United States. Solid Waste and Enforcement and
Environmental Protection Emergency Response Compliance Assurance EPA530-R-94-046
(5305) (J5503) January 1995
&EPA CMA/EPA BIF
Workshop
Edited Transcript
Ftecycled/Recyclable
Printed on recycled pape'r that contains at
least 50% post-consumer recycled fiber
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DISCLAIMER
This- document contains discussion and a serlies of questions
and answers by individual EPA staff members, and does not
constitute a rule or final Agency guidance. The: view expressed
by the EPA staff in this workshop transcript afej those of the
speakers, and do not necessarily reflect the official policies
and positions of EPA. In addition, the supplemental answers to
questions not addressed at the workshop were also prepared by the
EPA staff speakers and similarly do not necessarily represent the
official policies and positions of EPA. This transcript is not
intended, nor can it be relied upon, to create any rights
enforceable by any party in litigation with the United States.
EPA edited the original .draft transcript fojr- clarification
and readability. Also, this transcript does not! contain a record
of two sessions - RCRA Overview and General BIF Overview - as
those sessions were not recorded and transcribed'.
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TABLE OF CONTENT'
I. TRANSPCRIPT PAGE
A. Waste Analysis of Feed Streams 1
B. Monitoring Requirements .... 1 6
C. Automatic Waste Feed Cut-Off ; 9
D. Owner/Operator Inspections ........... 14
E. Subpart BB Inspection . -. .16
F. Recordkeeping ......... 19
G. Training for Facility Personnel ....... 25
H. Compliance Testing ,'. ...'......_ ; 28
I. Management of Residues 34
J. Regulatory Development Up-Date 38 ,
K. Wrap-up . ... .44
II. ATTACHMENTS
A. Agenda for the Workshop . A-l
B. List of questions generated at the Workshop......... B-l
* C. List of Speaker and Phone Numbers . C-l
r
D. ' List of EPA Combustion Guidance Documents . ......... D-l
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' PROCEEDINGS
.'imp I i uq f. Analysis of Feed Streams
>'
,Mt -hc.jinbi ownki : My name i r, .John Dorabrowski . .I'm with the Office
''I w.'inl r» Ptoqiamr, .Enforcement, -RCRA Enforcement Division and I
in i 'ill ly wot k for Susan Bromm and I'll be'working for Susan in the new
"i '|..iii i r..il ion. The next discussion is on sampling and analysis. "To
! |.ip i hi 55 _ presentation, we took questions- .that CMA members had
pi f.'t'Mil f"l to.KPA and-developed a .generalized discussion.
Examples of some general requirements for sampling and analysis,
whir/ii KF-H -touched on a couple of these earlier, are: general .facilities
r.i aiiii.il fin; BJF requirements, such as demonstration of qualification for
r-Kpinpt.ion. and waivers, chlorides, metals .and ash feed rate limits for BIF;
l.lip t i eat merit standards. ' . .
Some general questions- submitted by the CMA members centered
ftround what should be contained in a waste analysis plan. Today we will
.not'discuss the detailed requirements of a waste analysis plan. However
I would like to bring your attention to some new guidance developed by
EPA. It's tit-led Waste Analysis'At Facilities That Generate, Treat And
Dispose Of Hazardous Waste. it.'? currently in a draft form but should be
finalized soon, and a Notice of Availability will be published/in the
Federal Register. This, is a revision to-the 1984 guidance. [At the time
of the release of this transcript, this document is available through
NTIS. Please refer to OSWER No; 9938.4-03 and Publication NO. PB94-963-
603 when otdering.] - ,
Some other general items that should be contained in a waste
analysis plan and are of" interest to BIF owners and operators include:
sampling analysis frequencies; analytical procedures; and quality
assurance arid quality control measures. As we discuss these items, please
keep in mind that these are things that you want to keep in the waste
analysis plan among other things.
The first item I would like to discuss is frequency. When should
a facility sample and analyze its waste? First of all, this discussion
can apply to all feed streams required by the BIF rules. Some factors one
needs to consider are: sources of the feed stream, variability, batch
sizes, and stability of the operation. Let's take a look at various
frequency options for sampling and analysis. Different options are going
to be applicable for different facilities. The frequency options that we
will discuss here today are phase sampling using statistical analysis,
batch sampling and case-by-case sampling. We will discuss each of these
options in detail. .Please note that this discussion is applicable to BIFs
with interim status as well. As you select an option, you should .consult
your Regional or state enforcement personnel for assistance. Also, the
option that: you select during interim status may change when it comes time
to obtain a permit, at which .time you should consult with Regional or
Slate permitting personnel.
Let's talk about frequency-of sampling for batch operations.- This
option is applicable to feed streams that changes through time or that .are
transported to a facility in batches. For .example off-site wastes, or
feed streams that are generated at varying quantities and,concentrations
and being fed at different times. An important point in batch sampling
is that the sample should be representative. Two additional important.
points about batch sampl-ing are: first, the analytical results you receive
for that batch -is what you should use to calculate the fe.ed rates; and
secondly, no new material is being added to the batch after the sample has
been taken or while you're feeding that batch to the BIF unit. That was
pretty simple. A more extensive option 'that is available to BIFs in waste
analysis is phase sampling in conjunction with statistical analysis. This
option is'appropriate for on-site waste (as-generated n9t as blended).
For- this option, a facility would develop an extensive data base on the
waste or the feed stream that it is being considered for feeding into the
BIF unit. Based on this data base, the. facility can then establish the
frequency at which'it will sample and -analyze. For example, after taking
samples for thirty days, the facility develops a statistical data base.
.Based on this database., thp facility may decide toreduce the sampling and
analysis frequency to weekly or even' monthly, or whatever may be
applicable for that site. As for determining feed rates for this option,
the facility should use the upper confidence limit, generated from this
data base for each constituent of concern. One issue 'regarding this
approach may come up is that a facility may have developed its statistical
data base and established a -frequency. However, when it took a sample -and
received the analytical results, the analytical results were below the
established upper confidence limit. For this situation, EPA recommends
that the facility use the established upper confidence limit for that
analytical data in determining feed rates.N Now, for analytical data above
the upper confidence limit (meaning you'have your established frequency,
and you get your results back "and you see a couple of constituents that
are now above this upper limit you had established) , what should the
facility do? In this situation, EPA recommends a facility considers a
couple of options. First, the facility should evaluate the analytical
data that are above that limit to determine why they are above the limit.
Outliers, incomplete data and QA/QC will be discussed following the
frequency discussion.. The facility could resample, -which is part of the
QA/QC procedures, use the higher value of the feed rate1, until resampling
shows that you're back within that confidence limit, and then go back to
using the .upper confidence limit. Another option may be increasing
sampling frequency, meaning the facility may have not correctly selected
the appropriate frequency'for that facility, or for, that operation. This
may be indicating that you should sample more often. I'd like to bring
to your attention, if you do use the upper confidence limit instead.of the
higher analytical value for the constituent, the Regions may come in and
evaluate that higher analytical data point to see if the waste analysis
is really adequate enough as far as frequency is concerned.' May be this
higher limit should be the limit used for feed rate calculations because
the statistical analysis is weak, or this data point may or may not be an
outlier. But it's going to be something that the. Regions will want to
look at and probably will.
If you're using statistical analysis, the initial data base that
was discussed earlier should be continuously updated. A facility should
continue to add data to this data base and thereby recalculate an upper
confidence limit that will be used for feed rate calculations for
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constituents. In summary, every tirae a facility receives an analysis, add
it to the data base. There's one point I'd like to bring out here.
Facilities should be cautioned that the data base may become too large.
For example,
the facility has been aawpling once a week' for ten years. The data base
with all of this analytical data is extremely large. The facility may
want to consider, when looking at that upper confidence limit, a more
recent time frame of the data, maybe the most recent two years or one
year. This gives a more accurate snap shot of the facility's current
.operations, where as the total of ten years of data may not reflect
current operations. So, the data base should be continuously updated but
also maintained. .
Let me explain the intent of this next slide. The intent is not
to have process knowledge alone for determining feed -rates. Process
knowledge in combination with analytical data," or just analytical data is
what we are looking for'when calculating feed rates. We're not confident
that process knowledge alone could give you that feed rate number or
calculation. For example, we have case where facilities have said, I'm
not measuring that constituent because 'I know it's not there and we took
'a sample and the analysis showed that the constituent was there. Another
example "would be chrome^ coming off piping. The piping part of the
process. It's a^oiraple example but there "are others.. Process knowledge
can be used to determine when a statistical analysis and the data base is
no longer applicable. This is similar to maintenance of that data base
discussed earlier.. And, finally,, a good starting point for statistical
analysis working into phase sampling is SW-846 Chapter 9.
Case-by-case sampling. This is for an operation that doesn't fit
into any of the two schemes just discussed. For example, it may be
plausible that a facility can work something out with the state or Region
on a worst case scenario. However, I would suggest' for whatever option
selected, especially like a case-by-case option, the facility should
consult with State or Region to obtain some guidance or direction.
Different options may be applicable and they may not be. But just keep
in mind, whatever'option you select, it's going to be evaluated during an
inspection and when it comes time to permitting. So, it is best to try
to work things out with the Regions or states, if you can, in developing
an option.
Now I'd like to move on to another aspect or'another area where
the questions presented by CMA centered around. Keep in mind this is
something a facility would want to keep as part of the waste analysis
plan. First, detailed information on sampling and analytical procedures.
The following are just some items why this is important. First, it is
necessary for compliance with BIF requirements. For example, feed rates,
constituents, confirming the properties of materials. Meaning all
materials in question that is being fed into the BIF. Some examples of
detailed characterization for analytical parameters are right here.- I-
guess the ones that.are of real concern are the BIF metals, chlorides,
ash, in some cases dioxin and furans. Others that are"listed here are
dependent upon the facility, maybe for their requirements, .fuel spec
requirements or other regulations. When SW-846 is not specified in the
regulations, any reliable analytical procedure is acceptable. However,
SH-846 ia a good starting point because it can be used as a guidance
document when it's not specified in the regulations. So Chapter 2 of SH-
846 is where I would recommend you start looking. When using other
methods that are not specified in SH-846. or not specified in the
regulations, you want to use good, general RCRA QAQC type of procedures
with any method selected. When SH-846 is specified in the regulations,
that method must be used. In some cases, facilities don't like to use
methods specified in SW-846. There is an option available if there is a
SW-846 method specified in the regulations and the facility leally care
does not want to use it. This option is in 40 CFR 260.21 which is "peti-
tions for equivalent testing or analytical.methods." In summary, this
petition allows a facility to petition the Administrator to add to the
regulatory requirements a testing or analytical method. Basically, you
are petitioning to add to the regulatory, requirements another method
because that's what the" facility wants to use. A key with this petition
is that the proposed method must be superior or equivalent to the existing
method. However, it is my understanding that this is not a very quick or
expeditious route to take. Might be quicker just trying to implement the
other method required by the regulations.
Maximum holding times. There was a question related to maximum
holding times and turn around times. A good reference is SW-846 Table-
2.21, or if it's a method not specified in SW-B46, ~l would recommend
looking into the QA procedures recommended for the method selected. Now
questions started centering in around incomplete data and outliers. This
is something that should be contained in the waste analysis plan on how
to deal with incomplete data and outliers. The important thing to stress
here is that for incomplete data and outliers documentation is very
important. Some references for incomplete" data and outliers are listed
here, Chapter r of SW-846, Guidance on Setting Permit Conditions arid the
Handbook for 'QAQC Procedures for Hazardous Waste Incineration. These
should all be available at NTIS. I don't have the EPA document number on
the last two document, at this moment but I can get that for you later.
Now we're going to discuss outliers. Think back to the
statistical analysis discussion. We were discussing chat one analytical
point that may be out of'range. The most important point we'ie going to
try to make here for outliers are quality assurance procedures. Again,
documentation, determining .why and corrective action to be taken to
prevent this from occurring in the future are the most important elements
that should be considered for outliers. Just because you get a data point
that doesn't seem like it fits within the rest of data, don't just, ignoie
it of discount it. We'd like you to follow some structured steps on how
to approach that data point and how to address it. .-Documenting this is
going to help when, it comes times to make a compliance deteiminat ion.
Without this type of documentation or this structured procedme,
determining compliance becomes a little bit more difficult. And ayain,
if you go through all of the QA procedures, an outlier may not be an
outlier. It may be valid data point and that's what needs to U-
determined.' And the facility will have to include, this data point'01 t ak<-
.corrective action. Now we'll discuss incomplete data. Basically a .|.i.,,l
corrective- action in dealing ..with this problem is resampling ,,n.i
reanalyzing. An important point here is documentation and I fun i :;ii<.;;:;
that enough. We would like to have this documentation av,.iK,M,- ,,
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l.i.ivo
faci
' i i'-n. ' Th irs dnriimontat ion may become valuable during the permitting
'::- in <1-M minim ti-i f rptjuency of sampling and analytical procedures.
i' to demonstrate that. waste, stream is still within the previous
r> r,l learns as shown by the statistical analysis. .It's important to
dor-umenf.ation to back this up to ' show what's happening at the
lity and 'to sho'w compliance that this waste 'stream hasn ' t changed.
These situations about incomplete data and outliers presented here
tty to \jives you a feel for how you should handle them. But really it's
, qoing to be a 'site specific issue.. I could always give you an idea on how
to jiddress this problem. I definitely recommend, that you consult with
you i- -state, or Regional ,off ice on how they would like to see you approach
this problem. And this is also applicable for frequency determinations.
As' discus,sed earlier with incomplete, data, all quality assurance and
(iocumpiitation and corrective measUres should be taken with outliers as
wpll. You don't want to have these outliers and incomplete data problems
frequently at the facility. Make s'ure that this problem is addressed,
corrected and is not reoccurring. I have provided a couple of examples,
which are not in your, manual. ,In the. first example of hazardous waste and
statistical analysis. A facility generates waste on-site, and has this
waste piped directly to a storage tank and subsequently burned in the bn-
site boiler. The waste is produced in a stable chemical process that is
well characterized by laboratory analysis. Meaning there is good data
base of analytical data. The waste is initially well characterized for
the BIF parameters using .statistical evaluations as just discussed. The
waste is also characterized to see if it. meets the. facility's fuel
specifications. The facility knows they can burn this waste in their
unit. Based on statistical analysis a frequency for complete
characterization, meaning all BIF requirements, is determined e.g.,
monthly; quarterly,, annually, whatever is applicable to that site . Also
complete characterization analysis ,is conducted whenever the process
change has occurred or whenever the waste deviates from their fuel specs.
The facility getting indications that something is different in your
waste." Better recharacterize it.
'Example 2. Hazardous waste ' fuel ' batch analysis. The facility
receives hazardous waste from numerous off -site sources and blends these'
wastes on-site. An initial characterization now is performed on each
waste stream before acceptance and discharge into the storage tank system.
Once the tank is .filled, a complete characterization for the BIF
parameters is conducted. The analytical results from that
characterization is used for the feed rates. And then the facility feeds
this waste as a batch into the boiler. No further fuel or material is
added Lo this batch being burned. Example 3 . Normal fuel statistical
analysis. The facility feeds pulverized coal as a primary fuel. Coal is
received from off -site sources, stockpiled on-site, , ground and milled
before feeding. From statistical analysis based on historical data, the
facility has 'established specification, maximum concentration for metals
and chloride. A -representative sample of each shipment of coal are
collected and analyzed to verify that-the coal confirms to our statistical
analysis specifications. . .
MR. DOMBROWSRI : Question, how can the Agency cite facilities
for inadequate waste analysis when it was never specified in the
regulations or any guidance documents on proper methods such as
statistical analysis, outliers, etc.? First, I would like to introduce
the'panel members; Ken Gigliello, Oliver Fordham from the Office of Solid
Waste, Bob Holloway and Sonya Sasseville. Want me to repeat the question?
How can the Agency cite facilities for inadequate waste analysis
when it was never specified in the regulations for any guidance documents
on proper methods such as statistical analysis or outliers,, etc.?
MR. HOLLOWAY: The regulation clearly says you have to sample
_a.nd analyze as often as necessary to insure compliance with the
regulations. You've got to sample and analyze as oftern as your situation
dictates in order to'know what you're feeding before you feed it.' With
respect to guidance oh statistical approaches for establishing a sampling
program, some of that are in SW-846 already. The Agency has established
guidance. Plus, if you weren't sure how to deal with these issues, as far
as outliers, or whatever, the Regions and the states have been there to '
provide guidance.
.'I - . ' "
MS. SASSEVILLE: And one of the concerns was, I think, with some
facilities that really hadn't made an effort to figure out what was
necessary a'nd we certainly did see some examples'of that.
MR. FORDHAM: As John has discussed, SW-846 Chapter 9 is OSW's
guidance on sampling and statistics for proper sample collection. It
talks about the number of samples necessary and how to calculate upper
confidence levels". This is the basic source for figuring out what you
need to do as far-as your sampling and analysis plan atid frequency of
sampling is.concerned. * »
QUESTION FROM AUDIENCE:
(inaudible)
MR. FORDHAM: This is true and it gets back to the discussion
you had this morning-. Do you want us to prescribe every step that you
have to do, or do you want us to give you some flexibility to be able to
most cost effectively apply these to your own analysis. We could
prescribe a very rigid set of statistical procedures but I think it's
better to allow flexibility because we can't account for all different
type of analyses that are going to be required for the world of hazardous
waste testing. We need to have this flexibility.
MR. GIGLIELLO:- It sounds like the question is of two parts.
One is saying that there are no methods in place; the other is centering
on the frequency issue. And the methods that John has talked about are
laid out in SW-846. -How to analyze, how to sample. The frequency, I
think, is the issue that a lot of us have a more difficult time dealing
with and as Ollie has said, we could choose to say, for instance, and this
is not the way it exists now, that if you are a commercial facility that
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accepts waste frow ten off-site sources, you- will do it this way, aa
opposed to if you are a facility that has on-site waste and you only burn
one waste stream, you will do it this way. The point of the matter ia.
we have not done it that way. He have not mandated to that level of
detail, in a great number of instances because your industry, in
particular, has refused to want to do it that inflexibly. And there is
this balance of what you want. To be honeat, from an enforcement
standpoint, we'd like to have In the regulations, you will sample five
times a day or whatever the number is because then we could go out and
verify whether or not you've done it. But chat has not been traditionally
the way the RCRA program is stt up and if you really feel that is the
approach that we should take, then that's something that you should convey
to the people that are writing the rules. To be honest, the frequency
issue is going to be on a site specific basis and right now there's just
no way around that. There is absolutely no way around site specific basis
-for frequency of sampling. The method, however though, is something you
should be able to get from SW-846 or if you have a different method which
you feel is better, you may _choose to use it based on the provision in 40
CFR 266.102(b).
MR. DOMBROWSKI: This next question brings up an interesting
point. Actually it's something I had on the slides and I failed to
mention. What is,fthe Agency's guidance when constituents of concern are
not detectable. Osihg- an SW-846 methodology in repeat sampling produces
different detection limits. I will defer the SW-846 question to Oliver,
as far as the second part, the point about when detection limits are
varying. First with the statistical analysis, it may not be appropriate
when the detection limits aren't varying or you're not getting any
variation, therefore you really couldn't have a statistical analysis but
what happens when you do have variation. That's a good question and there
are some different thoughts out there. One is, maybe statistical analysis
might be applicable.to that variation, or maybe methodology which you're
getting the detection limits from is not the correct one, or selecting a
different method might be more appropriate. That would be something you'd
have to work out with your Region or state.
MR. FORDHAM: Instrumental detection limits are so sensitive
these days, that generally they're well below any EPA regulatory limits
except for a few nasty oily wastes and samples oJ that nature, but
generally detection limits are much lower than any regulatory limit so
whether you use the detection limit, or zero, really won't make too much
difference in your statistics.' It only presents a problem if the
detection limit happens to be very close to the regulatory.limit.
MR. DOMBROWSKI: I would like to familiarize you with Oliver's
background. He is our SW-846 person here today and is very familiar with
that aspect of regulatory requirements and guidance.
(comments from audience-inaudible) . . - . .
' MR. FORDHAM: Even though you have the non-detect numbers that
are well below the regulatory limit, based on the sample matrix there can
be a lot of differences in the detection limits that are achievable
sample-to-sample-and that variability and detection limit can throw you
into a high upper confidence limit. Hay be that is what people are
talking about here. It's not that you may have all your values well below
the -regulatory limit. They way all be non-detect. But if you apply these
statistica to them and look* at the variability just in detection limits
sometimes you get into problems, if the detection limit is near the
regulatory limit.
MR. FORDHAM: We've come up against this with commercial
laboratories where it's impossible to get acceptable detection limiia in
an organic matrix for metals.
MR. FORDHAM: Good detection limits for the metals in oily
matrices should be achievable by the new microwave methods. You ought to
be able to destroy the sample matrix and. thus get good detection limits
from metals. The other issue on the detection limits is the variability.
Increasing the variability can make that upper confidence level higher.
I think this is probably been a debate that's gone on for years and years
when you've got a non-detect, do you call it zero, do you call it, the
method detection limit, what do you call .it. I don't know that there's
ever been any resolution. I think there may be some problems but I don't
'know of any and I don't think SW-846 has any particular guidance on that.
(question .from audience Inaudible)
MR. FORDHAM: The microwave methods are not always as vigorous
as some of the hot plate methods and so the amount that's digested may not
be as high but they are more precise. All of our studies show that the
repiroduceability of the microwave methods is much better so if you use
those consistently, you'll probably get much more precise analysis.
MR. DOMBROWSKI: '- ' Let's go on to the next question. Is
analytical-data required for fuel, for flue gas and process vent gas fed
to boilers? If so, does EPA have a protocol method or recommended,methods
to sample -and analyze these gas streams? If not, what is "EPA's
recommendation? Yes. It is required of you to analyze your vent gases
going into your units. BIF regulations state all feed streams. The flue
gases and process vent gases are feed streams. I'll let Oliver talk about
analytical methods available for gas sampling.
MR. FORDHAM: There aren't any methods in SW-846 on how to sample
gases. . There are some new methods that'have just gone through technical
workgroup review last year for analyzing certain BIF metals and ce'ttain
things in gas streams, but .1 don't believe that, talks about sampling,
that's just an analysis.
MR. GIGLIELLO: Again, let me try to answer it fiom an
enforcement, standpoint. In most cases that I have seen, where wu havt- a
problem is if you fail to do something. We haven't seen people ounie in
and ask us "we don't.really have a method,to measure the gas goin
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i ni'-i'iini)-: pt f>|i I cm, 01 if there is a problem that you don't kno.w how to do
11 , V'li know,: romp in and talk to us. But if you don't.'do it at all,
'n't put it. into .writing as to what's going on., then we have no
i li >! ii.it i /< t hfii bnnirnlly nay, look, the regulations say, do this, you're
"'' 'il.'imj it , wh.it '.-. t-.hf? alternative that we have?
(inaudible)
MR. DOMBROWSKI: If a facility mixes all waste before feeding
into i IIP boiler will it demonstrate compliance (inaudible) the mixture of
tho ntteams. I'm going to refer back to'the three areas we just talked
-ihoi.it. Batch, statistical and case by case. In this example here -it
.Nfx-'ms 11 ike you would be a batch. We're talking about mixing all your
.'t.rpatnc and then you would sample the mixture prior to feeding into the
HIP unit. - . . ,
.:;_.. . . (conversations inaudible) ._..'.'
MS. CHOW: ' I'm going to ask John to pick, out the questions
that he can answer easily and answer them in the' next IS minutes. When
we transcribe the tapes, we'll try to address as many of;the remaining
questions as possible in the transcript. For site specific questions, we
will have to refer to the Regions or the States to gather more information
and address them individually. So another 15 more minutes on this before
we move on to the next topic. - ' . .
MR. DOMBROWSKI:- How often is a confidence limit established?
Is-it recalculated with each new data point? If so, a high value even
when the lower confidence limit.can drastically raise it especially if the
data base is small. That's true. But as we talked about in statistical
analysis, every time you receive analytical data, you should add it to
that data base. If there 4s a'data point that you feel is potentially an
outlier or. can mess up your data, you should go through QAQC procedures
to evaluate that data point and maybe resample and analyze.
MR. GIGLIELLO: I've got one here that I could take a crack at.
Do you plan to-allow some period of time to utilize "new guidance" for
those who have used-the1984 guidance in designing their waste analysis
plans? And the second part of that, is new guidance being applied now?
The main difference in this new guidance is that the prior 1984 guidance
did not have any mention of the land disposal restrictions program. And
the document itself was not very user friendly. Therefore, we are
revising it for the new guidance, we have sent this document through two
rounds of review. We ..also sent it to a number of people in the regulated
community. There were 30 people that we sent it to directly that have
commented on it. As John said, it's in printing right now and will be
available through NTIS. I would say the answer fco the first question is,
yes. 1 would think we're going'to have to make some accommodations for
looking at having some time to implement the new guidance. But the thing
you have to remember about the waste analysis plan guidance, it's not a
document that you create once and then ten years later you're still using "
it the same exact way you did ten years ago. I mean it's a kind of
document you have to look at on some kind of routine basis and see what's
going" on with the material that you are burning. What's going on with the
waste streams. Am I getting different waste streams? So it has to be
somewhat of a living document. This document updates a lot of the old
information. There are new examples in there of what a waste analysis
. plan should look like for generators, for instance, because that.
information wasn't there before. So, the answer to the question is.,- it'.s
being used now to the extent that the permit writers have it in their
hands and they're going to be using it probably during your permit
decision making. So it would really be good to get your hands on this
'document. And I said, it should be coming out very soon to NTIS. I don't
think anybody's "imminent from the BIF standpoint of getting a permit right
now, so I don't think it's crucial right now that you get it but I think
it will be available within the next couple of months. [As of April 1994,
this document has become available through the NTIS with
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that you show Croea your quality assurance that you're getting performance
from your method. That you can prove the performance of your method.
Unfortunately when it gets down to the Regional and particularly the state
level (the states have primacy of their own programs), they can be more
restrictive than EPA if they want to on these issues. And quite often
that's what happens. Hot having the resources, they often just mandate
that an SH-846 method will be used. We are working with our Regions and
with states to try to bring this word to them to give more flexibility
because we know the cost of analysis is high and we prefer the most cost-
effective methods be used.
MR. DOMBROWSKI: I want to clarify and respond to this one point
here. We have two issues here with respect to statistical analysis and
the phase sampling. In our example we said 95%, or 97.5% confidence
.limit. SW-B46 has 90%. These are not requirements. It's guidance. It's
what we'd like to see. You may determine based on bur guidance what's
appropriate for your facility.
MR. GIGLIELLO: I have a question here. If a facility spells
out in its waste analysis plan exactly how sampling and analysis will be
conducted, then the WAP is included in the permit, is a facility
considered being compliance as long as it is complying"with the WAP?
^ * *
It's basically a straight-forward question. The-_ thing you've got
to remember about' any waste analysis plan, is that when -we go out and look
at waste analysis plans, we're looking basically for two things. We're
looking for, is it an adequate plan (particularly for plans that have not
been approved yet), and if it is, are they following it according to what
it says. So, the permit really has nothing to do with it per se because
chances are you're going to have to modify your waste analysis plan during
the permitting process.. Interim status waste analysis plans in other
words may be different than your permitted waste analysis plan. There are
very few situations I think this particular situation happens. So, when
we go out and look, we can potentially get people on violations both for
an inadequate plan (particularly if it has not been "approved) or failure
to follow the plan. And again, I think we've been 'dancing around all
morning on what is really adequate. And that's the thing I think we have
some a fair amount of disagreement with the industry, and maybe even
internally at times on what is adequate. And so, the answer to this
question is, if you are in compliance and it's adequate, yes. If you are
following your plan and it's in concurrence to the permit, the answer is
yes. But it's more involved than that be'cause we have to determine if
it's adequate. You know, that's probably the bigger hurdle for us. It's
a little easier to determine whether or not you're actually complying with
your plan. Are you doing it twice a day or whatever the frequency is.
That's easy for us to determine. the bigger hurdle for both you and us
is, is it an adequate plan? And that's not that an easy a thing to do up
front. ,
MR. (Audience--?) : Since the WAP, this scenario was included
in.the permit, is it fair to assume that EPA then believes the waste
analysis plan is adequate?
MR. GIGLIELLO: In most -cases you would presume that to be the
case. Let me .just tell you a real practical problem. Host permit writers
do not go to the facilities. It's a reality. I've seen it happen a
number of times and what we have found'in a number of cases is what's in
the permit is not what's in the field. In that situation I cannot tell
you exactly if that's incorporated verbatim into .the permit and its never
been seen, that you will be in compliance. If there's something out there
going on that is not reflected in the waste analysis plan, it should be
reflected in the waste analysis plan, then, you know, all bets ate off.
But technically, you're right. If we approve it, and it's as it exists
in the field and you're complying with it, then you're right, you'd be in
compliance.
MR. DOMBROWSKI: ' Keeping with the schedule; I'm going to go
ahead and introduce Mark Mercer from the Office of Solid Waste. He's an
environmental engineer in PSPD, Permits and States Programs Division.
He'll be talking about monitoring requirements..
Monitoring Requirements t Automatic Waste Feed Cut-Off
MR. MERCER: In this section we will be discussing the monitor-
ing requirements in the BIF rule. BIF rules set forth numerous monitoring
requirements to describe what needs to be monitored and how the equipment
should be calibrated. The monitoring standards are discussed in 266.102
and 266.103. The subject we will be talking about is monitoring feed rate
and production rate. The feed rate is required to insure that materials
fed to the device during routine use is less than during the COC or the
trial burn and the production rate is required to insure that the devise
is not being operated outside the envelope established during the
Compliance test and trial burn. So'if the normal actual operation is ten
times that of what is set in the trialr burn', then it is clear that the
trail burn wouldn't be valid. These monitors assure EPA that the device
is operated within the envelope, they-need to be accurate and that's why
we have these provisions. To show the accuracy, EPA has validation
requirements that vary from device to device. This section discusses some
of those validation requirements and directs facilities to the re'source
documents that provide specific details. ' Another issue is temperature of
the gas going into the air pollution control device. This is done in the-
existing rule to insure that the mix between gaseous and particulaLe
metals is the same during the Compliance test and trial burn as it is
during actual operation: In the new strategy, we'll be getting into
temperature in terms of dioxin but that's another issue. The idea heie
is you don't want to have more metals going out and not being caught by
the particulate control device. This section discusses the need £or one
or two ranges. A number of these requirements are discussed in various
points in the reg. I won't read the individual citations here. Ay you
can see there's a number of citations that are included in youi handout
for, future reference. ........_..' __...:. .. .: ,
The first question is, can surrogates be use-<; th.it
is fed coal by a system that feeds multiple boilers. -Ketch >jiu- is. nut
Page 6
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i- r.ui /.], i..nly I IIP tot .il foed to all of the boilers. Does he need to add
1 !"; Mp.il.if I iI. y In monitoi the fnpd-.rate to each boiler? He currently has
1 h" op.ibi 1 it y to monitor to the steam ' production in each boiler
:-'.-pii n_r.|y._ (;aii 'he ur.e tlie nteam production rate as a surrogate for coal
-I ">) t.itc:' T|IP answer is no. We are requiring that he must" know how much
''il i : MO ing in and in particular 'the feed rate is more critical than
pii,.|ii.-t imi rat p and the'rule does not allow surrogates for this important
P--II .IMK-I or. Fofd rate is done to support the knowledge of metal feed going
.i nl <> I h" fari 1 j't.y.
