quantitating total
PCDDs, total PCDFs, total TCDD congeners, and total TCDF congeners, in addition to 2,3,7,8-TCDD
and 2,3,7,8-TCDF.
Other methods available for analysis of PCDDs and PCDFs include EPA Method 23 (Appendix A of 40
CFR 60), SW-846 Method 8280, and CARB Method 428.
C.4.3 Total Organic Chlorine (RCl)
C.4.3.1 Volatile RCl
Volatile total organic chlorine is collected on a VOST as described in Section C.3.8 above. The sorbent
tubes from the VOST are thermally desorbed by heating and purging with organic-free helium (SW-846
Method 5041A). The gaseous effluent from the tubes is bubbled through pre-purged, organic-free
reagent water and trapped on an analytical sorbent trap in a purge-and-trap unit. After desorption, the
analytical sorbent trap is heated rapidly and the gas flow from the analytical trap is directed to the head
of a wide-bore column under subambient conditions. The volatile total organic chlorine compounds
desorbed from the analytical trap are determined by GC/MS using SW-846 Method 8260.
C.4.3.2 Semi-volatile RCl
As previously described in Section C.3.5, semi-volatile RCl is collected in an SW-846 Method 0010
sampling train. Sample extraction for semi-volatile RCl is conducted via SW-846 Method 3542. Sample
analysis is conducted by SW-846 Method 8270C using GC/MS. The semi-volatile compounds are
introduced into the GC/MS by injecting the sample extract into a GC with a narrow-bore, fused-silica
capillary column. The GC column is temperature-programmed to separate the analytes, which are then
detected with an MS connected to the GC. Analytes eluted from the capillary column are introduced into
the MS via a jet separator or a direct connection. Identification of target analytes is accomplished by
comparing their mass spectra with the electron impact (or electron impact-like) spectra of authentic
standards. Quantitation is accomplished by comparing the response of a major (quantitation) ion relative
to an internal standard using a five-point calibration curve. Additional information regarding SVOC
sample collection and analysis using the Method 0010 sampling train can be found in Appendix B of
U.S. EPA’s guidance document entitled Risk Burn Guidance for Hazardous Waste Combustion
Facilities (U.S. EPA, 2001).
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C.5 REFERENCES
ASTM, 2003. “Standard Test Method for Organohalide Pesticides and Polychlorinated Biphenyls in
Water by Microextraction and Gas Chromatography.” West Conshohocken, Pennsylvania: American
Society for Testing and Materials, ASTM D 5175-91, January 2003. Digital Object Identifier (DOI):
10.1520/D5175-91R03
ASTM, 2008. “Standard Test Method for Determination of Polychlorinated Biphenyls (PCBs) in Waste
Materials by Gas Chromatography.” West Conshohocken, Pennsylvania: American Society for Testing
and Materials, ASTM D 6160-98, August 2008. DOI: 10.1520/D6160-98R08
ASTM, 2010. “Standard Test Method for Analysis of Polychlorinated Biphenyls in Insulating Liquids
by Gas Chromatography.” West Conshohocken, Pennsylvania: American Society for Testing and
Materials, ASTM D 4059-00, December 2000. DOI: 10.1520/D4059-00R10
California Air Resources Board (CARB), 1990. “Method 428 - Determination of Polychlorinated
Dibenzio-p-dioxin (PCDD), Polychlorinated Dibenzofuran (PCDF), and Polychlorinated Biphenyl
Emissions from Stationary Sources.” Sacramento, California: California Environmental Protection
Agency, Engineering and Laboratory Branch, Monitoring and Laboratory Division, September 12, 1990.
Dry Color Manufacturers Association, 1982. “An Analytical Procedure for the Determination of
Polychlorinated Biphenyls in Dry Phthalocyanine Blue, Phthalocyanine Green, and Diarylide Yellow
Pigments.” Arlington, Virginia, 1982.
Erickson, M. D., 1997. “Analytical Chemistry of PCBs, 2nd Edition.” Boca Raton, Florida: CRC/Lewis
Publishers, 1997.
Midwest Research Institute, 1985. “Operating Procedure - Analysis of Samples for PCBs by GC/ECD,”
EPA Contract No. 68-02-3938, MRI Project No. 8501-A6, December 1985.
U.S. Environmental Protection Agency, 1979. “Continuous Air Pollution Source Monitoring Systems.”
Washington, D.C.: Office of Research and Development, EPA-625/6-79-005, June 1979.
U.S. Environmental Protection Agency, 1980. “Samplers and Sampling Procedures for Hazardous
Waste Streams.” Cincinnati, Ohio: Office of Research and Development, Municipal Environmental
Research Laboratory, EPA-600/2-80-018, January 1980.
U.S. Environmental Protection Agency, 1982a. “Handbook for Sampling and Sample Preservation of
Water and Wastewater.” Cincinnati, Ohio: Environmental Monitoring and Support Laboratory, EPA600/4-82-029, September 1982.
U.S. Environmental Protection Agency, 1982b. “Test Method: The Determination of Polychlorinated
Biphenyls in Transformer Fluid and Waste Oils.” Cincinnati, Ohio: Office of Research and
Development, Environmental Monitoring and Support Laboratory, EPA/600/4-81-045, February 1982.
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Combustion.” EPA-600/8-84-002, February 1984
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U.S. Environmental Protection Agency, 1984b. “Development of Analytical Test Procedures for the
Measurement of Organic Priority Pollutants in Sludge.” Cincinnati, OH: Environmental Monitoring and
Support Lab, EPA 600/4-84-001, January 1984.
U.S. Environmental Protection Agency, 1984c. “Method 608 - Organochlorine Pesticides and PCBs.”
Federal Register, 49, 89-104, October 26, 1984.
U.S. Environmental Protection Agency, 1984d. “Method 625 - Base/Neutrals, Acids, and Pesticides.”
Federal Register, 49, 153-174, October 26, 1984.
U.S. Environmental Protection Agency, 1985. “Test Methods for Determination of Pesticides and PCBs
in Water and Soil/Sediment by Gas Chromatography/Mass Spectroscopy, Method 680.” Cincinnati,
Ohio: Office of Research and Development, Environmental and Support Laboratory, Physical and
Chemical Methods Branch, November 1985
U.S. Environmental Protection Agency, 2003. “Method 1668, Revision C: Chlorinated Biphenyl
Congeners in Water, Soil, Sediment, and Tissue by HRGC/HRMS.” Washington, D.C.: Office of Water,
EPA-820-R-10-005, April 2010.
U.S. Environmental Protection Agency, 2001. “Risk Burn Guidance for Hazardous Waste Combustion
Facilities.” Washington, D.C.: Office of Land and Emergency Management, EPA530-R-01-001, July
2001.
U.S. Environmental Protection Agency, 2013, Code of Federal Regulations, Title 40, Part 60 (40 CFR
60), “Standards of Performance for New Stationary Sources, Appendix A - Test Methods.” July 1, 2013.
U.S. Environmental Protection Agency, 2014. “Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, SW-846.” Washington, D.C.: Office of Land and Emergency Management.

