P3.sm4 2-Y 737. sat= is contaminated with PCBs (polychlorinated. by Wayne P. Starke, VP Sales Sun Environmental. Canton, Ohio (216)

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1 by Wayne P. Starke, VP Sales Sun Environmental 1700 Gateway Blvd., SE Canton, Ohio (216) P3.sm4 2-Y 737 sat= Our public utilities, industries, public institutions and government agencies are faced with the daily problem of disposing of transformer oil that is contaminated with PCBs (polychlorinated biphenyls). Because transformer oil is a liquid it cannot be sent to chemical landfill. The most common alternative has been incineration in an EPA approved incinerator. A typical scenario involves contacting an approved hazardous waste hauler, who comes onto the property, pumps the contaminated oil into a tanker capable of holding about 5000 gallons and then hopefully transporting it safely to one of four major commercial incinerators approved to burn PCBs. Shortly, the mail delivers a certificate of destruction stating that the contaminated oil has been incinerated. This scenario carries with it some risks and concerns. Once the oil is transported off the property, will it be transported safely? One reads in the newspaper frequently of tanker trucks being involved in accidents and the contents spilled on the highway. The cost to dispose of 5000 gallons of oil might quickly grow from several dollars per gallon to something in the six figure range. If the oil makes it safely to the incinerator, what guarantees are there that your oil is actually burned and at the time the certificate says it was. Unfortunately, there are dishonest companies in the hazardous waste business. Companies that want to make a quick dollar and run. Your oil might not be burned but stored in an unsafe manner or it might be sold for use as a fuel or as a road tar. If it is burned, what happens to the ash from the incinerator. Is it properly buried? What is the liability of the heavy metals that might exist in the ash over time? The purpose of this paper is to present a proven alternative to off site incineration of PCB contaminated mineral oil. This alternative is the on site chemical detoxification process.called PCBX.

2 PIS CUSSION Incineration is required under its permit to achieve six nines of destruction. This means that 99,9999% of the original PCBs must be destroyed. To verify if this level of destruction is achieved, the stack gases of the incinerator are supposedly monitored on a continuous basis. If however an upset were to occur causing a release of impartially burned PCBs the emission would not only contain PCBs, but would contain the deadly dioxins and furans which are significantly more toxic at lower concentrations. It is for this primary reason that you won't find your average individual willing to have an incinerator in his or her backyard. Why are incinerators so wildly used in this country as a so-called safe method for the disposal of PCBs and yet no one wants one in his backyard? HOW safe is the original owner of PCB Contaminated mineral oil who uses an incinerator for disposal. Many owners are attempting to address this concern by sending an environmental audit team to the incinerator on a periodic basis to inspect and approve the incinerator for future shipments. I an incinerator company were to fail financially, was there an closure fund to ensure that the site would be completely cleaned of any residual pollution. If not, is there adequate insurance coverage to cover the proper closure. It might be wise to check the actual language of an incinerator's insurance policy to make sure there is not lingering liability on the part of the generator. An incinerator can't stop its process and recycle PCB contaminated material that is improperly burned. An incinerator can't burn heavy metals that might be in commingled liquids. The resultant ash is hauled off to a landfill and hopefully properly buried. However, it is possible that the ash could be buried in the same cell with another generator's material that is not safe and hence ends up causing a serious pollution problem. Landfills today are built with state of the technology to ensure that there is no contamination of

