United States.        Solid Waste and •     Enforcement and
               Environmental Protection  Emergency Response   Compliance Assurance  EPA530-R-94-046
                             (5305)          (J5503)           January 1995
              Edited Transcript
                                       Printed on recycled pape'r that contains at
                                       least 50% post-consumer recycled fiber



     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'.

                             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


     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

     D.  ' List of EPA Combustion Guidance Documents  . ......... D-l

     '                      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 to—reduce  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
                                                                           Page 1

 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,- „,„„,
                                                                         Page 2

     •••' 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:
                                                                                       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
                                                                          Page 3

 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
 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?


        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-the•1984 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
 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

        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

 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.,  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

        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

 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.'
       -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

       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

 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.
     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)      :

                                                       /~ '"

        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.
      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

  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
         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

        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,-,
                                                                         Page  12

     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
        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  next•one  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

  • '--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

          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

         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

        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

 '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  was•completed.

         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'

 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
         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

  •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.                  "

        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.

      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

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

 ";'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



  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
                                                                                        by avoiding
                                                                                                                                         data Cucn cue
                                                                                                                                               '  «*•
                                                                                                                    c            v your  strip
                                                                                comply with the
                              that it ha

                              ~      =•"

                                                                                                                                           '•= -"'•«
                                                                               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

                                                                                                           «            "™
this is a format you can-coMideV
                                                                                                                              do something  like  that,.

                                                                                                                                      " ' ? V  "'M-
                                                                                                              e Agency received a nu.nbei of
                                                                       Page 22

  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

                    *. 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 "
                                             01    ""I"
                           (comment inaudible)

         MS.  SASSEVILLE:        No,

         (comments inaudible)
 probably^           g     Tat
      th<, hourly
average?   Well, I think one reason for
                                                                    of facilltica trying to get
                                                                    I guess we juat  feel  that  it
                                                                                                                               S that we do aee a  »«t
                                                                                                                             «"h the regulations. so
                                                                                could say it-s acceptablif
name of
                                                                                                                                         '." ta» «"
                                                                               .ore stringent that  t requ, a
                                                                               waste feed rates in
                                                                                                                                    ^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
                                                                  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/
                                                                                                                                        "hen' burnin»

                                                                                                      computer actually monitors and i(.c-u,U:;  ,,,  ,
                                                                      Page 24

             » .)•• | 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

                     (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
        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) '"••-.•                              •
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

         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

  :-!,,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

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

  !'"• -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
                                                   •   "             "

         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

        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

 •,•"" '•'.•'' 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
  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
        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
considering, these suggestions if they are appropriate.
 a large  body of water such as an ocean or a large  lake '* and they
                                                                want to
                                                                                                    .ending out  to  .verybody ,
                                                                                       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
                                                                                                                            ' surrogate differently,  !50
                                                                                       . lot ,f tMn9,
                                                                                                                          i,  io,
                                                                              to spike up ,r.o reach maximum chlorine level., for examp.e  o  wl
                                                                                                     But we wouid »k- - ^  -    '  >—
                                                                       Page  32

         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
   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?     •        •
                      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

 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

         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

 ."!,.-.• ,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.     '                      :              •»-.'•
                                                     • • •*  '
        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.        ;
                                                                          Page 35

       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.           •                                     '
                               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.]
       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

             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?
         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

        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

                    (Bnd of proceedings as  recorded.]

        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

   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
          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

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

        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

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

    ''';'	'  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

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

                          ATTACHMENT A
 March  29.  1994

                        CMA/EPA BIF WORKSHOP
                           REVISED AGENDA
 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

 Introduction  •      '        j
    * CMA & EPA Representatives
 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
 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

                       CMA/BPA BIF WORKSHOP
                          REVISED AGENDA
8:30 *- 9:15
9:15 - 10:00
10:00 - 10:15

10:15 - 10:45

10:45 - 11:00

Compliance Testing-     '   '  .
   * Establishing operating .conditions:r
        - Feed rate limits        .   •
        - Recertifying, retesting, &

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


 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

 If there is variation,  then statistical analysis does have meaning
 for on-site generated wastes..  Case-by-case may or may not be an

 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

 Included in  response.

 How  many  states  are  RCRA  authorized?    Are they   also  BIF
 authorized?           .   •                            ••   .

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.
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.

             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--

 '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
      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

       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;
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?
                                                                              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

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
                                                                                      'Waste   analysis   plans
                                                                                                             During   inspection:;

  •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?
       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?               ,

10.    Is CO >100  pp» HRA a violation by Itself, even if the AHFCO has

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

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

      .  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

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

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?'
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?                                      ,

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?
                                                                                         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
      ,  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

 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
       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

       What  is   the  boundary  limit   for   subpart  BB   monitoring
       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
       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

       constituents that are determined to be  non-detect in the waste

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

13.    Why was  the retention time for'operating data and  inspection logs
       changed•from 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

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
       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 responding•to  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)?   .                                     •


5 .

6. '




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,
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

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

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

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  is•dioxin 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
 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-
         won't  this dilute the  focus--even overshadow--the purpose of  Che

         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

        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

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

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

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

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 !»•

.. 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?           '

                           ATTACHMENT C


      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

                         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
 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  !-




                                        RCRA/SF Hotline

                                        RCRA/SF Hotline

                                        RCRA/SF Hotline

                                        RCRA/SF Hotline
Public Information
Hazardous Waste Incineration: Questions
and Answers/ April, 198$ --
                        *• * * '
Permitting Hazardous Waste Incinerators
(Fact Sheet) , April, 1988       •
                                        RCRA/SF Hotline

                                        RCRA/SF Hotline

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,/

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'