United States
Environmental
Protection Agency
Washington, DC 20460
EPA/530-SW-88-024
Office of Solid Waste
APRIL 1988
EPA
Permitting
Hazardous Waste Incinerators
(TRODUCTION
Incineration reduces the
ilume of hazardous waste and
beaks down the chemical con-
tituents of the waste into
leir less toxic residues. A
fell-operated incinerator can
3stroy hazardous waste safely.
The use of incinerators to
|ianage hazardous waste is like-
to increase in the near
Jture. This development re-
ects a growing understanding
|n the part of industry, regu-
atory agencies, and the public
lat incineration is safer than
ts chief alternative
iisposal in landfills—for
lany types of hazardous
/astes. It also reflects
lecent regulatory changes. In
Ihe 1984 Amendments to the Re-
source Conservation and Recov-
bry Act (RCRA), for example,
Congress placed stringent re-
strictions on the land dis-
Dosal of untreated hazardous
v'aste. These limitations are
be phased in by 1990.
To ensure that hazardous
?aste incinerators are safe
and effective, the Environ-
lental Protection Agency (EPA)
and the states regulate them
ay requiring that they obtain
la permit to operate. The per-
Imitting process that an incin-
Jerator owner or operator must
ffollow is strict.
Public involvement is a
[required and important part of
Ithe permitting process. EPA
[has prepared this publication'
to inform the public about the
process for permitting inciner-
ators, and to encourage public
participation.
USING INCINERATORS
TO TREAT HAZARDOUS
WASTE
Incineration can effective-.
ly treat many types of hazar-
dous wastes, such as dioxin
and organic solvents. In
addition, contaminated soil
from the cleanup of abandoned
hazardous waste sites can be
incinerated. So can gases,
liquids, solids, sludge, and
slurries containing hazardous
waste. Some types of incinera-
tors even allow for the re-
covery of energy and recycling
of chemical by-products. Incin-
eration reduces the volume of
waste that would require expen-
sive hazardous waste land dis-
posal. Therefore, a growing
number of companies favor
building new incinerators or
converting existing furnaces
to burn hazardous wastes.
For decades, industrial
incinerators have burned waste
products. More recently, hazar-
dous waste incineration tech-
niques have been refined so
that wastes are burned more
effectively. Important condi-
tions for proper incineration
include high temperatures
(usually 1500-2500 degrees
Fahrenheit), enough time •with-
in the incinerator, sufficient
oxygen, and proper mixing of
the waste with oxygen.
Several kinds of incinera-
tors are suitable for treating
hazardous wastes. The rotary
kiln incinerator—used primari-
ly for burning solids^and the
liquid injection incinerator
account for roughly 90 percent
of all incineration of hazar-
dous wastes in the United
States. Other designs include
the fluidized-bed incinerator,
the multiple hearth inciner-
ator, and co-incineration
methods.
PERFORMANCE
STANDARDS FOR
HAZARDOUS WASTE
INCINERATORS
An incinerator's perfor-
mance is measured by how com-
pletely it destroys hazardous
waste. Incinerators must demon-
strate they can meet several
performance standards to be
approved to operate. No incin-
erator can burn 100 percent of
the waste fed to it. However,
the EPA performance standards
require an incinerator to des-
troy or remove • 99.99 percent of
.the organic hazardous con-
stituents. This, percentage is
called the destruction and
removal efficiency (ORE). For
dipxins and PCBs, the required
ORE is 99.9999 percent. A ORE
of 99.99 percent means that one
molecule of the hazardous con-
stituents out of every ten
thousand molecules is not
burned or removed and is vented
from the facility through its
The Congress, in an effort to address the nation's growing concern about its hazardous and
solid waste problem, enacted the Resource Conservation and Recovery Act (RCRA). The Hazardous
and Solid Waste Amendments of 1984 greatly expanded RCRA and the Environmental Protection
Agency's (EPA) authority to manage these wastes.