3 the surrounding environment. Unfortunately, we are a society that learns the hard way. What seems like adequate technology might prove to be flawed in the future. Linings that seem to be able to withstand attack by various materials might not be suitable against future compounds or worse yet maybe a combination of today's chemicals. Landfills that are covered by a closure fund give a certain degree of security. However who is to say that today's fund is adequate or tomorrow's closure. Mobile on site processes such as the Sun Environmental's PCBX Process is different from incineration at a fixed site and landfills for the following reasons... * All PCBs are destroyed chemically with no air emissions, no harmful by-products. * No PCBs are transported off the generator's site and out of site out of mind. * All results of the chemical process are verified on site. If any residual PCBs still exist in the transformer they can still be chemically treated right on the transformer with a repeat application. * PCBs don't regenerate, once they are chemically destroyed and removed from the oil the equipment and the site are PCB free. The PCBX Process was the first PCB process granted a federal permit to operate throughout the United States. It is also the first process to receive a permit to operate in Ontario, Canada - the first Province to require a formal permitting procedure for mobile treatment processes. The PCBX Process was developed by Sun Oil as a way to safely remove PCBs from transformer oil without damaging the oil or the transformer. Since its first operation in 1981, Sun Environmehtal has processed over 12,000,000 gallons of oil contaminated with PCBs. This oil is still in service today, PCB free and of excellent quality for use as transformer oil. PCBX PROCESS DESCRIPTION Sun Environmental's PCBX Process is a chemical

4 process which permanently destroys the PCB molecule resulting in a PCB free transformer oil and harmless by-products. The process is housed in mobile trailers which can operate within 500 ft of the transformer being serviced. The process can be set-up and operating in about half a day. Once operating, it can process about 5,000 gallons of contaminated oil per day. The process can handle up to 10,000 ppm of PCBs. Once the process rigs are set-up, hoses are connected to the top and bottom valves of the transformer. As soon as the process equipment is lined out and good clean oil has circulated through the system, oil from the transformer is pumped into the process rig while clean oil is returned to the transformer, maintaining a proper oil level. The first part of the process involves chemical destruction of the PCBs. This is achieved through the use of a sodium based reagent which atrips the chlorine atoms off the PCB molecule, while encouraging the polymerization of the remaining molecule. The chlorines combine with the sodium to create a harmless salt. Both products are then removed by mechanical separation equipment leaving the oil clean and PCB free. Sun Environmental's PCBX Process has been used on more than 12,000,000 gallons since Thousands of transformers are in service today operating on PCBX'd oil. Oil qualify date from transformers serviced indicate oil qualities that are as good as new oil. That is because the PCBX Process after it has destroyed the PCBs completely reclaims the oil. The process removes excess water, gases, color bodies, and carbon particles. ANALYSIS Disposal of PCB wastes must be done in a prudent manner using the best state-of-the-art technology that is cost effective, and of minimal risk to the generator and the environment. Typical comparable costs today are as follows:

5 Incineration: drain, flush and retrofill transformer with new oil $5.00-$6.00/gal transportation to incineration incinerator Total cost $3.25/loaded mile $ /ual $6.12-$7.58/gal plus transportation PCBX on site detox: complete processing with guarantee to non-pcb status, plus reclamation of oil - $5-8/gallon. When the risks associated with transportation, landfill of wastes, and the inability to be assured of actual destruction are factored in, it makes the mobile on site treatment option worthy of serious consideration. Two other benefits of the PCBX Process are worth consideration Firstly, the PCBX Process restores the original oil, hence the conservation of a valuable resource. It takes approximately 66 barrels of imported crude oil to make one barrel of transformer oil. We need to cut back on our importation of foreign crude, and when we can restore transformer oil we are helping to do just that. Secondly, there is a lot of interest in staying with a product that is proven. Transformer oils that were refined years ago have demonstrated they are reliable. The newer crudes tend to be more paraffinic rather than naphthenic based. Naphthenic based oils have better pour points, and anti-sludging tendencies. The newer crudes, although bonforming to the specifications, are blends which have not withstood the test of time for performance, aging and anti-sludging. As the phrase goes - 'Stay with a Winner'. SUMMARY PCBX is a proven technology that is an excellent

6 alternative to incineration - for the following reasons: 0 it is cost effective 0 it is minimal risk 0 it represents state of the art technology 0 it preserves a natural resource 0 it restores a proven dielectric fluid 0 it avoids the liabilitv of transportation 0 it is a verifiable service on site Sun Environmental has service representatives that can analyze your situation and prepare a cost estimate tailored to your particular situation. Sun Environmental also offers services such a environmental testing and analysis, askarel transformer reclassification, turnkey disposal and replacement.