In, the case of production rate, the question is, can surrogates
.bo uf!fd for monitoring production rate? In particular, can a facility use
monitoring of feed rate in lieu of monitoring producti-on rate? The.
"xample is, a facility wants to use input of fuel (mass, knowing BtU
content of fuel) in lieu, of steam production rate. .Kind of the same idea
as the feed rate but the answer Is different. The regulations allow you
1" do it. The regulation 'allows-the use cf surrogate for production rate.
The section 4.2.3 of the federa'l implementation document for the Boiler
Industrial Furnace Regulations states, depending on the facility on their
measurement capabilities, the appropriate units for measuring production
ia£e may be represented as the raw materials 'feed rate, thermal input or
production rate. Here we've provided a little more latitude. We just
want to make sure that the machine's not running at a much greater
capacity than it was during the Compliance test or trial burn and this is
considered sufficient and accurate whereas for the metals feed rate, we
wanted be make sure that not too much metal was coming out.
The next question is on. validation of monitors. What procedures
are acceptable to EPA to ..validate the waste f eed . f low meter, the
temperature monitoring device, the .production rate monitor, strip current
recorder-output, computerized recording systems to demonstrate compliance .
with BIF limits.. The answer is, facilities should use the guidance
provided for incinerators in the document handbook, quality assurance,
quality control procedure for Hazardous waste incinerators. Although this
document is written for incinerators,it is applicable to BIF also in this
situation.. This document provides guidance-on arriving at requirements
between the permit writer and the facility. And that's the way your
permit's supposed to work. Now, on an interim status, we have a question.
In some cases the language is not specific enough so on an interim status
to use without ambiguity. In these cases, the facility should use a good
faith effort to interpret the language. The facility should proceed
according to their interpretation. If a facility is uncertain as to what
to do, they should consult their State or Regional enforcement personnel.
They should also document the rationale for their determinations with
subsequent review by inspectors..
Another issue was single .range or dual range CO monitors. The
question was can a facility calibrate a single range rather than a dual
range. The answer is yes. A dual range is not .actually required by the
nile. "Technically. 266 Appendix 9 2.1.4, performance and equipment
specification states, the dual range specifications can be met by using
one analyzer for each range; a' dual range unit or a single measurement
range unit are capable of meeting both specifications within a single
unit. The Catch 22 id; it has to be as accurate. As long as the 3,000
parts per million range unit can show a calibration of less then 10 parts'
per million .3%, the single range unit can be use. Most people will find
the dual range unit to be more practical. . " '
The fourth question was on applicability of the maximum
temperature limit on air pollution control inlet gas. Now these questions
will respond to the current rule and in the new strategy, the answers are
a little bit different. The question is why does 266.103(c)(1)(A) require
max temperature limit entering an ESP? The ESP power and inlet flow rate
are* specified as key parameters of ESP performance. EPA seems to be
concerned that the temperature entered in the ESP not exceed 450 degrees
Fahrenheit, to avoid dioxin formation. Why not just set the cut off limit
at 4-50? Well, the temperature limit was meant to control metal removal
efficiencies. ESP'-s remove particul,ate but not gaseous metals and the
same is true for"baghouses. ' The relative proportion of particulate metals
to gaseous metals was present during the task should also be maintained
during toutiue upeialions. The questioner was perhaps thinking about the
new strategy where.we're concerned about dioxin formation and worried
abo.ut dioxin formation in the air pollution control devices.
Hot vs.' Cold Hydrocarbon Monitoring
If facility can demonstrate a consistent correlation between hot
and cold readings, can adjusted cold readings be used? No, hot
hydrocarbon units must be used only after recertification.
We were told early on by vendors that hot hydrocarbon units are
not very reliable in the field. We definitely heard early on that there
were troubles with these units and it turns out most of the people were
able to get their devices up and running. The few facilities-that were
having trouble getting devices-up and running had like 340 parts of
million hydrocarbons and those hydrocarbons even with the heated line were
gunking out in the line and plugging the flow and this has given them
trouble. . ;
... '-''
* * ^
What is the purpose in keeping the one minute averages for Oj
after the corrected CO has been calculated?
MS. Chow: ' . Actually, we're going to address that later on when
we talk about record keeping. I don't have my paperwork here in front of
me, but there is a citation ... the regulation requires that the facility
to monitor the CO and 02 and the hourly rolling average and then further
down in the regulation it refers back to Appendix 9. And if you go
Appendix 9, in Section.2.1.2.1, I finally remember it correctly, 'it does
refer again back, to the continuous monitoring requirements. If you look
at the definition for that, you have to monitor every 15 seconds and
record and compute the average and record every 60 seconds. OK? So, you
should do it. But we're going to clarify that a little later on when we
talk about record keeping.
I think the purpose of requiring record keeping for each one
minute, what amounts to one minute.average, is to allow the inspectors
when they come out' there to insure compliance with the regulation. ,
Page 7
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MR. MERGER: Are the BIF regulated metals the only concern for
the ash as particulate? If so. why does not RCRA regulate only metals?
Hoc, aay sodium chloride.
MS. SASSEVILLE: Hell, there's also a concern about organics
that might be absorbed onto the particulate matter, so that's the second
reason that we're concerned under RCRA with particulate.
MR. MERCER: Metals and the temperature
particulates are important for other reasons.
limit but still
MR. HOLLOWAY: Is the question ... is part of .the question if
we're controlling the metals not feed rate limits? Why we're also
limiting PM, particular matter. Was that part of the questions? If so,
I guess there are two reasons we want to limit PM. One is. the answer that
Spnya gave about concern about volatilized organics and the other is we,
at least, currently, and maybe for an extended period in the future, we
don't feel we really have an adequate means of controlling metals feed
rates into these devices. We all know that the sampling analysis scheme
we're using and assuming based on testing, albeit testing, how much of the
metals are going to partition and the chlorine for that 'matter, is a
pretty crude method of complying with division standards. So we're using
PM also ... a PM J.lmit also as a supplement to contro.l the toxic metals,
>
MR. MERCER: Next question is what is the reasonable amount of
time the agency allows to fine tune the calibration of a. CEM unit before
the burning of waste fuel must be stopped?
MR. HOLLOWAY: Again, I'm not a CEM expert, but it seems logical
that before you can burn hazardous waste, your CEM has to meet our
performance specifications, so you need to fine tune it, before you start.
That may mean complying with performance specs before you burn the
hazardous waste. .
_ (comments inaudible)
MR. HOLLOWAY: . What's the question again? I'm not sure of the
question? No, excuse me, their question which sounded a -little different
and may be more interesting.
QUESTION: ' You've already gotten up and' proved that your system
worked and then you have to do your daily calibrations and maybe they're
asking how Idng can you be down for daily calibrations when you' have to
send off a feed sample.
MR. HOLLOWAY,: - I understand the question, not sure of the
answer, maybe somebody else does.
MR. - . - -. . .-.- The question is do you, can you continue
burning hazardous waste while you're calibrating your monitor on a
daily basis, under the daily calibration -requirement. Can you continue
burning hazardous waste while you're calibrating. That's the question.
'
about this. I don't think that there's anything specific in the
regulations. Basically the answer is that you can continue operating
during the daily calibration if it's short-. If it gets into ... I mean
we've heard.people talking about an hour or whatever and that's not
acceptable. It has to be, you know, on the order of minutes. I think we
may have had some discussions that got a little bit more specific.
MR. MERCER: If it's more than several minutes, then you
probably ought to check with the state and the Region to see if they think
it's appropriate.
MS. SASSEVILLE: I mean is that-reasonable. In your daily
practice, do you find that your calibration is much longer than a few
minutes? How long?
MR. HOLLOWAY: That's a good point. The answer was that it-can
typically take 20 to 30 minutes to calibrate.. What kind of monitors, CO
or ... all of them? That's a good point.
MR. MERCER: Will extrapolation of ash operating limits be
allowed in certain circumstances (i.e., non-detection levels)?
MR. HOLLOWAY: I guess the question might be if during the
compliance test they had non-detect levels of ash and complied with the
PM limit, can they then, if they do have the detectible lev.el of ash can
they extrapolate it and say by ... if extrapolated, then document by I
guess straight line extrapolation t.hat they, should not be in compliance
with the PM limit. I think our policy on extrapolation of ' feed rate
limits beyond which you demonstrated during a compliance test is generally
not recommended. So no.
MR. MERCER: This question is on calibration gases for CEMs.
If you protocol one gas as have to tie used for daily calibrations,
quarterly air testing and annual, spec testing?
MR. HOLLOWAY: I'm not sure I understand the question. There's
certainly something we can't answer here.
MR. MERCER: Do you need to protocol one gas?
MR. HOLLOWAY: I don't know; '
MS. SASSEVILLE: How many more 'questions do you have, Maik?
-MR. MERCER: Five. '
MS. SASSEVILLE: OK. Why don't we ... can we go ahead and Id.
Dwight 'finish his discussion and then it we have time before lunch we'll
come back to these questions.- " ._.... ,.._ .. . . _ ...
MR. MERCER: Remember the "question^ that came up on the sailijr-n
of automatic waste feed cutoffs?' Dwight will be covering vh,it in in:;
discussion and I give you Dwight Hlustick.
'MS. SASSEVILLE:
I know that we have had some discussions
Page 8
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Am r.ni.it ic Waste'Feed 'Cut-Off
Ml' IIMIKTirK: I think it's' unfair to already have six questions.
!- I r.m qnl to give the preKontation . Mainly what I'm going to cover
i,- in tjio automatic waste fee'd cut of £ issue and other issues.
.i.:i.ii r-l with it. - Of course, the permit standards are in
. IIP,- (K) (7) (i i) and, those standards which are parallelled in the
Mint' ntatus standards. We'll .get - into that in a second. The
iiif:! ion temperature must, be maintained while waste is in the combustion
. Kxlmiifjt-. gar, must be ducted to the air pollution control device as
,-tn there's hazardous waste in the combustion chamber and specific
mr>l.pi s must be monitored as long as there's waste in the system. And
ho case of BI,Fs, that would be specified in 'the permit what those
niPters .are. These are the monitoring requirements under
Hi? (e) (8).. That's where they're specified in that rule.'
unit
|viij.
in
-The main thing is the testing of the waste feed cut-off system.
-if7 mufit: be doiie every .seven days but there is a waiver .. You ' d have to
justify. jt in the event of an inspection except in the case of a permit.
It would be. specif ically stated in the permit whether 'you have a thir(ty-
day interval (instead of seven days),. That's not the case during interim
status. Interim status of course is addressed in 266 103 . The first
items here are in (b)(3) which addresses the certification of precompl-
iance, but all of you should have past that by now.
Then 2.66 . 103 (c) (1) addre.ss.es certification- of compliance.
266 . 103 (g'l (8) addresses automatic waste feed cut off and the first item
is a minimum combustion temperature. As specified, you must maintain the
minimum combustion temperature as specified in the COC (Certification of
Compliance) while hazardous waste remains in the combustion chamber after
a waste feed cut off. Some of the operating parameters specified include
the feed fates of the waste and the specified waste constituents, the flue
gas CO and HC concentrations, maximum .production1 rate, maximum Combustion
chamber temperature,, as- well as the minimum combustion chamber
temperature. Maximum flue gas temperature to the air pollution control
device and specif ic .operating parameters specified for the air -pollution
control device must also be 'maintained.
An important item here- is that the minimum combustion chamber
temperature must be maintained as long as there's hazardous waste in the
combustion chamber after a cut. off, and that's true for all those other
parameters that I mentioned. That is you have to meet, the requirements,
t.he operating requirements. For liquid injection in boilers we would
expect that th'ere would only be a few seconds that the hazardous waste -
could actually be in the combustion chamber after the waste feed cut off.
So, that would not. be a problem unless you .plan to restart "burning
hazardous waste within the next hour. This is because you have to measure
and maintain the hourly rolling average. For other devices we expect this
to be much longer. Especially in the case of cement kiln where it could
run into hours! -The hazardous waste residence time should be specified
in the COC. The' method of determination should also be specified and this
is especially true for devices that burn solids or have some type of long,
hold time in the system.
It also requires that you monitor combustion chamber temperature,
not only just for routine cut offs but anytime you have an automatic waste
feed cut-off. Especially true if you're going to restart within the next
hour. In other words, you're not cutting-off the waste feed for a long
period of time but you're planning to restart once you come back into
compliance with whatever parameter you're controlling or required to
control. There may or may not be a violation if there's an automatic
waste feed cut. off. That depends on-whether you violate you-r operating
requirements or not. The monitoring applies to all operating parameters
as specified in 266.103(g) U) and (2). These monitoring requirements will
lapse if hazardous waste burning is ceased for an extended period.
Therefore, greater than one hour. In other words, if you're not going to
restart, you'shouldn't have a problem if you stop monitoring.
All parameters must be monitored and be within required "limits
before hazardous waste can restart and that's specified in 266 ,103(c)(1).
There ^was a question about waste down stream of the cut off valve, when
you cut off and then there's still waste that can trickle into the system
by just, you know, gravity or whatever. We felt this could be minimized
by heating the line, and/or recirculating the waste back to the feed tanks.
Variance from operating conditions during automatic feed cut offs are not
allowed by existing interim status regulations and we discussed this quite
a bit with the Regi.on.s and that's the way they would like to keep it'. If
the device exceeds its operating parameters while wastes are dribbling or
leaking into the combustion chamber, this is generally considered a
violation. The operating condition of course is defined by the COC.
Here we get into the testing of the automatic waste feed, cut off
system and that's set forth in 266.103 (j.) (3) . Requirements are generally
the same as for a permitted facility. During interim status, EPA will
allpw the use of mechanical and electronic testing and you're allowed in
some permits to demonstrate all the interlocks electronically save one.
OK. Now one has to be done mechanically and you have to actually activate
the shut,off value and that's basically parallel with whafr's in the permit
requirements and it-stated pretty much that way in th'osfe regulations. The
hitch is that each time you do a mechanical test;, it ha"s'to be done on. a
different parameter.. . In other words, you can't do the same parameter each
week or month, depending on what the situation in your facility. So you
have to shift around from one parameter to another. This demonstration
is not required if there was an automatic waste feed cut off since the
previous demonstration. And it's- important to show the valve closed
completely.
Here .we're getting into an area which is of concern both in
boilers and in any other type of device and that is when the facility
stops burning hazardous waste over extended periods. Again I- restate that
we have to meet the hazardous waste monitoring requirements, as long as
there is hazard waste in the combustion chamber. The question here comes
with respect to residues. That is 'how residues should be handled
especially if you're going to cease burning over a long extended period
of time. Residues are- still considered hazardous waste until the device
has completed a burn out period of at least twenty-four hours. Now this
is not in the regulations, but this is guideline generally followed by the
Regions, and assumes that there's no .-hazardous waste burned during the
Page 9
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burn out period and the residuals have a reasonably abort residence ti»e.
That is routine residuals that you remove from the air pollution control
devices ... the aah or the dust ... residuals with longer residence times
require longer burn out periods and therefore, the burn out period must
be longer than the residence time of any residual. Burn out period only
applies to residuals routinely discharged. This- excludes residuals
adhering to the inside of the device and the air pollution control system.
Residues such as those which are removed during maintenance such as
scrapings are still considered hazardous waste. This is just to tell you
it's not detailed in the rules other than ... I mean the only thing you
could go by is rules for clean closure which we weren't going to require
that for a short term ... when I say relatively short term compared to
closure. This policy is generally being followed by the Regions riqht
now. ' ..
This last item with regards to automatic, waste feed cut-off
testing we added was a specific item in another presentation. I think we
already answered that. But you have to do the test. Now there is a seven
day requirement in the regulations that allow .us to go into a thirty day,
if it creates an undue burden for the facility. If you'do go to a thirty
day status under interim status, you had better document that very well
so that it doesn't create a problem as far as an inspector is concerned.
So you have to have a gobd reason for it. That completes what I have to
say. I already"have a half a dozen questions although I think I've
answered most qf them.along the way. We'll see if I "have.
When the BIF is not burning hazardous waste, can one turn off CEM
and automatic cut-off devices? I think we covered that. As long as there
is no hazardous waste in the combustion chamber. What'about when one BIF
unit is only burning non-hazardous waste and another one is burning
hazardous waste. Well, obviously, the one is pot burning hazardous waste
wouldn't have to do the monitoring if it didn't have any hazardous waste
in the combustion chamber. It's obvious the other one does, they would
have to monitor.
Does a liquid need to be cut off when you have redundant CEM and
one is calibrating and the other shows a calibration out of range? That's
a good question, "
(
MR. HOLLOWAY: Could you repeat that?
MR. HLUSTICK: Does the liquid need to be'cut off when you have
redundant CEM and one is calibrating and the other shows a calibration but
of range? I think that sort of holds to what you said before. It depends
on the time frame we're talking about and I think Bob answered that before
as best as we can.
if
The next one is, how quickly does the feed valve need to be closed
a BIF.limit is exceeded? I'd say as quickly ,as possible
MS. SASSEVILLE: it's not a staged thing. As soon as the
parameter reaches the limit, it has to activate and that's why the
automatic waste feed is cut off. It's important. It's not a manual cut
off, it's ... you know, you should have a signal that's sent to the cut
off trigger to cut off the waste as soon aa the equipwent detects
exceedances. That's the whole idea..
MR. HOLLOWLY: It's automatic and immediate. Fast.
MR. HLUSTICK: What is expected from the seven day waste streara
cut off test and the thirty day cut off test? Can a thirty day cut off
test be done on a monthly basis? The rule says thirty days.
MS.Sasseville: Well, let's stick with the thirty days
if it's set thirty days
I mean
MR. HLUSTICK: That's ... buf what is expected from a seven day
stream cut off as compared to the thirty day? I think they're both
expected to be the same. Just one's an alternative to the other.
MR. HLUSTICK: What does instantaneously mean in terms of cut
off of hazardous waste flow? Some systems cannot shut off instantaneously
without creating safety problems for operations of BIF. Well, that can
be a problem, and I would say, you know, that you should try and set up
your cut off so you minimize the potential of having a violation of your
operating requirements.
MR.HOLLOWAY: And more importantly, if you believe that you
cannot cut your waste feed off quickly, then you should have already
talked to the state or the Region to apprise them of your situation and
gotten approval to do something different, it's kind of late three years
after the rule has been promulgated to be asking this question. The
regulation requires the wastes be automatically cut-off, and the Agency
has always intended this to be done as soon as detection of exceedance is
made. Otherwise, this whole waste feed cut-off effort has little meaning.
MR. HLUSTICK: You now saytburn out requires dt least twenty-
four hours. Is that new information? Yes. As far as EPA Headquarters-
is concerned; not as far as the Regions are concerned. The Regions have
been doing this for sometime. If a device like a CO monitor or
feed rate monitor fails, hazardous waste feed stops. Does this 'mean that
the boiler must be shut down? If so, how can you finish burn out?
MR. HOLLOWAY: , If you're exceeding an operating parameter, then
only the hazardous waste must be immediately cut off. The boiler can'i
continue burning hazardous wastes. Otherwise, it may be a violation of'
266.103(c) (1) and 266.103
-------
li-"!1 > <' . HOU.OWAY: I think your response might be that you should
t him- t.o op'Mfite without feeding hazardous .waste but keep burning
but you're going to be out of compliance with the
.in:-: i I i .11 y file 1
i r"in I .it i iiti.
Ml',-HLUSTICK: OK. Must, the cut-off be instantaneous or can
liiol be rammed out over, a definite period .of time to prevent boiler
or shut down? Well, it could be as long as you don't violate your
"pci'.Tt.inq requirements. "But, you know, in other words you could have an
viiljfM rut off 'before you get to the limits. That would be the only way
you c'.mld do i t.
MR. HOLLOWAY: If'you'1 re speaking of voluntary waste feed 'shut
cl^wn, thriri-obviously you can either do that immediately .or as slow as you
MR. HLUSTICK:. The second-item is a good one. State inspectors
USP the 'terms lag time and length of cut off. Please define and discuss
the significance. I think you should ask them what they mean by that.
(laughter) Then we have a nice fun one here. 'What location is preferable
to measure the combustion chamber temperature ? I'd say as close to the
-combustion chamber as you"can.
MR. HOLLOWAY:
Sounds site-specific to me.
MR.-HLJJSTICK: Yeah. But I mean we realize there's limitations
on temperature. During an automatic waste feed cut off test, how do you
nho.w that the valve has closed completely? -This assumes that the
automatic waste feed cut off valve is tested only when there is no
hazardous waste flow. I think that's pretty much site specific and you're
going to have to address that in the COC on how you're doing that.
MR. HOLLOWAY: And since they've already submitted their COCs,
I guess if you didn't address this issue then you probably ought to submit
a supplement to your COC explaining this issue and others that you might
hear today.!
MR. HLUSTICK: Then we have the $64,000 question. What is an
undue burden for the seven to thirty day extension?
.MR. HOLLOWAY: 'Site specific. -
.MR. HLUSTICK: Bob s"ays site specific., (laughter) :
'(comments/laughter)
/~ '"
Residues which are removed during maintenance are hazardous waste.
t)o you mean if the BIF was burning listed waste, characteristic waste
would not leave a hazardous derived from waste? Well, if that's the case,
if you're that lucky to have that situation. Fine.
-. MS. SASSEVILLE: Provided that they sampled and the analyses
show that the residues no.longer have the characteristic.
MR. HLUSTICK: Right. Must the valve be physically closed even
if waste stream ... I.can't read ... is impossible. -.Is that what it
means? You know who wrote this one? I can't really quite make it out.
Excuse me? >.
(comments inaudible)
MR. : Must valve be physically closed even if the
waste stream is bypassed? Regulators have stated that the valve must be
closed and show that no waste .As .leaking through valve yet guidance
suggests using bypass so unit won't shut down. How do you show valve was
closed completely? . -
\ --- MR...HLUSTICK.S. That's a good one. - ' -' - -
MR. HOLLOWAY: I don't understand the question.
MR. HLUSTICK: . Well, I think he is bypassing it around the valve
and therefore you can't show the valve is closed completely, is that what
you're saying? ' '
MR. : In one of the guidance documents there's a
statement that in case of (inaudible) you can put a bypass around the
valve so that you can'continue your waste stream- feed without shutting
down the boiler (inaudible) without shutting down your unit completely.
about?
MS. SASSEVILLE: Do we know what document is that we're talking
MS. SASSEVILLE: Is this a BIF implementation document?
MR. :' . Right. It's a guide (inaudible*) *..
*
, MS. SASSEVILLE: , Are you saying that the way that is
recommended in -there you really wouldn't be able to show that the valve
is closed? ' . '
MS. CHOW: As Dwlght said earlier, you can simulate for all but
one. You'should at least test one every seven days and you should test
a different parameter every time. When you're testing, you can't have a
bypass if your're trying to determine whether it's leaking or not>
Otherwise, it just doesn't make sense at all.
MS. SASSEVILLE: Yeah, otherwise it just wouldn't work. And
considering that it' is only one parameter every time, they just have to
shut off the waste feed to So it. - ' .
MR. HLUSTICK: OK. Let's try this one here. Where and how do
we measure combustion temperature in a boiler? Do we want to see the
outlet gas temperature or the flame temperature? I think what you're
looking at is a situation where you should be able to correlate the outlet
Page 11
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temperature with the flawe tenperature and ...
MS. SASSEVILLEs I thought that usually ... was that for the
combustion chamber temperature? Because usually, we always talk about in
guidance that you should avoid measuring the flame temperature generally
for things like ORE. Hhat we want is the gas temperature.. What we're
talking about in the BIF rule though is for metals and ideally what it
would be is the bed temperature because that's- what relates to the
volatilization of metals. So, that's what you want to shoot for. We know
there are problems with it, but it's not the flame temperature or the gas
temperature that you're shooting for. It's more the bed temperature
because we're concerned with metals and we're talking about the maximum
temperature.
MR. HOLLOWAY: And with respect to the minimum temperature, of
course, it would be the gas temperature, still not the flame temperature.
MR. HLUSTICK: Yeah. It's a little difficult to measure the
flame temperature. I have heard repeatedly from the Regions in the
context, of Part B, questions on how this will' likely work in the
development of permit conditions. What mechanism is'there to work it out
with the Regions^u^ing the interim status? Do you just,discuss it and
document it with.the Regions, send the Regions a letter, reach a formal
agreement signed.-by both EPA and operator, or what? Regions are often too
busy to give written documentation and interpretations with respect to
.these issues. I think you've covered all the possibilities and you .should
try and get the best you can. ' Obviously, written is the best.
MS. SASSEVILLE: And the key thing is if'nothing else, to
have documentation at the facility so that when EPA people come on site
at least you have a rationale for everything'that you did.
MR. HLUSTICK: This one is a misunderstanding but OK, we'll read
it off. If a required monitor fails, you stated that you must not operate
the unit. Later you state that all controls must be'in place for twenty-
'four hours after.the hazard waste feed stops. The monitor fails and you
stop hazardous waste feed immediately. Are" you allowed some period'of
time to shut down the boiler in order to do it without equipment damage
or is there a non-compliance situation? The twenty-four hour time as I
Stated-before has to do with the residual. -It does not have to do with
the monitor. The monitoring is strictly a function ... of the residence
time of the hazardous waste in the combustion device. -Here is another
question. Many cases, when CO levels-are rising above the standard, the
total instantaneous closure of the automatic waste feed cut off will cause
a much more catastrophic upset than a control cascading closure, e.g.,15%
every ten seconds. This has been discussed with .-some Regions but will
headquarters prefer specific guidance or give specific guidance . '. . I
don't know what, that meant,.. . . . . . _ .-.
. MS. SASSEVILLE: It sounds like this is the question again
whether people can ramp down as opposed 'to having an immediate cut off.
I mean, I guess we already answered that. -
HR. HOLLOHAY: And if you're concerned about the interruption
to a facility of abruptly cutting o£f automatic waate feed then you can
certainly establish a trigger level that's much lower than the automatic
waste feed cut off than your operating limits. So that once you reach
that trigger level, then you can ramp down in a way that you think is
appropriate for your system.
MS. SASSEVILLE: And a lot of these things are questions that
were brought up during the process of developing the BIF rule and we've
had a lot of discussions with people on this and discussed it in the
preamble so these are things that were considered at the time the rule was
being developed.
MS. CHOW: Actually one point I want to make about setting your
cut off trigger at the operating limit. I recommend that facilities do
not set their operating limit the same as the permit limit. Otherwise,
every time when you have a cut off, you would probably exceeded your
limit. so, then every cut off now could become a violation. So 1
recommend that you actually set your cut off trigger conservatively at a
level that will cut off the feed before you violate the operating limits
MS. SASSEVILLE: I guess another comment-that's worth making
is when "we' do inspections, I think, Ken Gigliello earlier referred to the
EPA/OSHA task force from several years ago and one of the things that they
found out when they inspected all of the commercial incinerators and all
of the interim status incinerators was that there were really high numbers
of automatic waste feed cut offs. I don't know what the situation is for
BIFs, but something to keep in mind if you do have .concerns with, ramming
down and all these issues is that most important thing is to just to try
to prevent the cut offs in the first place. And it actually may .be more
practical for a BIF than it would be for an incinerator since you do have
other streams going in that tend to even things out. But it's really
important to make sure that you're blending things well before they go in.
That you're not having spikes in the BTU content of materials going in
'because all of those things detract from steady state operation and that's
when you get cut offs and that's whdn you have combustion problems. So
it really pays to think about these things ahead of time and kind of adopt
a preventive mode as opposed to worrying about the cut offs after the
fact.
MR. HLUSTICK: . Here's one for you, Sonya. . ' '
(comment inaudible)
MS. SASSEVILLE: That's right. Another good point is Lhdt then-
is an allowance for variability directly incorporated into the way we set
limits because they are on a rolling average basis. So that does u-nd to
damp out things and that was the purpose of setting it up that way.
MR. HLUSTICK: 'Here's an item for you, Sonya, though'. I:; i In;
agency planning to limit the number of waste feed cut of fa and why?
MS. SASSEVILLE: "' OK.
that the waste we cut off is
That is in the BIF rule it sell ami it :i iy:
. well,-that you.have to be. in .-.,iii|. I i an,-,
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l"'1'
'ii:
"IK
I' I ' HMO;-. I li.-u 'il^ir-'H w^r.te in the unit. So if the waste feed cuts
-iii-l ilmn t hole's lio.fxcfedence while waste remains in the unit, which
ifl. imf.-., then that's not necessarily a problem. The main
liPip'n a cut off but whatever parameters that reached its
1 lr! nl ' ! '. pxr.-pedirjq. while there's waste in the unit, then that is
irli. i f.fl a violation and that's in the BIF rule. We talked also in the
mlr- ,md in its preamble about the rolling average limits and things
liko rout i in ions monitoring after the cut off -occurs. Those are all meant
,t"-br
-------
KR. HLUSTICK: If you can't read Che values, you've got to cut
o££ the waste. Because you can't determine your hourly rolling average.
KR. HOLLOHAY-. Hell, the approach that we contemplated when we
wrote the regulation is that when you exceed your maximum span value, then
you're still Monitoring CO. You're cutting the tip off the spike. The
spike may go all the way up to ... the CO spike might go all the way up
to, well, who knows? 5,000 to 6,000. But if your span only goes to
3,000, you're still measuring. You're just pegging it at 3,000 so you're
not catching all of the spike but at least you're measuring something.
That's what we had contemplated. I hadn't heard that any Regions were
doing something, different.
(question inaudible)
MR. HOLLOWAY: You should really talk to the Region how to deal
with that because I'm not aware ... wasn't aware of this situation.
MR. HLUSTICK: Here's a good one. 266.109, 266.110 allows for
BIF units operating under certain conditions be considered as satisfying
a low risk waste and ORE waiver requirements for units operating in this
manner. Does- the weekly automatic waste feed cut-off procedure still have
to test for minimum combustion temperature?
MR. H9LLOWAY: Is the situation the facility is exempt from
a ORE requirement:? They're exempt from a ORE requirement so why do they
... so is it necessary for them to establish a minimum temperature during
... that would apply during the waste feed cut off? And the answer would
be yes because they're certainly different combustion conditions can occur
during after the waste feed cut off, i.e., lousy, conditions can occur than
the waiver of the ORE contemplated. ORE will be waived when we think
there is no toxic organics. present or when the operations were such that
we were sure ORE would be attained even without a test. So, in the case
of a low risk waste, as I was saying, now I thought of another is'sue. In
the case of a low risk waste, I guess the point is that the waste itself
-would have minimum levels of toxic organic constituents but you can still
get PICs produced from ... during a waste feed cut off, You can still
have PICs produced from the incomplete combustion of non-hazardous "non-
toxic organics". ' SO the bottom line is yes, you still need to monitor and
establish a minimum temperature even though you're complying with the ...
even though you're eligible for ORE waiver.