As a result, EPA is promoting regulations and programs to reduce, recycle, and treat wastes;
restrict land disposal; and require corrective action for releases of. hazardous waste into the
environment. EPA's Office of Solid Waste, through its publications, aims to foster public under-
standing and encourage citizen involvement in helping to manage the national waste crisis.
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smoke stack. A DRE of 99.9999
percent means that one. molecule
out of every million is not
destroyed. Other performance
standards require that gaseous
hydrogen • chloride be reduced by
99 percent, or to 4 pounds per
hour. Furthermore, and that
particulate matter—very small
particles of debris—in stack
emissions must be kept to a
minimum (180 milligrams per dry
standard cubic meter).
Current performance stan-
dards do not explicitly address
emissions of metals or products
of incomplete combustion
(PICs). The burning of some
wastes may release small quan-
tities of metals through the
smoke stacks. These metals
usually adhere to particulate
matter. Therefore, restrictions
on particulate matter emissions
help prevent emissions of •
metals in quantities that may
pose a threat to public health
or the environment.
Products of incomplete com-
bustion (PICs) are products
that are not totally destroyed
by incineration. PICs occur in
any combustion process—such as
in automobile engines, boilers,
barbeques, woodstoves—when
some organics are only partial-
ly destroyed or when new com-
pounds are formed. PICs are
present in very small quanti-
ties and are predominantly
non-toxic emissions. According
to current EPA data, PICS do
not present an unacceptable
risk.
An incinerator must demon-
strate compliance with perfor-
mance standards during a per-
formance test called a trial
burn. The conditions under
which the incinerator operates
during the trial burn are then
included in the permit to
assure continued compliance.
THE TRIAL BURN
Before conducting a trial
burn, the incinerator operator
usually develops a trial burn
plan. The trial burn plan
describes (1) the content of
the waste to be fed into the
incinerator (waste feed); (2)
operating conditions to be
tested under the most adverse
situations; (3) monitoring and
sampling tests to be conducted;
(4) how trial burn data will be
analyzed; and (5) how sampling
results are to be verified and
reported.
A TYPICAL
ROTARY KILN INCINERATOR
From the list of chemicals
making up the waste feed, the
applicant proposes several of
the most difficult compounds to
burn. The .selected compounds
are referred to as the Princi-
pal Organic Hazardous Consti-
tuents, or POHCs. POHCs are
selected because if they are
destroyed to the required DRE
of 99.99 percent, the destruc-
tion of more easily burned
compounds will be even more
complete. Sometimes a more
easily burned but highly toxic
compound is also selected as
one of the POHC compounds. This
is to make sure that such a
toxic component is destroyed
during incineration.
During the trial burn, the
owner and operator, with EPA or
state oversight, must measure
emissions from the incinerator
for POHC compounds, particulate
matter, and hydrogen chloride.
Using those measurements, EPA
can then determine whether the
incinerator meets the perfor-
mance standards.
The information that is
gathered during the trial burn,
confirming that the facility
can meet the DRE under speci-
fied conditions, is used to set
the final permit conditions.
The facility must then maintain
these specified operating condi-
tions at all times -when burning
hazardous waste. When operating
conditions deviate from those.
in the permit, the waste feed
must be automatically stopped.
THE PERMITTING PROCI
Under RCRA, the Federal gc
ernment and many state govern!
ments are authorized to oversea
hazardous waste facilities.
Regulations issued under RCRA
in 1980 enable Federal and
state governments to better
control the treatment, storage,
and disposal of hazardous
wastes. In addition, the regula-
tions set up a process for issi
ing strict operating permits to
facilities that properly manage
such wastes and for closing
those that fail to do so.
A permit specifies the con-
ditions under which the facili-
ty can operate. These condi-
tions include, for example, the
allowable range for incinerator
temperatures, the types of |
waste which may be burned in
the incinerator, and provisions
for automatic shutdown if per-
mit conditions are violated.
Adequate security procedures,
facility inspections, personnel
training, contingency planning
for emergencies, use of the
RCRA manifest waste-tracking
system, and accurate record-
keeping must also be ensured.
Moreover, owners and operators
must describe plans for secure-
ly closing the facility at the
end of its useful life.
