&EPA
                         United States
                         Environmental
                         Protection Agency
                          Office of
                          Research and
                          Development
Office of Solid Waste
and Emergency
Response
                         Superfund
                          EPA/540/2-91/004
February 1991
Superfund
Engineering  Issue
                         Issues Affecting the Applicability and Success of
                         Remedial/Removal Incineration Projects
RPM/OSC SUMMARY

    The Regional Superfund Engineering Forum is a group of
EPA professionals, representing EPA's Regional Superfund Offices,
committed to the identification and resolution of engineering
issues impacting the remediation of Superfund sites. The Forum
is supported  by and advises the Superfund Technical Support
Project.

    Incineration has been a recommended method for disposing
of hazardous materials, and its use in the Superfund Program is
increasing rapidly. It has become one of the most often selected
methods for treating hazardous constituents found at Superfund
sites. Because of the increased reliance of Superfund decision-
makers on incineration, the Engineering  Forum has  identified
the informed evaluation of incineration as a remedy, an
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Incineration



Pyrolysis



Wet Oxidation



Neutralization



Precipitation



Distillation



Air Stripping/Soil Aeration



Activated Carbon



Evaporating/Dewatering



Phase Separation



Fixation



Extraction/Soil Washing



Membrane Sep./lon Exch.



Evaporation



Filtration



Activated Sludge



In Situ Biodegradation

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       Heat recovery (optional - not normally applicable to
       onsite incineration)

       Air pollution control equipment to treat:
          Products of incomplete combustion:
             Minimized in combustion chamber and
             afterburner. Afterburners can significantly
             reduce the toxicity of the exhaust gas from an
             incinerator.
          Particulate emissions:
             Venturi scrubber
             Wet electrostatic precipitator
             Electrostatic precipitator
             Quench systems
             Fabric filter
          Acid gases:
             Packed towers
             Spray towers
             Spray dryers
        Residue handling and disposal
           Ash
              Solidification
              Use as fill material onsite or offsite disposal
           Liquids
              Neutralization
              Filtration
              Precipitation (metals)
              Clarification
              Carbon adsorption or air stripping (for small
              amounts  of  organics which are sometimes
              recovered  in scrubber water)
              Discharge to a POTW after successful treatment
              using one  of the above four options.  Use to
              cool ash from the Rotary Kiln
    Figure 2 presents a  schematic diagram of a typical
incineration system.
                                                                     Exhaust to
                                                                    Atmosphere
                                                                        1
                                         Auxiliary  Combustion
                                          Fuel        Air
                                                      Wastewater
Residue
Treatment
• 	


-^
                                                                                    To Disposal
                                                                        Source: U.S. Environmental Protection Agency 7 988b.

                                 Figure 2. Incineration System Concept Fow Diagram
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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    When incineration is considered along with other possible
treatment methods, the relative risks involved with the use of
each of the technologies should be taken into account. Table 1
shows the total excess lifetime cancer risks that environmental
releases from incineration pose to the most exposed individual.
These values, which were developed to support the Resource
Conservation  and  Recovery Act (RCRA) hazardous waste
incineration regulations, are based on assumptions that included
process upsets and covered a wide range of operating conditions.
As shown in Table 1, the risks presented by metals are likely to
be higher than those presented by Principle Organic Hazardous
Constituents (POHCs) and products of incomplete combustion
(PICs). The total estimated risk (including metals, POHCs, and
PICs) does not exceed 1 in 100,000 and is unlikely to do so as
long as the all appropriate incinerator standards are met.  This
information should be considered in light of the other risks that
are associated with a particular superfund site as indicated from
any required risk assessments.

    The  information in this report was obtained through a
literature survey and contacts with several  EPA representatives
experienced in the use of incineration for the cleanup of toxic
waste sites and for the treatment of RCRA hazardous wastes.
    In addition to the EPA Regional and state technical advisors
listed on page 25, the following people can be contacted for
specialized information:
   Robin Anderson
   EPA, Washington
   202/398-8739
EPA policies and practices,
remedial operations
  James Cudahy
  Focus Environmental
  615/694-7517

  Paul Lemieux
  EPA, RTP
  919/541-0962

  Kevin Smith
  International Technology
  615/690-3211

  Sonya Sasseville
  EPA, Washington
  202/382-3132

  Lionel Vega
  EPA, Washington
  202/475-8988

  Y.J. Kim
  EPA Region 5
  312/886-6147

  Dr. Barry Dellinger
  University of Dayton
  Research Institute
  513-229-2846

  Laurel Staley
  RREL
  USEPA, Cincinnati
  513-569-7863
                                                              Full-scale, mobile, thermal
                                                              remediation projects
                                                              Secondary combustion
                                                              chamber/afterburner impact on
                                                              toxic air emissions