Guidance for Applicants Requesting to Treat/Dispose
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APPENDIX D
QUALITY ASSURANCE PROJECT PLAN TEMPLATE

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
QUALITY ASSURANCE PROJECT PLAN (QAPP) TEMPLATE
See Section 4.2.20 for Guidance relating to the QAPP
Approved OMB No. 2070-0211

[A1: Title and Approval Sheet]

QUALITY ASSURANCE PROJECT PLAN FOR
APPROVAL OF PCB DISPOSAL METHODS

Submitted to the U.S. Environmental Protection Agency for Approval by:

Name

Signature

Date

Name

Signature

Date

Name

Signature

Date

Name

Signature

Date

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
Table of Contents
A PROJECT MANAGEMENT .............................................................................................................
A1 Distribution List ........................................................................................................................
A2 Problem Definition/Background ..............................................................................................
A3 Quality Objectives and Criteria for Measurement Data .........................................................
A3.1 Data Quality Objectives ................................................................................................
A3.2 Measurement Performance Criteria..............................................................................
A3.3 Analytical Data Criteria ................................................................................................
A4 Special Training/Certification ..................................................................................................
A5 Documentation and Records ....................................................................................................
A5.1 Data Recording ..............................................................................................................
A5.2 Field Operation Records ...............................................................................................
A5.3 Laboratory Records .......................................................................................................
A5.5 Records Management and Document Control .............................................................
B DATA GENERATION AND ACQUISITION.................................................................................
B1 Sampling Process Design .........................................................................................................
B2 Sample Methods
B3 Sample Handling and Custody .................................................................................................
B3.1 Sample Numbering ........................................................................................................
B3.2 Sample Labels ................................................................................................................
B3.3 Sample Packaging ..........................................................................................................
B3.4 Field Chain-of-Custody Record ....................................................................................
B3.5 Sample Transfer and Shipment .....................................................................................
B3.6 Laboratory Sample Custody..........................................................................................
B3.7 Sample Containers, Preservation, and Holding Times ................................................
B4 Quality Control ..........................................................................................................................
B4.1 Field QC procedures ......................................................................................................
B4.2 Laboratory QA/QC procedures .....................................................................................
B4.3 Data quality indicators...................................................................................................
B5 Instrumentation/Equipment Testing, Inspection, and Maintenance .......................................
B5.1 Field Equipment .............................................................................................................
B5.2 Laboratory Equipment ...................................................................................................
B6 Instrument/Equipment Calibration and Frequency .................................................................
B6.1 Calibration of Field Instrumentation ............................................................................
B6.2 Calibration of Laboratory Instrumentation ..................................................................
B7 Inspection/Acceptance of Supplies and Consumables ............................................................
B8 Non-Direct Measurements ........................................................................................................
B9 Data Management......................................................................................................................
B9.1 Data Recording ..............................................................................................................
B9.2 Electronic Data Deliverable ..........................................................................................
B9.3 Data Validation ..............................................................................................................
B9.4 Data Transmittal ............................................................................................................
B9.5 Data Reduction...............................................................................................................
B9.6 Data Analysis .................................................................................................................
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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
B9.7 Data Tracking and Reporting ........................................................................................
B9.8 Data Storage and Retrieval............................................................................................
C ASSESSMENTS/OVERSIGHT ........................................................................................................
C1 Assessment and Response Actions ..........................................................................................
C1.1 Field Audits ....................................................................................................................
C1.2 Laboratory Audits ..........................................................................................................
C1.3 System Audits ................................................................................................................
C1.4 Data Quality Assessments .............................................................................................
C1.5 Response Actions...........................................................................................................
C2 Reports to Management ............................................................................................................
C2.1 Frequency, Content and Distribution of Reports .........................................................
C2.2 Personnel Responsible for Report Preparation ............................................................

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
A: PROJECT MANAGEMENT
A1: Distribution List:
The following individuals and organizations will receive a copy of the approved QAPP. [Exclude those
that do not apply.]
•
•
•
•
•
•
•
•
•
•
•

[Name], Senior Manager
[Name], Quality Assurance Officer
[Name], Senior Laboratory Personnel
[Name], Project Manager/Demonstration Lead
[Name], Quality Assurance Officer
[Name], Health and Safety Officer
[Name], Field Team Leader
[Name], Field Team Member
[Name], Laboratory Coordinator
[Name], Technical Staff
[Name], Analytical Laboratory

A2: Problem Definition/Background:
[Describe the project or refer to other submitted documents with a project description.]
The purpose of this project is [insert purpose of the project, e.g., to properly dispose of PCBs through
incineration].
The data generated will be used to ensure that [insert explanation here, e.g., the wastes that will be
managed by the facility are within the scope of the approval].
The data quality needs to meet [insert data quality standards here] to accomplish the goals of the project.

A3: Quality Objectives and Criteria:
The outputs from the systematic planning process which are used to design the study and measurement
performance or acceptance criteria established (e.g., precision, bias, accuracy, representativeness,
comparability, completeness, sensitivity) as part of the study design are described below. For example:
A3.1 Data Quality Objectives
[For help with the DQOs, EPA provides guidance on the DQO process to help in the development
of an appropriate study design (EPA, 2000 and 2006a)].
A3.2 Measurement Performance Criteria

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
The measurement performance criteria (MPCs) are [insert description of measurement performance
criteria, e.g., combustion efficiency and/or destruction removal efficiency].
A3.3 Analytical Data Criteria
[Insert description of analytical data criteria, e.g., use of split samples and/or performance evaluation
samples.]

A4: Special Training/Certification:
[Insert description of certifications held or that will be obtained by personnel and methods of tracking
these certifications.]