MR. HLUSTICK: .OK. The nextone is does this twenty-four hour
burn out apply to liquid feed only BIFs where there is no ash generated?
I would say yes, but also, it doesn't matter because the-twenty-four burn
out only applies to routinely generated residuals. And if you're not
generating any, it wouldn't matter.
This is a good one. Somebody wants a list of speakers and
their phone numbers, (laughter)
: MS. CHOW: I can give Cindy Bryck's number.
MR. HLUSTICK: For tier one or adjusted tier one assuming all
(metals)/in equals all (metals) out (the stack). Therefore, why would
combustion temperature make a difference in compliance? I think we just
answered this one, didn't we?
MR. HOLLOWAY: That's a good question. I think. The question
was ... I.believe the question was, you're complying with tier one or
adjusted tier one for metals. Do you have to tnonitor temperature? You
have to establish a temperature limit and comply with it. You would not
need to establish a maximum temperature, but you still would need to
establish a minimum temperature that applies during the waste feed cut off
because the max deal with metals and the min. deals witli PICs.
MS. CHOW: OK., I guess that's all the questions. It is time
for our lunch break and let's reconvene at-1:45. (AFTERNOON SESSION)
Owner/Operator Inspections
MS. ANDERSON: We're going to start off this afternoon with
something that I think is pretty straightforward. From the information,
you submitted to us, you asked for a basic overview on what
owner/operators are required to do in terms of inspections at your>
facilities. So, I've put together .'a few slides covering these
requirements. One of the areas that we found the most violations "in is
the written inspection schedule requirement that's in 265.15. Primarily,
the violation is that facilities don't_have this type of written
inspection schedule. In the BIF regulations, you're required to comply
with a lot-of general facility standards that all TSDFs are required .to
comply with and this is one of the basic ones. So, it's important that
you-, as a facility owner/operator, have something written down and
actually take some time to look at .all_ your equipment--your safety
equipment, any emergency equipment, other equipment that you think is
important in preventing or responding to releases of hazardous
constituents. That type of equipment has to be inspected on a regular
schedule and you have' to identify in that schedule what problems you
expect to see with that equipment, what type of malfunctions could occur,
what you're looking for when you inspect it. And, again, keep the written-
inspection schedule at the facility and provide it to the inspector when
they come on site. Now, this applies to not only the BIF unit, but any
units that handle hazardous waste at your facility. So, if you have
containers or tanks or surface impoundments in addition to your BIF unit,
those types of units have specific inspection requirements under thai
particular unit's requirements in 265 during interim status and those
types of things have to be put in your written inspection schedule-.
Again, the regulation's intent is to make sure you're inspectimj
for any type of problems with the equipment that can lead to threats 01
releases of hazardous constituents. Generally, when you're deteiiiuniny
the (frequency of your inspections, you .'re looking at what t lie
deterioration rate is; you might use manufacturer's specifications to come
up .with how of ten you think-you have to inspect certain pumps or cei tain-
valves.' And again, certain areas have to be inspected daily, and it 'a
required: in the regulations. Any area that's subject to loadui.j m
unloading where you could have spills, you have to inspect those typt-:; ot
areas on a daily basis. And. if you have any kind of spill, you "ei'.l t ,
clean it up right away. Again, these are pretty stidiqht io.w.n.l
Page 14
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'--in i i ''i"'1!]! ;:
H"w in I hr> BIF regulations, there are a couple of specific
'i !''' i"." i "<|uii oinpnts that: you need to be aware of and one of them is
' /. '-..n-lu"! visual daily inspections of all of your BIF related equipment.
Hi'- l>"i.l"i, .all of the feed lines going into it, any pump and valves, all
i li.ii i yp" (.f equipment has to be inspected'on a daily basis; and you have
i.. k»fp n i prru d of that. -Again, you- also have -to test your automatic
w,i::if I fi>r\ r-ut. off system, which :i think Dwight mentioned earlier. The
minimum ifquiiement in the regulations is to test it once every seven
l.iy."., iinlps.'i you tliink that there is good reason why you can do it less
licqur-tit ly than that, in which case you document in your record why you're
dninq.it lens- frequently than every seven days and that .way it's there to
l>> T.pnt. to the inspectors when they come out to see your facility.
Another important area of violations ... again, it may seem
. junl Like , paperwork violation and pretty inconsequential-,, but the
""TrTspecT.aoiT"log"Ts the only" record" t"ha"t "we" have" "to~~check: to make sure "'
yoti'te doing .these inspections, so it' s ' important to. us that the record
be complete. And that it includes a date and time of your inspection, the
observations that are made and the name of the person who actually does
the inspections. And if there are any repairs. Just to summarize, the
main areas that we find deficiencies in are: lack of any kind of
inspection log or if you're not doing your daily inspections, you haven't
recorded them in your inspection log.- We may go out and see an actual
problem and,:if it's past the time when .you normally would have inspected
it, if that wasn't in your inspection log, that's another indication that
maybe you'-re not doing inspections on the required schedule. Or if you
haven't taken corrective action, and there's a puddle on the ground and
it hasn't been cleaned .up, that may be another indication that you're not,
complying with these inspection requirements. So, again, if you have
questions, please pass them up and we'll take a look at some of your
specific areas of concern. .
Q., Are inspections required on days when hazardous waste is not
burned? A. For BTF-specific inspection requirements in 40 CFR 266.103
(j), the BIF and associated equipment must be visually inspected when they
contain hazardous waste. For the general inspection requirements in 40
CFR 265.15, -the owner/operator is responsible for writing into the
inspection plan how often certain equipment needs to be inspected. The
plan should indicate any changes in the inspection schedule, including
when hazardous waste is not being burned.
Q. And how far upstream of the combustion unit do you inspect?
That is from the point of generation? A. Again, since the regulations
are specific to the kind of units, you would have, for instance, a tank
feeding into the boiler. If carrying hazardous waste, the pipe's from the
tank, the tank itself, the boiler ... all of that is going to be part of
your required inspection. The requirements under' the tank regulations
include inspections of the tank, and ancillary'equipment. You should have
an inspection -schedule for that unit. Technically , the waste is
generated when it. enters the pipe to' be fed to either a tank storage unit
or to be directly fed to the BIF.
Q. For records that !are .maintained by computer, how quickly
must the records be retrieved during an inspection? Example, records feed
rate. If you're keeping your inspection logs on a computerized disc-the
inspection log and the written inspection schedule needs to be available
to the inspector when they go on site so you should be able to retrieve
that information fairly quickly. It's up to the inspector. They may
allow you to. send it in to them if they don't want to see it on the spot,
but it is required that they have -access to it when they go to an.
inspection. I don't think there's''any time frame. .
MR. - GIGLIELLO: I'd be curious, whoever asked this question.
Is there a problem retrieving computer records and if so, what is the
problem that you see because as Kate said, an inspector can, within his
or her own discretion'basically say, OK, you don't have the records here,
send them to me within X number of days.. OK? But if they feel-that they
need that information in order to do their job that day, basically you are
required to produce that record. So, is there anything peculiar about
computer records that are difficult to access_. I _wpuld thinks computer
records would be easier to access. To be perfectly honest. Is there some
unique thing about computer records that' I'm not aware of that makes it
more difficult to access these things. Or are they in a main frame 4,000
miles away that you've got to call up on Saturday afternoon? I mean, what
is the problem? I guess that's the question I'm asking.
(comment from audience inaudible)
You're saying it's a data reduction problem?
(comment from audience inaudible)
Can people hear what she said? Could you just repeat it.
MS. ANDERSON: She said in their'Region they had archives and
data and the inspector allowed them about a week to provide the data to
them after the inspection. So, it sounds like a reasonable approach to
the problem. . ' " ' '
MR. GIGLIELLO: One of.the practical things you can do. I
know some of you probably think some of the inspectors are wild-eyed and
crazy people, but in most cases when the inspector walks in, what they do
is have an opening inspection. I always did, and I explained, this is a
series of things I want to go through to get from you. And one of the
things would be records. If at that point, you know that the inspector
is going to ask for certain records, you may say, look, it's going to take
us some time to get these records, can we mail them to you. Instead of
waiting for that moment when he asks for the records, like five hours
later. Tell him upf.ront that you have a practical problem with getting
this data because it's a 150 mg disc. So that's a real practical thing
-you might want to present with the inspector when they first walk in the
door. If he doesn't say what record's he's .looking-.for, take the
initiative and say, look,, what are you going to need from us, so I can go
to my main frame or go "to my computer people and get the data for you.
Instead of just waiting for him to ask the question. I know some of you
aren't thrilled with the idea of providing, a lot of data, but'it could
help in the long run.
Page 15
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MS. ANDERSON: OK. One laat question here. In the information
collection requests (ICR) dated 10/21/94".on page 134. first bullet, it
otatea that daily inspections are performed each working day. 260 times
a year. Does that wean only Monday through Friday? A. Again, I think
that certain daily inspections are required whenever there's hazardous
waste in the unit and it could be on a seven day a .week schedule for some
facilities. I would think it's every day that the facility's in
operation. Again, one thing you have to remember about the ICR is that
it's an estimate that takes into account the variability from facility to
facility. So you can't really use an ICR estimate as your definite
blueprint for the minimum requirements. Tho.se are estimated time
requirements for a facility to comply with the regulations, but it may not
be the maximum or the minimum. Any other question? OK. Great.
Next, we're going to have a discussion on the air emission
requirements, and Ginger Gotliffe, who's an environmental engineer in the
Training and Guidance Section of the RCRA Enforcement Division is qoina
to lead that discussion. a
Subpart BB Inspections
b
MS. GOTSIFFE: As owners and operators of BIFs, you are most
likely also affected, by this new rule (264/5 Subpart BB) that addresses
equipment leaks. These requirements are nearly identical for both interim
-and permitted facilities, the only difference- is for reporting
requirements. There was a comment about reporting requirements earlier
this morning. This is one of- the rules that does -require a permitted
facility that has these requirements incorporated into their permit to
provide semi-annual reporting of any exceedances. This rule was
promulgated because of Section 3004(n) that was added in the HSWA amend-
ments. This requirement told EPA that we must address air emissions from
TSD facilities. The Agency has done this through a two phased approach
The equipment leak regulation is part of Phase 1. The other part of Phase
1 addresses leaks from process vents. There are only six very specific
types of process vents that are affected, Phase 2 will address, tanks
containers and surface impoundments. Most likely you will be affected by
that phase with the tanks. That is expected to be promulgated later.this
year. The equipment leak rule affects equipment handling organic wastes
Facilities can have hundreds of these pieces of equipment on site
Basically, the rule requires you to monitor, inspect and to repair the
leaks in a timely fashion.' Compliance is demonstrated through your record
keeping requirements. We will discuss 'applicability, waste stream
determination, our various options for controls,' your record keeping
requirements and reporting. And after the summary, we'll go over-the
differences between the rule, for permitted facilities versus interim
status and how permitted facilities that have interim status BIFs can
identify which pieces of equipment must comply with.this rule. The rule
was promulgated in June of 1S90 in Federal Register (June 21,1990) page
25454. Equipment that is in vacuum service is exempt from this regulation
and there are other types of exempt units.,- Production units, waste water
treatment, subtitle D municipal units, domestic sewage systems and closed -
loop reclamation. However, other types of recycling that you might have
on your facility are affected by this rule. These are the fleven types of
equipment that are covered by the jule. Some of these categorieThave
"SS ?h *"lfln*tioM which Hil1' alcer your monitoring frequency and the
values that you are looking for to determine whether your have a leaking
piece of equipment. For example.,, for pumps there are three different
categories: general, no detectable emissions and also a pump that is
outfitted with a dual mechanical seal and a sensor system. Valves also
have different categories including unsafe to monitor and difficult to
monitor. if a valve is located six feet overhead and could put the
inspector into jeopardy, then the facility may go to a yearly inspection
cycle but a written schedule must be written. Also the equipment that is
covered by this rule must, be clearly identified so that when an inspects
either the facility inspector or a regulatory inspector comes through, can
quickly and easily identify equipment as.being covered under this program.
There are several different types of determinations that the
facility must perform on the waste stream in contact with the equipment
These are the organic concentration determination and your fluid state
determination. As mentioned before, the rule only applies to equipment
that is in contact with waste over 10% organics. Initially you will need
to determine which pieces of equipment- will be contacting organic waste
of that concentration. Also you need to determine the fluid state because
that will make a difference in your .monitoring and your inspection
frequency.
For the waste determination of the organic value, you have two
options. Either you can use one of-five different methods specified in the
rule for the direct measurement (basically GC/MS) or you can rely on
knowledge. Knowledge of the process can include when you know that no
organics are used in the process or whether the waste stream is identical
to other processes where you've already conducted direct measurement.
For the fluid state, you need to determine, if you are working
with a gas,.light liquid, or a heavy liquid. The determination here is
quite important because it significantly alters your inspection strategy.
Facilities do have options of how they want to handle tlieit
equipment and the inspections. They can work on the basis of woi k
practice. You can modify the equipment.so that you can get a categoiy Of
no detectible emissions or you can have other equipment modifications and
additions such as adding control devices. The work practices-are based
on a leak detection and repair program. Basically, you do your leak
detection monitoring, using method 21. In some case's it -is jua'i a
physical inspection to see if something' is dripping or if you can detect
by smell that there's a leak. And then the facility has to initiate
repair within five days and complete the repair within fi-fteen Also all
the leaking equipment must be tagged until that equipment is fixed unlt-^j
it is. a valve in which case the - Lag -must remain on the valve ~ioi two
months. . . . ;
Method 21 is basically the use ot a portable oiyamr ju.Uy-,., -...
locate the leaks. For most cases, a leak is-defined as a K-v.-l ,-,,, I '
or. exceeding 10,000 PPm. The ref«ienc.-e compounds a.t- l,-;i,-,l-,n i I--
Page 16
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'vi I, ..], ,,|..;,i I li^ i/vspoiisr factor must be calculated for each compound and
«.Ti--.i l.c (,«..;: | li.in to. Encli facility must determine, based on the organic
li'««i"..-il(: in .yom plant, what type of portable organic analyzer: is
, ii'p'j <-.il.|" I o wlMl you have. MS could work for all compounds. Flame
i -in ;-..!>. ion would work for all compounds. Photo .ionization is better for
.|-|"i,,.-ii j.- '(impound;;-. Klectfolytic conductivity is better for halogenated
' -ni|i. .ini,i,j. _ ,. _
Hopairs rmist begin within five calendar days of determination if
ilvM-'n a-leak. The equipment must be tagged and repair must be completed
within fifteen days.. You 'must document all this -to .demonstrate
omp] fniK-p. You- must identify the date that you determined there was a
\f-nk. When repair starts, what the repair operations'were, who conducted
it, and when it wascompleted.
Another option that you' have for your equipment is to operate
....*;'lUiPro^Dt .that is no,.detectable 'emissions.. .. These^are .cerhain types of
pumps or'.valve's'that, will not-allow .any emissions to leave the unit. You
aqain would use Method 21. However, that is only an annual monitoring
pvp'nt and you are only monitoring for 500 ppm above background. That test
munt -be done initially and again annually.
. The third option that- you have is to add different types, of
controls to your other equipment. For example, you can add dual seals and
sensors.for certain types of pumps and compressors. You can add caps,
-close loop sampling or you can hook, up your system to a control device
tliat is specified under the AA requirements for process vents. Again, you
have the visual inspection for detectable emissions and you,have the same
repair scenario. . .
So, in summary, for the different types of equipment, you can see
that, in different cases you will be testing for different values and you
will be testing different frequencies. If using the work practice method
the facility would conduct monthly monitoring for a leak of 10,000 ppm.
If operating under no detectable emissions, the facility would perform an
annual test for 500 above background. For equipment specifications for
say a pump using dual seals and sensors, then you would base a leak on the
failure of your sensor. Also,- remember the difference between the
different fluid states; for heavy liquids what you're relying on is
physical inspection. This should be done during the weekly walk-through
inspections. If evidence of a leak is found .then within five days the
facility jias to go back with your organic probe (Method 21) to determine
if there is a leak. For valves you can-earn a reduced monitoring schedule
for a well maintained facility'that has few leaks! If you complete two
successive months of determining that there are no leaks in your vajlves,
then you can go to a quarterly monitoring schedule.' There also is another
option for 2% leaking which allows no more than 2% of your valves to leak
at any time, and then you can move to a quarterly schedule.
This slide shows the different choices that you have for pressure
relief devices and flanges. For pressure relief devices, what you have
to do after release, you have five days to do a Method 21 testing and
repair within five days, that's a.slightly different case than all the
others. And again, for the other three types, I think that's pretty
straight forward.
Record keeping. Again, when an inspector is checking on the
facility's compliance they're going to be looking at your records to find
out how often you've found leaks and how quickly you have repaired them.
This is to insure that all the equipment is operating in a safe manner..
Detecting general category leaks is not a violation, but not repairing it
in a timely fashion is. However, exceeding the no detectable emissions
- limit is a violation. '-..' '
General records required. You must have a list in your operating
record of the ID numbers, locations, designation, per-centage of organics
that that equipment is handling as well as the method, of compliance or the
designation. And those are all specified in 264 and 265, section 1064\.
I apologize that all of these slides only say 264. It is section 265 as
well. If you're adding a closed vent system and control devices, your
-operating records-must be kept-based orr 10S4(e). -For equipment thatr's~ not
subject to the monthly leak detection, in other words, for the equipment
that is subject to the annual NDE requirements, you must list those pieces
of equipment. You must list pressure relief devices. The NDE results,
and also list the vacuum'service equipment which was exe.mpt from these
requirements. There's also a requirement under 1064(h) for the valves
that are considered difficult to monitor and unsafe to1 monitor. The
facility must create an inspection plan for those pieces of equipment to
allow yourself a schedule to inspect those pieces of equipment at least
"once a year. . :
Marking of leaking equipment. Tagging is very important, and will
be used by the inspector as he or she is walking through the facility.
Also, information must be kept under 1064(d) to show you conducted your
monitoring, the monitor that was used, the dates that you did the
inspection, the repairs that were made and any repairs that were delayed
and the rationale for why that repair was delayed.
Information must be kept on barrier fluid' systems and also
information for determining exemptions. If you're doing^ test results and
you've determined that a piece of equipment that used to handle hazardous
waste of a concentration to bring it in under this rule and now no longer
does, you must keep records of all test results-for that.
Records retention is for three years for the monitoring of repair
and detectable emissions and all other records must be kept for the life
of the facility. -_,.
I .
Semi annual reports. These are required only for., permitted
facilities. These reports should cover control device exceedances that
were uncorrected for' over a day, pumps in light liquid, valves and gas or
light liquid service and compressors not repaired within fifteen days.
You don't need to file this report if there weren't any exceedances.
In summary, this rule applies to TSDs, handling organic waste
greater than 10%. .Fluid type is very important as well as designation of
the equipment to determine how often you have to conduct your inspections.
i Record keeping is very important to demonstrate compliance.' There are
Page 17'
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different applicability standards depending on the type, o£ the facility.
For interim status, you wist have been in compliance by the effective date
of the rule which was December 1990. For permitted facilities that
received their permit before that date, you are shielded until your permit
is opened by the Agency. However, if the facility itself asks for a
modification to the permit, then BB requirements will be applicable to
that portion of the facility where the modification is taking place. For
a facility or unit newly subject to RCRA because' of a new listing or a
newly identified waste, BB must be adhered to six months after the
effective date of that listing. -For newly constructed facility or unit,
it would be on the opening day and also for a un'it newly subject to air
standards, it would also be on the day of start up. I think that there
have been some questions about a permitted.facility that is shielded which
now operates a BIF in interim status. And how to determine whether the
equipment that's going from a permitted tank into .an interim status BIF
should be classified. Basically, the equipment is exempt from those
requirements if the permit was issued before the effective date and the
conducting system was in place and the conducting system has been covered
by the permit. So this is going to be a very site specific determination.
You'll have 'to go back and look into your permit and find out if that
equipment is covered or not. If not, then it's an.interim status.
Q: With^regard tb 266.103(h) Fugitive Emissions. Is this where
Subpart BB is p£rt;i.nent to this BIF regs. If so; why doesn't it state
that? Can you iook that up?
MS. ANDERSON: OK. .It sounds like what that question involved
was the requirement to maintain a negative pressure, or keep the combustion
chamber closed so that there are no fugitive emissions. That is part of
the BIF rule. That's not part of the rule that Ginger is talking about,
so she's talking about .separate things that apply to other hazardous waste
units at your, facility.
MS. GotHffe: Section 266.103 (h) refers-to the emissions from
the BIF itself like seals,etc. Section 266.103(a)(4)(viii) is what pulls
in the equipment leaks standards.
Q: How do you define clearly identified in reference to pumps,
valves, compressors. In other words, are tags absolutely required, or are
detailed inventory lists adequate? "
MS: Gotliffe: There's two separate requirements. The equipment
must be marked and included in inventory lists and then there's also the
requirement that it must be tagged if it's leaking. The tag has to be a
physical tag put on that piece of equipment. First, in your records, you
must have an inventory list of those pieces of equipment. You also have
to have the equipment marked either physically on the .piece of equipment
or through a boundary design, or a coloring or other system, so that as
someone is walking through the facility, they can clearly identify any
piece of equipment as- being under the BB program or not.
Q: Are Subpart CC requirements in the -upcoming standards'for
tanks, containers and surface impoundments duplicative of Clean Air Act
standards and do we need both?
HB, Gotliffe: They should complement each other. The
requirements that you have a, say,' a production facility, should have
similar requirements to this under the CAR. These requirements (CC) ate
only for pieces of equipment used in the TSD type of operations. Do you
need both? I believe the answer is yes because they conplement each
other.
Q: Where does Subpart BB begin? If you are transporting
hazardous waste by truck from one process to your BIF unit, is the process
unit subject to BB?
Ms. Gotliffe: Production units are not covered, however any
piece of equipment handling waste from that unit that contains over 101
by weight organic concentrations and is located at a TSD must be in
compliance with BB. BB applies only to.those seven pieces of equipment
identified in the BB rule, so if you're using a truck that's not covered
by BB.
Q: Applicability flow chart did not include waste gas, not
hazardous waste, what is the regulatory definition for waste gases? Is'
the process of vent gas containing fuel value still called waste gas? if
not, does the BTU determine gas to be fuel or waste? What is the cut off
BTU? Basically, what is the regulatory definition for waste gas?
MS. ANDERSON: ... and see if that answers the question that was
asked. We often do get questions about whether process gases being vented
are hazardous waste or not, and the answer is that whatever process the
gas originated from.would have had to be a hazardous waste process for us
to regulate an uncontaine'd gas. Now contained gases are something
different and those specifically are regulated if they meet the" definition
of solid waste but for uncontained gases, if they're coming from some,
other process, they're not regulated. If they're coming from a hazardous
waste tank or a hazardous waste process, then they are regulated.
MS. Gotliffe: The waste gases from the 6 process vents covered
by AA must be analyzed to see if the facility must put control devices on
them. The BTU value may be a factor in picking a control device.
Q: Hazardous waste fuel tanks that supply hazardous waste fuel
to the BIF units are operated as ninety day or less hazardous waste tanks
under the generator regulations. The BIF units and associated equipment
are monitored under Subpart BB and the tank systems are monitored undei
other fugitive emission monitoring requirements. Is this correct? So
this question is, is the equipment that's associated with a ninety day 01
less tank have to comply with BB?
Ms. Gotliffe: Well, a ninety day or less tank is"exempt Iiom
.the permitting requirements so-that would be outside the univeiijt:.
MS . ANDERSON:
though. Right?
They have to meet the technical ;:t an.l.ii ,I:i,
MS. GOTHFFE: That is coriect, pai ti'i-ularly foi th.>
Page 18
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I'll i<: .|.::;,,..j.,t ,.,| wil.h t-.hnt. tank, 'you know, that is controlling" the fluid
'"'!» ii ili.it: I.ink,- not necessarily all the way down the line to the BIF.
.' '! ,-..ill.I iio"d t exempt 90 day-tank. However, once the CC standards are
(.u.imil., itod. IP.-:.'; than 90 day tanks "will likely be subject to'cc.
0: Can samp 1'es. he taken through an open-ended line that meets
ill". ir.,)ui i-pni any sampling. '
MS. GOTI.IFFE: Open-ended lilies should not be used for sampling..
Thi> discussion of this is on page 25460 of the June 21, 1990 Federal
p'-ijistpi preamble. Waste' should be sampled at points prior to their
"xposuie to the atmosphere.
Q: What is the boundary limit for subpart BB monitoring
applicability? Basically what we have is a point of generation, flowing
through some equipment to a less than ninety day hazardous waste tank;
flowing through some more equipment to a BIF unit. The equipment that
is going from the point of generation, as long as it is greater than 10%
organics does have to come under BB. If the equipment is part of the
ninety day hazardous tank system, in other words, it is the valve that is
controlling what is in that tank', then that would be exempt.. However, all
equipment on down the line to the treatment would still be covered by BB
until the treatment reduces the organic level.
M.S. GOTLIFFE: If.the equipment is associated with a less than
90 day exempt tank,' then it is exempt'from-the BB requirements. However,
for other equipment on the piping, location is not important. As long as
it is in contact with waste containing 10% organics, it must meet BB.
Question: Is scrubbing medium from a control device installed
on a less than ninety day accumulation tank- 'for a listed waste also, a
'listed waste? .If so, why? It's not derived from TSD of the waste and
it's not a mixture. Scrubbing medium from a control device.
MS. GOTLIFFE: In the preamble, I don't think we discuss:
scrubbing media used in control devices as being a listed waste. See page
254V7. It is mentioned in the-preamble to the proposed CC standards (FR
July 22, 1991) see page 33491 and 33508. Spent carbon should be managed
as a solid waste and must be. regenerated to minimize the release of
organics into the atmosphere by using a control device or else destroyed
by incineration. ,Since this rule is only in the proposed stage, please be
sure to find the final determination on spent carbon from the final CC
rule. . '-..!
' , Q: Will Subpart BB leak definition be modified to reflect the
leak definition used by other regulations, such as the HON and Air
Permits. This Would eliminate the need for calibration records at 500 and
10,000 ppm. . .' -
Ms. Gotliffe: .There's no move that I know to modify those and
I unfortunately don't know exactly how those things are defined in the
other regulations. I'm afraid I can't answer that one.
Q: Please elaborate on equipment designated'not to leak and to
.give some examples. "
I
Ms. Gotliffe: Pumps, magnetically-coupled centrifugal pumps,
magnetically-coupled gear pump, canned meter centrifugal pump, and
hydraulically-backed diaphragm metering- pump. Valves: sealed bellows
valve, diaphragm valve, and pinch valves.
' ' ' "
Q: Seminar publication.
Ms. Gotliffe: It was a seminar 'publication -that was done
,several years ago When the rule first came out and we went to all the
Regions that did training for the public as well as-for the regulatory
community and it covers T both__AA and BB. It -was entitled,_"0rganic Air
Emissions from Waste "Management Facilities". The document number is
EPA/625/R-92~/003. It was written by ORD and OAQPS in August 1992.
Recordkeeping
My name' is Emily Chow. I am a chemical engineer, and I work in the
Office of Waste Programs Enforcement. Up to this point we have talked
about the various aspects of the BIF rule and some of the inspections an
owner/operator needs to-perform. At this time, let's go over another very
important aspect of'the BIF rule, which is what a facility has to do to
document its operation and compliance. Based on the questions that I have
received from you, they can fit into four general categories. The first
category contains, the types of record required of BIF facilities,
particularly the BIF units. The second category is how frequently should
a facility record the data? The third category is what-format should a
facility use to record their data? And the last categ&ry; is where should
a facility keep, its data and also, for how Ipng ,shoul"d "it keep the data?
Now, today, besides addressing your concerns in these four areas I Would
also like to take the opportunity to share with you some of the
difficulties and problems that our inspectors encountered when they
conduct inspections. So, these are the five topics I'm going to cover
today in this session. However, before I do that, let me just define the
term recording or recordkeeping for your in the context of the BIF rule.
Recording is an act to capture or to memorialize the actual
operation-of a BIF unit either mechanically, such as via strip charts, or
electronically; such as via computers. A facility may choose to record
the operating parameter required by the regulation either on an
instantaneous basis of on an hourly rolling average basis. And we'll
explain and talk about these two terms, later when we talk about frequency.
Let's now discuss the first topic, the types of records a facility
has to keep. Obviously, there are dif.ferent types of records a facility
has to keep and some, of the records ought to be kept for three years while
the others until closure of the facility. Now, at the back of your notes
Page 19
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for this session, you will see that there are a nuwber o£ tables and some
attachments. Table 1 Buntnarlzeo the major types of records a BIF unit
must have. This table, however, does not include all the recording
requirements for BIF units nor does it include other requirements for the
BIF facility. It only addresses the BIF unit itself. The owner/operator
should go through the regulation with a fine tooth comb to determine what
applies in his facility and how long he should keep the records.
Let's now go over Table 1 and let me tell you how this Table is
organized and what it contains. There are three pages to this Table and
this Table has three columns. The first column lists the types of units
such as interim status units, permitted facilities,' direct-transfer
facilities, small quantity burners, or recovery units to recover metals
or precious metals. The second column gives you the location where you
can find the requirements in the 40 CFR. Then the third column gives you
the bulk of the table, the actual- parameters that you need to record. One
thing I want to point out is that the Tables only address the parameters
that you have to set limits for in the COC. Let me give you an example
of what I meant by that. If you look at the first page of Table 1 and go
to the middle .of the third column under' total feed streams,, it lists the
parameters that you need to keep records for. However, I didn't put down
that you need to record the.total feed stream, because the regulation does
not require an owper/operator to set limits for the total feed stream.
However, that doesVt. mean that you don't have to record'the total feed
stream going into* the units. Specifically in 266 .103 (c) (4) (iv) (d) , it
states that a facility has to -record the mass feed rates of the
constituents. To derive the mass feed rates, you should know the
concentration of the constituents and the flow rates of the feed streams
going into each feed stream. Therefore, you need to record the total feed
going into the combustion unit. Also, there is a misleading sentence in
this Table on the first page. It's the second dash under the total feed
streams on the 3rd column. It says, if recording volumetric flow rate of
the total feed,-then you-also need the composition. That sentence is
misleading because it doesn't matter what unit you use to record the feed
going into the units, whether it is mass or volume, you will need the
concentration anyway. I put down density also depending on the units.
Let's say you have your feed stream going in -- it's measured in volume
(gallons per hour). But if it's a solid, then the sampling analysis
(concentration) will be in milligram per kilogram. So you cannot directly
do a calculation to determine what your mass feed rate is for that
constituent without the density. In these situations you will need to
have the density to convert the ratio of mass to volume. So please cross
out that sentence, which actually comes up in the following two categories
also: the total hazardous waste feed, stream and the total' of pumpable
hazardous waste feed streams. So, please cross out this sentence for
those two categories also. All right. Let's turn to the second part of
Table 1. Again, on opt of column 3, there are "three parameters. The CO,
-02 and Hj. There should be a bracket next to these three parameters to
indicate all;three must be continuously-monitored^at the same 'point-. So,
if please add a bracket next to these three, then it would explain that
better. Now again, please take a look at pag& 2. In the first column,
we are referring to the smelters, the melters or refining furnaces that
recovers, metals or precious metals, and the major requirements associated
with them; The third'page goes over - the major requirements for small
quantity burners, direct transfer facilities or facilities that generate
residuals. So, it has basically the same format -as Table 1, I just want
to again reiterate the fact that Table 1 only lists the major repotting
requirements. It doesn't have everything for you and the reason is that
I really want you to go through the regulation instead of relying on the
handout that I'm giving you today so that you will understand the
regulations and see what part of the regulation applies to your facility.
