Understanding the new federal requirements for PCB destruction
January 1, 2009 by Eric Smith, Ph. D.
Since the current rate of attrition will not allow the country to meet its international obligations under a number of treaties and conventions, on September 5, 2008 Canada’s federal government enacted new PCB legislation to accelerate the removal and safe disposal of PCB wastes.
The new regulations require that owners of inservice equipment such as PCB (askarel) transformers and PCB Power Factor Correction capacitors have them removed from service by December 31, 2009. Similarly, owners of transformers containing mineral oil bearing PCB concentrations greater than 500 ppm or transformers that are greater than 50 ppm located at sensitive sites, also have them either removed from service or reclassified to non-PCB status. (Sensitive sites include hospitals or senior citizens’ care facilities, drinking water treatment plants, food or feed processing plants and preschools, primary schools or secondary schools.)
As one would expect, many PCB owners are concerned that this tight time frame adds hardship in tough economic times and that the deadline is unattainable.
The new PCB Regulations indicate that, “Extensions may be granted for the 2009 end-of-use deadline up to December 31, 2014, on a case-by-case basis and upon the demonstration that conditions set out in the Regulations have been met.” The intent of this provision is to afford some flexibility for equipment that cannot be replaced by the deadline due to technical constraints for engineered-to-order equipment or if the facility is scheduled for permanent closure before 2014.
If a PCB owner feels their situation is unique enough to warrant an extension, they must submit their request in writing to Environment Canada for review. However, Environment Canada has made it clear that it provided sufficient warning of these new Regulations and emphasize that extensions will not be granted for economic reasons alone.
For the vast majority of owners of PCB transformers, the December 31, 2009 deadline will apply. Let’s look at a few PCB transformer replacement scenarios.
PREPARING A BUDGET
When faced with the replacement of an askarel transformer, the disposal cost is determined by the volume of liquid and the weight of the empty carcass, both of which are on the name plate of the transformer. Prior to the promulgation of the new PCB regulations, the reasons to remove PCBs related mostly to liability, accident prevention and environmental stewardship. Now the removal is required.
If you need to replace a PCB transformer, determine as soon as possible what type of transformer you need for your particular site. This is also an
opportunity to: replace aging switchgear; install a larger KVA transformer; change from liquid to “dry type” units; relocate a substation within a building; increase or decrease redundancy; move indoor substations to outdoors; and, upgrade to new technology equipment.
In anticipation of the deadline, orders for new transformers are increasing and delivery times are expected to become longer. Current delivery times ranging from 18 to 22 weeks depending on the number and type of transformers ordered. It’s important therefore to order equipment as soon as possible.
Before a PCB transformer replacement project can begin, a few regulatory issues must be satisfied. In Ontario, for example, PCB owners must go online to the environment ministry’s “HWIN” Internet site to obtain a Generator Number if they don’t already have one. They will have to register PCBs as waste class 243-D solids and 243-D liquids when transformer disposal is involved. The Generator Number will be used for completing the TDG manifest for removal of the PCBs from the site. The owner will also have to submit a letter to the local ministry office requesting “Director’s Instructions” for greater than 50 litres of PCB liquid, providing all of the pertinent details of the proposed project.
Access to a transformer substation is probably the most significant factor affecting project costs. For transformers at ground level where the access door is large enough to remove the unit intact, a PCB transformer can be drained and removed and the new unit placed into the vault in less than a day. Similarly, if below grade substations are accessible, a crane can lift out the PCB transformer intact and drop in the new unit in just a few hours. However, in those cases where substations are totally inaccessible, it can take several days to remove a PCB transformer and install a new one.
Some extractions and installations can be challenging when the transformer access is on the side of a building, especially several floors up. Special “transformer” platforms may have to be constructed to facilitate removal and installation.
In those instances where the access to the vault is on the roof, a crane may be able to remove the PCB units and lift the new transformers up to the vault. Cranes large enough to do these lifts can cost tens of thousands of dollars a day so a decision needs to be made as to whether it’s economically feasible to use them or not. These huge cranes can take eight to 12 hours to assemble and require the shutdown of an entire city block. Also, the job requires permits, police at both ends of the block and, if public transit is impacted, additional costs for removal and re-installation of street car cables (for example).
If a project is time critical, using a crane will enable extraction of the PCB transformers and placement of the new units inside the vault in just a few hours. When the last new transformer is securely placed in the substation, the vault cover is replaced and secured and the crane can then be disassembled; a process that takes another 8-12 hours. Following installation of the new transformers, the vault is cleaned and usually painted to return it to a pristine state.
What do you do if the transformer substation has poor access or is totally inaccessible?
When an inaccessible PCB transformer needs to be changed out, there is only one option, and that is “cut-down” of the transformer and installation of a dry-type replacement unit in situp. It’s surprising how many askarel transformers fall into the category of “inaccessible.” They’re particularly abundant in high-rise buildings where substations were constructed in a manner that never took into account that the transformer would have to changed-out one day.