A5: Documentation and Records:
[Insert description of documentation and recordkeeping, such as records and documents to be included
in final report, where the records will be kept, etc.]
A5.1 Data Recording
[Insert description of how data will be recorded, e.g., use of data logging software.]
A5.2 Field Operation Records
[Insert description of field operation record-keeping methods, e.g., use of field logbooks.]
A5.3 Laboratory Records
[Insert description of laboratory activity documentation methods, e.g., use of sample custody
records.].
A5.4 Records Management and Document Control
[Insert description of records management plan and document distribution methods, e.g., records
retention schedules.]

B: DATA GENERATION AND ACQUISITION
B1: Sampling Process Design (Experimental Design):
[Insert a description of the project’s experimental design, including, as applicable, a table that
summarizes the components of the monitoring and sampling plan.]

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
B2: Sampling Methods:
[Insert a description of sample/data collection procedures; list of equipment needed; identification of
performance requirements; description of corrective actions to be taken if problems arise.]

B3: Sample Handling and Custody:
[Insert description of how samples will be handled and transferred for ultimate disposal.]
B3.1 Sample Numbering
[Describe how samples will be numbered for unique identification.]
B3.2 Sample Labels
[Describe sample labeling procedures and methods.]
B3.3 Sample Packaging
[Insert description of sample packaging methods. Include details surrounding shipping.]
B3.4 Field Chain-of-Custody Record
[Insert description of sample custody records.]
B3.5 Sample Transfer and Shipment
[Insert description of sample transfer and shipment procedures, e.g., use of tracking numbers.]
B3.6 Laboratory Sample Custody
[Insert description of laboratory sample custody procedures, e.g., sample condition checklist for use
by sample custodian receiving samples.]
B4: Quality Control: [Insert list of QC activities for samples, such as sampling techniques and
frequency, control limits, corrective actions and statistics]
B4.1 Field QC procedures
[Insert field sampling QC procedures.]
Table 1. Definitions, Requirements, and Frequency for Typical Field QC Samples
QC Sample

Description

Typical
Frequency1

Equipment Blank

[Insert description of criteria for equipment
blanks.]

[Insert frequency].

Field Duplicate

[Insert description of criteria for field duplicates.]

[Insert frequency].

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
QC Sample

Description

Typical
Frequency1

Field Blank

[Insert description of criteria for field blanks.]

[Insert frequency].

Trip Blank

[Insert description of criteria for trip blanks.]

[Insert frequency].

B4.2 Laboratory QA/QC procedures
[Insert description of laboratory QA/QC procedures.]
Table 2. Definitions, Requirements, and Frequency for Typical Laboratory QC Samples
QC Sample

Description

Typical Frequency

Matrix Spike

[Insert matrix spike description.]

[Insert frequency].

Calibration Blank
(CB)

[Insert CB description.]

[Insert frequency].

Method Blank
(MB)

[Insert MB description.]

[Insert frequency].

Surrogate Internal
Standards (SIS)

[Insert SIS description.]

[Insert frequency].

Calibration Check
Standards (CCS)

[Insert CCS description.]

[Insert frequency].

Recovery Internal
Standards (RIS)

[Insert RIS description.]

[Insert frequency].

Laboratory Control
Sample (LCS)

[Insert LCS description.]

[Insert frequency].

Reagent or Solvent
Purity Checks

[Insert reagent or solvent purity checks
description.]

[Insert frequency].

B4.3 Data quality indicators
[Insert description of quantitative and qualitative data quality indicators (DQIs), such as accuracy,
precision, etc. See the glossary for quality control statistics, e.g., percent recovery.]

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
Table 3. QC Sample Acceptance Criteria and Corrective Actions
QC Sample

Acceptance Criteria

Corrective Action

Equipment Blank

[Insert acceptance
criteria for this sample].

[Insert description of corrective action that will
be taken.]

Instrument Solvent
Blank

[Insert acceptance
criteria for this sample].

[Insert description of corrective action that will
be taken.]

Method Blank

[Insert acceptance
criteria for this sample].

[Insert description of corrective action that will
be taken.]

Matrix Spike

[Insert acceptance
criteria for this sample.]

[Insert description of corrective action that will
be taken.]

Surrogate Spike

[Insert acceptance
criteria for this sample.]

[Insert description of corrective action that will
be taken.]

Laboratory Control
Sample

[Insert acceptance
criteria for this sample.]

[Insert description of corrective action that will
be taken.]

Instrument Check

[Insert acceptance
criteria for this sample.]

[Insert description of corrective action that will
be taken.]

Duplicate Sample

[Insert acceptance
criteria for this sample.]

[Insert description of corrective action that will
be taken.]

B5: Instrument/Equipment Testing, Inspection, and Maintenance: [Insert description of equipment
testing, inspection, and maintenance methods and schedule.]
B5.1 Field Equipment
[Insert summary table of maintenance procedures for field testing equipment below.]
Table 4. Examples of Maintenance Activities for Field Testing Equipment
Equipment

Maintenance
Activity

Frequency

Corrective Action

CEMs

[Insert description of
maintenance activity].

[Insert
frequency].

[Insert corrective
action].

Sampling trains

[Insert description of
maintenance activity].

[Insert
frequency].

[Insert corrective
action].

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
Rotameter

[Insert description of
maintenance activity].

[Insert
frequency].

[Insert corrective
action].

Pressure transducer

[Insert description of
maintenance activity].

[Insert
frequency].

[Insert corrective
action].

Thermocouple

[Insert description of
maintenance activity].

[Insert
frequency].

[Insert corrective
action].

Volumetric flow
meter

[Insert description of
maintenance activity].

[Insert
frequency].

[Insert corrective
action].

B5.2 Laboratory Equipment
[Insert description of routine testing and maintenance of laboratory equipment, including a table
similar to Table 4, if applicable.]

B6: Instrument/Equipment Calibration and Frequency: [Insert list of all project equipment which should
be calibrated, method and frequency of calibration, etc.]
B6.1 Calibration of Field Instrumentation
[Insert table with description of calibration of field instrumentation below.]
Table 5. Examples of Calibration Procedures for Stack Sampling Equipment
Equipment

Calibration
Procedure

Frequency

Acceptance Criteria

CEMs

[Insert calibration
procedure]

[Insert frequency]

[Insert acceptance
criteria]

Sampling trains

[Insert calibration
procedure]

[Insert frequency]

[Insert acceptance
criteria]

Rotameter

[Insert calibration
procedure]

[Insert frequency]

[Insert acceptance
criteria]

Pressure transducer

[Insert calibration
procedure]

[Insert frequency]

[Insert acceptance
criteria]

Thermocouple

[Insert calibration
procedure]

[Insert frequency]

[Insert acceptance
criteria]

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
Volumetric flow meter

[Insert calibration
procedure]

[Insert frequency]

[Insert acceptance
criteria]

B6.2 Calibration of Laboratory Instrumentation
[Insert laboratory instrumentation calibration procedures in table below].
Table 6. Examples of Calibration Procedures for Laboratory Equipment
Equipment

Calibration Procedure

Frequency

Acceptance Criteria

Analytical
balance

[Insert calibration
procedure.]