                                                              Mobile incinerator markets and
                                                              technology
                                                              EPA policies and practices, RCRA
                                                              incineration permits
                                                              EPA policies and practices, RCRA
                                                              incinerator permits
                                                              National incinerator expert
                                                                                          POHC and PIC thermal stability
Innovative thermal treatment
technology
                              Table 1. Total Excess Lifetime Cancer Risk from Incinerator
                                    Emissions to the Maximum Exposed Individual0
   Emmlslonltem
          Risk Range
  Probability statement
      POHCs
      PICs
      Metals
      Total
           10-7to10-10
           10-7to10'11
           10-5to10-8
           10-5to10'8
1 in 10,000,000to1 in 10 billion
1 in 10,000,000 to 1 in 100 billion
1 in 100,000 to 1  in 100,000,000
1 in 100,000to1  in 100,000,000
                                                                                               a Source: Weinberger et al. 1984.
                       Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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INCINERATION SYSTEM DESIGN,
OPERATION, AND PERFORMANCE

    A complete discussion of the design, operation, and
performance of incineration systems is beyond the scope of this
report. Detailed information on any of these  topics  can  be
found in the references listed at the end of this report. This
information should be useful to the RPM/OSC in obtaining
some background and perspective on issues pertaining to the
use of incineration. It is the objective of this section, and of the
entire report, to provide  the  RPM/OSC with  enough  basic
information, resource documents,  and  personal contacts to
allow themselves to conduct technical oversight and monitoring
of remedial activities.  To keep the report as  concise as possible,
this information is presented in a series of tables, as follows:

Table 2     Design and Operating Characteristics of a Typical
           Incineration System

Table 3     Typical Design Parameters for Air Pollution  Control
           Equipment on Hazardous Waste Incinerators

Table 4     Summary of Continuous Emission Monitors

Table 5     Typical Automatic Waste Feed  Shut Off (AWFSO)
           Parameters

Table 6     Example Operating Parameters and How They
           Affect Performance

Table 7     Waste Properties  Affecting Incineration  System
           Performance

Table 8     Operating/Failure Modes Leading to the Formation
           of Excessive Products of Incomplete Combustion
           (PICs) and Low Destruction and Removal Efficiency
           (ORE)

Table 9     Reaction  Products Observed from  Thermal
           Decomposition of Various Materials in UDRI Flow
           Reactor Studies

Table 10    Maintenance Checklist for a Rotary Kiln Incinerator

    These tables are excerpted from the references listed on
pages 27-28. Some values have been updated  and additional
information  has been added,  where appropriate, to  provide
more complete information.  These additional values were
determined from discussion with various incineration  experts
during the development of this document.  It is suggested that
the OSC/RPM seek the advice  of some of the experts  listed in
this document and of the regional RCRA incineration contacts
regarding appropriate values for the incinerator to be used at
their specific site.

    Table 2 focuses on an incineration system with a rotary kiln
and  a liquid  injection  unit  exhausting  into a secondary
combustion chamber (afterburner). Other tables in this section
also rely heavily on reported information and experiences with
rotary kiln incineration systems because these units have been
and are scheduled to be used for the treatment of contaminated
soils at most Superfund sites.  Approximately 0.91 million tons
of the 1.3 million tons of contaminated soils and sludges that
have been treated or contracted to be treated (approximately
70 percent) by onsite thermal treatment methods have or are
projected to be treated by rotary kiln incineration. The remaining
tons are fairly evenly split among low- and high-temperature
desorption, circulating fluidized  bed, and infrared conveyor
furnaces (approximately 6 to 9 percent for each type of unit).

    Table 3 provides an overview of design parameters for Air
Pollution Control Equipment which is typically included  in
incineration systems.  This table is useful as a reference  in
specifying design criteria for these systems.

    Table 4 provides an overview of the continuous emission
montitors that are typically used  on incinerators.  Ranges and
typical values are provided.  Generally, if continuous emission
monitors are within the specified "typical values", the incinerator
is probably operating in compliance with applicable or relevant
and appropriate requirements (ARARs).

    Table 5 is a summary of operating parameters which are
required by an operating permit to trigger an automatic cessation
of feed, in the event that a safe operating range is exceeded.
These precautions may not always be included in incinerator
designs, but do help to insure safe operation and compliance
with ARARs.