Besides what is required for the combustion unit itself, ttieie are
other recordkeeping requirements too. For instance, the general facility
requirements apply to most of the facilities. If you have tanks or
containers on site, you will have to comply with the Subpart I and Subpait
J requirement's. Again, Subpart BB may apply to your facility as well.
The regulation also requires the facilities to keep a correspondence file
to allow the public to have access or make copies of relevant information.
The information to be included in the correspondence file is listed in
266.103(b)(6). The regulation is very clear in terms of what is required
in this correspondence file. But for some reasons, people are confused
over what is required. Quite a number of questions came up regarding
this, so let me address them here. One question came up on whether a
facility should have a separate correspondence file or should they mingle
this file with their other operation logs or other files. My answer to
that is it depends on h6w comfortable you are to have the public going
through your records. Bear in mind that the public has the right to look
at what is in the correspondence file. The more spread out'the files are,
the less control you would have as to what people are looking at. So,
it's up to the facility.
Another question came up regarding .a third party sending a FOIA
request (Freedom Of Information Act) to the .regulatory -agency requesting
information on a particular facility. The question was whether the
facility should keep the FOIA response that was sent to the third party
in the correspondence file. And the answer is.no. If you look at
266.103(b)(6), it stated that the correspondence file should have all the
correspondence between the facility and the directors of states and local
regulatory agencies. So, information the regulatory agencies sent out as
a result of FOIA needs not be' included in the file.
The last question on correspondence file was regarding
inspections. Section 266.103(b)(6) listed out a list of documents a
facility should keep in,the correspondence file. . You should keep all of
the COCs and COPs,. compliance test results, any inspection reports, any
notices of violations and compliance orders.' The question was"what it an
inspector came on site and the inspection was not focused on the BIF unit
.itself but on equipment or, containers that are associated with the BIF.
units or the BIF operations. For instance, it could be a SubpaiL UB
inspection, and the inspector was inspecting the pipes that go into the;
boiler and the valves that are associated with the combustion unit,. Oi ,
it could be an inspection which focuses on-tanks and- containers. iJluju-lil
inspection-reports generated from these types of inspections be, incl udt;.nt
and any notices of violation (NOV) in the correspondence; til.- It
Page 20
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";'i.|>l i.ui'-" ciul.M is t frail ted from the inspection, the~y too need to be
.' '!! iifl.' used quite often to measure the amount of wastes, fuel,
uiil-i.iw inal "i ials that go into the BIF units. Questions come up all the
' \n\r- ,<:: to; how a -facility should measure and monitor the feed that goes
'"'" ' '"? I!IF units. Lei 'me try to make- this clearer ,he,re: In
'''.. l.ur(h) (7.) (in (a) , where it-says that a facility should know the mass
I >>(! ial.p'of the constituents in pounds per hour. Therefore, a facility
i.", Kiipppsp.d to monitor the mass feed rates of constituents going into the
unit;:. The regulations don't specify whether a facility should measure
HIP volume or the mass that goes into the unit. However, I would like to
point out that whatever unit you use, the owner/operator must ensure
pnough components are available to calculate the pounds per hour of feed.
Feu example, the unit for the feed going in should jive with the unit
ftf-Lhe concentration. - Tf not,'. you. -should also ressrd the-density.. - --
I hope to explain the recording requirement further in Table 2.
IiPt. me explain to you what the table'contains. Again in Table 2, I focus
mostly on parameters that we set -limits for in the COC. The first column
deals with the type of feed.' It could be the total feed going in, the
total hazardous waste feed going in, or the pumpable hazardous waste feed -
-going in. The second column deals with the constituents of concern.
.Again, for the total feed you'll see that what I put down is for the.
constituents and not the total feed itself. But again, it doesn't mean
that one doesn't have to record the-total feed. The third column deals
with the physical states of.the feed. Whether it's a solid, a liquid, or
gas. And the fourth column deals with the facility's mode of monitoring,
whether you are monitoring the mass going in or the volume going in. The
idea is that the fifth column would give you what is required to be
recorded for-different scenarios. In summary, the owner/operator has
about three or four entries that need to be recorded for the feeds.
Again, one must also record the total feeds, the total hazardous waste,
and pumpable hazardous 'waste going in. In addition, a facility must
record the concentration of the constituents. The facility may also need
the density. And the last thing it will need to record is the mass feed
rates of each constituent. So these are the parameters required by the
regulations for recordkeeping.
If a facility, for whatever reason, has difficulty meeting these
requirements, it should contact the appropriate EPA Regions and States.
Now, this is in no way meant to undermine the regulation. The regulation
is clear as to what are required. However, in certain situations, it may
iMke more sense if one make recording entries in a different way. Not
necessary that.an owner/operator is recording less than what is required,
but maybe he/she can record in a different way. Therefore, if you feel
that, you have an extreme situation, you should contact -the States or the
Regions. ;
Now, let's go over the second category, how frequently
should a facility record? We received quite a number of questions
regarding the hourly rolling average and instantaneous limits. In
266.102(e) (6)'(i) , 266.103 (b) (5) and 266 .103 (c) (4) (iv) or the. 40 CFR, the
BIF regulation defines quite clearly what a facility has to do for the
hourly rolling averages. Let me quote that for you. The facility must
continuously sample' the .regulated parameter without interruption and
evaluates the detector response at least once each fifteen seconds and
compute and report the average Value at least every sixty seconds.
Therefore, the owner/operator must record the.one minute averages. Then,
the regulation went on to( explain the hourly rolling average. It is the
arithmetic mean of the sixty most recent one minute average values record-
ed. So, in addition to the one minute averages, the owner./operator must
also -record the hourly rolling averages. This applies to' all of the
parameters that a facility chooses to use the hourly rolling average for.
And, again, it applies to CO and O, as indicated in Appendix 9. Actually,
CO and O; are the parameters one must use the hourly rolling average, and
not the instantaneous limits. . ,.
Now in the case of instantaneous limits, 266.103 (b)'(5) defines that as a
limits for parameter that may be established and continuously'monitored
and reported on an instantaneous basis and then in parenthesis,"'"Such as"
the value that occurs' at any time. Let me, at this time, give you some
background on the intent of what we meant when we put this down in the
regulation. Basically, the regulation allows the owner/operator two modes
of monitoring. 9ne can do it instantaneously or based it on the hourly
rolling average. For the instantaneous limits, what the' Agency's intent.
was that the owner/operator-"should set limits and at any time or discrete,
moment of its operation, the owner/operator should know that he/she is not
exceeding these limits. As for the hourly rolling average, it's a little
more lenient. It allows you to -take into consideration the peaks and
valleys of the operation. . It allows you to set an average limit and
allows you to average out the operating values ... the operation
throughout a period of time to make sure that the average value within
this period of time does not exceed the average limit. So, as you can
see, the second mode, the hourly rolling .average is indeed more lenient
than the instantaneous limits. The problem comes in when the regulation
defines qui=te clearly what the monitoring and recording frequency should
be for the hourly rolling average but it is not very clear for the ,
instantaneous limits. But, as I said, when we examine £he intent, it's
very clear. The instantaneous limits were never,meant" to be anything less
than what is required for the hourly rolling/average. Upon evaluating
this issue, EPA Headquarters met with the Regions and came up with a
recommendation that we feel would best meet the intent of the regulation.
The EPA Headquarters' recommends the monitoring and recording frequency.
for instantaneous limits to be every fifteen seconds just like the hourly
rolling average without the averaging. We have told the EPA Regions our
recommendations. And now we're telling you and eventually when the
transcript is done, we're telling the public of what our recommendation
is. I understand that quite -a number of Regions are currently working out
different frequencies with some of the facilities. We're not asking the
Regions to change what they had negotiated. However, we feel it is our
responsibility to let'you know what EPA Headquarters' intent was when we
wrote the regulation and what our .recommendation is. -
Let me address one additional question. A question came up on
whether one should use or could use instantaneous limit for carcinogenic .
metals and lead. The answer is yes. Actually for carcinogenic .metals and
lead you have three options. You can use instantaneous limits; you can
.Page 21
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.
In this talk, I am giving vou a loi- f important for me to make.
these recommendations is L^hei; you setT^od ° *" "M°n
will give you good indication on ho
complying with ^eregatonS\lthorhratlT '^ ^ h°" WeU ifc
our review, it Is -not. the purpose of Sis talk "1°° * ^ ^^
if the records 'are not organized tL £ ' In many lnstances, even
th° '
^
the database.
uses any abbreviations or acronyms in
will not know how well youe operto f* 3 COnCer^- to ^ because you
tails of your operating" data. %oTunL ar^riMc T^S**- ^ ***
them in the data. . And if you choose tn c"tical and you must have
some parameters and instantaneous limits £' %£* r°Ui"9 ^s for
clearly so one knows what he/she is looking at ' ? _ ^ them,,
»e toucS
record/ or monitor when the instrumen
continues to record when it is
scale
by avoiding
data Cucn cue
' «*
c v your strip
comply with the
that it ha
~ ="
llot
'= -"'«
efficiencies of its units whatev "9 "^ trans' analVs" on the
mind that it ought to be able t ^ 3 facility uses- J«st bear in
inspector when the data ar" requested « C°PlM °£ ^ data t0 the
states agreed to accent dat^ nreq,U.e-Sted- «°»ever, if EPA Regions or the
then just make sure that tha/^' ^ C°Uld hapP6n in some ca^-'
compatible with the hardware that .h n"6 St°"d in a ^mat that is
this out ahead of timebefo^ ^ou ££%? £' ^°' ^ Sh°"ld ^
maximum daily values in adrtit-^ ^"".ic cne data. Some facilities submit
« "
t.
this is a format you can-coMideV
do something like that,.
for
" ' ? V "'M-
e Agency received a nu.nbei of
Page 22
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1''! '''" ""I""1" <! r'Tmd bocomen horrendous and impossible to keepT To
1 " h-M".1'!. ih" Aq»nry does, not- think this is a' major issue. With the
1 -l1ii"l' i".a main flame. This should not be too hard to do. "If
.1 l.i.-i lily <)OPS . that , it' should label the discs clearly and s.tore the
'I !:-:: in .in oiqnnized fasliion no that data 'retrieval would not be. an
i::;;ii.«. - Th i;: nhould be easier^than going to the 'data storage location,
wh»i<> I ho facility has to "go through piles and .piles of hard data to
In,-aic ii.it a that are requested, by the inspector.. If a facility for
wji.itpvoi ipason cannot store data on-site, . I "would suggest that you
'v-1,,1,,,-1 the appropriate EPA Region or State to plead'your case. One thing
I do want, to remind you is that the inspector has the right to have access
to all of the recor-ds that are required by the regulations. If you .claim
any of the information confidential (CB)I, just do so-and the Agency will
.treat it accordingly. Since We are on the subject of CBI, I would like
. .'.Pjpl^ify some questions that ca_me up in the__.past.. - Some, companies had .
claimed the quantity of hazardous waste and the types of hazardous waste
burned-at. the facility CBI. In Section 266. 103 (b) (6) where it talks about"
tiie correspondence files, the. regulation clearly stated that, the facility
ought to notify the public of the quantity of hazardous waste, and the
type of hazardous waste tliat it burns. So the*se information are really
not: CBI information.
Let's now move on to talk a little bit about record retention.
How long should you keep the record on-site? Generally, there are two
durations of time. Some of the records have to be kept for three years,
as I mentioned before, and some have to be kept until closure of the.
facility. I did not indicate.the retention of each type'of record in
Table I because I want you to go through the regulation carefully to see
what applies to your facility. However, let me give you a few examples.
If a facility is not claiming any exemptions or
recovering any metals, most of the operating records pertain to regular
BIF units liave to be kept until closure of the facility. For smelters,
mel'ters or refining furnaces or small quantity burners, records should be
kept for three years. For direct transfer facilities, some of the
requirements should be kept until closure of the facility and some (such '
a.s the inspection logs) can be -kept for three years. Also, all of the
records on the residual should be kept until closure of. the facility. I
hope at this point I have answered most if not all of the questions that
were submitted prior to this workshop. . ' - .
Now, I would like to take the opportunity to share with you some
of the problems that the EPA inspectors noted to show you the dilemma that
we face when our inspectors go out. A common problem we see is that data
are very unorganized. -They're'not in any format; just numbers recorded
randomly. Often times the numbers don't have units and again, I can't
stress enough that numbers have to have units for the data' to be
meaningful. There are times the' feed stream data do not integrate well
with the concentrations. Often times data are missing. For instance,
analyses were not done for feed streams. So, the facility doesn't have
concentrations to calculate the mass feed rate: There are times the mass
feed rates'-are missing, and sometimes even days of operation data are
missing. Let me give you an- example of a question that .came up to
illustrate this point. A facility claims that it has only one strip
chart and sometimes the strip chart fails. It" failed because the paper
ran out or because some other mechanical problems occurred. The question
is, when it fails, should we feed hazardous waste? And the answer is no.
A facility should not feed hazardous wastes into the unit if it cannot
record its operations to show compliance. I would recommend, in a
situation like this, the permit writer should tie the strip chart as a
trigger to the automatic waste feed cut off. One last thought I want to
leave with you is that regardless"what the situation may be, if a facility
fails to keep any necessary records on-site or if the facility has missing
data, not only that the facility is'in violation of the record keeping
requirement, the potential for-harm is great when we calculate penalties
for-such violations. When there is no data showing the potential for harm
is low, the Agency has no choice but to assume that the potential for harm
is great. That concluded my talk. If you have any questions regarding
this recordkeeping discussion, please pass it up and we'll address them.
(conversation inaudible)
MS. CHOW: OK. Sonya brought up a good .point. I just want to
make it clear that' if-your facility is burning hazardous wastes and the
strip chart is not recording, it is a, violation. A facility is supposed
to continuously record and monitor its operation when burning hazardous
wastes. All right. Let me address these
questions that you have.
QUESTION: Why did it take the Agency more than two years to
address how often a facility must keep instantaneous records? We have
already purchased and installed equipment based on one minute average.
MS. CHOW: Frankly, because most of the facilities are using hourly
rolling average and we have not- encountered this issue being a real
problem until very recently. Since the issue is being raised now, that
is why we are addressing it at this time.
' * » '
The next question is why was the retention, time' for operating data
and inspection logs changed from three years to closure of facility? It
would seem three years is adequate for compliance checks. This creates
a big problem in how to keep records of the magnitude for twenty or thirty
years. May be Bob can address that? :
MR. HOLLOWAY: As I recall, I think we issued a technical :
amendment to change some of' the recordkeeping requirements from three
years to the life of the facility just to be consistent with the
incinerator regulations. I think,, frankly, as we were developing the BIF
regulations, we thought that in many cases perhaps requiring recordkeeping
for only three years was appropriate. Then when the rule came out,
various folks alerted us to the fact that 'for incinerators, it's-a
lifetime requirement, and we couldn't justify a. difference. So, the
bottftmi line is that's why we changed.it. I guess I should point out that
we are going to go through a rule making. We're in the process now of
developing upgraded'regulations. I'll talk more about that tomorrow. But
as we do go through'that rule making, if in fact we think that, and this
rule making will include incinerators as well as BIFs ... if we think that
Page 23
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*. wrevou " V°M§r"' mea8UtinS C0 « »
The reg savs 100 par ^ per -mi th\aucfmatio ««e feed cut off?
instantaneous basis which i« uh» i" ' 3pply "ith C0 on an
average. Z-m not sure th^ebS ^S?^^ T» 'I""
with it on an instantaneous basis that wl wo.n/h 9 V «»Plyin
And as I'm speaking, Sonya's WOUl*nave a Problem with it.
we decided that
a"d We
options thatcamat the
considered various options W consdered
so that we wou^n..tPhave to requTre 1l!
average capabiHty and the conclusion was
and so we did *lv. facilities onl/one "
d
01 ""I"
***
(comment inaudible)
MS. SASSEVILLE: No,
(comments inaudible)
probably^ g Tat
sr
th<, hourly
.ppro,h
°£
"«»
jrr.r
-««"
-"»""'.
average? Well, I think one reason for
hQurly
of facilltica trying to get
I guess we juat feel that it
records.
cacuiated
S that we do aee a »«t
«"h the regulations. so
"
could say it-s acceptablif
""""
as
name of
?
accept
'." ta» «"
.ore stringent that t requ, a
S
waste feed rates in
pet
rather
^stion, we track
inspection o
as your units correspond with your COC then it iuL Lfc " °"9
us to check compliance. i don't think ?hT/ u 6aSler for
pounds per hour. As a matter of f, , .h " 3 Problem that you use
pounds per hour. 3Ct> the re9ulati°" says you should do
Wlth the reader and Pinter? -
tO record the
the
Yes. Another question i, Tf
unknowingly, That actions
Unknowingly^ ! guess if Tt is
unknowingly will be S vxolat
whether Ur kno^ Tit or not
hazardous wastes, the
regulation. lt , s .
'
^ pOtentia11/
agency?
criminal;
"hen' burnin»
computer actually monitors and i(.c-u,U:; ,,, ,
Page 24
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» .) | tuition arid what is set in the regulation, I'd said, no.
.'"' HOI.I.OWAY: You don't have to keep it. It might be of
f to you ami it might be of interest to t he inspector, but. you
MS. fllOW: OK,.- The next question. Is there a .way to store and
ir:<> ,111 f Ipfl.ronir: form for inspection records? What about signature
i c>qui lomniit n. > .You're talking about inspection that's done by the
'wiifi ,"i')[>(M ator . , '
M.S. CHOW:
Did I already answer this question? Good., Thank
MS. SASSEVILLE: Double check on the signature since quite a few
ppoplp seem to think it's required that, they sign it. ".
MS. ANDERSON: I'll double check. I thought it was just the'name.
Maybe I'm wrong. [According to .40CFR 265.15 (d) , only the name is
required, not the signature. However, States may have" niore stringent
requirements).
(laughter - comments inaudible)
MS. CHOW: OK. The next question. Are mass feed rate records
required for constituents that are not detected. If so,'why?
. MS. SASSEVILLE: Determination that they were not detected',
right? Is that the question?
N ....
MS. CHOW: If the constituent is not detected, then you should
record the detection limit. Use -the detection limit as concentration to
calculate your feed as your worst case. The second part of the question
is how should records be handled if an erroneous one minute data point
gets into the hourly rolling average.calculation? When you say erroneous,
I assume you have done some kind of check to determine that number is
wrong for some reason and I will say that you should go ahead in your
records document why this number is wrong and be ready to support it.
There's a third question. .
MR. HOLLOWAY: ' (inaudible) if we're not addressing the right
question, you all speak up. We're -trying to guess what you're asking and
sometimes we take the easy way out, if you hadn't noticed. So, if you
have any follow-up questions, ' speak up. -,
MS. CHOW: All right. If a facility records its data
electro'nically, is it permissible to use data compression techniques for
the stored information? The compression would record one .data, point for
every fifteen minutes of data provided that data did not vary plus or
minus 2.S% parts per million. I.don't think so. Particularly not every
fifteen minutes. ' '
AUDIENCE: I know that EPA is interested in responding to the
public's interest in knowing about operation of BIFs, incinerators, etc.
Industry is also interested in responding to legitimate interest that the
public has but it seems that a lot of things that are required to satisfy
public interest groups are rarely actually used. In our company, the'BIF
correspondence file is a good example. Nobody ever asks to see it. Does
EPA'make any attempts to find out if such requirements are actually
beneficial?
MR. HOLLOWAY: I think it's an interesting point. That's
something that we might look into during the upcoming rule making.' You
might ask that question in the proposed regulation as the regulated
community, you should get back to us as to whether or not the
correspondence file or other things are really useful. It's a good point.
MS. CHOW: . Question? . .
(inaudible) '"-.
MR..HOLLOWAY:
Yeah. I think it's a valid point. It's good.
MS. SASSEVILLE: One question for you. Not necessarily 'to
answer right now, but about that correspondence file. The issue is, is
there a chance that people just aren't:aware that it's there or does it
seem more likely in your specific situation that they know it's there and
they're just not interested. Because the reaction to the two things might
be different. .
-MS. CHOW: OK. -That's all the questions I have. Any more? If
not, I'm going to turn'the time back to Kate again to talk about personnel
training. -
Training for Facility Personnel v '
MS. ANDERSON: Again, as Ken mentioned this morning, several
years ago there was an EPA/OSHA Task Force that .jlookea lit commercial and
interim status hazardous waste incinerators. One of the main objectives
of that task force was to look at whether or not the facility employees
had been proper-ly trained according to the RCRA personnel training
requirements. A question that we got from you requested a basic overview
of the RCRA personnel training requirements. I know there's already been"
a question out there as to whether or not there's any -more written
guidance or additional .information on how to put together a RCRA personnel
training program. I did some checking into this before this presentation,
and there was a mention of a document in the original May 19, 1980 Federal.
Register where the personnel training requirements were promulgated and
it said the agency was. working on'a guidance document. But I checked in
the EPA library and there wasn't any indication that that document exists.
So, for those of you who have looked for it,. I can relate to your
frustration because I couldn't find it either. .What I'm going to go over
right now are just some general requirements in 265.16 that talk about the
personnel training requirements and if you all have more specific .
questions, I'm sure we'll get to them.
Page 25
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Basically, there's flexibility allowed in these regulations
because they say that you can either have formal claasroow training or on
the job training that trains the employee. The main goals are that the
employee is able to know what to do in case .of an emergency and to
effectively implement the contingency plan.
Some of the other basic requirements have to do with the
qualifications of the training director. This is something we look for
when we're out on inspections, to make sure that whoever is in charge of
your training program is qualified. Another important consideration is
that if your employee hasn't been trained yet and they'have six months to
get the training after they've been employed by you," "that during that
interim period before they receive training, they're strictly in a
supervised position.
Another important requirement is the annual review, it is important
to have an eight hour refresher or refresher training class on an annual
basis. Here again this is where we find a lot of violations and it seems
like just a paperwork requirement, but again, it's the only way that we
have of checking to see that you're properly training employees. You need
to have records for everyone showing that they have had this training.
You need .to have these records until the closure of the facility. And if
the employee leavsg,.you need to have them for at least three years after
the employee leaves .your organization. Again, make sure that you have the
position description, the job title, the employee's name and the type and
amount of training that they had. This helps us determine whether or not
the training was adequate for the responsibilities that the employee is
faced with at your facility. And, remember there should be documentation
of completion of these courses. And usually most trainers provide you
with some type of certification at the end of the training so that's
fairly easy to comply with.
Just to summarize what ,1've gone over, the basic violations that
we find out there have to do with incomplete records and that's something
you can rectify fairly easily by just being diligent about keeping records
on your employees; Making sure you have job descriptions for everyone and
making sure that the training they have matches up to their
responsibilities. So, please send your questions up and we'll try and
answer them.
MR: GIGLIELLO: Before we take questions, there's just a couple
of things I'd like to say about personnel training, that over the years
I've come to'find out. When I used to work in the private sector, I used
to do environmental audits for major companies in the U.S. and one of the
things we looked at were specifically personnel training in the records
program. And the thing that I actually believe is that the reg here is
perfectly fine. It's clear what it is you need to do. Straight forward.
.And I don't think there's 'a whole lot of gray areas, to be perfectly
honest.- I think this is probably of all the areas in RCRA one of the most
straight forward. The biggest problem that people have is that they do-
too much generic record training and not enough site specific RCRA
training. And some of the things that I've seen when I worked for this
major manufacturing company is, they had developed a video on their site.
It was a thirty minute video showing exactly where waste came from, from
the beginning, walking them through, where it ultimately wound up in the
plant. Where it was collected and then where it ultimately went. And
they showed that video to every new person. They showed it on a quatcerly
basis to people that hadn't seen it and they recorded everything. And it
was excellent, r went to people when I did the audit, and I asked people.
do you know what hazardous waste is? Do you know how to handle it? And
the people in the plant that handled it knew. Because it was site
specific. A lot of the people that do health and safei-y training do this
basic stuff on cradle to grave and to a-lot of people in the plant, it
means nothing, absolutely nothing. But if you walk them through and say,
look, we generate TCE. TCE is bad stuff. Here's how we collect it. It
goes in this drum storage area. We've got to keep records of it. Here's
where it ultimately goes. It's incinerated; it's land disposed, whatever.
It has real meaning for people. It worked and it was great. Site
specific training is the way you have to do it. If you don't do it.that
way, you're wasting your time with a lot of generic hoopla and a lot of
people aren't going to get a whole lot.out of it. So, I would urge you
to do it. We in EPA have a requirement that we have to do health and'
safety training every year before sending anyone out on inspections.
Well, we do it. We document it. So -this is something that we do
internally within EPA. It is not that hard to do and it boggles my. mind
again, to this day, how many violations we find in the personnel training
area. It's straight forward. It's easy. And I don't understand why
people can't comply. I'll be perfectly honest. To this day I don't
understand why people can't. Sorry.
MS. ANDERSON: Q. One question here is how far up the line in
management is RCRA training required? Theoretically, this could be
interpreted as requiring the highest levels "to have training. A. I uhiiik
that's part of'why we require the job description to be included in the
training records is that we're looking at how training matches the
responsibility of the employee. So that, if you have a manager like the
vice president who, rarely goes into the plant, but sometimes might, well
maybe he needs some kind of training but maybe he doesn't need as
extensive training as the front line person who's there and has to handle
an emergency when it comes up. I mean some of it is just kind ot-common
sense and, you know, again, I can't give you any definite answer, but I
think if you follow OSHA's requirements'for safety training that you're
going to be fairly certain you're complying with the RCRA requirements.
Q. OK. Does haz worker training suffice for contractor training,
that is non-employee personnel who works on.sale? A. Again, I think the
RCRA regulations are specific to employees of the facility. I'm not sine
how a contractor would work, but a" contractor would have' to have OiillA
training to be in compliance with the OSHA requirements. And aijdin,
that's going to suffice for any EPA training in this area.
Q. OK. I understand how personnel training is important .Un. u
facility. Likewise, I would like to know how EPA trains its peisoniiel and
specifically its BIF inspectors. Our Region-.has had experience wiih ,i I'.IK
inspector who is extremely unknowledgeable about.''the RCRA piogram and i n.-
BIF requirements. A. Well, sorry about that. But we do tiy and .j,;t .nil
and do training for our RCRA - inspect ors. We.did some un-' .ti..inin-|
actually this summer. It's going to be even more difficult ,,n.-c- in-
Page 26
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:-!,,i,..: ,-,,,. ,mt hoi ir.pd because some of the state inspectors may not have
ilir.,,,|,H ,,, ii.-uiiinq. I think that one problem is the. turnover rate for
Mi';,,..-! ,,,;; i;; fairly high and that tmakes it difficult to keep up-to-date
,-n -..,.,yt hi nq Hint.'n going on in RCRA.- But there are requirements that
*"." sot out -foi -our EPA inspectors, some basic training requirements,
I" m.ik'V sijrp that they are trained. There's some hours of basic RCRA
t-i.'iimiKj'thnt they have to have and then there's program specific training
Mi.it i.hoy |,nvf. lo have before they can be a lead inspector. So, it
I ir;l in h:s mp to hear that somebody''s out there you feel is totally
ini'Iii.il i ( ipd. Again, - the regulations, when they were new, there may have
I '"MI .in pxouse that there's some lag time in getting up to speed,. Now
Mi.it il'n been three, years, i would hope that most of our inspectors have
/i I IP.IS! a basic understanding of the-BIF regulations and the RCRA
ip']iiiipmpnts definitely. So, I don" t know, what else I can say-to that.
<"on|(i bo a contractor'.
Q. Again, what is the eight hour requirement you mentioned
-who;; discvissing the annual review training? A. I~'was referring to OSHA's
requirement for an annual eight hour annual refresher and that's what we
act.ua.lly have to go through as Ken-mentioned after we've had our basic
twenty four or forty hour course. ' . .'''.
Q. What is meant by written job description? What does the'
job description need to say? A. Again, the purpose behind having the job
description in there is so that we have an . indication of what the
responsibilities are of the person in the particular situation. So, you'd
want to describe what their basic day-to-day responsibilities are and that
should relate to what type of training they have to have. Anything that
would give us an idea of what their responsibilities are so that we could
evaluate what type of training they should have had. That's the type of
information we're looking for.
MR. GIGLIELLO: One problem that I've.heard with that is that
a lot of companies say they, have problems with the unions where you
Basically put down a job description in this hazardous waste personnel
thing and it's not there. Say they have a job as a laborer. OK? And
that's their job description. The union's approved it and everything else
and all of a sudden you put down their' function that they're hazardous
waste handler which.is really .all we care about. We really don't care
about the laborer designation. We want to know what this giiy does or this
person does in relation to hazardous waste. That's:the job description
problem we've heard. And I don't know if that's a common problem anymore
witli the unions getting into this job description, but as Kate said, what
we want to know specifically, is this the person, that generates the waste
and puts it in the five gallon bucket? Is it the person that takes the
five gallon bucket to the storage area? Is it the person who signs the
manifest? That-'s the kind of information we want as a job description,
not the union label. The union label from our standpoint isn't going to
help us any. It's not going to tell us anything. If you say he's a
laborer or you say-he's a technician per say, that does not help us. We
need more specificity than that. . ,
MS. ANDERSON: Q. Does, a person who walks through a permitted
facility need training? . If so, what about site specific training
requirements for agency inspectors? A. "Again, I think Ken touched on
this earlier. When we, meaning the Regions, States or HQ-personnel, go
Out "on inspections, we're required to have health and safety training, the
same as probably many of your employees are. It's an OSHA requirement and
so they should have their forty hour training or their twenty-four hour
training depending on the frequency of their site visits and they need to
have an eight hour annual refresher under OSHA. So, if that's what you're
getting at, that's the kind of- health and safety training that pur
employees are required to have when they go out on sites.
Q; OK. Who's a qualified trainer? That's a good question. I
_think OSHA actually has a certification program now for its trainers. In
terms of RCRA, the'regs;just says qualified. That could mean a lot of
things, but you would -at least want someone who has had training
themselves and has had experience training other people. I'don't have any
other specifics for you off the top of my head. I can look into this
jnore, if you want and see'if there's any specific qualifications., But
again, a lot of this is kind of 'common sense. I mean you want, somebody
who's going to be able to impart the information to your employees 'to be
able to help them know what to do.
Any specific .training content required? Again, along the same
lines, the regulations are pretty general, but there would be specifics
according to the responsibilities of the people you're training. And
certainly this is where OSHA requirements help,fill, in the gaps because
where RCRA may be a little bit vague about what's required, OSHA's pretty
specific and chances are you're going to have to comply with the OSHA
requirements too." Yeah? -.-_-.- .