[Insert frequency.]

[Insert acceptance
criteria.]

GC

[Insert calibration
procedure.]

[Insert frequency.]

[Insert acceptance
criteria.]

Pipettes

[Insert calibration
procedure.]

[Insert frequency.]

[Insert acceptance
criteria.]

Thermometers

[Insert calibration
procedure.]

[Insert frequency.]

[Insert acceptance
criteria.]

B7: Inspection/Acceptance for Supplies and Consumables:
[Insert list of project supplies and consumables and their acceptance criteria.]

B8: Non-direct Measurements:
[Insert description of any existing data that will be obtained from non-measurement sources, such as
literature files, planned use of data, acceptance criteria and limitations.]

B9: Data Management: [Insert description of the project data management process, e.g., data storage,
software.]
B9.1 Data Recording
[Insert description of data recording procedures. For more information, see Section A9,
“Documentation and Records.”]
B9.2 Electronic Data Deliverable
[Insert description of electronic data format and method of delivery.]

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA
B9.3 Data Validation
[Insert description of data validation procedures. For information about specific data validation
techniques, see Sections D1 through D3.]
B9.4 Data Transmittal
[Insert description of data transmittal methods.]
B9.5 Data Reduction
[Insert description of data reduction methods.]
B9.6 Data Analysis
[Insert description of data analysis methods.]
B9.7 Data Tracking and Reporting
[Insert description of data tracking and reporting methods.]
B9.8 Data Storage and Retrieval
[Insert description of data storage and retrieval methods, such as types of data to be collected,
storage media, procedures for safeguarding the data, etc.]

C: ASSESSMENTS/OVERSIGHT
C1: Assessments and Response Actions:
[Insert description of project assessments planned, information expected, schedule, participants,
reporting of results, etc.]
C1.1 Field Audits
[Insert description of field audit procedures.]
C1.2 Laboratory Audits
[Insert description of laboratory audit procedures.]
C1.3 Data Quality Assessments
[Insert description of data quality assessment procedures.]
C1.5 Response Actions
[Insert description of response action procedures.]

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DISCLAIMER: THIS TEMPLATE IS ONLY AN EXAMPLE AND IT IS NOT REQUIRED TO BE
USED OR SUBMITTED TO EPA

C2: Reports to Management:
[Insert description of procedure to report to management about project’s status.]
C2.1 Frequency, Content and Distribution of Reports
[Insert description of frequency, content and distribution of reports.]
C2.2 Personnel Responsible for Report Preparation
[Insert description of personnel responsible for report preparation.]

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

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APPENDIX E
CLEANUP, EXTRACTION, AND DETERMINATIVE METHODS FOR
PCB AROCLORS, HOMOLOGS, AND CONGENERS

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Disclaimer: Methods discussed in this guidance are for informational purposes and do not guarantee the
use of any specific method. EPA may require a specific method or not accept the method requested by
the applicant to be used on a case-by-case basis. In some instances, EPA may require a comparison
study of a proposed method with an EPA method before determining whether or not to allow the
proposed method. Additionally, methods may be updated in the future and EPA’s stance on a particular
method may change.
Table E-1. Summary of Extraction Methods for PCB Samples
Method

Matrix
Types

Extraction Technique

Analytes

Method
3510

Aqueous

Separatory Funnel LiquidLiquid Extraction

Semi-volatile and Nonvolatile
Organics

Method
3520

Aqueous

Continuous Liquid-Liquid
Extraction

Semi-volatile and Nonvolatile
Organics

Method
3535

Aqueous

Solid-phase Extraction

Semi-volatile and Nonvolatile
Organics

Method
3540

Solids

Soxhlet Extraction

Semi-volatile and Nonvolatile
Organics

Method
3541

Solids

Automated Soxhlet Extraction

Semi-volatile and Nonvolatile
Organics

Method
3542

Air
Sampling
Train

Separatory Funnel & Soxhlet
Extraction

Semi-volatile Organics

Method
3545

Solids

Pressurized Fluid Extraction

Semi-volatile and Nonvolatile
Organics

Method
3546

Solids

Microwave Extraction

Semi-volatile and Nonvolatile
Organics

Method
3550

Solids

Ultrasonic Extraction

Semi-volatile and Nonvolatile
Organics

Method
3562

Solids

Supercritical Fluid Extraction

PCBs and Organochlorine
Pesticides

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Table E-2. Summary of Cleanup Methods for PCB Samples
Method No.

Method Name

Cleanup Type

Method 3610

Alumina Cleanup

Adsorption

Method 3611

Alumina Cleanup and Separation of Petroleum
Wastes

Adsorption

Method 3620

Florisil Cleanup

Adsorption

Method 3630

Silica Gel Cleanup

Adsorption

Method 3640

Gel-Permeation Cleanup (GPC)

Size-Separation

Method 3650

Acid-Base Partition Cleanup

Acid-Base Partitioning

Method 3660

Sulfur Cleanup

Oxidation/Reduction

Method 3665

Sulfuric Acid/Permanganate

Oxidation/Reduction

Table E-3. Summary of Analytical Methods for PCB Samples
Matrix

Method

Description

Feed Material
Oils

EPA/600/4-81-045

GC with halogen-specific ECD
or MS (Aroclor)

ASTM D 4059-00

Soils, sludges, solid
wastes

Capacitors

SW-846 Method 8082A

GC/ECD (Aroclor)

SW-846 Method 8082A

GC/ECD(Aroclor)

ASTM Method D6160-98

GC/ECD (Aroclor)

EPA Method 624-S

GPC (Aroclor)

No standard method exists
Select from methods
given above

Stack gas samples

EPA Method 1668A

HRGC/HRMS (Congeners)

CARB Method 428*

HRGC with low resolution,
electron ionization mass
spectrometry (LRMS)
(Homolog)