    Table 6 is a summary of operating parameters that affect
incinerator performance.  This is useful general information
which should assist the  RPM/OSC in reviewing  incinerator
designs to assure the efficient performance of an incinerator at
a particular site.

    Table 7 summarizes the physical properties of solid waste
which can adversely affect the performance of an incinerator.
Waste streams that are difficult to treat can cause frequent
shutdowns, thus significantly  lengthening the time required  to
remediate the site.  Also, some waste streams can form toxic
PICs and  should not  be  incinerated  without the use of an
afterburner.

    Table 8 summarizes failure modes that can result in the
incinerator failing to comply with ARARs.  These conditions
should be avoided.

    Table 9 lists some of the PICs that can form from various
mixtures of organic compounds. This list is particularly useful in
determining what POHCs to  designate during a trial burn.  In
addition, it provides the RPM/OSC with an indication  of what
organic chemicals may be emitted from an incinerator  burning
a particular mixture of contaminants under suboptimal
conditions.

    Finally, Table 10 lists some of the maintenance that must
be done on an operating incinerator. This is useful to the RPM/
OSC in determining the level of effort required to implement an
incineration remedy.
 Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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  Table 2.  Design and Operating Characteristics of a
               Typical Incineration System0
Parameter
      Typical values
Rotary kiln
  Operating Temperature, *F
     Ashing kiln
     Slagging kiln

  Types of Waste
     Ashing Kiln
     Slagging Kiln
   Solids residence time, min
     Ashing kiln
     Slagging kiln

   Gas residence lime, s

   Gas velocity through kiln, ft/s

   Heat release levels, Btu/lt3 per h
     Small kiln, million Btu/h
     Large kiln, million Btu/h

   Kiln loading, % kiln volume
     Ashing kiln
     Slagging kiln

   Kiln operating pressure, in.H20

   Excess air, %
 1200 to 1800
 2200 to 2600


' Low BTU waste (e.g., contaminated
 soils) <5000BTU/lb
• High BTU waste >5000BTU/lb

• High BTU waste >5000BTU/lb
• Moderate moisture & halogen content
• Both drums and drummed wastes


 30 to 60
 60 to 100

 1to2

 15 to 20

 25,000 to 40,000
 8 to 35
 35 to 100


 7.5 to 15
 4to6

  -0.5to-2.0

  75 to 200
 Liquid injection unit
   Operating temperature, *F          1800 to 3100
   Residence time, s                Milliseconds to 2.5
   Excessatr,%                   I0to60
   Waste heating value, BTU/lb       s 4500

 Secondary combustor (afterburner)
   Residence time, s                2
   Operating temperature, T          2200 typical
      TSCAwastes      '           >2250
      RCRA wastes                 1600 to 2800
   Excess air, %
  10 to 60
                                          Table 3.  Typical Design Parameters for Air Pollution
                                         Control Equipment on Hazardous Waste Incinerators0
 Air pollution control
 equipment	
 Typical design
 parameters
  Particulate
     Electrostatic precipitators
      Fabric filters
                                                                            Venturi scrubbers
                                                                         Acid gases
                                                                             Packed towers
      Spray dryers
SCA = 400-500 ft2/1000 acfm
Gas velocity = 0.2 ft/s

Pulse jet A/C = 3-4:1
Reverse air A/C = 1.5-2:1

AP= 40-70 in. W.C.
L/G = 8-15 gal/1000 acfm
Superficial velocity = 6-10 ft/s
Packing depth = 6-1 Oft
L/6 = 20-40 gal/100 acfm
Caustic scrubbing medium,
maintaining pH = 6.5
Stoichiometric ratio = 1.05