(question inaudible)
MS. ANDERSON: Yes. They are. That's a good point. His point
was that the RCRA requirements for record keeping are separate from the '
OSHA requirements. .OSHA may have additional record keepi-hg requirements
or less, but you still- have .to comply with all the requirements, such as
they are, laid-ouf in RCRA and in addition to that, th'e "OSHA requirements
as well.
... - i1 .
Q. This question is, is annual review on 365 day basis or once
per calendar year? .Regions and states are split on this issue'. A.
Again, what we try and do for our employees is make sure that it's within
the calendar year. In other words, if we have our annual refresher in
October of one year, we try and make sure we have it in October of the
next year and before 'the date, not afterwards. So, I guess we do it on
a 365 day year. So, that's not a calendar year.
Q. All the speakers have given today guidelines, policies, etc.
and emphasized that these are just recommendations. Do you plan to issue
NOVs and fines based on these and if so,, what authority .do you have to do
this? A. It's a'very practical question. Again, where we said it's
guidance and policy, it's just.that. It's recommendations that we can
give to you to help you comply with the regulations. Where the
regulations allow some flexibility, .the guidance we've given you can help
you better define the limits and where the regulator thinks you are either
Page 27
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in or out of cowpliance with the regulation. - Does anybody want to add
anything to that ...
MS. : I guess everybody won't be able to hear me
but let we clarify the questions that were asked or the guidance that we
were giving (inaudible)
MS. ANDERSON: What we were giving was not on things that are
above and beyond the regulations. They were on how to comply with the
regulations. So, if you choose to go about it some other way, then it may
not necessarily be wrong, but you are taking a greatet risk and certainly
you have to show that what you're doing is right and that your rationale
is valid. Although this is guidance, it's not above and .beyond what the
regulations require. It's how to comply with what is -on the books. Are
there any last minute announcements that you guys would like to make?
Compliance Tenting
MR. RAUENZAHN: First discussion we're going to have today is
regarding compliance testing. As an overview, we're going to start
talking about rep'ertification and retesting requirements. Then we're
going to move on* to testing requirements for Tier 1 . and Tier 1A, the
validation status* of some of the stack test methods, use of data in lieu
of a trial burn and conclude with'a real fast overview of selection of
waste feed streams and what's important of when it comes to actually
designing a trial burn.
Recertification retesting requirements. These are in 266.103.
Recertification is required within three years of submitting the previous
certificate of compliance and owner/operators must recertify every time
they change designs or choose to change operating conditions. And
whenever you do recertify, of course, you have to retest.
For Tier 1 and Tier 1A, you must remember that both of these
-establish feed rate, limits. It assumes that everything you feed into your
boiler is going out the stack, so stack testing itself is not required for
Tier 1 and.Tier^lA to establish these limits. But remember that other
standards still apply if you choose to go Tier 1 or tier 1A £or metals.
The particulate matter of standard still applies and-you still need to do
particulate matter testing.
Next thing we're going to.discuss is the validation of our stack
test methods and hopefully discuss some of the problems that you all
confronted out .there. An important .point to bring up. -A general
complaint we hear is that a certain method hasn't been validated at my
type of facility. Methods are not routinely validated at every type of
facility they will be used at. Just because a method has not been
validated at your type of facility doesn't mean it can't be used or it
should not be used or somehow it will not work. Whether a method will
work at your type of facility is more dependent on the conditions of the
gas stream you're sampling than the type of-facility it was validated at.
Now that doesn't mean that you may not have to make some minor
modifications to the method in order to get it to work at your facility.
Hexachromeifl a good example of this. And we'll get to that in a cainute.
Other than that caveat, all have been validated as hazardous waste
incinerators. The multiple metals train, hexachrone, HC1/C12 and VOST and
semi-VOST have been validated for thirty compounds. They've all been used
with good success at boilers. Some people have had problems with and
we'll get to that on the next slide.
OK. Hexachrome. Hexachrome requires a high pH in the
impinger. If you don't maintain a pH over 8.5, you will start having
problems with Chrome 6 turning into Chrome 3. Ways to get around this,
simp.le modifications you can make that doesn't affect the validation of
the method, are: you can use a larger impinger; use a higher
concentration of KOH in the impinger. The important thing is you do what
you need to do to get the method to work' at your facility. Another
problem is temperatures above 300 degrees F may present a problem. It is
my understanding that teflon tends to cold flow when it starts to get
somewhere near 300 degrees. If this will create a problem at your,
facility consider using quartz for glass fittings in order to get around
this problem. Once again, the important thing is not to rigidly stick to
the validated method but modify it reasonably as you need to in order to
get the method to work at your facility. .
HC1/C12. According to our folk's in ORD, there's only the one
circumstance where this has been a problem. When you have extremely high
levels of ammonia in your gas stream, you may run into problems. If you
do run into this situation, work with.your Region. If you run into other
situations which are unusual and you don't think it's going to work, work
with your Regions. The Region is going to-wind up making the final call
in the long run anyway.
Finally, dioxin method 23. There's really not a problem with
dioxin or method'23. It's an air method and the air people made what some
people consider a short cut when it comes to determining the recovery for
dioxin. What they did was, they made the assumption that the recovery off
of the particulate is the same as the recovery off the X-82. Some people
have philosophical differences with that'. They say, you've got to figure
out what the recovery is off the particulate and'the recovery off of the
X-82 and that you can't assume that recovery off the X-82 will be the same
as on the particulate. Well, that said, if you have a problem with that
and you don't want to use the method, there are things that, you can do.
The problem is that the regulations tell you you've got to use method 23.
If you want to use something else, you're going to.have to once again wotk
closely with your Region and try to iron things out. They may be able u>
do something. It starts to get really difficult however, when the method-
is mandated in the regulations. .
Data in lieu of a trial burn.. . Start out with whal i .s not
-acceptable.- If-you've got different sized un-its, you caiv't- use duiu in
lieu of a trial burn. If the air pollution contidl devices ate dilli-it-m
on the two facilities, you can't, use it.- If the-re_'s different opei tit in-.|
or maintenance histories, you can't use data in lieu of a trial lnjuu-i .
Situations where it may be acceptable is where you have idem i IM I unii:;
at the same site, you have the same operating and maintenance hi:;i ..t >.-.;
Page 28
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!'" -I it ,v_ i h.it. yim'r" lining must result from a compliance test- that was
!-:.M .! i>y .1 i f«-|iiintoiy atjeticy. Those are the situations when it may be
i.v.,.,,1 .,KI,, YC.III notice I didn't sny when.it is acceptable. The reason
-------
example, chlorinated phenols, maybe. So, those are jiiut aome of the
things that we're thinking about. He are working on written guidance to
the permit writers which we think will also be at some point available to
applicants as well to look at. At this point what we're shooting for as
far as the document that would be available outside also would be the end
of April. So. we'll see how that goes, but that's what we're looking at
this
point.
" "
MR. RAUENZAHN: Next question, a practical- question. We'd like
to modify our boiler, alter combustion chamber, what steps must we take.
Part A Class 3 permit mod, recert of compliance, and
if our compliance test fails must we initiate closure?
MS. SASSEVILLE: I guess I could start out with that. A permit
mod, if facilities aren't permitted, a permit mod isn't, necessary. You
would have to ... Bob, jump in if you want ... you would have to recertify
compliance after making the changes and I'm trying to think. If you
failed, then yes, I guess you would have to shut down and not be able to
operate until you get under a permit. If it is a facility that, I would
have to think, if it came in under a Class 3 permit 'mod and it's one of
those that we treat as if Jit were under interim status, because it doesn't
have any permit conditions, I think it would still b.e basically the same
that you would have,to go through the steps of recertifying. Bob, any
jk _
MR. HOLLOWAY: I frankly have forgotten exactly what the BIF
regulation says when you fail a compliance test. I'm not sure whether if
you fail a compliance test then you have to stop burning and yqu can't
burn until you're under an operating permit or whether the regulation
gives some flexibility and says you can only burn after that for a period
of 720 hours arid only for purposes of shake down and subsequent compliance
testing. I'm not sure what the rule says. Anybody here happen to know?
Any of you guys happen to know?
QUESTION: I just wanted to ask if during.the compliance test
you'd want to provide enough scenarios that you might flunk one of the
scenario but might pass one of the ...
MR. HOLLOWAY:. That's an excellent point. Everybody hear that the
point was that in order to deal with this possibility of failing a
compliance test, you ought to run under multiple test conditions in case
you fail one, at least you'll be able to operate under one of the other
conditions. Good point, sir. .
MS. SASSEVILLE: Maybe we just didn't think about this at the
time that the rule came out because we were more thinking about the
initial certification where i.t didn't necessarily matter if you failed
initially as.long as you came up with a passing-test that was different
from the failing tests by the.time of the'compliance date: But once you
make .it a modification then it gets to be a little different. I don't
.think we really thought about that.
MR. RAUENZAHN: The next question is from a facility that wants
to use data in lieu of trial burn. Their problem is they've been informed
by the Region that they don't have any funds to oend an inspector out to
observe the teat. Is there any advice as to what to do under that
situation?
MS. SASSEVILLE: Could you repeat the question.
MR. RAOENZAJtN: Data lieu of a trial burn and EPA doesn't have
funds to do travel to observe the test. Any advice?
MS. SASSEVILLE: I would say, you're going to have to, I know
we keep saying this, work with the Region on that because it may be site
specific. It may be that they are going to have to look at the teat
report in order to be able to decide whether to accept it or not. You
know, it's not in the regulations that it has to be observed in order to
be acceptable, but there's just a question as to whether they'll feel
comfortable accepting it if nobody's seen "it. So, you have to woxk with
the Region.
QUESTION: I've run into the same problem. One of the problems
I'm having is that some of the people in the Region are very uncomfortable
in one situation or another looking at this data because they don't have
the personnel or expertise to look at it. And they're looking to
headquarters or OAQPS for guidance but you want to tell it to go back to
the Region for guidance or tell it to what they're comfortable with. I
would like to see more ofOAQPS or HQ providing guidance to the Regions
saying it's up to them but this is what we would recommend.
MS. SASSEVILLE: Yeah. In a way we're talking about two
different things. We can't really answer these questions here because it
is site specific. However, the Regions know that they can come to us it
they need assistance on making that site specific decision. So, we are
available and the Regions are aware of that and the states also.
MR. RAUENZAHN: The next question wonders why particulate matter
testing is required for adjusted Tier'l compliance. Then it goes on, if
you assume a worst case scenario, i.e., ash'in equals ash out, isn't that
the same logic used for metals and chlorine.'
Well, the particulate matter standard is a separate standard from
the individual metal standards. You need to comply with all standards.
MR. HOLLOWAY: And again, as we said yesterday, we're not only
... we're using PM as a control not only as a supplemental control.foi
metals but also to control adsorbed organics and in fact as you know, you
can have particles of soot that can result from poor combustion and a I'M
standard would deal with that. So again, the. PM controls are used both
to deal with metals as a supplement to a metals controls and also to deal
with adsorbed organics.
MS. SASSEVILLE: I just .happened to think about some ol t lioa.-
questions on accepting compliance test data in lieu at a tiial hum
Something that is probably worth keeping in mind is 'that with t h.- n.-w
combustion strategy and the new considerations we have roi donicj a , i::;.
assessment including PlCs and dioxins, it may be likely that l lie d.u.i (,',
Page 30
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,"" ''.'' i'-ir-.ii i''» <>f compliance isn't going, to be enough anyway or that
i<'in,!, ..illy-lin p'nijnqli (01 certai n '.performance standards but it's most
I n !-, i li.ii .you1 in going to. have to test again anyway in order to get the
I I ' ! it-,-i _.inrl. UK- dirixin data to put into the risk assessment so ...
MR. PAUF.NZAHN: Next quest-ion, is what is the status of omnibus
-iui IMI it y vfi-nuj! (lie particulate .standard. I guess the .015 versus .. ;
MH. HOLLdWAY: _ I' 11 tell you what ... I'm going, to talk about
i h.it ,1 little bit later on this morning, so if you still have a question,
.-iii'i you might after I finish, why don't you raise it again.
MR. RAUENZAHN: Next question. Given the EPA calls in Part B
pfMmit and the three year deadline for compliance tests will occur before
I ho t rial burn is approved, (a) will it be necessary to perform the
<-omp]iance test or can' the .facility wait until the .trial burn is
p
-------
if» fine with M. However, some Regions or States »ay be adamant about
having the facilities record the calculated »ass feed^ rates as par^of
their normal recording, then you will have to comply with that because
oLnteL^H d- Y th,6 BIF re9ulatio«- So, I personally do not have a^y
problems with it a* long as the affected Region or the State accepts it!
QUESTION: i have one wore question (inaudible)
MR. RAUBNZAHNi
(comments inaudible)
Use the detection limit.
MR. HOLLOWAY: The comment was, what happens when a constituent
'
feed rates and everything, and i. think the ans^°L wh ^hng^e'us"
probably correct. Yeah. I don't know how else to deal with it?
lower on?.' SASSEVILLE: There'd "° technical basis for going with the
fc
MS..CHOwf- ' Put yourself in the shoes of the regulator If the
constituent concentration is below the detection, it doesn't tell you
don ;lnknowXwhat tT ^ ?" ^ "* *b* ce"a- level. And'we
don t know what the actual concentration is, so, u'sinq the '
limits will be the most conservative approach.
MS. CHOW:
(comment inaudible)
If you.can come up to the microphone, we would like
suggestion^
considering, these suggestions if they are appropriate.
a large body of water such as an ocean or a large lake '* and they
'
want to
-"
no«tle.tion.
(or
d6
^.
.ending out to .verybody ,
example
MR. HOLLOWAY:
Are these documents available through NT1S for
in Cincinnati and those are free. So they're available through there
until the supplies run out and then they'll be available thought f NTiS '
_' MR RAUENZAHN: I'm not sure we can answer this without a little
clarification, but this one's addressed, to Sonya . It says based on yout
comments, can we still use the surrogate for trial burns? V
I'll
' surrogate differently, !50
. lot ,f tMn9,
i, io,
u,
,,
to spike up ,r.o reach maximum chlorine level., for examp.e o wl
But we wouid »k- - ^ - ' >
Page 32
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Hi'. I'AtlKNZAIIM: Next question. Must EPA be notified when
ni'i !.: <-i>nilii>;t r>d for state air permit requirements and that's .,.
That's up to the air program.
;- m> RAUKNZAHN: Arp two sets o.f test conditions required "to
"-'I -1)1 I i .sli ,-t u;;.ib|p minimal combustion chamber temperature, especially when
n-ii ui. 1 1 q,i;; and liquids are the only-fuels. Conditions that demonstrate
m-ixiimihi . omhust-ion chamber temperature are', not Likely to demonstrate
'
mi
ni m, 1 1 temperature.
Mi;. SASSEVILLE: Yeah. I suppose we're talking about a permit.
who, e you have to demonstrate maximum temperature for metals and minimum
temperature for DRE and PICs. There's no way that you' can set those from
t IIP name test unless you want one temperature that you have to maintain
a, 11 HIP time which of course isn't feasible. So, you really would have
_ l.L°J!io';J?*L0. separate tests;. UnlejSs of, .course you 're complying, with. lien. i.=.
for metals in which case you don't need, to do the maximum temperature.
Did that answer the question?
QUESTION:
I was referring to. the minimum (inaudible)
MS. SASSEVILLE: Oh, you mean ... for maintaining interim
ntatus? OK. That I think- we've generally allowed under a separate
I mean it's not a very complicated .... '
QUESTION: Regulation says that you can use the lowest hourly
rolling .avera'ge but that.'s likely not to be a useful temperature because
you're pushing for maximum temperature. ' ' '
MR. HOLLOWAY: Exactly. So you can run a separate test for your
low temperature . .. to establish low temperature that would apply during
the automatic waste* feed cut off. '
MS. SASSEVILLE: . It wouldn'.t have to be a very complicated test
since you're'not testing for DRE or anything, so ... '
MR. HOLLOWAY: in fact, I guess all you'd have to show is
compliance with the CO limit. You don't need to worry about metals or
chlorine or ... whatever. Or^even PM; just CO.
MR. RAUENZAHN: Next question is regarding one of the test
methods. The EPA me'thod for HC1/C12 does not discriminate between HC1 and
Cl in the HC1 portion of the sampling train, is there anything being done
to address'this? . . ' '-'.-
I.can get -to our
I guess this is the first time I've heard of it.
people and hopefully get- an answer in the transcript.
INOTE: We assume that the HOC1 in question was sampled'from the stack.
If this is the case, we would expect HOC1 to be trapped in the acid
solution designed for HC1 collection. We wish to measure all reactive
species of Chlorine, of which HOC1 is one. Therefore, we do not consider
this to be a problem with'the method.) .
Has it been brought to your attention that method 1057 has a
significant positive bias on the chlorine analysis? When Cl reacts with
the caustic hypochlorite, something or other continuous to react and a
vportion will form additional chloride. The bias is that 1C analysis CLPIC
area-is multiplied by two for the reassumed half split. Larry Johnson of
EPA in RTP is aware of this. Is there any dialogue with the. BIF method
developers to resolve this?
[NOTE: The caustic impinger designed to trap diatomic chlorine
does so by forming HC1O and HC1 in the impinger. The method can be biased
to higher Chlorine concentrations when the caustic impinger is
contaminated with%a reducing agent. The reducing agent aids in the
formation of HC1, which is what the analytical method, 9057, measures.
If this is a concern for your facility, use the reducing, agent Thiosulfate
in the caustic impinger to ensure that all the chlorine forms HC1. If
this is done, make sure you change the calculation so that every two HC1
detected represents one-diatessi-c-Chlorine;- The air program has endorsedJ
this as an acceptable alternative for their Method 23. Consult the OAQPS
Technology Transfer Network for specifics on this alternative.]'
MR. RAUENZAHN: How do you suggest.adjusted Tier 1 boiler
(inaudible) you cer.tify at maximum feed rates needed. If you do not
accept extrapolation,, should we spike, i.e. particulate/ash. This is not
a specific site problem. Many boilers are dependent on their processes
heat demands and cannot arbitrarily run at 100%.
MR. HOLLOWAY: Well, under Tier 1 you don't need to spike the
metals because your feed rate .limits are the Tier 1 screening limits,
irrespective of what level of metal you may be feeding during your test
to demonstrate compliance.with PM and CM and whatever else. Is that the
question? Do you have to spike metals under Tier 1?
MS. SASSEVILLE: Was it about spiking ash? If you need to
do. that .to get a level that you can live with then, yes. "And that's not
an uncommon thing for trial burns to spike some ash' material.
* '
QUESTION: .. .So you'd rather see spiking than ash (inaudible) you
would consider that better for the environment?
MS. SASSEVILLE:
extrapolation to be valid:
We would not necessarily consider an
MR. RAUENZAHN:- The answer is yes.
MS. SASSEVILLE: Because removal efficiencies change as you ...
as the load on air pollution control device, changes, so ...
MR. RAUENZAHN:- Is recompliance, i.e., a new test burn required
three years after the last test burn, or three years after the last COC?
MR. HOLLOWAY: I believe the regulation says you must submit a.
new certification of compliance, a revise'd certification or renewed,
whatever it is every three years, so that's irrespective of when you do
the actual tests. Again, so you have to certify within three years of the
Page 33
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previous certification.
>
MS. SASSEVILLE: if you're talking about that you did a trial
burn in between there, then I mean, was that your question? If you're
collecting the same information ... if you have the right information. I
don't see why you couldn't put that information into a COC and just
resubmit early and then use that to start your time frame.
(question inaudible)
MR. HOLLOWAY,: That's correct. The comment was in the handout
or in the slide. It says that the ... you have to recertify within three
years of the previous certification of pre-compliance. ' You're right.
That was a typo. It should have been certification of compliance.
.MR. RAUENZAHN: Next question. As EPA considers the no dioxin
testing scenario which I fully support, what chlorine levels will default
to no test? And if EPA does" not know the answer to this, what are they
doing to find out? .
MR. HOLLOWAY: That'"s a really good question. One of the
concerns we have is whether somebody will use a test method that has very
high detection limits, frankly. But if we can find a method or if "we can
find an approach-that, ensures that a method with a good detection limit
is used for chlorine. .And, by the way, I should also say that we also may
be concerned about brominated dioxins and.other halogens but so, if ...
we feel comfortable- that no feed streams are being fed to a device that
contained detectable levels of halogens at good detection limits, then I
think we will be prepared to say that dioxin testing isn't needed. But,
again, I don't know how we're going to ... we haven't gotten to do that
.yet. We haven't finished dealing with that issue.
MR. RAUENZAHN: .Next question. Somewhat related. How do we
submit a Part B application which must include a dioxin test when there
is no official guidance on how to set it up.
MS. SASSEVILLE: As usual, talk to your Region. You can also,
I mean, we mentioned a little bit earlier, some of the ideas that need to
be incorporated as far as worst case and also which I mentioned earlier,
there will be a guidance document out probably at the-end of April which
should help you out with that.
MR. RAUENZAHN: Next question. EPA's own published data
suggests that metal volatility is somewhat less than would be expected
based on uncertainties. Is EPA collecting data and continuously analyzing
results of low/high temperature trial burns to verify the need for these
tests? Is there some range that could be acceptable for operating
temperatures to limit the need, for t.wo trial burns?
MR. HOLLOWAY: That's an interesting point and the Agency will
be looking into the existing data base as we go through the upcoming-
rulemaking to see if there are ways we can simplify the regulations. So,
yes, we will be looking'into it. We haven't yet.
MR. RAUEHZAiai: next question, if I submitted data from boiler
A in lieu of, I suppose a trial burn. Tor boiler B during the 720 hout
extension after August 1992, does that wean that I could not burn at all
in boiler B assuming I do not burn more than 720 hour total in both
boilers?
MR. HOLLOWAY: I have no idea what that says.
MS. SASSEVILLE: That does sound kind of site specific, too.
I don't think it's something we can answer.
MR. RAUENZAHN: ... BIF only one stream burns at a given time.
Given also 2) two of the streams do not have enough material accumulated
to perform six hours of compliance test and 3) given two streams are high
BTU greater than 12,000 BTUs per pound, is it acceptable to not pecfoim
a compliance test on these two streams if they are analyzed. I guess this
is two streams that do not have enough materials to perform six hour
compliance test. And that's it for compliance testing. I'm also lucky
enough to be the person giving the next discussion, so is the slide
projector on back there, Andy? There you go. OK.
Management of Residues
MR. RAUENZAHN: What we have to discuss here is give guidance
in three points. The frequency of residue" sample on analysis; the
handling, and storage of bevel residues; a little bit about F039
constituents that first came out of the administrative study. You folks
also requested a review of what the requirements are and"we hope to go
over that by giving an example, finally at the very end.
; Now, for a frequency of residue sample analysis we recommend that
sampling and analysis be done daily. Now, based on John's discussion
yesterday and the setting up of statistical models, you can, based on
certain site specific factors, gain enough 'information about the residue
to sample and analyze less frequently than daiJLy. And some of those
factors are: historical data, knowing the variability of toxic
constituents in your residue. If-they, don11 vary a whole lot, you may
want to back off from daily. If you make changes in your operations that
may affect the constituents in your residu'e then you may want to sample
and analyze more frequently. If you never make changes to your
operations, then you may want to go over a longer interval. Liability
factors. You have to remember as this stuff accumulates, you're gettiiuj
more and more residue that you need to handle and you. need to deal with.
Obviously, if you sample and analyze over shorter periods of.time you
don't have that much residue to deal with at any one particular time. In
the event that there was a. non-compl-iance, if you're sampling daily,
there's not a whole lot of material and your liability factor is a herk
ot lot lower then they would be if you had six months worth 61"stu.il which
is out of compliance. And finally, storage factors which I'm goimj tu ijoi
to two slides from now.
Frequency of residue sample analysis. We recommend, as .a 1111111111.
weekly sampling and analysis .assuming you-can justify Lesu th.in ti.n I y
Page 34
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."!,.-. ,v).iin, li.iRf-d on factors I just went over.
.''ininqp of Bevill Residues. What you need to do is you need, to
!i".u i. Hi..". wast i» an a hazardous waste rather than a Bevill residue and
ili" ir.. will bf> no problems as Ear as Bevill compliance' is concerned. If
."ii til- til I ic i hand, l know you folks wouldn't do this, so let's say we have
.1 i-rMimnt kiln I hat takes all-of its cement kiln dust, piles it into a
'>i IVM of n quarry,. tests once''every six months, and God forbid, it fails,
I iiKl:: out .that, half of, that .residue is already thrown into the -quarry, it
IIIH -i major compliance problem at that point in time. The'only way you
nn avoid having a compliance problem as far as Bevill is concerned is to
inrsiiinp the stuff is a hazardous waste until you find out. otherwise, and
1 hon when 'you find out otherwise, go ahead and dispose of'it as residue
ru if you find out that it fails, go ahead and treat is as a hazardous
wa nIP . i
-j. - _ 'And-YO-U're_.also.going, to have to separate the-residue-by sampling
ppriods. If you were to decide to- sample daily, you would have to keep
your daily residue separated. That way you can tell the difference
between one day's residue and the-next day's residue. -If you test weekly,
you can tell the difference between one week and another week. One?
again, the rationale is, is that the sample" fails, it must be managed as
.a hazardous waste and if you keep your residue separate, your sampling
period separated, you know what's the hazardous waste and what's not and
it keeps things nice and simple"for you. .
F039 constituents. Now this came from the interim final rule.
I don't believe this is in your handouts. This is new late, breaking news.
Basically what the interim final rule did'is it stayed the Appendix 7 non-
metal residue limits. It set the F039 limits in lieu of those Appendix
'7 .non-metals. Unfortunately. we did not replace the default value for
chemicals not listed on the stayed list. What this means is that if the
toxic constituent is not listed on F039, the owner/operator need not test
for it. And we'll be sending out communications to everybody. By
everybody I imagine we mean the Regions first and I imagine you can get
the communication from the Regions from that point when that communication
.comes out. OK. . . .~
Now this is the overview. If there's a boiler and you're burning
'at least 50% coal on a total heat input or mass basis, then your facility
qualifies for the Bevill exemption. OK? If you don't burn coal, you burn
'natural gas, you don't have any residue, unless you're burning hazardous
waste, it's assumed that all the residue comes from the hazardous waste.
Point number 2 is how you go about determining the first point of the two
point test. You have to go out and you need to composite samples, . ten,
twenty-four hour residue samples to determine the upper tolerance limit
for each of the constituents you expect to find in your residue-. -I
imagine now that's everything on the F039 list. .Now you can .choose, not
to do this and go directly to 'and apply the .F039 limits and the metal
limits in Appendix 7. For some facilities that are doing that, it's more
stringent because your residue may 'have naturally a concentration higher
than what's published in F039 but if this is too much of a bother "for your
do, then that's up to the facilities determination.
OK. Now, after you've determined the upper tolerance limits every
day for some period of time, you need to get historical data. You need
to find out what's in the residue. That's one of the four factors I
mentioned and that help you determine your sample and analysis frequency.
And then you sample and analyze for these constituents and compare them
to the upper tolerance limits to make a Bevill determination. Let's
assume for now everything goes well; everything passes; none of them fail;
and based on this historical data, you sampled and analyzed for say a '
month. None of them have failed. They're all comfortably below your
upper tolerance limits or the F039 limits. You decide to back off on that
daily testing
and decide once a week. That's acceptable.
Next, after determining the upper tolerance limits, you start
burning hazardous waste, RCRA storage requirement comes into play. Once
again, you don't want to find yourself in a situation of piling all these
-wastea-in-, the corner of a quarry (particularly for the cement-kilns) ar.d
the dust is blowing everywhere and then he finds out later that' it fails
the Bevill test and he should have been managing the whole thing as a
hazardous waste the whole time. For that reason, store it in a RCRA
storage facility pending the Bevill determinations.
There's one more point. I would like to make. Based on
historical data, you can relax your sampling frequency. Once again, it's
based on those four factors .. possibly others, depending on the type-of
facility. ' If you have fairly consistent residue and it is below the
Appendix 7 and F039' limit's, you may decide to reduce your sampling
frequency. You can relax it more than weekly, even if you want. More
than our recommended amount, but it's been our experience that most
facilities are going weekly and that's the smart thing to do. But if you
can handle that much residue and you don't care,, the only real compliance
problem you can run. into when it .comes to Bevill is not properly handling
and managing hazardous waste. If you're storing it in a RCRA storage
facility and you dispose of it properly, you should never have a
violation. ' : »-.'
* '
i
QUESTION: Most of your slides are not in the new books, can you
provide copies? . . ' .
MR. RAUENZAHN: .We will include them in the transcript. OK?
For clarification, did you say that the default value for constituents not
on the F.039 list.were stayed and not replaced, therefore facilities are
only obligated to.test for constituents on the F039 list? That's what I
said. .
I I'm not so sure we can answer this one, but it(says, LDR analyses
are based on a single grab sample. Compliance levels and LDR are set at
99% confidence levels. Thus, per 10 to 20 samples, there is close to 100%
probability of failing. Has EPA given any thought to changing the
procedures to allow for outliers and natural data variability to enable
facilities to comply?
MS. SASSEVILLE: ' That's an LDR question. Unfortunately, ...
none of us works on that rule 'here. ;
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MR. RAUEMZAHN: And, well, let me give a atab at this. What I
think they're saying is the compliance levels that were set in LDR were
baaed on some 99% probability limits and that the F039 numbers who are
based on the 99* confidence interval, that should help you. OK? Because
the mean ia standing at a 50% confidence level. 99% should be over here
-- right?
(comments inaudible)
MR. RAUENZAHN: If there's a 99% ... I agree with what you're
saying but .... and if the residue you're analyzing is from the same
population of F039, I agree. OK? I think you're making a couple of bad
assumptions; your worst assumption is that Bevill residue is F039, which
it is not. But to get to what I think is your point, yes you may fail
1% of the time due to statistics. That is one of the reasons why we're
telling you that you've got to handle this stuff in RCRA storage
facilities. Because 1 % of the time you may fail through no fault of your
own. Is that what you're asking? If that's a fact... that's statistics.
But remember that your assumptions are faulty. Bevil! residue is not F039
and may have constituent concentrations widely different from F039.
That's why there is a first part of this two part test..
*
How often^Sliould the base line upper tolerance level be updated?
Is an evergreen approach of random non-waste ... oh; I don't understand
that .. that's not my repertoire, but every time you make a process
qhange, you have to update your upper tolerance limit.
MR. HOLLOWAY: If you make any change in your design or
operation, that could affect the base line, the normal . levels of toxic
constituents -in the residue, then you "have to reestablish your upper
tolerance levels. '
MR.. RAUENZAHN: You may want to do it every so often anyway
because there are situations where things that are'beyond your control or
things that you're not aware of may be going on in your system that may
be affecting the concentration of the residue so it might be a smart thing
to update them periodically: Is it required to do Bevill for burning non-
hazardous waste? Bevill doesn't apply to non-hazardous waste. So ...
i -MS. SASSEVILLE: That determination doesn ' t need to be made
because it's clear that the residues would be exempt. There's only a
question when you're burning hazardous waste and trying to figure out what
the effect of the hazardous waste has on the residue.