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Ash samples

SW-846 Method 8082A

GC/ECD (Aroclor)

EPA Method 680

GC/MS in Selected Ion
Monitoring (SIM) mode
(Homolog)

EPA Method 1668A
Aqueous samples

HRGC/HRMS (Congeners)

EPA Method 608

GC/ECD (Aroclor)

EPA Method 680

GC/MS in SIM mode
(Homolog)

EPA Method 625.1
ASTM Method D5175-91

GC/MS (Aroclor)
GC/MS (Aroclor)

Final Product/Effluent
Oils/ Organic Liquids

EPA/600/4-81-045

GC with halogen-specific ECD
or MS (Aroclor)

ASTM D 4059-00

GC/ECD (Aroclor)

SW-846 Method 8082A

GC/ECD (Aroclor)

EPA Method 680

GC/MS in Selected Ion
Monitoring (SIM) mode
(Homolog)

EPA Method 1668A
Insoluble granular solids
(Soils, Ash, Non-Bulk
Solid Wastes, etc.) and
dissolvable Solids
(Process Waste, Sludge,
etc.)

Insoluble Bulk Solids
(filter media, wipe
samples, etc.)

HRGC/HRMS (Congeners)

SW-846 Method 8082A

GC/ECD (Aroclor)

ASTM Method D6160-98

GC/ECD (Aroclor)

EPA Method 624

GC/MS (Aroclor)

EPA Method 680

GC/MS

EPA Method 1668

HRGC/HRMS

SW-846 Method 8082A

GC/ECD (Aroclor)

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DISCLAIMER: THESE CHECKLISTS ARE ONLY EXAMPLES AND THEY ARE NOT
REQUIRED TO BE USED OR SUBMITTED TO EPA

APPENDIX F
EXAMPLE CHECKLISTS FOR THERMAL AND NON-THERMAL
TECHNOLOGIES FOR USE DURING THE TEST

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DISCLAIMER: THESE CHECKLISTS ARE ONLY EXAMPLES AND THEY ARE NOT
REQUIRED TO BE USED OR SUBMITTED TO EPA
Table F-1. Example Checklist for Thermal Alternative Methods (e.g., Thermal Desorber) for Use
During the Test*
Parameter

Yes

No

Is O 2 being measured?
What is the concentration? _________________%
Provide instrument information: Manufacturer:
Model:
Is CO being measured?
What is the concentration? _________________ppm
Provide instrument information: Manufacturer:
Model:
Is CO2 being measured?
What is the concentration? _________________%
Provide instrument information: Manufacturer:
Model:
Is the waste feed rate being monitored?
Provide instrument information: Manufacturer:
Model:
Is the residence time being calculated?
Is the combustion efficiency (if afterburner is present) being
calculated?
Has the efficiency been demonstrated to 99.9%?
Is the venturi pressure drop being measured?
Provide instrument information: Manufacturer:
Model:
Is the venturi scrubber liquid flow being measured?
Provide instrument information: Manufacturer:
Model:
Is the spray tower liquid flow rate monitored?
Provide instrument information: Manufacturer:
Model:

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DISCLAIMER: THESE CHECKLISTS ARE ONLY EXAMPLES AND THEY ARE NOT
REQUIRED TO BE USED OR SUBMITTED TO EPA
Table F-1 (cont.). Example Checklist for Thermal Alternative Methods (i.e., Thermal
Desorber) for Use During the Test*
Parameter
Is the quench water discharge rate monitored?
Provide instrument information: Manufacturer:
Model:
Is the scrubber liquid discharge rate monitored?
Provide instrument information: Manufacturer:
Model:
Is the quench water make-up rate monitored?
Provide instrument information: Manufacturer:
Model:
Is the scrubber liquid make-up flow rate monitored?
Provide instrument information: Manufacturer:
Model:
Are ash/residue samples collected?
Sample ID: __________________
*Additional monitoring may be needed.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Yes

No

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DISCLAIMER: THESE CHECKLISTS ARE ONLY EXAMPLES AND THEY ARE NOT
REQUIRED TO BE USED OR SUBMITTED TO EPA
Table F-2: Example Checklist for Non-Thermal Alternative Methods (i.e., Chemical
Dechlorination) for Use During the Test*
Parameter
Was a waste feed sample collected?
Sample ID: __________________
Are process product samples collected from the reaction vessel?
Sample ID: ___________________
Are process product samples collected from the storage tank?
Sample ID: ___________________
Is the waste feed rate monitored?
Is the product rate monitored?
Is the reagent feed rate monitored?
Is the quench feed rate monitored?
Is the reaction vessel pressure monitored?
Provide instrument information: Manufacturer:
Model:
Is the reaction vessel temperature monitored?
Provide instrument information: Manufacturer:
Model:
Are vent emissions to ambient air being monitored?
Provide instrument information: Manufacturer:
Model:
*Additional monitoring may be needed.

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Yes

No

Approved OMB No. 2070-0211

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APPENDIX G
PCB AROCLORS, HOMOLOGS, AND CONGENERS

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As a reminder, the definitions of Aroclor, Congener, and Homolog are provided below
Aroclor
A commercial mixture of PCBs previously manufactured by Monsanto. Aroclor is one of the most
commonly known trade names for PCB mixtures. There are many types of Aroclors and each has a
distinguishing suffix number that indicates the degree of chlorination. The numbering standard for
the different Aroclors is as follows: The first two digits are usually “12,” which represents a 1200
series product as designated by Monsanto. A 1200 series PCB product is a refined PCB product
usually derived from the 1100 series crude PCBs. The second two numbers indicate the percentage
of chlorine by mass in the mixture. For example, the name Aroclor 1254 means that the mixture
contains approximately 54% chlorine by weight.
Congener
Any single, unique, well-defined chemical compound in the PCB category. The name of a congener
specifies the total number of chlorine substituents, and the position of each chlorine.
For example, 4,4'-Dichlorobiphenyl is a congener comprising the biphenyl structure with two
chlorine substituents - one on each of the #4 carbons of the two rings.
Altogether, there are 209 individual PCB congeners having the molecular formula C12H nCl10-n,
where n = 0-9. This definition includes monochlorobiphenyls.
Homolog
Subcategories of PCB congeners that have equal numbers of chlorine substituents. For example, the
tetrachlorobiphenyls are all PCB congeners with exactly 4 chlorine substituents that can be in any
arrangement. Altogether, there are 10 homologs.