Low temperature:
Retention time 15-20 sec
Outlet temperature 250-450°F
Stoichiometric ratio (lime) = 2-4
   SCA=specific collection area
   A/C = air-to-cloth ratio in units of ft/min
   L/G = liquid-to-gas ratio
a Source: Buonicore 1990.
 4 Sowecs: Tiltman, Rossi, and Vick 1990; Schaefer and Albert 1989.
                                      Table 4. Summary of Continuous Emission Monitors0
Pollutant
o*
co?
CO
NOX
S02
Organic compounds (THC)
Monitor type
Paramagnetic
NDIR°
NDIR°
Chemiluminescent
Flame photometry
FID"
Expected
concentration
range
3-14%
2-14%
0-100 ppm
0-4000 ppm
0-4000 ppm
0-20 ppm
Available range"
0-25%
0-21%
0-5000 ppm
0-1 0000 ppm
0-5000 ppm
0-1 000 ppm
* Source: Oppelt 1 987. b For available instruments only. Higher ranges are possible through dilution. c Nondispersion infrared.
Typical value
8%
8%
40 ppm
200 ppm
Varies by waste
<20 ppm
d Flame ionizing detection.
                           Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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      Table 5. Typical Automatic Waste Feed Shut Off
                     (AWFSO) Parameters0
Table 6.  Example Operating Parameters and How They
                     Affect Performance0
Parameter
(example value)
High CO in stack (1 00 ppm)*
Low. chamber temperature*
(14007 for rotary kiln
1700°FforSCC)
High combustion gas flow
(Varies by size)
Low pH of scrubber water (4)
(e.g. not less than 6.5)
Low scrubber water flow
(Varies by size)
Low scrubber pressure drop
(20 inches W.G. for venturi)
High scrubber temp. (220° f)
Low sump levels (variable)
High chamber pressure (positive)
High chamber temperature
(2000°F for rotary kiln,
2600°FforSCC)
Excessive fan vibration
Low burner air pressure (1 psig)
Low burner fuel pressure
(3.0 psig for natural gas)
Burner flame loss
Low oxygen in stack (3 percent)*
Loss of atomizing media
High stack S02*
High waste feed flow
High Opacity >5%
Purpose of AWFSO
Excess Worker Equipment
emissions safety protection
X
X
X
X
X X .
X X
'X
X
X X
XXX
X X ;X
X
X
X X
X
X
X
X
X
                                                                             Operating
                                                                             parameter
                      Effect
a Source:  Oppeltl987.

* Rolling averages of these parameters can sometimes be used. (Leonard, Paul
comments 10/23/90)
 Temperature           Combustion reaction  rates  increase  with
                      temperature until the rates are limited by mixing.
                      High temperatures can  also elevate  NOx
                      emissions.

 Combustion gas       For  a fixed chamber volume,  the waste
 flow rate              constitutents remain in the chamber for a shorter
                      time (have a lower residence time) as the flow
                      rate increases. As the combustion gas flow rate
                      increases, gas velocity  through the chamber
                      increases.  This can  result in  increased
                      entrainment of solid material (fly ash) and
                      emission of particulates.

 Waste feed rate and     As waste feed rate decreases, the heat release in
 heat content           the combustion chamber will decrease and
                      temperature may drop. Waste heat content can
                      affect combustion temperature. Insufficient heat
                      content can result in the need for auxiliary fuel
                      which will adversely affect the economics of the
                      process. Wide variations in heating value of the
                      waste can cause puffing (positive pressure surges)
                      in rotary kilns.

 Moisture Content of     Moisture decreases the heat content of the waste
 the Waste             and, as a  result, reduces  the combustion
                      temperature and efficiency when high moisture
                      waste is burned.

 Air input rate           Air supplies oxygen for the combustion reactions.
                      A minimum is needed  to achieve complete
                      combustion; however, too much airwill lower the
                      temperature (because the air must be heated) and
                      quench combustion reactions due to excessive
                      cooling.   The additional air will  increase
                      combustion gas flow rate, which then lowers the
                      residence times. Increased air input can increase
                      combustion efficiency by  increasing the amount
                      of  oxygen  available  to  oxidize  organic
                      contamination.

 Waste atomization      Atomizing liquid waste into smaller droplets will
                      increase  the effectiveness of fuel/air mixing and
                      the burning rate. Waste feed and atomizing fluid
                      (air  or steam) flow rates and pressures affect
                      atomization. Suboptimal waste feed and atomizing
                      fluid flows will result in less efficient atomization
                      resulting in the production of larger fuel/waste
                      droplets.

 Feed System           Consistent, reliable delivery of waste feed  into
                      the incinerator is critical to the efficient operation
                      of an incinerator. The design of appropriate feed
                      systems can be difficult for inconsistent or difficult
                      feed streams.