Existing Facilities
Facilities that already
existed when the regulations
took effect operate under
"interim status." Interim
status allows a facility to
continue operating under a set
of specific standards until a
final permit decision is made.
Existing incinerators with
interim status must follow the
stringent permitting process
outlined on these pages.
The EPA and state agencies
oversee operations at facili-
ties that have interim status.
By 1989, EPA must issue or deny|
final permits to incinerator
facilities having interim
status. About 150 of these are
awaiting permit decisions. The
majority of these facilities
are located near the chemical
plants or manufacturing sites
where waste is generated.
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IIT PROCESS STEPS
Existing Incinerators with
brim Status
(submit Part A. Applicant
/ides general information,
as the name and location
e facility, its owner,
of •waste accepted, maximum
lacity, and other environ-
ital permits governing the
(ility. This step is required
abtain interim status. Most
|sting incinerators submitted
A in 1980.
JSubmit Part B. Applicant
Ivides detailed information
scific to the individual
Jility. This information
ibles EPA to evaluate the
bposed design and operation
1 an incinerator. Completion
| a Part B application is long
complex. It also includes a
burn plan and/or trial
data or data from a simi-
incinerator. (The following
bps reflect when a trial burn
an is submitted with the
|plication.)
Review of application.
lA reviews application and
lal burn plan. Trial burn
|an is evaluated to see if it
juld adequately test the per-
Irmance of the unit. During
|is period EPA may ask for
are information. EPA or the
late approves the trial burn
|an.
Trial burn. Applicant con-
icts the trial burn with EPA
state staff in attendance.
Trial burn analysis and
^view. Applicant submits data
id information on incinera-
performance during trial
lurn. EPA reviews information
Ind may request additional data
pom applicant.
. Preparation of draft permit.
f the trial burn demonstrates
at the incinerator meets per-
'ormance standards, EPA pre-
oares a draft permit. Permit
ncludes operating conditions
sased on the data gathered dur-
ng the trial burn. If it ap-
pears that a facility is unable
to meet statutory or regulatory
standards, a "Notice of Intent
to Deny" is prepared. Either
way, acceptance or denial of
the permit, a 45-day public
comment period must be held.
7. Public comment on draft per-
mit. EPA solicits, reviews,
and responds to public com-
ments. Public comment period is
at least 45 days. A public
hearing -will also be held if
requested.
8. Permit determination.
Final permit is issued or de-
nied depending on public com-
ment and the facility's ability
to meet RCRA regulations. Final
permit describes operating con-
ditions for the facility, and
is effective for up to ten years.
If denied a permit, a facility
must comply with closure/post
closure requirements.
New Facilities
For new facilities, a RCRA
permit application and trial
burn plan must be approved and
proposed for public comment. If
a complete EPA and state review
shows that the proposed inciner-
ator design and trial burn plan
are acceptable, and public com-
ment's are addressed, a four-
phase permit will be issued.
This permit establishes the
conditions to be met by the
facility following its construc-
tion. Each phase of the permit
specifies operating conditions
for that portion of the incin-
erator's operation.
PERMIT PROCESS STEPS
For New Facilities
1. Submit Parts A and B.
Applicant includes a trial burn
plan with the permit application.
2. Review of application. EPA
performs technical review of
the incinerator's design to
determine if the incinerator is
likely to meet the performance
standards.
3. Preparation of draft permit.
EPA prepares a draft permit
that includes a trial burn plan
and facility design specifica-
tions. It also includes operat-
ing conditions under which the
facility is expected to meet
the performance standards.
4. Public comment on draft
permit. EPA publishes for
public comment the draft permit
and trial burn plan. The public
comment period is at least 45
days. If requested, a public
hearing is held.
5. Four-phase permit. After
EPA review and public comment,
a four-phase permit is issued
or the application is denied. A
permit would establish the con-
ditions to be met by the facil-
ity following its construction.
6. Start-up/Sfaake-down period
(Phase One). This phase
allows limited burning of
wastes to help stabilize the
new facility's operations.