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Table G-1. List of PCB Aroclors
Chemical Abstract
Service Registry
Number (CASRN)
12674-11-2
147601-87-4
151820-27-8
11104-28-2
37234-40-5
11141-16-5
71328-89-7
53469-21-9
12672-29-6
165245-51-2
89577-78-6
11097-69-1
11096-82-5
37324-23-5
11100-14-4
12767-79-2

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

IUPAC Name Type
Aroclor 1016
Aroclor 1210
Aroclor 1216
Aroclor 1221
Aroclor 1231
Aroclor 1232
Aroclor 1240
Aroclor 1242
Aroclor 1248
Aroclor 1250
Aroclor 1252
Aroclor 1254
Aroclor 1260
Aroclor 1262
Aroclor 1268
Aroclor (unspecified)

Page 156

Table G-2. List of PCB Homologs
CASRN
27323-18-8
25512-42-9
25323-68-6
26914-33-0
25429-29-2
26601-64-9
28655-71-2
55722-26-4
53742-07-7
2051-24-3

IUPAC Name
Monochlorobiphenyl
Dichlorobiphenyl
Trichlorobiphenyl
Tetrachlorobiphenyl
Pentachlorobiphenyl
Hexachlorobiphenyl
Heptachlorobiphenyl
Octachlorobiphenyl
Nonachlorobiphenyl
Decachlorobiphenyl

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Number of Isomers
3
12
24
42
46
42
24
12
3
1

Page 157

CASRN
2051-60-7
2051-61-8
2051-62-9
13029-08-8
16605-91-7
25569-80-6
33284-50-3
34883-43-7
34883-39-1
33146-45-1
2050-67-1
2974-92-7
2974-90-5
34883-41-5
2050-68-2
38444-78-9
37680-66-3
37680-65-2
38444-73-4
38444-84-7
55702-46-0
38444-85-8
55720-44-0
55702-45-9
55712-37-3
38444-81-4
38444-76-7
7012-37-5
15862-07-4
35693-92-6
16606-02-3
38444-77-8
38444-86-9
37680-68-5
37680-69-6
38444-87-0
38444-90-5
53555-66-1

Table G-3. List of PCB Congeners
Congener
Number IUPAC Name
1
2-Chlorobiphenyl
2
3-Chlorobiphenyl
3
4-Chlorobiphenyl
4
2,2'-Dichlorobiphenyl
5
2,3-Dichlorobiphenyl
6
2,3'-Dichlorobiphenyl
7
2,4-Dichlorobiphenyl
8
2,4'-Dichlorobiphenyl
9
2,5-Dichlorobiphenyl
10
2,6-Dichlorobiphenyl
11
3,3'-Dichlorobiphenyl
12
3,4-Dichlorobiphenyl
13
3,4'-Dichlorobiphenyl
14
3,5-Dichlorobiphenyl
15
4,4'-Dichlorobiphenyl
16
2,2',3-Trichlorobiphenyl
17
2,2',4-Trichlorobiphenyl
18
2,2',5-Trichlorobiphenyl
19
2,2',6-Trichlorobiphenyl
20
2,3,3'-Trichlorobiphenyl
21
2,3,4-Trichlorobiphenyl
22
2,3,4'-Trichlorobiphenyl
23
2,3,5-Trichlorobiphenyl
24
2,3,6-Trichlorobiphenyl
25
2,3',4-Trichlorobiphenyl
26
2,3',5-Trichlorobiphenyl
27
2,3',6-Trichlorobiphenyl
28
2,4,4'-Trichlorobiphenyl
29
2,4,5-Trichlorobiphenyl
30
2,4,6-Trichlorobiphenyl
31
2,4',5-Trichlorobiphenyl
32
2,4',6-Trichlorobiphenyl
33
2,3',4'-Trichlorobiphenyl
34
2,3',5'-Trichlorobiphenyl
35
3,3',4-Trichlorobiphenyl
36
3,3',5-Trichlorobiphenyl
37
3,4,4'-Trichlorobiphenyl
38
3,4,5-Trichlorobiphenyl

Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 158

Table G-3 (cont.). Summary of PCB Congeners
Congener
CASRN
Number IUPAC Name
38444-88-1
39
3,4',5-Trichlorobiphenyl
38444-93-8
40
2,2',3,3'-Tetrachlorobiphenyl
52663-59-9
41
2,2',3,4-Tetrachlorobiphenyl
36559-22-5
42
2,2',3,4'-Tetrachlorobiphenyl
70362-46-8
43
2,2',3,5-Tetrachlorobiphenyl
41464-39-5
44
2,2',3,5'-Tetrachlorobiphenyl
70362-45-7
45
2,2',3,6-Tetrachlorobiphenyl
41464-47-5
46
2,2',3,6'-Tetrachlorobiphenyl
2437-79-8
47
2,2',4,4'-Tetrachlorobiphenyl
70362-47-9
48
2,2',4,5-Tetrachlorobiphenyl
41464-40-8
49
2,2',4,5'-Tetrachlorobiphenyl
62796-65-0
50
2,2',4,6-Tetrachlorobiphenyl
68194-04-7
51
2,2',4,6'-Tetrachlorobiphenyl
35693-99-3
52
2,2',5,5'-Tetrachlorobiphenyl
41464-41-9
53
2,2',5,6'-Tetrachlorobiphenyl
15968-05-5
54
2,2',6,6'-Tetrachlorobiphenyl
74338-24-2
55
2,3,3',4-Tetrachlorobiphenyl
41464-43-1
56
2,3,3',4'-Tetrachlorobiphenyl
70424-67-8
57
2,3,3',5-Tetrachlorobiphenyl
41464-49-7
58
2,3,3',5'-Tetrachlorobiphenyl
74472-33-6
59
2,3,3',6-Tetrachlorobiphenyl
33025-41-1
60
2,3,4,4'-Tetrachlorobiphenyl
33284-53-6
61
2,3,4,5-Tetrachlorobiphenyl
54230-22-7
62
2,3,4,6-Tetrachlorobiphenyl
74472-34-7
63
2,3,4',5-Tetrachlorobiphenyl
52663-58-8
64
2,3,4',6-Tetrachlorobiphenyl
33284-54-7
65
2,3,5,6-Tetrachlorobiphenyl
32598-10-0
66
2,3',4,4'-Tetrachlorobiphenyl
73575-53-8
67
2,3',4,5-Tetrachlorobiphenyl
73575-52-7
68
2,3',4,5'-Tetrachlorobiphenyl
60233-24-1
69
2,3',4,6-Tetrachlorobiphenyl
32598-11-1
70
2,3',4',5-Tetrachlorobiphenyl
41464-46-4
71
2,3',4',6-Tetrachlorobiphenyl
41464-42-0
72
2,3',5,5'-Tetrachlorobiphenyl
74338-23-1
73
2,3',5',6-Tetrachlorobiphenyl
32690-93-0
74
2,4,4',5-Tetrachlorobiphenyl
32598-12-2
75
2,4,4',6-Tetrachlorobiphenyl
70362-48-0
76
2,3',4',5'-Tetrachlorobiphenyl
32598-13-3
77
3,3',4,4'-Tetrachlorobiphenyl
Guidance for Applicants Requesting to Treat/Dispose
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Page 159