\
MR. RAUENZAHN: You mention that natural gas has no ash content,
then why must we analyze our natural gas ,for BIF metals? Isn't this a
waste of time and resources which could be better spent on real^issaes?
I guess I was answering to what the -regulation said as far as Bevill was
concerned. That it's assumed that for these don't have any ash.. For. any
high quantities of ash and ' that at that point if you do start getting
quantities of ash, let's assume that it came from your hazardous waste,
you know. '
MR.
HOLLOWAY:
Yeah. . That's true Scott and it would
certainly be the appropriate X guess and good if we could, the Agency
could establish default values for .levels of metals or chlorine or
whatever that might be in natural gas. But I don't think we've looked
into that. 1C we have time, if you guys have data you'd like to ptovide
us on levels of metals and chlorine what else would be important/
Organics? Toxic organics that could be in natural gas, we'll certainly
consider putting out some sort of guidance or interpretation that could
include default values. That could be zero or whatever.
MS. CHOW: Let me just make a comment on that. A while ago, I
received a copy of a document written by the Southern California Gas
Company regarding a study that this company conducted on its own pioduct.
This report c'ontains disucssions on the analytical methods the company
used to analyze their natural gas. They found that there were traces of
metals, such as mercury in their gas. Some of the contaminants may not
necessarily be in the product originally , but were -there as a result of
contaminations through the pipe lines. 3p, natural gas may not be as
clean as some of us like to think. From what I can recall, the levels
were not high, but they were there. Unfortunately, I don't have a copy
here with me. Yes, I will see whether I can attach a copy with the
transcript package. [The EPA is unable to obtain permission to release
this document at the time of the transcript.]
i
MR. RAUENZAHN: I'll stop and say, personally speaking, I know
of one problem in my home state of Pennsylvania as" far as natural gas .is
concerned. They're finding puddles of mercury under the gas meters of old
homes, which indicates to me that there's at least some metals in natural
gas. - . -
You stated that if you burn liquid waste and natural gas, not
coal, you assume that all the residues come from the waste, OK, it's the
same point. Is this EPA policy? Could it be communicated to the Regional
offices who keep asking for natural gas analysis for metals, ash, etc.
MR. HOLLOWAY: There-are two separate issues here. The EPA's
already stated either in the regulation or Preamble to the Bevill
regulation that if you're co-firing hazardous waste with oil or gas, then
your residues are not eligible for the Bevill exclusion because we're
presuming that the residues are more characterized by the hazardous wauLe
you're burning than anything ... any residue coming from oil or gas. The
separate issue is in complying with the feed rate restrictions or the feed
rate limits under the BIF regulation. You'need to know what's in aJ1 ot
your levels of metals and whatever that's in all of your feed stieainu.
Including natural gas, if you're burning natural gas. So, that's a
separate ... entirely separate issue. -
MR. RAUENZAHN: Next question says,- why frequent and expensive:
Bevill analysis if residues contain levels of BIF elements leas tlun that
found in .natural top soils we live with ev.ei.y day. _ . .
If your Bevill residue is t.liat clean,' and you ate assuit-il t licit /'"'
can back otf of frequent expensive testing, then that':; cei I ciinl-,: '
prerogative. But you need data. Do you have that, data? Tlu-ii ih'it'V;
fine. At other facilities, that may not be tiue.
Page 36
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H<)M'»pnwf;K.1 .. junt another point as far as Bevill's concerned
"in iiinpocfcor.s (at least at cement kilns facilities) they do
<>--iii. .inrpA storage facility and .you can get away with storing a year.'s
,n[ nt-uff- in there ... now I .don't know why you'd want to do that,
don't see how you could be out of non-compliance as - long as .you
t thai year's worth of stuff appropriately. So, once again, it's a
sile specific call that you folks .make, you know, based on your resources,
hriw expensive it is and what not: All those factors-get factored in.
Next question is addressed to you again, Sonya. You
mentioned t-hat ash extrapolation' is not .allowed if you have an air/_
pollution control device due to collection efficiency variability. 'What
about- a facility that does not have air pollution control device such as
natural gas boiler? Is it allowed in this case? If not, why not?
lot.
MS. SASSEVILLE: That's n&t something we've really talked about
MR. -HOLLOWAY: Excuse me, John. Another consideration we've had
does not only effect on air pollution control collection efficiency but
it's the issue of partitioning. How much of the ash is going to partition
to the combustion gas versus that stays in the bottom ash, or whatever.
And we just don't have and neither do you have enough data to fully
understand partitioning for metals or_ash or anything else. So, it's not
expensive to run a PM test, so you cannot extrapolate ash. You must run
a- new PM test. By ,the way, let me just finish. Guys, if you're
complaining about PM testing, you're in for a rude awakening under the new
regulatory regime. .We've been talking about dioxin testing and much more
comprehensive testing than we've talked about today, so I wouldn't be
worrying about PM testing. ' -. . ' -
(question inaudible)
MS.SASSEVILLE: At the least I.don't think it's something we
pould answer here. We wo.uld have to think about whether there can be
anything else that influences it.
MR. HOLLOWAY: That -does sound more reasonable, but again,
there's probably something that maybe we're not thinking about. Maybe we
can give it a try and try to d'eal with it in the transcript but, have you
'talked to the Region about it? .
(inaudible) f-
All right. So I.guess nothing's going - to happen any time soon?
MS. SASSEVILLE: Actually another good point that was brought
up is that there is; for things like this, a difference between, compliance
certifications and permits where the permit writer does have more
flexibility on the permitting process of what they accept whereas .for
interim status where it was set up to be self implementing, it is pretty,
prescriptive and so that Regions are really sticking to what's in the
regulations which doesn't allow for extrapolation. So, if this idea does
hold merit then it could be considered under a permit but probably not
-under the interim status. ' . ' -
MR. RAUENZAHN: Next question is more common. Please include
references for obtaining natural gas test analysis data. Other sources
.would be a better for this type of information. I imagine API [the
American Petroleum Institute] has a constituent list of a what a natural
gas would be. From what I remember, 'though, natural gas varies a lot
across the nation. So, your local gas "company may be a good source. SAE
[the Society of Automotive Engineers], with all the natural gas vehicles
'that are going into fleets since the Clean Air Act Amendments of-1990,
they must -have-lots-of data also1. There are better places to gst this
kind of data_ than from'-us.
A Tier 1 BIF, I guess 'this relates to the previous issue. A tier
I BIF burns hazardous waste that has a very low ash content. If repairs
to the inside of the boiler are necessary, is it required to treat any
thin film coating of residue on the equipment as hazardous waste?
(
MR. HOLLOWAY: Any residue that you generate., as a result of
maintenance, has to be managed as hazardous waste, if the BIF burns a
listed hazardous waste or if the wastes exhibit a characteristic., That's
point 1. And if you're burning a listed hazardous waste, then the
residues based on the derived from rule are considered to be hazardous
waste. If you're not, burning listed waste, then you need to see whether
the residue exhibit a characteristic.
MR. RAUENZAHN: Is there any means of obtaining some of these
guidance documents electronically, i.e. on bulletin boards?
MS. SASSEVILLE: .Not at this point. It might;be something we
do sometime in the future, but at this point, np, they"'-re not available
that way. .
MR. RAUENZAHN: OAQPS does have their technology transfer
network and we depend a lot'on them for our sampling and analysis methods.
You can get on their technology transfer network, as I said. There are
several resources and they're available to giving you validation of.test
methods and also some technical publications for problems people have had,
how they got around them and whatnot. So ...
, MR. RAUENZAHN: Thank you. 'The OAQPS Technology Transfer Network
modem line is 919-541-5742. And there's also a number for help which I
don't know since I di'd'n' t" know this one. [NOTE: The help line for TTN
is 919-541-5384.' For the Emissions Measurement Technical Information
Center, EMTIC, the help number is 919-541-5222:] 'That's all.
MR. HOLLOWAY: Emily, should we-start in 15 minutes from now rather
than waiting for 10:-15, let's speed this up, all -right? So, you want to
start again at 5 after 10?
Page 37
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MR. GIGLIELUO: There are sixteen people that asked for the ERP.
I have the copies in the back Cor those sixteen people. I also have
additional nine copies for someone vho wants it and I need to see Maryanna
Ramos...
(Bnd of proceedings as recorded.]
PROCEEDINGS
MR. HOLLOWAY: ... I will go quickly on upgrading the technical
emission standards and we want to talk about the driving forces for
revising those standards and then give you some idea of our current
thinking on some of the key issues. But again .bo put things in
perspective. The waste minimization combustion strategy has a number of
components. Let me give you a quick overview on where we stand on each
of these. With respect to public outreach, I think everybody knows that
we held a national roundtable back in November of '93, a forum of virtu-
ally all the. stakeholders on these co'mbustion regulations, not just the
BIF rules but the incinerator rules as well. We had over 200 people
attending and as a follow-up we have Regional roundtables scheduled in San
Francisco, Chicago"!- Houston and Atlanta. The one in San Francisco is the
first one schedule* for April 16th; the one in Houston' will be second.
That's scheduled *for the 23rd and then Chicago is next and Atlanta is the
final one. They're a week apart on Saturdays, and we will try to get as
many local citizens and public interest groups attending as possible.
Waste minimization. The waste minimization piece of the
combustion strategy, we've already provided guidance for what's called a
program in place back in May of '93. What that really means is the
requirement for all generators and treatment 'storage and disposal
facilities to -develop a waste minimization plan. And in last Kay we
developed a guidance to a system in developing those waste minimization
plans. Just recently in December we sent out letters to generators and
their CEOs advising them or requesting, recommending that they make those
waste minimization plans available to the public. .And-finally, we're in
the process now erf developing an overall waste minimization strategy.
Facility permitting. We discussed this yesterday. This is
another major feature of the strategy. I think we've already called in
all of the Part B applications, for commercial interim status facilities
and of course, we're giving top priority to permitting all of the interim
status facilities starting with the commercial guys and then moving to the
on site facilities as opposed to permitting new capacity.
Public involvement in the permitting process. We are currently
developing a proposed regulation to help ensure public participation.
That regulation is scheduled to be proposed in.the Federal Register some.
time in the window between this May and July. A couple examples of the'
requirements are 1) each facility, any facility would have to conduct a
public hearing .". . a public meeting before submitting their Part B
application. Another requirement would be for a public notice of the
availability of the trial burn plan.
Risk assessment ia also a major part oC the combustion strategy
with respect to upgrading the emission standards. The Agency's current
approach is to require a risk assessment for all new permits to insure
that the emissions in fact are safe. We've developed what's called an
addendum to indirect exposure ... to an existing indirect exposure
guidance document. By the way, this risk assessment is different from
the, as most of you know, it's different from the risk assessments that
we've conducted to date in the combustion program and much different than
is included in the BIP regulation. It involves multi pathway indirect
exposure assessment. And as I said, we've developed what amounts to an
update or a refinement to an existing guidance document that the Agency's
Office of Research and Development had developed back in I think it's 1989
or 1990. We've submitted that addendum to EPA's Science Advisory Board
for review. We've also asked for public comment on it. We've published
a notice in the Federal Register requesting public comment on the addendum
and we're in the process now of revising the addendum. I believe the
revised ... the addendum will be made public sometime ... will be ready
for public distribution in late spring or summer. In addition, we're
developing a guidance on how to conduct a risk screen so that you can
avoid the time and expense of conducting a comprehensive risk assessment
and I understand the guidance document- on how to conduct a screening
assessment will also be added roughly in that same time frame, by some
time "this summer. Of course the advantage-of a risk screen is that it's
quicker and cheaper than a comprehensive risk assessment but the downside
is the risk screens are conservative, very conservative'and because of
that you might fail. And if you fail the risk screen, of course, you
really don't have a choice but to get into'the comprehensive assessment.
Enforcement. We probably don't need to discuss that too much with
this group. .1 think you're pretty much aware of what we're doing in the
enforcement area.
Now let's focus on the emission standards.piece of the combustion
strategy. We really have a couple of phases that we're dealing with on
the emission standards. One is the rulemaking process that we're going-
through, just starting now. And secondly, however, we want to apply
upgraded controls, particularly on dioxin and particulate mattei
immediately during the permitting process. So, let me talk about both of
these. First> with respect to the rulemakings, let me give you some idea
of why we're doing this, what the schedules are and what we're thinking
about doing on some of the key issues. 'Why are we doing it? The Ag'ency
frankly is concerned that our-existing standards are not necessarily
protective, or don't ensure safe burning in every situation. Fo? example,
the existing regulations don't have limits on dioxins. Another example
is, as I've said before,, a number of the BIF regulations for metals foi
example and chlorine are purely- risk based regulations based oij site
specific risk assessment. Those risk assessments only .consider diteul
exposure through inhalation, don't consider multi pathway exposuie. iJo
.for a number of.reasons, those and other reasons, we're concerned_tlidti ihe
existing regulations may not ensure safe burning. That's not.to s.iy I h.it
facilities out there, that your emissions are actually-posing a liuk The
concern is that our regulations don't ensure that, your emissions me a,id-
The cement people in particular are fond of-standing up in public; iiu-.-t ni-|:>
and saying that they're only emitting -a tenth ox one pet cent .it i l.u-
Page 38
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il l;.w.il...|.. "iii i.-.Hi oils, or t.he emissions allowed by BPA'.s regulations and
i !'. ii ; :M,,];-I hiiKj that we want to put a stop to. Another issue is as a
i'-.-:iili .,f IMF | j t iqat .ion, we've entered, into settlement agreements' to
I'1 "\'-'' ""l promulgate revised standards for ,BIFs, and incinerators too,
I 'i Mill iii.il I ft " ' .
what..1 s'tIIP schedule? We've broken the rulemakings down into two
p.h.iKorj wii.li Mie first phase'including incinerators, .kilns and melting,
.jmHhinq and refining furnaces and 'those regulations' are scheduled to be
piop"«pii by September of '95:' We hope, to be able to beat that date, at
l»nst our management does. We will be promulgating, we're obligated to
pmmulqate those regulations'by the end of '96. The second phase will
iiK.-ludp boilers and industrial furnaces. We've split them up simply
. beraur.p we just don't have enough resources, don't have enough people to
deal with all source categories at once. We would prefer to do the.m all
'Fit-once, we just can't handle the load. ,
.. - _^.-i-jJ!-2me__?£- _fcJl§_._k_eyjissues__or_.cur_r_en.t. thinking_ on key -issues One,
you'.ve heard about this. We are considering whether it is' appropriate to
-establish technology^based or risk-based standards. And I - think it's
fairly clear that we will be establishing standards that reflect the ;use
of best operating practices . or technology-based standards. We will,
however, certainly consider residual risks by one or more approaches. The
options that, we're now looking at, one option .is to use the approach as
outlined in the Clean Air Act Amendments which established . . . which
requires the Agency to establish the MACT standards . . . _the maximum
achievable control technology standards. And under the Clean Air Act, the
MACT process, the Agency has to revisit these source categories within
seven years of establishing the MACT standard to determine if the residual
risk is significant. And if the. residual risk is unacceptable, then the
Agency would of course rachet down on the MACT standard. That's one
option. Another option is to use what we call a generic risk assessment
on the national standards. The national standards for dioxin or PM for
example. And here, what we can do is identify some reasonable worst case
scenarios, look at model facilities, assume a high emission rate, we'll
assume emission rates at the limits, assume some worst case scenarios for
exposure, dispersion, whatever and show by generic risk assessment that
these performance standards, the regulations appear to be protective in
most cases. Another approach is to use site specific risk assessment.
Either a screening model, a comprehensive approach or maybe something even
simpler than a screening model where if we were to use a generic risk
assessment on the national basis, then maybe on a site specific basis all
we'd have to do is determine whether the- facility's features meet the
conditions of .the generic risk assessment. If so, no more questions
asked, it should be protective, if not, you fall outside of the generic
risk ^assessment assumptions, then maybe.you'd have to go "into either a
screening model-or a' comprehensive risk assessment approach. And there
may be others. I think we'll be using a combination. I personally think
we'll be using both generic and site specific risk easements but we'll see
what happens. To the extent we use risk assessment, to the extent that
r-isk assessment affects the emission standards, the regulations, it's
Likely that the risk assessment will only be used to rachet down on the
emission standards, not to back away from the technology-based emission
standards.
Now, haying said that, we also are very concerned about applying
reasonable technology-based standards, if in fact the technology based
standards require emission levels that go well beyond what a risk
assessment would require. Again, if the risk assessment, let's say a risk
assessment shows that a dioxin TEQ of one nanogram is just fine, yet our
technology-based standard would say that these facilities can easily meet
a technology based standard of .2 TEQ. Well, in applying a ,2 TEQ, for
example,.we would certainly want to consider economic impacts on various
folks. Again, even under RCRA we would do this, again because we're going
beyond what the risk assessment calls for, and as you know, RCRA is
primarily a risk based statute. So, a couple of approaches ...and by the
way, these .approaches also are very consistent as many of you know, with
the Agency's mandate under the Clean Air Act, under the MACT standards.
The MACT standards or the MACT process clearly allows the Agency to
consider, if not require, the Agency to consider or to develop different
standards. For example, for new facilities versus existing-facilities and
-i allows-us to consider different standards for small versus "large
facilities. Obviously we're talking about reduced standards, -less
stringent standards for small facilities and for existing facilities.
Again, it remains to be seen how this plays out.
There's another major issue and that is whether we should
promulgate the regulations under the Clean Air Act Amendments or" RCRA
authority or maybe even both authorities. And .the bottom line is we
obviously think it makes sense to promulgate these regulations under joint
authority. We don't think it makes sense for two different agencies in
the. office in EPA, two different offices in EPA to be developing standards
separately tor the same source categories. Cement kilns, incinerators,
boilers, whatever.' So, we have ... we are coordinating efforts with them.
We've had numbers of meetings at the staff level and the office director
level to coordinate our efforts and again we think it makes sense because
it avoids duplicative agency effort and obviously it helps you guys
because it avoids piecemeal regulation. We wouldn't be establishing for
example a PM standard.-of .-01 and say a year'from now anti then have the
Clean Air Act turn aroynd and establish a standard of'.001 a year or two
later. .,.'"
Now, so the current,thinking is to promulgate regulations for all
these source categories under authority of both statutes, Clean Air Act
and RCRA. But now, tinder RCRA, since RCRA is a risk based statute, we
need to ensure that when we apply the MACT process and develop the MACT
standard, we need to ensure that the MACT standards meet RCRA concerns.
And there are at least two concerns we would have under RCRA that might
go beyond, that might require something maybe more stringent than the MACT
process would drive us toward. One issue the residual risk. I mentioned
that earlier. Under the MACT process residual risk doesn't need to be
considered until seven years later. Under RCRA, frankly, we're
considering just what our options are for considering residual risk as I
mentioned earlier. ' Do we have to conduct a generic risk assessment? Can
we rely on site specific risk assessments, or can we just wait, even under
RCRA, and deal with risk like it's going to be dealt with under the Clean
Air Act. Wait"seven years later. .
Another concern is, does the MACT process ... is it going to drive
us always to do what we think are best operating practices? .In some cases '
Page 39
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in fact, the HJVCt process, uhich let me give you an example ... the MACT
process says you take the ... you look at a source category and i£ you
have oore than thirty different sources, if you have a data base for more
than thirty facilities, the MACT standard £or existing facilities is based
on the average of the best 121 of the technologies. If in fact applying
that formula, and by the way there's lots of flexibility as you might have
guessed into applying that formula, but if in applying that formula we
determine that the average of the 121 percent of the technologies really
doesn't represent best operating practice because for example, maybe the
industry isn't doing a very good job of trying _to control a given
pollutant and could" in fact have done a lot better job with existing
technology that has a reasonable cost, if that's true, then we might
determine under RCRA that the MACT process isn't good enough, doesn't give
us what we think is best operating practices, we have to go beyond that.
An issue that we're looking at is whether we should establish
separate standards, emission standards for metals, dioxins, PM, whatever,
for each source category, boilers, cement kiln, smelters, whatever,
separately or whether we should establish generic emission limits and
generic standards for a source category that might be called hazardous
waste combustors. There's,a lot of sentiment, frankly, for establishing
a generic emissiop-limits for hazardous waste combustors. The thinking
goes that hazardous waste should only be burned in devices that can do the
best job. If a 'given source category such as cement kilns or boilers
cannot burn hazardous waste as efficiently as other types of burners can
achieve, then maybe they shouldn't be burning hazardous waste.
On that point, let me back up. Current thinking is to establish
generic emission limits for all pollutants except possible for particulate
matter. We're leaning very heavily toward, generic standards for
everything but PM. On PM it's very much up in the air whether to go with
source category specific standards or generic standards for a couple of
reasons. Frankly, PM is a poor surrogate for metals emissions when you
look at what metals emissions you actually achieve for a given PM standard
across source categories, the metals emission levels can vary all over the
place at a_constant PM emissions rate. So one problem is PM,is a poor
surrogate for metals emissions even though that's one. of the reasons that
we're limiting PM. Another reason that we're considering, or that it's
very much up in the air as to which way we'll way for PM, is that some
very preliminary data analysis indicates that the PM standards might be
drastically different under the MACT process. Might be drastically
different for various source categories. So, -the economic'impacts could
be really substantial if we.had a generic PM limit. '
OK. I've talked pretty much about the rulemakings, the longer
term effort, now let's talk about what we are doing in the interim to
insure that as permits are awarded between now and the time new rules are
promulgated and become effective, to be sure those permits ensure safe
burning. And what we want to do is use what's called the Omnibus Permit
Authority to ensure that permits are safe. As I think most of you heard
before, the Omnibus, Permit Authority says that the EPA permit writer .has
the authority and the responsibility to apply additional controls to the
permit beyond those that would be dictated by the regulations Co ensure
that the emissions are protective of human health, and the environment.
And since this is outside of the normal. rulemaJcing process, however, the
permit writers will explain what their concerns are on a case specific
basis and of course, listen to and respond to comments from the
facilities. It sort of amounts to a. mini-rulemaking, rulemaking on a
specific site as opposed to a national rulemaking. In order to help out-
permit writers and also to give facilities an idea of where we're heading
with our dioxin and PM standards, we are now developing a technical
resource document called CETRED, that's the way we're pronouncing the
acronym, combustion emissions technical resource document, that is going
to take the available data base we have and apply the MACT process to it
and.based on that preliminary analysis, it's preliminary because it's
based on available data and frankly, there are a number of things we don't
understand now, and it may be many months before we do understand. For
example with respect to dioxin formation. Anyway, we're taking the
existing data base, existing knowledge and applying it ... using the MACT
process and identifying what we believe would be reasonable MACT numbers
for dioxin and PM and again, our permit writers will be using this. This,
will be a public document. The schedule' for making it available at the
. earliest, sometime in the middle of May. And it might be a little later
than that, but my best guess would be it should be available in the middle
of May. . :
To give you some idea of where these numbers may be heading,
everybody's aware I'm sure that when the combustion strategy was announced
last May three were target levels given for PM and dioxin. The target
level for dioxin was 30 nanograms, total congeners. The preliminary data
analysis shows that the MACT technology can achieve a total congener limit
level well below 30 nanograms. Well below. We're still looking at a lot
of issues. 'One of which is whether to establish dioxin limits on TEQs or
total congeners or both. The current thinking is that we will at a
minimum establish the dioxin level as TEQs. As a TEQ on a TEQ basis and
we might also, in addition, establish-a total congener level. The logic
for establishing limits on both would be our concern that health effects
data over time would show that some of the congeners we now think don't
pose significant risk could in fact pose significant risk. So, to be
conservative, there is some sentiment toward limiting both TEQ and total
congeners. By the way, the data indicate that a TEQ limit that might
represent MACT technology would be close to the EC target level of a tenth
of a TEQ. Of course, our technology-based dioxin limits, as opposed to
the European community target level, 'would be a number never to be
exceeded. It's a number never to be exceeded while under the EC target
level of a tenth of a TEQ as I-understand it, 'meant to be an average
value, as is as you may know the dioxin limit for MWCs. The existing
Agency dioxin limit for municipal waste combustors is .as I understand it
an-average level not necessarily a level never to be exceeded. So our
implementation approach would be more.stringent than either what the EC's
looking at or how the Agency currently -regulates MWCs. With respect, lu
MWCs, let--me -also point out that the Agency: is., reevaluating the MWr
. standards and expects to propose in the Federal Register ''revised .iioxin
limits arid PM Limits for MWCs by. I believe this September. Ami tin-
preliminary analysis indicates that both the dioxin and the PM It-vi-la win
be substantially lower than they are right now. And in d.UI'iti.m on
dioxin, under the MWC, revised MWC standards, they will be t-.st
-------
'" !.»'. M.inkin,, ir. to- oRtnblish dioxin limits on a TEQ basis-as opposed
i lir- nn i i-tit .ippioach of toi.nl congeners. I believe that's it.
"ii'i'ifiitr!? I figured if I didn't get questions from this, they
. If- we obtain our 'Pa it B today for -BIFs, would we be shielded by
|5-"UMii f 1'iin .the..combust ion strategy changes? Do you have an idea, Sonya? '
MS. SASRKVILLE: Well, first of all, I think 'it's'going 'to-
I'" h.-u.l to get. a permit for a BTF at this, point without having many.or
"'"Rl «f. the combustion strategy elements incorporated for any rule changes
th.vt hflpppn afterward. It's my understanding, if we're partially using
<'l'«an Air Act authority that there wouldh'.t be a permit as a shield. -That
-Mm limits would have to take effect even before modification to the
P-imit. We can recheck that for when do the ... send out the minutes.-
.I'ul I'm pretty sure that's the'case.
"^ '' -MR: HOLLOWAY: We're talking about in 'the "interim prior to
establishing regulations under joint authority.' No, you're absolutely
riqht. So, if we were to follow through and issue regulations under joint
authority Clean Air Act and RCRA, 'then J. think you are right. Then I
think the Clean Air Act requires compliance within, I think, three years
of tire MACT standards, and I think you're right, it would be irrespective
'of whether you already have a RCRA permit. You're right.
Where can you find a copy of the combustion strategy or the
principal components of the strategy? The RCRA hot line has copies of the
- information, the press release.and accompanying documents that describe
the strategy. .
x Who is the main contact to get information on the risk assessment
portion of the combustion strategy? Contact within the Office of Solid
Waste; Alex McBride. 'If you wa'nt ... talk to Alex about things such as
t;he screening model and general application implementation of the risk
assessment. If you have questions about nuts and bolts of the methods,
of the data inputs, whatever, the^ algorithms, then you should be talking.
to the'Office of Research and Development and the contact, there would be
Jphn Schaum, but I'm sure he's- in the locator.
How does EPA. plan to keep tabs on over zealous "permit writers'who
choose to over use or even abuse their Omnibus Permit Authority. What are
t.he checks and balances? .
I can't imagine that would ever happen. In 'reality, the permit
writer has to explain to you, as we said, as our guidance documents, an
old guidance document"says, the permit writer needs to explain to you what
his concern is with respect to dioxin, PM, explain the.risk methodology
that he thinks is appropriate to use, if any, to identify more appropriate
standards. He needs to explain where the dioxin and PM levels came from
that are going to be presented in CETRED. Using the supporting
documentation we'll provide he should be able to answer all your
Questions.
MS. SASSEVILLE: As -far as the official checks and balances.
certainly the Permit Appeals process is there, not that we want to
encourage people to appeal, but as far as legal checks and balances, there
is the appeals process. One thing to keep in mind that there were a
number of appeals of metals limits that were set for incinerators under
the Omnibus provision and most of those permits were upheld. So as far
as just the idea of using the Omnibus provision, that has been upheld
widely so it would only be if there is some specific use of it that's not
appropriate that there may be a problem.'
MR. HOLLOWAY: Another question. Will the MACT rule be under
RCRA or Air Regulations or both? The MACT rule, the"'MACT standards are
a Clean Air Act Amendment standards, but what I was trying to point out
is that Agency intends to establish technology- based standards for your
industry under joint Clean Air Act and RCRA authority. It goes on to say,
if MACT is duplicated under RCRA, how will EPA avoid the double jeopardy
of multiple program penalties and enforcement actions on a company who
might only have a single non-compliance identically covered by RCRA, MACT
and by a Clean Air Act (inaudible). Issues we have not yet even begun to
discuss with the Air people, the MACT people, is how we would implement
these regulations. And that's an important issue, we just haven't gotten
to, it yet. '
If limits are set on dioxin and furan emissions will this be done
using a scientific risk assessment or will it be done in an arbitrary
manner, such as'the German standard? Certainly, under the.rulemaking, as
I said before, we're leaning toward a technology-based approach for the
dioxin standard and we'll go through ... it'll be scientific approach,
looking at existing data as well as data"we intend to obtain over the next
several months both at the research level, lab scale level, bench scale
level as well as fuH scale data.
Research shows that 290 NMs, whatever that is, wave length UV
light from the sun destroys dioxin. This was shown in ... Sevaso . . .
wherever it is ; . . Italy. why is the atmospheric discharge of small
amounts of dioxin the.top priority of emission concefhs?
- . * *
4 "
Did many of you attend the dioxin seminar? The public dioxin
seminar, the EPA, ASME jointly sponsored dioxin seminar, when was it? A
couple of weeks 'ago down in the .Research Triangle Park. There was a
speaker, Dr. Linda Birdbaum, an expert on dioxin toxicity and exposure,
whatever, was explaining the concerns. If you have a question about that,
talk to Dr. Birdbaum. '
MS, SASSEVILLE: If the question was related to the idea that
maybe dioxin isn't persistent in the environment, that's certainly not
correct based on our data which indicates that there are high levels of
dioxin out there, especially in some areas that acts kind of ... sinks ...
like the Great Lakes', for example. So it is persistent in the environment
and the levels seem to be on a general increasing trend. So, they do seem
to be persistent. I think we hear that they've somewhat leveled off right
now, but there's no guarantee that that will persist.
COMMENT: A clarification of what you said was (inaudible) The
second point that was made here at- the conference was that hazardous waste
Page 41
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consideration ia (inaudible)
MR. HOULOWAY: I think in summary the comtent relates to why is
the Agency worried about or so concerned about dioxin. emissions from
combustion sources. Aren't there greater things to worry about, more
prominent sources o£ dioxin emissions and the answer today is the same as
it was when you raised the question four times at the dioxin seminar. The
Agency has two separate Congressional mandates to control toxic emissions
from hazardous waste combustion units under the Clean Air Act as well
under RCRA and we're going to do that until the statute changes.
What is TEQ with respect to the dioxin discussion? That's a good
point. We use a lot of acronyms. TEQ relates to a toxicity equivalence
approach where the toxicity of various dioxin and furan congeners are
related to the toxicity of the most toxic congener which is 2,3,7,8 TCDD.
Some tetra through octa congeners ... for some reason' those are the only
congeners considered, I don't know why. Some of the congeners within that
band are considered to have zero toxicity compared to 2,3,7,8, while
others are considered to have a toxicity of a tenth of 2,3,7,8, and I
don't know what some of the other ratios are, but the"idea is to have a
toxicity equivalent compared to the most toxic dioxin congener.