The transformer cut-down process in general terms involves the use of saws rather than torches to minimize heat. The fins and the top of the transformer are cut away and then the tank is cut down into pieces small enough to be man-handled. The tank walls are cut away until the core is completely exposed. Once the tank walls have been removed, the core is taken apart piece by piece. All of the core components are placed in drums for removal from the site.
Depending on the construction and the size of the transformers, it may be possible to remove individual coils with a hoist and place them right into a drum. As each PCB transformer is removed from the vault, the dry-type replacement transformer is brought into the vault in pieces and is reassembled after being assembled and tested at the manufacturing facility.
NO ASKAREL TRANSFORMER RECLASSIFICATION OPTION
For many years the market offered “reclassification” of askarel transformers to non-PCB status using what became known as the “PERC” process. Perc is perchloroethylene or tetrachloroethylene, the toxic solvent used by the dry-cleaning industry.
The perc reclassification process involved the removal of the askarel and replacing it with perchloroethylene. The transformer was re-energized and the perc was continuously circulated through a distillation unit to keep the PCB levels sufficiently low to allow the PCBs in the core and coil to leach out over time. Although the process had some successes, there were several notable failures that lead the companies who were using this approach to abandon it altogether.
It’s noteworthy that perc-insulated transformers are still in service. Some are below 50 ppm PCBs and others have leached back to over 50 ppm. In any case, the owners we have talked to are targeting them for replacement despite spending a lot of money on the reclassification process.
In the normal course of events, if the PCB concentration in a perc-insulated transformer was considered sufficiently below 50 ppm PCBs, the perc was drained from the transformer and it was retrofilled with silicone, R-Temp or other dielectric fluid. Again, depending on the internal construction of the transformer in question, the PCBs in some cases continued to leach slowly into the new insulating liquid, giving rise to another problem: PCB-contaminated silicone or R-Temp. The transformer owners we have talked to are choosing to replace their “perc” transformers.
MINERAL OIL TRANSFORMER RECLASSIFICATION
Contrary to what some people believe, mineral oil transformers were never manufactured with PCBs in them. They became contaminated when serviced by contractors using pumps and hoses that were previously used for servicing askarel transformers. In some cases the oil transformers became contaminated with PCBs to several thousand ppm.
As mentioned earlier, mineral oil transformers containing 500 ppm PCBs or more either have to be replaced or reclassified to non-PCB status by retrofilling. Assuming a transformer still has some life expectancy, retrofilling simply involves replacing the PCB-contaminated oil with new or refurbished oil.
The PCB-contaminated oil from the transformer tank and conservator are drained into proper 16-gauge, 205-litre bung type drums. The transformer is maintained under dry air or nitrogen blanket to prevent intrusion of moisture into the transformer core.
New oil or refurbished oil is pumped into the transformer after it’s been degasified and clay filtered to improve the dielectric strength and overall quality of the oil. When two transformers are in the same substation, it may be possible to switch the load to one unit while the other is drained and retrofilled. Following a period of a few hours to several hours, the retrofilled unit is re-energized and the load is switched over to the retrofilled unit
(and the process is repeated with the second transformer).
After a period of 90 days, the PCB concentration in the transformer tank will equilibrate as the PCBs leach from the core. The core components that retain PCBs include the paper, wood, tape and particleboard. As long as a transformer is close to full load, about 90 per cent of the PCBs will leach from the core and reach equilibrium, leaving 10 per cent still in the core and coils. We have found that allowing a transformer to sit for a while after draining, followed by a flush of a drum or two of retrofill oil, will maximize removal of PCBs with a single retrofill.
For transformers that are contaminated with PCBs to levels exceeding 500 ppm, the units will have to be drained and refilled every 90 days until the final PCB level is 50 ppm. This process is referred to as “serial retrofilling.”
“HISTORICAL” PCB STORAGE SITES
Before Swan Hills was open for destruction of PCBs, owners had no other choice but to store PCB wastes on their site. The Ontario Ministry of the Environment assigned a PCB Site Number and required generators to register their PCB wastes and from that point on, once a PCB owner was in the database, their name would remain there.
Swan Hills has been open for 12 years now and PCB owners who have disposed of their PCBs are undertaking to have their PCB site listed as “Historical” with the environment ministry, a process commonly referred to as “site decommissioning.” It’s important to note that having a site listed as a historical PCB site will say nothing about the environmental health of the rest of the property.
In order to accomplish a PCB site decommissioning, owners must provide data to the ministry to confirm that there have been no PCB residues in the storage containers or storage rooms that may have resulted from leakage, spillage or mishandling of PCBcontaminated wastes. In order to assess this, any rooms, substations or containers previously used for storage of PCBs must be wipe-tested for PCB residues; the number of samples taken depends on the floor area. The PCB residues must be 10 g/100 cm2 or the area will have to be decontaminated and re-tested.