Table G-3 (cont.). Summary of PCB Congeners
Congener
CASRN
Number IUPAC Name
70362-49-1
78
3,3',4,5-Tetrachlorobiphenyl
41464-48-6
79
3,3',4,5'-Tetrachlorobiphenyl
33284-52-5
80
3,3',5,5'-Tetrachlorobiphenyl
70362-50-4
81
3,4,4',5-Tetrachlorobiphenyl
52663-62-4
82
2,2',3,3',4-Pentachlorobiphenyl
60145-20-2
83
2,2',3,3',5-Pentachlorobiphenyl
52663-60-2
84
2,2',3,3',6-Pentachlorobiphenyl
65510-45-4
85
2,2',3,4,4'-Pentachlorobiphenyl
55312-69-1
86
2,2',3,4,5-Pentachlorobiphenyl
38380-02-8
87
2,2',3,4,5'-Pentachlorobiphenyl
55215-17-3
88
2,2',3,4,6-Pentachlorobiphenyl
73575-57-2
89
2,2',3,4,6'-Pentachlorobiphenyl
68194-07-0
90
2,2',3,4',5-Pentachlorobiphenyl
68194-05-8
91
2,2',3,4',6-Pentachlorobiphenyl
52663-61-3
92
2,2',3,5,5'-Pentachlorobiphenyl
73575-56-1
93
2,2',3,5,6-Pentachlorobiphenyl
73575-55-0
94
2,2',3,5,6'-Pentachlorobiphenyl
38379-99-6
95
2,2',3,5',6-Pentachlorobiphenyl
73575-54-9
96
2,2',3,6,6'-Pentachlorobiphenyl
41464-51-1
97
2,2',3,4',5'-Pentachlorobiphenyl
60233-25-2
98
2,2',3,4',6'-Pentachlorobiphenyl
38380-01-7
99
2,2',4,4',5-Pentachlorobiphenyl
39485-83-1
100
2,2',4,4',6-Pentachlorobiphenyl
37680-73-2
101
2,2',4,5,5'-Pentachlorobiphenyl
68194-06-9
102
2,2',4,5,6'-Pentachlorobiphenyl
60145-21-3
103
2,2',4,5',6-Pentachlorobiphenyl
56558-16-8
104
2,2',4,6,6'-Pentachlorobiphenyl
32598-14-4
105
2,3,3',4,4'-Pentachlorobiphenyl
70424-69-0
106
2,3,3',4,5-Pentachlorobiphenyl
70424-68-9
107
2,3,3',4',5-Pentachlorobiphenyl
70362-41-3
108
2,3,3',4,5'-Pentachlorobiphenyl
74472-35-8
109
2,3,3',4,6-Pentachlorobiphenyl
38380-03-9
110
2,3,3',4',6-Pentachlorobiphenyl
39635-32-0
111
2,3,3',5,5'-Pentachlorobiphenyl
74472-36-9
112
2,3,3',5,6-Pentachlorobiphenyl
68194-10-5
113
2,3,3',5',6-Pentachlorobiphenyl
74472-37-0
114
2,3,4,4',5-Pentachlorobiphenyl
74472-38-1
115
2,3,4,4',6-Pentachlorobiphenyl
18259-05-7
116
2,3,4,5,6-Pentachlorobiphenyl
Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 160

Table G-3 (cont.). Summary of PCB Congeners
Congener
CASRN
Number IUPAC Name
68194-11-6
117
2,3,4',5,6-Pentachlorobiphenyl
31508-00-6
118
2,3',4,4',5-Pentachlorobiphenyl
56558-17-9
119
2,3',4,4',6-Pentachlorobiphenyl
68194-12-7
120
2,3',4,5,5'-Pentachlorobiphenyl
56558-18-0
121
2,3',4,5',6-Pentachlorobiphenyl
76842-07-4
122
2,3,3',4',5'-Pentachlorobiphenyl
65510-44-3
123
2,3',4,4',5'-Pentachlorobiphenyl
70424-70-3
124
2,3',4',5,5'-Pentachlorobiphenyl
74472-39-2
125
2,3',4',5',6-Pentachlorobiphenyl
57465-28-8
126
3,3',4,4',5-Pentachlorobiphenyl
39635-33-1
127
3,3',4,5,5'-Pentachlorobiphenyl
38380-07-3
128
2,2',3,3',4,4'-Hexachlorobiphenyl
55215-18-4
129
2,2',3,3',4,5-Hexachlorobiphenyl
52663-66-8
130
2,2',3,3',4,5'-Hexachlorobiphenyl
61798-70-7
131
2,2',3,3',4,6-Hexachlorobiphenyl
38380-05-1
132
2,2',3,3',4,6'-Hexachlorobiphenyl
35694-04-3
133
2,2',3,3',5,5'-Hexachlorobiphenyl
52704-70-8
134
2,2',3,3',5,6-Hexachlorobiphenyl
52744-13-5
135
2,2',3,3',5,6'-Hexachlorobiphenyl
38411-22-2
136
2,2',3,3',6,6'-Hexachlorobiphenyl
35694-06-5
137
2,2',3,4,4',5-Hexachlorobiphenyl
35065-28-2
138
2,2',3,4,4',5'-Hexachlorobiphenyl
56030-56-9
139
2,2',3,4,4',6-Hexachlorobiphenyl
59291-64-4
140
2,2',3,4,4',6'-Hexachlorobiphenyl
52712-04-6
141
2,2',3,4,5,5'-Hexachlorobiphenyl
41411-61-4
142
2,2',3,4,5,6-Hexachlorobiphenyl
68194-15-0
143
2,2',3,4,5,6'-Hexachlorobiphenyl
68194-14-9
144
2,2',3,4,5',6-Hexachlorobiphenyl
74472-40-5
145
2,2',3,4,6,6'-Hexachlorobiphenyl
51908-16-8
146
2,2',3,4',5,5'-Hexachlorobiphenyl
68194-13-8
147
2,2',3,4',5,6-Hexachlorobiphenyl
74472-41-6
148
2,2',3,4',5,6'-Hexachlorobiphenyl
38380-04-0
149
2,2',3,4',5',6-Hexachlorobiphenyl
68194-08-1
150
2,2',3,4',6,6'-Hexachlorobiphenyl
52663-63-5
151
2,2',3,5,5',6-Hexachlorobiphenyl
68194-09-2
152
2,2',3,5,6,6'-Hexachlorobiphenyl
35065-27-1
153
2,2',4,4',5,5'-Hexachlorobiphenyl
60145-22-4
154
2,2',4,4',5,6'-Hexachlorobiphenyl
33979-03-2
155
2,2',4,4',6,6'-Hexachlorobiphenyl
Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 161