With the incije'asing tightening of requirements .and the possibility
that the number of viable outlets for waste treatment- are.diminishing
coupled with the realization that pollution prevention will not likely get
us to zero, what is the Agency's current thinking on how industry will
Handle its waste arid if site specific BIFs are closed, I guess on-site
BIFs are closed, is the Agency considering the increased risk associated
with transportation? Well, in the first place, based' on the data we have,
it looks like it will not be that difficult to comply with the dioxin and
PM levels that we're considering and it is not that expensive. I'm sure
you might have opposing views on that- and you'll have an opportunity
during the rulemaking process to give us your thoughts on that and
frankly, even earlier. So, with respect to shutting down the on-site
facilities, one of the things as I tried to stress, we want to take into
account and that is the opportunity or the possibility of establishing
less stringent standards for small facilities to the extent that you've
got a small on-site facility, not all on-site facilities are small, but .
if you have a small on-site facility, then there certainly is some logic
to have a less stringent standard. The mass emission rates are lower from
a small'facility. Small combuster, and in addition the economics ... the
cost of a CEM is a greater portion of the capital cost, for example, or
the cost of a retrofit to comply with the dioxin standard is a greater
cost of a greater portion of the capital cost for a small facility than
a large facility. So, if in fact the technology-based standards drive us
to levels ... to emission levels that are well below any risk-based
standard, then we will consider economic impacts as needed.
The. -question was, are. we going to consider risk from
transportation, I guess storage and transportation and then the perhaps
it could' be argued that when commercial ,off-site facilities take waste
from a number of generators, there's less certainty as to what they're
burning and possibility for uneven operation. All those are real concerns
and we hope tp be able to take those into account during the rulemaking.,
Are there thoughts to lower the PM standards on BIFo? Yes. The
Administrator has publicly given some lower numbers such as lowering from
a .08 to .015 as her viewpoint. When the dust settles we'll have PM
standards that are ... let me slow down on PM. On PM, I'm not sure where
we're going to end up. Some oC the ... the target level in the Combustion
Strategy was .015 grains; the current standard for all hazardous waste
conbustors is .08. Some of our data indicates that some source categories
can get well ... can achieve levels well below .015. And as I said
before, the MWC standard that's now being revisited is going to end up
being ... there's a good possibility" it will be well below .015. On the
other hand, there are other source categories that when you apply the MACT
process indicates their PM level would not be that low. So,_ I don't know
where we're going to end up on PM.
.Where does the Agency currently stand on the allowable ambient
chlorine standard? It's my understanding that this value is being
revised, is that accurate? And,when will.it occur? I understand that
some of the, in fact,- some of the CMA members have made available to the
EPA toxicologist at Research Triangle Park, North Carolina, some new ...
I guess it's not new now ... some health effect data that we didn't have
available when we wrote the BIF regulation that shows that the ambient
standard for chlorine ... that the acceptable ambient level for chlorine
should be substantially higher than we used in the BIF' regulation. And
in the communications we've had with these people, I guess we said two
things. Primarily to the CMA reps. One, if the Agency toxicologists are
in fact convinced £hat new data exists such that the level should be
revised, we'll certainly take that into account in fixing the current.
number, but as a practical matter, unfortunately, we've got our hands tied
moving forward with the Combustion Strategy on all these schedules and I'm
not really sure how quickly we can move forward with some sort of
technical amendment or this would be more than a technical amendment ...
. some sort of rulemaking to provide notice and.comment on the new number
and then promulgate a new number. " - .
Just as an update, I haven't heard anything on this issue. I
forget who we we've been talking to. .We've been talking'to some of your
members. I haven't heard anything on this .issue in over two months and
I''d practically forgotten about it until about last week when I was trying
to think about some of the questions I might be getting today. And it
occurred to "me that nothing to my knowledge has happened on that. I
haven't heard anything from a toxicologist yet as to whether they've been
convinced by you guys arid until I do, I'm focusing on other things. Yeah?
(comment inaudible)
MR. HOLLOWAY: All right. ..I guess I asked for it. All light.
OK. Currently 60% plus of air borne air pollution conies ftoin mobile
sources. If headquarters doesn't know'the answers to these question:;,
what makes you- think that the Regions will provide better, it any.,
guidance? The point of us directing you-to:'the Regions and the staU-u in
riot because we don't necessarily know the answer. We can ceituinly onii.-
up with an answer among ourselves, but we just-., a lot of Lheue' i-.s-.tn,-:,,
especially the ones that we're trying to pass o££ deal willi site :;p,-.-ifn-
issues and we .don't know the issues.. We don't have t.h« tint.- ti. -j.-i
Page 42
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''';' ' in.. .'J'iio !3|.i«>ri f ic issues: That-1 s - what the Regions are for.
..n ' wlr. I hp A'lency has Regions. It seems like a lot of people are
u'-','i n".l llniiKjli.bli.it the Regions may not have the time to provide the
-- '-
I lion't-..Know how to deal with that other than I mentioned this to
:.'innl,.,ily ,11 the'break, if you try to communicate with the Region and they
jiu:i (inii'i. have time to deaf with' you, and frankly', things are going to
qoi. wnrnn in t.hat respect rather than better,, maybe all'you .can do is
ioc.'uinput: i he problem you're having and what action you plan to take
hojinifH.; of that problem and justify that, action. Justify why you think
t lin.1 net"ion meets the spirit and the intent of the regulation, if not the"
. oxact Ifttt.er of'the law.. Yeah, Dennis? .'...';
--.- -i ;'QUESTION: . _Thi.s__group_.of___peoplpr_deals_uith,_RCRA as a bedy-iv. ;
the whole, "of RCRA and we attend'a lot of conferences here in Washington
on the'subject of waste classification, land disposal restrictions, the
whole body that is RCRA. Do you know whether (inaudible) do we get the
kind of counsel that we in. the (inaudible) and, that is you go to the
Regions for the answer to a lot of these questions. If all of RCRA, I"
submit all of RCRA was administered in this fashion, we wouldn't be able
to get along because we would be trying to get interpretations -on
thousands of issues at the Regional-level. We really think you need to
think carefully about the message that you're getting from'this group that
the Regions are not being responsive to this sending .that you are
undertaking. You're sending us to them and they're kind of throwing up
their hands. And this group is in the middle. '
MR. HOLLOWAY: I understand exactly what you're saying. I can
sympathize and really, what in effect I think we're saying is, although
I don't like it ... is the process ... the way the process I .guess is
going to work, if it works at all, is that we send you back to the Region
then it's up to the Region to find the time.to deal with all the site
specific issues and understand exactly what your facility looks like and
why you '. . . what problem you have and why you think your fix.makes sense
and then often the Region would then turn and check with Headquarters,
with other Regions to see if your approach or if their response "to your
Request makes sense. All that takes an awful lot of time and the Regions
just don't have the time to do that as for the most part! So, I don't
know what the answer is. -I understand the problem. Something, I guess
we need to work on. .
COMMENT: I was going to address this issue finally in March. The
thing.'that people have to realize is that number one, we deal with the
Regions on a routine basis on the phone an enormous amount of time. OK?
(inaudible) (tape stopped) '
stuff out to the Regions, more and more stuff out to the states. If you-
really feel this strongly that you are not getting the input that you
need, OK, to be perfectly honest,' there's not much that we can do at our
level. I-mean, we spend an enormous amount of time w'ith the individual
Regions and enforcement cases and I feel we provide them with answers from
. a Headquarters standpoint. I personally have never been called by anyone
in a.regulated community saying, the Region is not giving me any kind of
answer. I haven't been called. I don't.know if Bob's been called. It's
just ... I haven't heard it and if .... (comment inaudible) well, that's
fine but I'll tell you the reality of it is, you have to do it at a much
higher level than sending it to Bob and me.
It is very unlikely that we can provide the site specific kind of answers
that you want from Headquarters. We're a finite number of people and we
just don't have the resources to do it.
MS. SASSEVILLE: Something to add to that is that, you know, we
-arc sympathetic to your eoneeinsi, but jusc to explain the position tfiat
we're in, -there have been times occasionally, when someone from
Headquarters has tried to work with the facility on a site specific issue,
either because they weren't aware of the policy or weren't thinking about
it..- And inevitably we end up answering the questions wrong and the reason
is because the Regions always know'some site specific fact that ' we
weren't familiar with just because the Regions are out at the facilities;
they are in more regular contact with the facilities and so it's not just
an issue of not having time but we frankly just can'.t do as good a job
unless we spend so much time with one individual facility that we're not
going to be able to do the national work. So, that's a big part of it'
too. ',''
MR. HOLLOWAY: Another question. Will generic standards for all
combustors be acceptable under the Clean Air Act? That's a good question.
I should have mentioned that. Generic standards would be acceptable under
the Clean Air Act provide'd that the generic standards were at least as
stringent as the MACT standard would be for each individual source
category. Thinking further about that, I don't know Vh|t case we would
have to make, if any, to justify going beyond the, MACT"standard for source
category to require compliance with the generic with, say the RCRA generic
emission limit. I'm not sure whether we'd have to make a case to go
beyond the MACT floor or above the MACT floor, as they call it, for that
source category. "
Let's 'see, what's next on the agenda? Did we ....since Houston
is going to be signing off- . . . are they like gone or did we ... well, I
was going to say, I don't know whether Emily or Ken might have had a few
words of wrap up,- but if we've already lost them, then we can decide here
what we want to do. Do you guys want to try that? .
MR. GIGLIELLO: ... the reality of the situation is that I
think the Agency is going to be a decentralized organization in the near
Suture. Our reorganization basically is empower, empower, empower. And
I'll tell you, the reality of it is, we are trying to farm more and more
Wrap-up (CMA fc EPA Parties)
MR. GIGLIELLO: I'll, try to make this quick. The first thing
I want to do is try to get everybody to fill out the evaluation forms.
Whenever we do any seminars like this, we really need the input, so I'd
Page 43
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like people to fill out those evaluation forms, give them to Cindy, give
them to whoever, so we could have those.
The other thing I wanted to say about the workshop. One thing
that would have probably made this more useful for all of us is if these
questions cane in before the workshop. As you've noticed, we've probably
gotten about, and I think my last tally, over 250 questions on our little
3x5. And we really tried hard over the last eight months, getting a
list of questions and trying to answer these questions that you had. And
in all honesty, and be very frank, I think we answered every single one
of the questions that you gave us beforehand, in a thoughtful manner and
we really researched it. Some of the answers that we'gave to you that
were impromptu, it wasn't fair to us at EPA to have to answer those, to
be honest. But we did try our best and I think we've answered most of
them. Maybe they weren't the answers that you_ wanted to hear, but we did
answer them to the best of our- abilities. OK? And we really didn't
expect that many questions to be perfectly honest. We thought we had most
of your questions and we thought we were going to answer those in the way
that we did.
What are the next steps? The next steps are, we're going to take
these audiotapes and transcribe it, edit it, if necessary, if there are
minor changes or .changes where we just made some mistakes up there from
the podium. 'We're'going to make those changes,- if need be, and we're
going to send that to CMA and other interested parties. There are some
questions that we are outright not going.to answer. I want to make that
perfectly clear.. If there were any site specific questions, and there are
a number of them, we are not answering them. If there are any questions
that we felt were off the topic totally, and there are a couple of those,
we're not going to answer them. Some of those-questions, you will not see
in the transcript. What we will do with those questions is compile that
list and have that attached to the transcript 'and send it out to you and
the other interested parties so you know what questions we received today.
But there will be some that we will not answer.
We'll also compile a list of the guidance documents and guidance
document numbers which we'll send out to you with the transcripts. I've
given out the ERP to everybody.' I have four copies left. If anybody
wants them, come and grab them. Two other things. We really hope to
learn from this workshop in order to improve future workshops like this.
In the new office of compliance that I'm going to be in, I think we're
going to be doing a fair number of these types of workshops both at the
Headquarters level and hopefully at the Regional level. .And maybe even
the states once we get them on board with this -process. But what we need
from you is how to make these more beneficial. Is the process of getting
the questions beforehand, trying to answer.them better? Is it better to
have more of a free for all? what format really helps and how can we
improve these work shops? We really need to know.
The last thing I want to do is to thank everybody. You've been
really good from the standpoint of being engaged, - asking questions,
staying awake, I know it's hard after a day and half of" just listening, to
a lot of EPA people talk about a lot of regulations ,to actually stay
awake. You've bene very good from that standpoint. You've asked a lot
of good questions, and I want to thank all the participants because you
really did a good job froa that standpoint, I also want to put in a plug
for the people that worked on the workshop, Emily Chow, Bob llolloway and
his staff, Sonya, and the other people from EPA, who had spent a lot of
time and a lot of energy putting this workshop together. Cindy from CMA
spent a lot of time and I appreciate her help as well. Houston, you're
probably gone by now, but if you're st.ill orbiting out. there, thank you
for participating and we really hope to see you in more jeminars like this
so we can have more dialogue. Thanks a lot. (applause)
[End of proceedings as* recorded.]
Page 44
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ATTACHMENT A
March 29. 1994
Time
CMA/EPA BIF WORKSHOP
REVISED AGENDA
Topic
8:30 - 9:00
,9:00 - 9:30
9:30 - 10:00
10:00 - 10:15
10:15 - 11:15
11:15 - 12:15
12:15 - 1:45
'1:45 --2:15
2:15 - 2:45
2:45 - 3:00
3:00 - 3:45
'3:45 - 4:15
4:15 -4:30
4:30
Introduction ' j
* CMA & EPA Representatives
,j
RCRA Overview !
* Brief Overview of the R'CRA Program
General BIF Overview 'j
* Brief overview of the BIF regulations
and available resources to assist in
implementing the regulations r
i -
Break . i
Sampling & Analysis of Feed streams
* Waste analysis & Waste analysis plans
* Frequency of sampling &!analysis
i
Monitoring Requirements & Automatic Waste
- . ' Feed Cut-Off ,
* What is required for measurement of:
- Feed rates !
- Production rates !
- Temperature ; .
- Emissions j
* Calibration of monitoring equipment
Lunch i
Owner/Operator Inspections ;
Subpart BB Inpsections j ;
Break ' i
Recordkeeping !
* Types of records i
* Special issues | .
* Format of records ''
Training, for Facility Personnel:
'* Who should, receive trainjing
* .What type of training' I
Wrap Up' for the First Day ;
Adjourn ' | .
-------
March 30. 1994
Time
CMA/BPA BIF WORKSHOP
REVISED AGENDA
Topic
8:30 *- 9:15
9:15 - 10:00
10:00 - 10:15
>.
10:15 - 10:45
10:45 - 11:00
11:00
Compliance Testing- ' ' .
* Establishing operating .conditions:r
- Feed rate limits .
- Recertifying, retesting, &
revisions
Management of Residues
* Applying the Bevill Exclusion:
- Sampling requirements
- Constituents for sampling
- Applicability of the two part1 test
Break ,
Regulatory Development Up-date .
Wrap-up ,
* CMA & EPA Representatives , . ;
Adjourn ' |
-------
ATTACHMENT B
case-by-case situation.
fc.Aa.ON WASTE ANALYSIS '
!.' l) ,What- p^rjrpntagn of BIFr, utilize the exemptions contained in the
IMK i pquJ ations? ' - -
Pl.Peqion VI provides practically no guidance for BIF-they avoid
I lie- qwe.it, ions. Who else besides Reuben Casso should we ask a
1 ) We do not have such information available to us . '-
2) Besides the permit . writers, a Specialized Hazardous Waste
fombustion Inspectors Wor-kgroup was established a'nd each Region
lias one or more representatives on this workgroup. For Region VI
the representatives are Teena Wooten ((214) 665-2279) and Ken
Cooper [ (713) 983-2148] '. "
1. A batch tank is analyzed before burning and then while burning.
.The. concentrations of BIF constituents, are higher (say 2x) .before
burning then during burn, 'which analysis should be used?
Use the. higher results. Sampling & analysis protocol should be
checked. Sounds like -there is a problem occurring with the
current sampling & analysis procedures. -
'If there is wide variability of data/low values cause the upper
confidence limit to be higher than if the low values were not
there. This seems unfair. Why should low values hurt when low
is better? -. . . '
In reference to concentrations of constituents, the higher values
of the upper confidence limit will require a- lower feed rate which
is mor.e conservative. Sug'gest using the statistical methodology
of "upper tolerence limits", therefore, the lowere values should
not increase' the upper limit.
'Re: SW-846 Sample holding temperature?
Why must a sample being tested for metals be held at 4",
when the material being sampled is liquid at temperature
in excess of 100° (at which it is stored), and solid at
holding temperature specified by. SW-846.
This, is a regulatory ' requirement for sample collection and
storage. You may want to try to ask the -Region for a variance in
the sampling & analysis plan if you can demonstrate that it has
no effect on the results.
Is a database (for statistical analysis) required when you fall
into case by case sampling.
Case-by-case sampling and analysis is for a sampling scheme for
a facility that cannot use batch or statistical analysis. A
database may be appropriate for other reasons . for a particular
Q.
0.
A.
0.
A waste is a waste, it is often subject to trace level of
analytical variations in BIF metals, Cl and ash. If a BIF
constituent's content in waste is insignificant compared to. .feed
rate limits established in the compliance certification, is
statistical sampling and analysis still a meaningful thing to do?
Or is this a case-by-case sampling candidate to determine
frequency'issue.
If there is variation, then statistical analysis does have meaning
for on-site generated wastes.. Case-by-case may or may not be an
option.
If a facility mixes all waste streams before imputing into the
boiler, why can't the point of measurement (i.e. the-sample to
-demonstrate compliance! be the mixture of tha streams?
Batch option could be appropriate as long as the sample is
representative of what is going to be fed into the1 BIF and no
additional rtiate.rials are added to the batch after the. sample has
been obtained or while, burning the mixture. This will ensure your
knowledge 'of the concentrations before .feeding.
Are sampling frequencies greater than one year acceptable? Assume
process generating waste 4 data supports this.
The Agency is currently asking for comments on the draft BIF Waste
Analysis Guidance regarding minimum requirement for sampling and
analysis as once a'year. We suggest that frequencies less than
this should be worked out with the appropriate state or Regional
offices given the-supporting data.
Is an ongoing waste analysis program required for an Adjusted Tier
I facility burning a listed waste? , .
""' *" . * *
An ongoing waste analysis program is required for all facilities
regardless of what tier they are operating under and whether they
are burning a listed or non-'listed hazardous waste. The concern
is not necessarily with the listed waste; rather, we are concerned
with the constituents in the waste and other feed streams. A
listed waste may contain constituents of concern that are
different._than the -constituents contained in the listing
description. '
Please"provide a copy of your example slides .to Cindy Brych of CMA
so copies can be made and distributed to attendees. If you have
a hard copy on paper of these few slides, we can make copies
today.
Included in response.
How many states are RCRA authorized? Are they also BIF
authorized? . .
B-l
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A. At the time o£ this workshop, only 4 atatea and 4 territories are
not authorized for RCRA and they are Alaska, Hawaii, Hyoming,
Iowa, Puerto Rico, America Samoa, Virgin Islands, and Guam. Only
1 state is authorized for BIP and that is Arkansas. {As of
December 1994, 3 more States are authorized.]
Q, How specific does the routine analysis have to be for an on-site
chlorinated organic waste? For instance: Full characterization
has been done and there are no heavy metals. Is analysis for
chlorine only for routine 'analysis sufficient?
A. We recommend that the full range of parameters be characterized.
However, it may be plausible to work with the Regions or states
' to establish different testing frequencies for different
constituents based on analytical data and statistical analysis.
Q. How is non-normal distributed data handled to calculate upper
confidence limit?
A. Use normal distribution for most cases. If you can prove
statistically that a log-normal distribution, ij? more appropriate
then it should kbe allowed. Arc sign and square root
transformations are out. They are basically'playing with numbers.
* .'''
Q. For everyone of the samples obtained for any of the types (batch,
SA, or case-by-case) does the full range of parameters have to be
run or can only a few parameters by chosen, using process
knowledge to determine which ones are more .important?
A. We recommend that the full range of parameters be characterized.
However, it may.be plausible to work.with the Regions or states
to establish different testing frequencies for different
constituents based on analytical data and statistical analysis,
Q. If an off-site waste is batch analyzed to establish a database,
. can statistical analyses be used to establish a reduced sampling
frequency or must each load be analyzed?
A. We recommend that each batch be fully characterized for off-site
. wastes.
Q. Does blending with fuel oil trigger use of batch analysis?
A. Yes, the batch analysis is recommended for off-site wastes and
blended wastes. Statistical analysis is only recommended for on-
site "as-generated" wastes.
Q. Phased Sampling: .
' SW-846 uses an 80% confidence interval - You-have given an
example of 95-97.5% is this required or just an example?
A. Material presented at this workshop is only recommended guidance
by EPA Regional and Headquarters staff.
A.
Q.
Q. Batch Sampling
Full metals analysis to be tested and verified by QA/QC
protocol can take 4-5- Dayo. How can waste be effectively
burned without maaaive tankage increase or can preliminary
(unaudited) analysis be uaed.
A. The facility can use data from a preliminary (unaudited) analysis *
at it's own risk.
Q. A lot of the compliance requirements under RCRA are based on grab
samples. Does a facility have to be in compliance on every grab
sample? Since most standards are based on longer term risk
exposures, shouldn't the compliance strategy be geared toward
demonstrating compliance in average over a period of time, say
hourly or daily?
Not for sampling and analysis. \ Case-by-case may allow for
compositing but this should be worked out with the appropriate
Regional or state office.
Sampling/Analysis
Can process knowledge be used for non-hazardous feed
streams, such as process vaporous air emissions or
combustion cooling water being burned in a BIF unit,
instead of sampling?
A. Generally no, we recommend process knowledge in combination with
analytical data be used.
Q. How often is confidence limit established? It is revaluated with
each new data point? If so a high valve; even when below
confidence limit, can drastically raise it, especially if database
is small. ;
A. The confidence limit is reevaluated every time the database is
updated, i.e., every.addition of a new data point.
Q. Do you plan to allow - some period of time to utilize "new
guidance"for those who have used 1984 guidance in designing theii
waste analysis plan? Is "new guidance" being applied now?
A. There is no .implementation period associated with guidance
documents. This new guidance document was developed to assist
facilities in updating their.existing waste analysis plans which
they are currently using.
Q. Do daily test methods have to be performed exactly as the te;;t
methods conducted during a trial burn test? Are the QA/UC
requirements the same for daily testing as during a trial bum?
A. No, after the, trial burn you are not required to use the- SW ti-li,
Method promulgated for the trial" burn unless the im-i hod i.s
promulgated as the regulatory operational requirements 01 in ill--
permit.
B-2
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'J Wh.-it a'rn n i.qni-f i cant differences between new waste analysis- draft
c)ii idfinre 'and the old 19B4 waste analysis/waste analysis plan
qnidancp? Is the presentation discussion of sampling (phased
.'Minpling based on the draft guidance?
A The- significant differences between the two versions are that the
MOW version is in a more user friendly format, it is updated to
.UK-Hide new regulatory requirements (e.g.,. LDR) , examples -are
provided1; it is more comprehensive. . ' The material for this
presentation- is not solely based on information from this guidance.
manual. This material is more specific for BIFs and was developed
in combination with the Regions. '' .
0. Can sampling methods be evaluated before being implemented to gain
approval to avoid an'N.O.V. upon inspection? -i.e. going "from
batch to phased sampling w/statistical analysis.
A. We recommend that a facility consult with the appropriate state
or Regional Office when selecting a sampling & analysis option.
However, due to lack of resources, it may not always be possible
to receive approval prior to an inspection,.
Q. If a feed stream is non-detect for a metal during the compliance
test, should feed rate limits be set using non detect value or
"zero"? . .
A. At this time, we recommend using the non-detect values, however
it is-not specifically required by the regulations. Keep in mind
that it may not always be below or at the non-detect value.
Q. Then, during interim operations if a non detect value occurs do you
use ND valve or'zero for feed rate calculation?
A. At this time, we recommend using the ^detection .limits, however it
is not specifically required, by the regulations. Keep in mind
that it may not always be below or at the non-detect value.
Q. If a sample result in above the 95% confidence interval and you
resample, and the resample result is within 95% CI then do you use
lower numbers 1 average of two or' sample again. Any' guidance
available on this? ' '
A.. If a data point is above the 95% CI, this data point should be
evaluated as discussed'for outliers using the appropriate QA/QC
procedures. Also, the sampling frequency should be verified. If
a resample shows you have returned within the 95% CI, use the
lower 95% value. However, we recommend that you use the higher
value until this data point can be disqualified or resampling
shows that you are within the 95% CI.
Q. Why is phased approach only appropriate for as-generated wastes
and not blended? -
A. The chances for irregular variability are much higher with as-
blended wastes (i.e., the waste stream will not be' consistent.
The phased approach is to show consistency.
Q. Confidence limit . -
Where in the regulations or guidance does EPA get the 95-
97.5% confidence limit? SW-846 only requires.80%.
A. The material presented for the workshop is only recommended
guidance from the Regional and Headquarters personnel.
Q. Waste Analysis - - .
If a waste stream does not change, does it-have to be-
. analyzed once per year. EPA seems to want onpe per year
sampling even when we know, that the waste does not change.
Where in the regulations does, it say that annual sampling
is required? " ,
A. We recommend th'at sampling & analysis be conducted at least once
a year. Frequencies less than this should be worked out with the
appropriate state or Regional offices given the supporting data.
Q. In establishing sampling frequency under phased sampling, should
all parameters be analyzed at the same frequency, or is it proper
for the facility to determine sampling/analysis frequency.on a
parameter specific basis. Example: Feed stream may only contain
2 BIF metals consistently show up below detection limits at low
MDL. . . ;
A. We recommend that the full range of parameters be characterized.
However, it may be possible to work with the Regions or states to
establish different testing frequencies for different constituents
based on analytical data and statistical analysis.
Q. 1. Where does the requirement to develop a statistical database
come from - not in rule or a BIF technical gufdance?
2. Can you address sampling frequency where"a"parameter is not
detected? .
, 3. Can process knowledge alone be used for non RCRA feeds (natural
gas, combustion air, either gas streams)
4. Is appendix VIII' required under interim status? What guidance
can you give for "excluding" constituents on the basis that they
not reasonably expected to be in the waste? Is process knowledge
acceptable? 'DO non-SW-846 methods need EPA approval?
5. Are there guidelines for demonstrating that multiple waste
streams, generated at different points in a process, are similar
(so sampling one is representative of all)?
A- 1- Statistical analysis is not a requirement, it is just an
option presented at this workshop. However, waste analysis is a
requirement.
2, 3, & 4. We recommend that the full range of parameters be
characterized. However, it may be possible to work with the
Regions of states to establish different testing frequencies for
different constituents based on analytical data and statistical
B-3
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analysis, Process knowledge in combination with analytical data
to determine constituent concentrations for feed rate calculations
or exclusion should be used. Non-SH-846 Methods may be used if
a SH-846 Method is not required by.the regulation*. Keep in mind
that if a non-SW-846 Method is selected it will be evaluated by
EPA during an inspection.
5. There is no guidance available in this area. EPA expects that
each individual generated waste stream be fully characterized
independent of other waste streams.
I have heard repeatedly to "work it out with the Regions". In the
context of a part "B" this will likely work and "result in permit
conditions. What is the mechanism to "work it out with the
Regions" during interim status. Do you just discuss it and
document it with the Region? Reach a, formal agreement signed by
both EPA and Operator? or What? Regions are often too busy to
give written documentation/interpretations of the issues.
First, it is true the Regions do not have the resources available
to develop a formal document or agreement on all the issues for
every facility. However, the facility should try to contact the
appropriate state $r Regional Office to arrange for a meeting on
specific ajreas they need to work out. At a 'minimum the facility
should establish contact with the appropriate personnel via
telephone? Documentation should be kept of all contact and
discussions. A common mistake facilities make, especially during
interim status, is they contact only permitting personnel. The
facility should always try to contact enforcement personnel
discuss issues as well as permitting personnel.
Not Answered;
Q.
Contrary'to Ken's comment, sites have brought up the question to
EPA on how too sample and analyze gas streams. EPA has not
identified a course of action.
Why can't'a site use general data for metal content of stream like
Natural Gas when most metals are not present instead of site
specific statistical Data?
Regarding outliers: . .
When performing statistical sample a metal comes up below
detection levels always (greater that 50-60 samples).
Then one sample shows detectable quantities of the metal
which if not used in the process or equipment material of
i construction. The outlier cannot be explained. Is this
then a violation if the waste was burned in a BIF?
In our process, product goes out the top of a distillation column,
and the waste to the BIF goes out the bottom. Can product quality
analysis change in waste stream characterization?
Q.
Q.
Q.
statements just made ? -unrealistic in cost believe > $1,000,000
Has 'EPA, in its "Hew" guidance on waste analysis plans considered
the cost of complying with the "Daily* frequency recommended.
Estimated cost to comply for my company would be about $50 million
dollars per year for this approach.
Your recommendations go way beyond the regulations of 40 CFR
265.13.
At our facility, for RCRA waste characterization, several classes
of similar waste streams were characterized in detail.
For BIF, we felt it necessary to further break down the
characterization to specific streams, but only for BIF
constituents (metals, i'.e., ash). Is this now a problem-will EPA
now require complete characterization including, for example
herbicides, viscosity, etc? Even if these streams are a subset.
of originally characterized wastes?
Sampling/Analysis . '
Is an "outlier" analysis considered a violation (assume
it's a valid analysis)? Given that statistical
reliability is always < 100%, should not "valid" outliers
occasionally be expected?
There seems to be a lot of confusion about how mon-detect values
are to be treated. Does the Agency have any guidance?
Not analyzing v^nt streams (burned in BIFs) has been the basis for
complaint process. Is the EPA currently developing analysis
methods for metals and ash for vapor streams?
Site-Specific .
Having multiple RCRA stacks may force a limit to near or
below normal organic matrix detection limits for metals.
Analysis in this situation is nearly impossible. Can
process knowledge be- -used? Options? What to do with
false positive that will result with pushing the low
detection limits?
Since Chrome from pipe is Crt3 and not the carcinogen Cr+6 does
EPA intend to exempt this form of chrome as it does f or' waste-
disposal . If not, why the inconsistency? . . .
We have had issues in finding laboratories that can mt-et
reproducibility and repeatability analysis as detailed .under SW
846. Is EPA reviewing test methods especially for ash and met a Is?
If 'a site is using a statistical approach and gets a "hit" i:;n'i
it also legitimate to switch to batch' sampling until, coral or.i.ibl<-
again that the waste is. statistically .unchanged?
Has EPA determined the
cost of waste analysis per the
Q.
'Waste analysis plans
During inspection:;
B-4
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Q.
O.
ii-iii-i.il Di-/Puni"i!3, EPA.has stated that wastes be analyzed at least
-IH-C p"i y"->i What in the statutory/Regulatory basis?
'Jyiiimyiit.; Many of those streams have been burned longer than EPA
r |,oon ,-iiouud. There is more than 20. yrs. data available on
j.lurHon piocessen that have not changed? Is the new guidance
i" M-/O,- nile this? Your phased'sampling obviously didn't include
'».<:t ... A typical plant i.e., 30 days x 6000/sample x 6 streams.