7. Trial burn (Phase Two).
Emissions and operating condi-
tions are monitored to deter-
mine if performance standards
are met. This period usually
lasts two weeks or less.
8. Post-trial burn. (Phase
Three). In this phase, the
incinerator may operate under
specified .limits for several
months, while trial burn re-
sults are reviewed.
9. Final operating conditions
(Phase Four). If the incinera-
tor meets the performance stan-
dards during the trial burn,
the incinerator is allowed to
operate under the final
operating conditions in the
permit. Some modifications to
these conditions may be
necessary based on the trial
burn results. If the incinera-
tor does not pass the trial
burn, the permit may be modi-
fied to allow an additional
trial burn. A major modifica-
tion of the permit, such as a
second trial burn, would
require a new public comment
period.
PUBLIC INVOLVEMENT
IN THE PERMIT PROCESS
Community involvement in
the permit process is strongly
encouraged. Procedures to
ensure public involvement vary
from state to state and often
overlap with EPA efforts.
Whether or not EPA or a state
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decides to issue or deny a
permit, a public notice will
appear in two local news papers
and at least a 45-day comment
period will be held. Informa-
tion about the permit, usually
in a newsletter or fact sheet,
will be provided to interested
community members. Additional
information and a copy of the
draft permit will be available
from EPA or the state.
If anyone submits a written
request for one during the com-
ment period, EPA will hold a
public hearing. Any testimony
provided at the hearing would
become part of a formal record.
In addition, EPA may hold infor-
mal meetings with community
members to hear their views and
respond to questions.
• During the comment period,
written comments and questions
may also be submitted to EPA.
All concerns must be considered
before a final decision on a
permit is made. Moreover, EPA
must prepare "Response to Com-
ments" within 60 days after the
close of the comment period.
This document responds to major
comments and explains what, if
any, provisions of the draft
permit have been changed.
The public comment period
ensures that EPA fully consi-
ders the public's concerns
regarding the effects of a
facility on human health,
safety, and the environment.
And technical or factual com-
ments from the public can
influence the provisions and
safeguards of the final permit
or cause a permit to be denied.
Citizens often offer useful
information to EPA about the
applicant or the facility site.
Practical information contribu-
ted by the public, about the
impact of the permit on communi-
ty services can be invaluable,
as well. For example, is the
applicant's contingency plan
feasible given the capabilities
of the local fire department?
For new facilities, the pub-
lic comment period occurs prior
to construction. Public com-
ments may be directed toward
important decisions—for in-
stance, the design specifica-
tions, selection of the POHCs,
waste feed components, contin-
gency planning, site security,!
trucking routes, and the need
for noise controls. For
existing facilities, already
operational, community membeJ
may wish to comment on trial]
burn results, monitoring and
operating procedures, site
security, noise control, arid
trucking routes.
For both existing and n
facilities, EPA conducts public
involvement efforts to keep cc
munity members informed and
respond to public inquiries
during the lengthy permit re-
view process. Again, public
involvement is encouraged.
Solving the nation's hazardous]
waste problem is up to every-
one.
For more information on the permitting of hazardous waste
incinerators contact:
Toll free RCRA/Superfund Hotline: 800-424-9346"or, in the Washington, D.C. area,
call 382-30pp.
Or contact EPA Regional Offices:
Region I
JFK Federal Building
Boston, HA 02203
(617) 573-9644
Region II
26 Federal Plaza
New York, NY 10278
(212) 264-8682
Region III
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-7:940
Region IV
345 Courtlqnd Street, N.E.
Atlanta, GA 30365
(404) 347-^433
Region V
230 S. Dearborn Street
13th Floor (HR-11)
Chicago, IL 60604
(312) 353-0398
Region VI
First International Bldg.
1201 Elm Street
Dallas, TX 75270
(214) 655-6785
Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2888
Region VIII
999 18th Street
One Denver PI., Suite
Denver. CO 80202-2413
(303) 293-1676
Region IX
215 Fremont Street
San Francisco, CA 94105 |
(415) 974-8026
Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-1099
United States
Environmental Protection Agency
Office off Solid Waste
Washington, DC 20460
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