Table G-3 (cont.). Summary of PCB Congeners
Congener
CASRN
Number IUPAC Name
38380-08-4
156
2,3,3',4,4',5-Hexachlorobiphenyl
69782-90-7
157
2,3,3',4,4',5'-Hexachlorobiphenyl
74472-42-7
158
2,3,3',4,4',6-Hexachlorobiphenyl
39635-35-3
159
2,3,3',4,5,5'-Hexachlorobiphenyl
41411-62-5
160
2,3,3',4,5,6-Hexachlorobiphenyl
74472-43-8
161
2,3,3',4,5',6-Hexachlorobiphenyl
39635-34-2
162
2,3,3',4',5,5'-Hexachlorobiphenyl
74472-44-9
163
2,3,3',4',5,6-Hexachlorobiphenyl
74472-45-0
164
2,3,3',4',5',6-Hexachlorobiphenyl
74472-46-1
165
2,3,3',5,5',6-Hexachlorobiphenyl
41411-63-6
166
2,3,4,4',5,6-Hexachlorobiphenyl
52663-72-6
167
2,3',4,4',5,5'-Hexachlorobiphenyl
59291-65-5
168
2,3',4,4',5',6-Hexachlorobiphenyl
32774-16-6
169
3,3',4,4',5,5'-Hexachlorobiphenyl
35065-30-6
170
2,2',3,3',4,4',5-Heptachlorobiphenyl
52663-71-5
171
2,2',3,3',4,4',6-Heptachlorobiphenyl
52663-74-8
172
2,2',3,3',4,5,5'-Heptachlorobiphenyl
68194-16-1
173
2,2',3,3',4,5,6-Heptachlorobiphenyl
38411-25-5
174
2,2',3,3',4,5,6'-Heptachlorobiphenyl
40186-70-7
175
2,2',3,3',4,5',6-Heptachlorobiphenyl
52663-65-7
176
2,2',3,3',4,6,6'-Heptachlorobiphenyl
52663-70-4
177
2,2',3,3',4,5',6'-Heptachlorobiphenyl
52663-67-9
178
2,2',3,3',5,5',6-Heptachlorobiphenyl
52663-64-6
179
2,2',3,3',5,6,6'-Heptachlorobiphenyl
35065-29-3
180
2,2',3,4,4',5,5'-Heptachlorobiphenyl
74472-47-2
181
2,2',3,4,4',5,6-Heptachlorobiphenyl
60145-23-5
182
2,2',3,4,4',5,6'-Heptachlorobiphenyl
52663-69-1
183
2,2',3,4,4',5',6-Heptachlorobiphenyl
74472-48-3
184
2,2',3,4,4',6,6'-Heptachlorobiphenyl
52712-05-7
185
2,2',3,4,5,5',6-Heptachlorobiphenyl
74472-49-4
186
2,2',3,4,5,6,6'-Heptachlorobiphenyl
52663-68-0
187
2,2',3,4',5,5',6-Heptachlorobiphenyl
74487-85-7
188
2,2',3,4',5,6,6'-Heptachlorobiphenyl
39635-31-9
189
2,3,3',4,4',5,5'-Heptachlorobiphenyl
41411-64-7
190
2,3,3',4,4',5,6-Heptachlorobiphenyl
74472-50-7
191
2,3,3',4,4',5',6-Heptachlorobiphenyl
74472-51-8
192
2,3,3',4,5,5',6-Heptachlorobiphenyl
69782-91-8
193
2,3,3',4',5,5',6-Heptachlorobiphenyl
35694-08-7
194
2,2',3,3',4,4',5,5'-Octachlorobiphenyl
Guidance for Applicants Requesting to Treat/Dispose
of PCBs Using Incineration or an Alternative Method

Page 162

Table G-3 (cont.). Summary of PCB Congeners
Congener
CASRN
Number IUPAC Name
52663-78-2
195
2,2',3,3',4,4',5,6-Octachlorobiphenyl
42740-50-1
196
2,2',3,3',4,4',5,6'-Octachlorobiphenyl
33091-17-7
197
2,2',3,3',4,4',6,6'-Octachlorobiphenyl
68194-17-2
198
2,2',3,3',4,5,5',6-Octachlorobiphenyl
52663-75-9
199
2,2',3,3',4,5,5',6'-Octachlorobiphenyl
52663-73-7
200
2,2',3,3',4,5,6,6'-Octachlorobiphenyl
40186-71-8
201
2,2',3,3',4,5',6,6'-Octachlorobiphenyl
2136-99-4
202
2,2',3,3',5,5',6,6'-Octachlorobiphenyl
52663-76-0
203
2,2',3,4,4',5,5',6-Octachlorobiphenyl
74472-52-9
204
2,2',3,4,4',5,6,6'-Octachlorobiphenyl
74472-53-0
205
2,3,3',4,4',5,5',6-Octachlorobiphenyl
40186-72-9
206
2,2',3,3',4,4',5,5',6-Nonachlorobiphenyl
52663-79-3
207
2,2',3,3',4,4',5,6,6'-Nonachlorobiphenyl
52663-77-1
208
2,2',3,3',4,5,5',6,6'-Nonachlorobiphenyl
2051-24-3
209
Decachlorobiphenyl

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Page 163