An.il.yt ica-1 Cost of waste "streams = 1.080.000. What-happened to
::w. fl-HS Chapter 9-80% confidence interval-Mow .95%? Do'you analyze
fm nil appendix VTII or a subset? dependent upon waste stream.
Wh,it- is the purpose of the ash test (ASTM methods). The ash test
in run at temperatures lower than- the minimum boiler temperature.
What, information is to be derived from this .test to determine that
the waste-feed to the BIF unit will not,result in an exceedance
of part-iculate emissions?
-. ' ' ' - *
Could data'which .was collected for "a recycling permit be used to
demonstrate consistency of an extremely stable process if data was
collected quarterly.for about six years, but not all parameters
tested-under BIF were deserved. The tested data did show little
to no variation of observed parameters. Current BIF testing is
done quarterly with inclusion of all parameters.
Could you give us a reference for a method'for metals, chlorides,
and ash in gas? (since we're required to analyze all feed streams
and we're been unable to find a method).
Is analytical data required for flue gas and process went gas feed
to boilers if. so, does EPA have, protocol method or recommended
methods to sample and analyze these gas streams, if not. What is
EPA's recommendation? " ' .. . . .
What methods are to be used? We know of no SW-846 methods that
apply for metals analysis of gas (in the feedstream) . or any
other methods either. Depending on answer, is it really necessary
to analyze a natural gas stream?
Where are the states going to get assistance on the Risk
Assessment requirements? , .
If a required monitor fails, you stated you must not operate the
unit. Later you state that all .controls must be in place for
24hrs. after H.W. feed stops. If a monitor fails and you stop
hazardous waste feed immediately are you allowed same period of
time to shut down the boiler (in order to do it with'equipment
change) or is this a non-compliance situation??
1.' Susan's description of her new office's direction - to work
with industry and to help better educate the regulated community
provide good. Will EPA consider providing more up-front training
before new regulations go into effect? Can the first one or two
inspections, after a new regulation goes into effect, be more
-oriented to identifying and correcting start-up problem .(with the
new regulations) recognizing that there is a learning curve for
. any new regulation rather than using hard-hammer enforcement
actions right off the bat?
Queationa on RCRA Overview - ' .
. 1. How do I get a.copy of the Enforcement Response Policy?'
2. Why is an "Ignitable" only material considered a RCRA Hazardous
Waste? Shouldn't these materials be regulated by OSHA regs
instead of RCRA?
Questions on AWFCO
1. Dp ..all of the parameters- during_,automaticT wasted feed sut-of-f
testing need to be tested or can one parameter fulfill the
requirement? ' .
2. Question on AWFCO testing parameters 266.109 and 266.110 allows
for BIF units operating under certain conditions to be considered
as satisfying the low-risk waste and ORE waiver requirements. For
units operating in this manner, does the weekly AWFCO procedure
still have to test for minimum combustion temperature?-
3. Some regulation allow programming systems to use the and logic to
prevent unneeded trips. Can this be used for BIFS.
4.. Most of the AWFCO parameters has an HRA valve as well as an
instantaneous maximum value i.e. co HRA of 100 ppm and
instantaneous max value of 3000ppm. It is enough that when the
AWFCO is checked electronically, that the signal for 300ppm will
suffice for both parameter HRA as well as instantaneously?
'».
5. - Does this 24 hr.' burn out apply to liquid f eed"'-only BIF's where
there is no ash. generated? '
6. What is expected from the 7-day waste stream cut-off test and the
30-day cut-off test be done on a monthly basis?
7.
9.
When redundant instruments which one is the liquid to be tripped
from and when is it allowable to be swapped to the other?
What exactly is a WFC for a unit burning "solid" wastes?
i.e. a charge is introduced every 5 minutes. A charge is
introduced the unit goes out of compliance but is back in to
compliance before the next charge is .introduced, has a WFC
occurred? . '
I understand that minimum combustion chamber temperature be
monitored after an AWFCO but most of be physically recorded on a
strip chart or data acquisition system? ,
B-5
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10. Is CO >100 pp» HRA a violation by Itself, even if the AHFCO has
worked?
11. Residues which are removed during maintenance are HH.
Do you mean only if the BIF was burning listed waste
characteristic waste would not leave hazardous derived from waste.
12. How quickly does the feed valve need to be close if a BIF limit
is exceeded?
13. In many cases, when CO levels are rising abo.ve standard, the total
instantaneous closure o£ the AWFCO will cause a much more
catastrophic upset then a controlled cascading closure e.g. 15%
every ten seconds.
14. This has been discussed with some Regions_ but will HQ prefer
specific guidance?
15. Is the Agency planning to limit the number of waste feed cut-offs
and why?
16. Where/How do we measure combustion temp, in a boiler?
* * "
17. Do you want tro-see outlet gas temp, flame temperature?
- . ^
18. 24 hour residual burn out- If BIF flows a tube-immediate shut down
required for safety - how apply this residual burn out 'in 'this
case?
19. What-is,an under burden for 7 to 30 day?
20. When a BIF unit is not burning hazardous waste, can one turn off
CEM & AWFCO devices? What about when on BIF unit is only burning
non-hazardous waste and another is burning hazardous waste?
21. Does the liquid need to be cut-off when you have redundant demand
one is calibrating and the other shows a calibration out of range?
22. Must cutoff be "instantaneous" or can waste fuel be ramped out
over a defined period of time (to prevent boiler upset or
shutdown)?
. State inspectors use the terms "lag time" and "length of cutoff".
Please define and discuss their significance.
23. What does instantaneously mean in terms of cutoff of hazardous
waste flow? " Some systems cannot shut of-f instaneously without
creating safety problems for the operation of the BIF.
24. Waste Feed Cert offs - Must value be physically closed, even if
waste stream by passed? Regulators have stated the value must be
closed and show that no waste is leaking thru value - yet guidance
suggested using by pass so unit won't shut down. How do you show
valve has closed completely?
25. What location is preferable to measure the combustion chamber
temperature.
26. You now say burnout reg wires 4 hours.
la that new information today?
-If a device like a CO, monitor or fuel rate monitor fails,
hazardous waste feed stops.
-Does that mean boiler must be shut down?
-If so, how can you finish burnout
27. During an AWFCO test, how do you show that the valve has closed
completely? This assumes that the AWFCO valve is tested only when
there is no HW flow.
28. What is the testing frequency for. the AWFCO VLV for leak-by and
to what percentage of the operating pressure do you hydrostatical
test to?
Questions on Training
1. I understand how personnel training is important for a facility.
Likewise, I would like to know how EPA trains its personnel, and
specifically its BIF inspectors.
Our Region has had experience -with a BIF inspector who is
extremely unknowledgeable about the RCRA program and BIF
requirements.
2. Does HAZWORER training suffice for contractor training? I.E. non-
employee personnel who work m-site.
3. " How far "up, the ladder" is training required?
Technician handling waste
Technician supervisor
Staff Engr. of generating unit
Dept. head of generating unit
Plant manager .
Offsite company manager
4. What is meant by "written job description"?
What does the job description need to say?
5. What is the 8-hour requirement you "mentioned-when discussing the.
annual review training?
6. Who is a qualified trainee?'
i
7. How far up the line in management is RCRA training reqtuied?
Theoretically, this could be interpreted as requiring the hiijli.-ui
levels to have training. ,;
8. Does a person who walks through a "permitted' facility- lu-.-.l
training? I,t so what about sit specific .training ,iequi i eim-nt:; h-i
Agency inspectors? ,
B-6
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win! wn.-, I IIP li.-iininq frequency of sampling and analysis that was
.i.'t.-.iiiiipcl ill the'BJF C/A? . -
Annual tfview-on ?65d basis or once 'per calendar year? (Regions
ninJ st;itr-r, are split on this issue).
Any specific training content REO'D?
7.
requirements. It this correct?
Supart BB - applicability flow chart did not include waste gas
(not H.W.). what is. regulatory definition for waste geses? Is
process vent gas ,containing fuel: value still called waste, gas?
If not, does BTU determing gas to be fuel? What is the cut-off
BTU? ' . .
If we obtain, our Part B today for our BIFs,'- would we be shielded
by permit from the combustion strategy changes?
The training requirements spelled out in RCRA are pretty general.
Does EPA have any additional guidance on the type of training it
would like to see for BIF operators? Could EPA work with ASME or
others to develop a training program that could be endorsed by
EPA? ' , X
Questions on Subpart BB ;
1- The permitted facilities exemption to BB applies to facilities (a)
permitted before Dec.1 '90
(b) where the permit covered the relevant accumulation tank and
piping...'
, other requirements?
2. BB .would apply to such "permitted exempt" facilities are of
(a) date of class 1 permit mod request (b) date of 'class 3 pamUt
travel request or (3) of class of 3 permit approval.
3. will Subpart BB leak definition be modified to reflect the leak
definition used by other regulations? ex: How, air permits This
would eliminate the need for calibration records at 500 and 10;000
ppm.
4. 1) With regard to 266.103 (h) (Fugitive Emissions). Is this where
subpart BB is pertinent .to the BIF regs? If so, why doesn't it
state that? How does. 266.103 (h) relate to 266.103 (a) (4) (VIII)
(this is where subpart BB is referenced) if at all?
2) If a fugitive leak is found in the combustion zone, how soon
must it be repaired? ( " '
5. Is scurbbing medium from a control device installed on a less than
90 day accumulation tank fbr a listed waste also a listed waste?
If so, why? It's not derived from TSD o the waste, and it's not
a mixture.
6 . The hazardous waste fuel .tanks that supply hazardous waste fuel
to the BIF units are operated as 90-day-or-less hazardous waste
tanks under the generator regulations. The BIF units and
associated equipment are monitored under subpart BB and the tanks
systems are monitored under after fugitive emission.monitoring
10.
11.
12.
13.
How do you define CERGLA identified In References .pumps, values,
compression etc?
In 'other words-are activity required or and detailed inventory
- lists adequate?
Where does Subpart BB begin? If you are transporting hazardous
_wast.e_ by _truck f rom one process to you BIF -unit, is -the process,
' unit' subject to Subpart BB?
Can samples be taken through an open ended one that meets the
requirements of subpart BB, or must a special sampling connection .
system be installed? '
Please elaborate on "equipment designed not to leak"- examples of
please.
What is the boundary limit for subpart BB monitoring
applicability?
Are the subpart BB requirements and the upcoming STDs for tanks
containers, and surface impoundment duplication of CAA STDs? Do
we need both? "
What is the' compliance boundary for a BIF unit. For example, does
subpart BB (fugitive emission) apply to production unit waste
storage facilities? ' . '
Questions on Racordfceepina
1.
2.
3.
Does chrome include Cr+3 as well as Cr+6 for BIF recordkeeping.
Cr+3 is exempt for other hazardous waste considerations. Cr+3 can
be.present due. to low level corrosion of equipment such as pipes
and tanks.
1. Will strip charts need to be kept for the lite of unit under
264 if records are also kept via computer means?
Are strip 'charts to be kept for life under 265 if computer kept
data? . .
Is there a way to store or use an electronic form for inspection
records? What about signature requirements?
4. Is the facility required to record/report mass feed rates of
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constituents that are determined to be non-detect in the waste
stream?
5. Can "keys" be used for atrip charts instead of physically losing
each chart as long as scape, etc. don't change?
6. If your computer system fails to record the info, unknowingly what
action(s) will be taken by the regulatory Agency?
7. What is the purpose of life of facility recordkeeping under BIF,
and will it be changed to RCRA type time limits (3 years)?
8. For CO, where limit is on rolling average, checked every minute,
does planet have to archive every 15_ -second (or less)
determination. Or cain they sort and back off to record just the
average -- each minute.
9. We track waste feed rates in pounds Ihr rather than gram/hour
because our air permit (which is more stringent than the BIF regs
would allow) is written in pounds/hr. is there-any problem with
this from an inspection/enforcement perspective?
*'- . . '
10. Because not a"ll operating records can be kept on computer disk -
for instance, inspection'logs signed by operators-the amount of
hard copies information will soon become very large. Will
microfiche be acceptable?
11. Are records that are placed on microfilm or microfiche acceptable
if the film/fiche is available at the site w/a reader and printer?
12. Is it O.K. to electronically scan an inspection sheet including
signature? Also, once this-- is done, can the original be
discarded?
13. Why was the retention time for'operating data and inspection logs
changedfrom 3 years is adequate .for compliance checks. This
creates a big problem in how to keep records of this magnitude for
20 or 30 years.
14. If you are measuring CO parameters on an instantaneous basis where
do you set the AWFCO for CO? The regs say lOOppm or hourly
rolling average basis?
15. Why is it necessary to record the minute averages every minute as
well as the hourly rolling average?
16. Is it necessary to record two values -for each parameter every
minute? a 60'sec. avg. and an hourly rolling average;
17.. Why ere you just now (afte,r 3 years) defining how often the
instantaneous limits must be monitored and recorded. We have
already purchased and installed equipment based on' one minute
averages.
18. Are mass federate records required for constituents that are not
defected? 1C so, why? How should records be handled if an
erroneous 1 minute data point gets into the hourly rolling average
calculation?
What is record retention time Cor daily calibration of CO + 02
monitors daily system audits (appendix IX).
19. We have documented required RCRA inspections with these
guidelines: use of an inspection form, must be in ink, form must
be signed, and forms must be hold for Agency inspection. During
inspections these have been considered deficiencies if not
followed. Yesterday it was stated that all the above are not
required. Please clarify.
20. I know that EPA is interested Recordkeeping in responding to the
- publics interest in knowing about operation of BIFs incinerators,
etc. Industry is also interested in respondingto legitimate
interests that the public has, But it seems that a lot of things
that are 'required to satisfy public interest groups are rarely
actually used? In our company, the BIF correspondence file is a
good example. Nobody ever asks to see it. Does EPA make any
attempt to find out if such requirements are actually beneficial?
21. If a facility records its data electronically is it permissible
to use data compression techniques for the stored information?
The compression would record 1 data point for every 15 minutes of
data provided the data did not vary 12.5% (PPM or GPM) . The
reconstructed data would be a straight -line for this time period.
22. Records for Records that are maintained by computer (Distribute
Control Systems) How quickly must the records be retrieved during
an inspection? By: Records seed rates..
Questions on O/O Inspection
1. In the information Collection Request (10/21/94) on page 134, 6th
bullet, it states that daily 'inspections are performed each
working day 260 times/year. Does that mean only Monday thru
Friday? :
2. Is there any means of obtaining some of these guidance document;:
electronically (i.e. bulletin boards)?
3. Are inspections required on days when hazardous waste iu not
burned? - . . -.'-_;. - - -
How far upstream of combustion unit do you inspect (i.e. I UJHI
point of generation)? .
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"47
5 .
6. '
~l.
8.
9.
10 .
11 .
12 .
n .
14 .
3raI .Uueotiona
II'.;-.-. IK'RA tpquire a facility to self-report RCRA violations'. Is
Mi"ir> any advantage in doing so? Assume reporting is not required
\-y.n -ppnnit or CERCLA, CWA or.'cAA..
"Inntcad of using a- definitive approach to national regulations,
l|pa
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5. For clarification, did you say that the default valuers for
constituents no on the F039 list were stayed and not replaced.
therefore, facilities are only obligated to loot for constituents
on the F039 list?
6. Host of your slides are not in notebooks. Hill you provide
copies?
7. LDR analyses are based on a single grab sample. Compliance levels
in LDR are set «99» confidence levels. Thus offer 10-20 samples
there is close to 100V probability of failing.' Has EPA given any
thought to changing its procedures to allow" for outliers and
natural data variability to enable facilities to be able to
comply.
8. How are we expected to- submit a part B application which must
include a dioxin test when there is no official guidance on how
to set it up. '
9. 266.103(cXBXd) says period recertification within 3 years of 3
years of previous certifications. Your slide says within 3 years
of the certificatipn of precompliance which is it?
10. .A tier I BlF'btirns HW that has very low ash content (no APCD. no
soot blowing etc) .. If repairs to the inside of the boiler are
necessary is it required to treat any thin film/canting of residue
on the equipment as a HW?
11. Is it requires to do Bevill for burning non-hazardous waste?
12. How often should the base line UTL be updated?
13. Is an evergreen approach of Random non-waste data periodically
added to the original data base a sound method?
14'. Where -to get compliance testing references' on new guidance
documents?
IS.. What is the status of omnibus authority vs particulate std 0.015
vs. 0.08)" .
16. Why is a PM test required for Adj. Tier I compliance? If you
assume worst case scenario, i.e. ash in equals ash not, that the
same logic used for the metals and chloride! (There is no APCD
in .this case)
17. Must EPA be notified when .testing is conducted for state ait-
permit requirements?
18. Are 2 sets of test - conditions required to establish a usable
minimum combustion chamber temperature?
Especially when' natural gas & liquids are the only fuels
Conditions that demonstrate maximum combustion chamber temperature
are not likely to demonstrate minimum temperature.
19. Sonya, Based on your comments, can we still use a surrogate for
trial burns?
20. As -EPA considers the "no dioxin testing scenario--which I fully
support, what chlorine levels will default to "no test".
If EPA does not know the answer to this what are they doing to
find and?
21. Is recompliance (new test burn? 3 year after cert, of compliance?
22. How do you suggest adj. tier I boiler owners certify at maximum
feed rates needed. If you do not accept extrapolation, should we
spike? (i.e. particulate/ash).
23. This is not site specific, because many boiler are dependent on
their process heat demand and cannot arbitrarily run at 100%. You
said data maybe acceptable in lieu of trial burn when observed by
EPA/regularly Agency, but we have been hold there are no funds for'
EPA Region to travel for test observation-any advice?
24. We would like to modify our boiler alter the combustion cha'mber-
what steps must we take part A , class 3 permit mod,
recertification of compliance? If our compliance test fails, must
we initiate closure?
25. What test/operating conditions isdioxin trial burn to be run
under? < E.g. 1. Max. or Min Temp.
2. Max. or Min Velocity .
3. What to spike: a. metals
b. Pohc c. Federates
4. Boiler lead (production rate) Max. or Min.
Are the answers in any EPA document that, a chloi inated pohc be
required for a dioxin or DRE trial burn?
26. If it is required during a dioxin test and the BIF doe's no_t bum
any chlorine containing waste, the dioxin emissions during test
likely could be artificially,high.
27. EPA has been invited to test but will not attend. Can their data
be used for identical unit? ' ' _
28. Although you suggest working with the Regions and States they aiu
not like to accept minor modifications, to method wit haul
significant trials/propfs-any suggestions on how to overcome thesi:
difficulties? .
29. Given Che .EPA (or state; whoever is supposed .to), calls, in l.lu-. piu l
B.,- and the 3-year deadline for'the compliance t
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u.
'2.
wiihin ). months of each other, could the trial burn be done be
li'\fmn .if is approved. . '
. 1. Is a concent ration limit (i.e. detection limit) acceptable
instead of a g/hr feed.rate'limit for constituents which can't be
dr-t-pct.ed? if a concentration limit is acceptable are mass feed
rate records required? If. so, why?
2. The tier I eligibility criteria references the.shoreline of "a
large body of waste' lake" .
What is considered ".A large lake"?
3. Agency notifications are required for compliance certication
testing. Are agency notifications required for annual performance
'spec test? ' , - . .
_Why. can't .".Ash'.;,: ho scaled up: to- the limits, when -a.-low-level of Ash-
is present in the tested feed stream. This should be allowed when
BIF unit has no APCD.
EPAs own, published data suggest, that metal volatility is .somewhat
less t'han would be expected. Based on these uncertainties, is EPA-
collecting data + continuously.analyzing results of low/high temp
trial burns to verify the need for these test? Is there some
range that could be acceptable for operating'temperatures to limit
the 'need for two trial burns? ",
.Given that you have more than one waste stream to burn of a given
time), 2) Two of the streams do not .have enough material
accumulation to perform 6 hours of compliance test 3) These 2
streams are high BTU (>12000 BTU/lb. is it acceptable to not
perform a compliance test with these 2 streams if they are
analyzed?
Sonya, You mentioned that "ash" extrapolation is not allowed if
you have an. APCD. due to collection efficiency variability. But
what about facility that does not have APCD such as "natural gas"
boiler is it allowed in this case? if not, why not!
Has it been brought to your attention that method 9057. has a
significant positive bias on the chlorine analysis. When (1
reacts with consitic the hypochlorite that burns continues to '
react and a portion will, form additional chloride. This biases
the 1C analysis since the (1 peak area is multiplied by 2 for the
assumed 1/2 split. Larry Johnson SPA RTF is aware of this. Is
there any dialogue with the BIF method developers to resolve this.
Questions on Regulatory Development Evaluations
1. I understand that Environmental Justice will be on additional
topic to the waste'min. & combustion strategy-Regional roundtable-
33-.
34.
35.
2.
6.
7.
9.
10.
11.
won't this dilute the focus--even overshadow--the purpose of Che
roundtable?
Will MACT Rule be under RCRA or Air Regulations, or Both?
If MACT is duplicated under RCRA & Air. How will EPA Audio the
double jeopardy of multiple program penalties & Enforcement
Actions on a company who might only have a single noncompliance
identically covered by a RCRA MACT £. by a CAA MACT?
.Currently, 60% of urban air pollution comes from mobile sources.
As MACT standards implemented, will the EPA eventually look at
actual improvements in local air quality, instead of continuing to
ratcheting down on industry?
Two of my feelings are:x . :' .
A. Combustion strategy seems to be in large part "Regulation" by
press conference news release. '
B. Enforcement initiatives seems to be enforcement, by ambush.
Seems there .could be a better way. Comments on above??
Strongly Encourage EPA to base particulate limit on site.specific
situation. For instance, NaCl particulate. should not be a
stringently limited as metals.
If part B permits are issued under joint authority of CAA & RCRA -
will the permit shield provisions of the CAA apply. To both CAA
and RCRA?
Omnibus authority is triggered by response to threat to HHTE.
Yet you say the CETRO would use preliminary MACT analyses to guide
the permit writers. Technology based. Z.sn't there legal conflict
here? ' . -
EPA argued in court that current standards do protect HHE
(Horsehead) . Is there new information that says standards don't
do this If not what is the rationale for new strategy?
What kind of time frame a chemical plant's BIF unit as to be
called for part B permit? Expect how many units may be called in
one year, and what is EPA Region's permit calling criteria on
minority?
If a BIF pact B application has submitted under current regulation
adn it isn't acted upon prior tb the new BIF'regs. in 1998 & 1999,
will a -facility have to start over? How will that be handled?
Are they thoughts to lower PM STd's on BIF?
Ms., Browner has publicly given some lower tt's
dg(SCF) as her viewpoint.
(from .08-0.02
B-ll
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12. The compliance process under RCRA has changed. Enforcement seen*
to be the only interest EPA has under BI^ in developing compliant
programs. What plans does the new office of compliance assurance
have to re-focus on good permit development first-thin follow with
enforcement?
13. Are proposal being considered for stack emissions only, or are
liquid emissions also being considered for Dioxin and furans?
*
14. Further explain the meaning of "never" exceeding the dioxin t
furan emissions that are currently an average value in germany?
15. Research shows that 290 ntn wavalangenth 0V light from the sun
destroys TCDD (dioxin). This was shown in Seveso Italy. Why is
the atmospheric discharge, of small amounts of dioxin the top
priority of emission concerns?
16. Will "opneric" standards for all combustors be acceptable under
CAA?
17. Halogen Acid Furnace (HAF) is defined as a unit producing >3V
Halogen Apld, During the development of .the rule, this part of
the definition- started out as 6%-20% then 3%-20V and ultimately
the upper*20V bound was dropped. 1) What happened to the 20% upper
limit? 2) Did EPA intend to include non-acid halogen production
such as gaseous anhydrous hydrogen chloride product manufacturing
as part of the HAF definition?
18. What is TEQ with respect to the. dioxin discussion?
19. If Headquarter doesn't know the answers to these questions, what
makes you think that the Region will provide better, if any
guidance? Typically Region (especially VI) provides little or no
guidance!
20. Where can you find a copy of the "combustion strategy" or .the
principle components of this strategy (i.e.. Federal register,
internal correspondence...)?
21. Who is the main contact (s) to get information on the risk
assessment portion of'the combustion strategy?
22. How does EPA plan to keep tabs on over-zealous permit writers who
choose to overuse or even abuse their omnibus permit authority?
Where are the checks & balances? '
23. Will RA guidance document be similar to those used for CERCLA
(RI/FS) and RCRA' (RFI) ?
24. Will facilities in interim states be required to perform RA? When
will EPA complete generic RA for national standard?
25. The last one I looked at are Horsehead settlement, industrial
furnaces are in the first of review rules for PM, Dioxins & furans
at least.
26. If limits are set on dioxin and furan emissions, will this be done
using a* scientific risk assessment or will it be done in an
arbitrary manner such as the german standard?
27. Yesterday, it was indicated that .public disclosure of waste
information is required and so claiming certain waste information
as confidential is not appropriate. Our company is very concerned
about the lack of sensitivity & understanding apparent in the
agency about this issue. Industrial espiorage does exist and is
very vanpant in the global economic community. As EPA delves into
more process information (i.e., waste generation points upstream
of disposal for permitting pruposes, RFA review and waste
minimization activities) these concerns increase. Considering the
"revolving door" to private industry, many regulators take
advantage of and the number of individuals reviewing the waste
info, submitted to the agency, what specific procedures are in
place to protect sensitive information designated confidential?
How does EPA assure the procedures are adhered to?
28. Where does the Agency currently stand on the allowable ambient
chlorine standard? It is my understanding that this value is
being revised. Is that accurate and when will it occur?
29. I .thought EPA back backed down from using omnibus authority to
tour when technical standards after CKRC sued you last year, and
ask use of omnibus authority was to be limited to case-by-case,
as determined by side-specific risk assessment. Also, since
omnibus authority is restricted to that necessary to protect human
health and the environment, how cap ERA justify using MACT (a
technology-based approach) to determine omnibus-based limits?
30. With the increasing heightening of requirements and the
possibility that the number of viable outlets for waste treatment
diminishing, coupled with the realization that pollution
31. The Agency's "concern" over combustion units seems to be based on
pretty soft reasoning. Where is the epidemiological study, teal
data to show that exclusive Agency effort and cost to the
- regulated community are justified-compared to other places efforts
resources could be applied. ,
'Have we created a political "frenzy" based on limited and
inadequate data that is attacking a non-problem-considering Lhe
high level of Prevention will hot likely get us to zero, what is
.the Agency's current thinking on how industry will handle H ':»
: wastes? And if site specific Bit" s are closed, , is the Agem-y
consider the increase Risk associated with transportation.
32. regulations that already apply to BIF's
33. Seems like a lot, of issues about the BIF rules ate still up. HI i !»
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.. ii yot EPA is planning on proceeding with permitting shouldn't
iho rulps he finished before we have to permit?
Thp RIF regulations include very comprehensive interim status
stfliulajds. The reqs are still pretty new. Facilities have spout
,i lot of energy and money trying to comply with the BIF
> f-gulations. -Now we are talking about completely rewriting the
BIF rpgs. What new evidence/information does EPA have that really
hums into question-whither the current regs are not adequate to
protect human health and the environment? '
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ATTACHMENT C
LIST OP EPA SPEAKERS AND PHONE NUMBERS [
Please contact the appropriate Regions and States for-.
questions concerning hazardous waste combustion. In'the event
= that any non-site specific questions cannot be resolved by the
Regions or States, then contact the following persons at EPA
Headquarters. Difficult issues brought to the individuals listed
below will be discussed by EPA Headquarters and the Region's.
1. Sampling & Analysis of Feed Streams.- John Dombrowski'
(202) 564-7036
2. Monitoring Requirement - Mark Mercer ' - -
(703) 308-8652
3. Automatic Waste Feed Cut-off - Dwight Hlustick
: (703) 308-8647 '.
4. Owner/Operator Inspections &
Training for Facility Personnel - Kate Anderson
(202) 564-4016
5. Subpart BB Inspections - Ginger Gotliffe
(202) 5*4-7072
6. Recordkeeping - Emily Chow
. (202) 564-7071
7. Compliance Testing & Management of Residues - Scott Rauenzahn
(703) 308-8477
8. Regulatory Development Up-date - Bob Holloway
..-..' ; .(703) 308-8461
9. Panelist - Sonya Sasaeville
(703) 308-8648
/ ' i ' ,
- Ken Oigliello
(202) 564-7047
C-l
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ATTACHMENT D
Hazardous Waste Combustion Guidance and
Hazardous Waste Incineration Guidance
Resource Documents
Volume I:
Volume II:
Volume III
Guidance Manual for a Hazardous
Incinerator Permits, July 1983
Guidance on Setting Permit
Conditions and Reporting Trial
Burn Results, Jan. 1989
Hazardous Waste Incinerators
Measurement Guidance Manual,
June 1989
Waste
Other EPA Guidance and Resource
Quality Assurance/Quality Control (QA/QC)
Procedures for Hazardous Waste Incineration,
January, 1990 "
"
Engineering Handbook for Hazardous Waste
Incineration, Sept., 1981 (currently being revised)
Trial Burn Observation Guide, 1988
Technical Implementation Document for EPA's
Boiler and Industrial Furnance Regulations,
March 1992
Combustion Emissions Technical Resource Document'
(CETRED) , May 1994 . .. :
. ! i
Exposure Assessment Guidance for RCRA Hazardous
Waste Combustion Facilities, Draft, April 1994
Memorandum on Trial Burns (Trial Bxira. Failure
Guidance), July 1994.^.
Addendum: Methodology for Assessing'Health Riskib
Associated with Indirect Exposure To Combustor !-
Emissions
NTIS .
PB84-100577
CERI
EPA/625/689/Q19
CERI
EPA/625/6-89/021
CERI
EPA/625/6-89/023
NTIS
PB89-179543
NTIS
PB89-179543
EPA/530-R-92-Oil
PB92-154-947
RCRA/SF Hotline
EPA/530-R-94-014
RCRA/SF Hotline
EPA/530-R-94-021
RCRA/SF Hotline
EPA/530-F-94-023
RCRA/SF Hotline
Public Information
Hazardous Waste Incineration: Questions
and Answers/ April, 198$ --
* * * '
Permitting Hazardous Waste Incinerators
(Fact Sheet) , April, 1988
RCRA/SF Hotline
EPA/530-SW-88-018
RCRA/SF Hotline
EPA/530-SW-88-024
D-l
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Various information materials on Hazardous Waste RCRA/SF Hotline
Minimization and Combustion Strategy, 1993 to present ' ,
Obsolete Documents
Volume IV:
Volume V:
Volume VI:
Guidance on Metals and Hydrogen
Chloride Controls for Hazardous
Waste Incinerators, Draft
Guidance on PIC Controls for
Hazardous Waste Incinerators,/
Draft
Proposed Methods for Measurement of
CO, 02, THC, HCL, and Metals at
Hazardous Waste Incinerators
*see below
*see below
**see below
* Refer to the BIF Rule. These documents need to be finalized/updated
** Refer to 40 CFR PArt 266, Appendix IX or the Methods Manual for
Regulating BIFs (NTIS #PB91-120006)'
NTIS: (703) 487-4650
CERI: (513) 569-7562
RCRA/Superfund Hotline:
toll free (800) 424-9346;
local (703) 412-9810
January 1995'
D-2
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