If there is any noticeable or suspect staining, rather than conduct a wipe test immediately to prove what is already suspected, the floor should be subjected to a thorough solvent washing. Once the floor has been decontaminated, confirmatory wipe tests are taken. The process is repeated as many times as necessary until the tests confirm PCB residues are 10 g/100 cm2
If a storage container or storage building was used to house the PCB wastes, proof is required to confirm that PCBs did not escape the confines of the structure. Soil or gravel samples are taken from each side of a concrete container, platform or transformer pad for a minimum of four samples for direct PCB analysis. A “composite” of the four samples is subjected to a modified “leachate test” to determine the presence of other chlorinated hydrocarbons, heavy metals, PAHs, pesticides, etc. as the situation may dictate.
If the inside and the outside of the PCB storage compound pass the analytical tests, the consultant’s report along with the lab’s Certificates of Analyses and the Certificates of Destruction for the PCB wastes can be submitted to the local ministry Director, requesting that your PCB storage site be considered inactive or historical.
Usually PCB owners go through this decommissioning exercise when they’re confident they’ve removed all of their PCBs from service but occasionally some do it despite knowing that more PCBs will be generated. If additional PCB wastes are required for removal, you need not go through the site registration exercise all over again if the wastes are removed promptly from the site after they’ve been taken out of service.
The new Federal PCB Regulations dictate that owners comply with several requirements relating to storage of PCBs including: maximum storage periods, prohibitions against storage, exceptions, access to storage sites, inspection of sites, maintenance, labelling and reporting requirements, disposal deadlines for stored PCB wastes.
It’s certainly possible that some PCB owners will eclipse the December 31, 2009 deadline due to the large numbers of transformers that need replacement. These situations are particularly common to the high rise office towers in major cities across Canada.
Although many owners of PCB transformers have taken steps to address the issue of replacement their equipment, many more have not done anything yet and are planning to wait until well into 2009 before drafting a plan. This may be okay for owners with a single transformer but for those with several units, the earlier the order is placed for new equipment, the better.
For PCB owners who are concerned about their project running into 2010, you have a chance of remaining onside with Environment Canada if you do the following: develop a replacement strategy; commit the funds; place an order for new transformers, set a “reasonable” time line, and start executing your replacement plan. Enforcement officers will more than likely focus their attention on those owners who have made little or no effort to comply with the new regulations.
It’s also noteworthy that Swan Hills Alberta may or may not be operating after 2015. It would therefore be prudent for owners of ballasts, cables and any other PCB contaminated wastes that require disposal by 2025, to get rid of their PCBs before 2015 to avoid the risk of not having the Alberta Special Waste Treatment Centre as an option for disposal of their PCBs. (See articles, pages 13 and 15 for various options.)
Eric Smith, Ph. D., is President of PCB Disposal Inc. in Ajax, Ontario.
Contact Eric at firstname.lastname@example.org
Swan Hills Treatment Centre
The Swan Hills Treatment Centre is located near Swan Hills, Alberta. This fully integrated hazardous waste treatment and disposal facility has been in operation since 1987 and is capable of handling all hazardous wastes onsite with the exception of radioactive and explosive wastes. The facility is owned by the Alberta government which has contracted with Earth Tech to be the long-term operator.
Earth Tech provides a “cradle-to-grave” approach as all wastes are sent to and treated at one site. Treatment options include high temperature incineration, stabilization/solidification and physical/chemical treatment. Solid treatment residues, rendered nonhazardous, are placed into a secure onsite landfill. Liquid non-hazardous residues are injected into an onsite deep well. All required analysis is performed in a full-service, laboratory at the facility.
The treatment centre can handle solids, liquids and sludges in drummed and bulk form employing systems for waste receiving, preparation, storage and tracking. Onsite storage includes 1,133 cubic metres of bulk liquid storage, a 700 cubic metre bulk solids pit and 17,000 drum spaces in various storage buildings.
In the last 18 months, the treatment centre has upgraded the tank farm and the FB&D incinerator and is well positioned to handle additional volumes of PCB wastes anticipated as a result of the new federal PCB regulations.
Although Earth Tech does not provide site services or transportation for PCB waste, the company has agreements in place with other firms that provide turnkey services for most PCB wastes: Aevitas in Cambridge, Ontario; Sanexen in Longueuil, Quebec; and, Trans Cycle Industries in Kirkland Lake, Ontario.
Naturally, the treatment centre has programs in place for health and safety, process safety, risk management and an environmental management system. The centre eliminates environmental liability as the Alberta government assumes long-term liability for the site and is responsible for site closure, decommissioning and long-term monitoring of the landfill cells. Information supplied by Gordon Godin, Marketing & Sales Consultant.