 Mixing/Turbulence      A burner must be selected which induces adequate
                      turbulence  into the combustion air/fuel/waste
                      mixture.  This promotes good  mixing of air and
                      fuel which leads to efficient combustion.
                                                                          "Source: ASME1988.
Issues Affecting the Applicability and Successor Remedial/Removal Incineration Projects

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                       Table 7. Waste Properties Affecting Incineration System Performance0
Property Hardware Affected Operating Parameter Affected Effect of Performance Example Feeds of Concern
Healing value
Density
Halogen and sullur
content
Moisture
Particle size distribution
H;CI ratio ofPOHCs"
Any lustofl characteristics
(determined by chemical
characteristics, e.g.,
alkalis)
Rotary kiln
Rotary kiln
Quench system, air
pollution control
equipment design and
operation
Feed system
Cyclone, SCC, ducts, wet
electrostatic precipitation
(WEP), instrumentation

Rotary kiln, cyclone,
ducts, quench elbow,
instrumentation
Rotary kiln temperature, flue gas
residence time
Weight of material held by kiln
Pump cavitation, pH control,
blowdown rate, particulate emissions

Kiln draft, particulate emissions
excess oxygen control, temperature
control
Incinerator's ability to thermally
destroy POHCs/PICs
Kiln draft, temperature, excess 02
control
Feed capacity, fuel usage
Feed capacity
Feed capacity, caustic usage
Increased fuel usage to maintain
temperature
Fouling of duct, cyclone, SCC,
process water system, and instruments
As H:CI ratio decreases, thermal
stability of POHCs increases and-
oxidation of PICs is reduced. Under
oxygen starved conditions the
tendency to form PICs increases as the
N:CI ratio decreases
Slagging of kiln, plugging of
instruments and downstream
equipment
Plastics, trash
Brominated sludge (high density
sludge)
Trial burn mixture, brominated
sludge

Soils, brominated sludge,
vermiculite
C2CI6, C6I6, C2HCI3, and similar
compounds
Plastic, trash, brominated sludge
Sources: a) Stumbar et al, 1989
       b) Taylor and Dellinger, 1988, Tirey, 1990.
     Knowing the thermal stability of  POHCs and PICs is
extremely important to the design of an  effective incineration
system. The University of Dayton Research Institute (UDRI) has
studied the thermal stability of 330  hazardous  organic
coumponds and  has ranked their thermal stability under
oxidative and pyrolytic conditions. This database is available in
Environmental  Science & Technology Volume 24, No. 3  pp.
316-328, 1990. UDRI has also determined the PICs which can
be produced from various POHCs under  different combustion
conditions.  The  PICs produced from  a given POHC vary
depending upon  whether the  atmosphere is oxidative or
pyrolytic.  Further, mixtures of POHCs produce different PICs
than the individual POHCs would alone. Some of UDRI's results
are presented in Table 9. Complete results can be obtained in
the following references.

    Dellinger, B.., Torres, J.L., Rubey, W.A., Hall, D.L, Graham,
    J.L, and Carnes, R.A. "Determination of the Thermal Stability
    of Selected Hazardous Organic Compounds,"  Hazardous
     Waste, Vol. 1, pp. 137-157 (1984)
                                         Taylor,  P.H.  and Dellinger,  B., "Thermal  Degradation
                                         Characteristics  of  Chlorinated Methane Mixtures,"
                                         Environmental Science & Technology Vol.22  pp. 438-447
                                         (1988)

                                         Taylor, P.H. and Dellinger, B.,  "Development of a Thermal
                                         Stability Based Ranking of Hazardous Organic Compound
                                         Incinerability," Environmental Science & Technology Vol. 24,
                                         pp. 316-328(1990).

                                         Dellinger, B., Taylor, P.H., and Tirey, D.A., "Minimizartion
                                         and Control of Hazardous Combustion Byproducts," Final
                                         Report and Project Summary prepared for U.S. EPA under
                                         cooperative agreement CR-813938-01 -0, April 1990.

                                         Tirey, D.A., Taylor,  P.H.,  and Dellinger, B., "Products of
                                          Incomplete  Combustion from the High  Temperature
                                          Pyrolysis of the Chlorinated Methanes,"  in Emissions from
                                          Combustion Processes: Origin, Measurement and Control, pp.
                                          109-120 (Lewis Publishers: Chelsea, Ml) 1990.
 8
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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     Table 8.  Operating/Failure Modes Leading to the
       Formation of Excessive Products of Incomplete
   Combustion (PICs) and Low Destruction and Removal
                             Efficiency0
   Condition
   Results
   Low oxygen to fuel/waste ratio



   High air/fuel ratio


   Low-temperature operation




   Waste surges
  Poor gas mixing in combustion
  chamber due to low turbulence
  Poor atomization for liquids
  Injection waste flame impinging on
  cool surface such as combustion
  chamber wall
  Liquid waste flame impinging on
  cool surface such as combustion
  chamber wall

  Poorly designed or malfunctioning
  air pollution control (APC) device
  or failure of APC
  Short residence time
  High halogen content (e.g. H:CI
  ratio too low)
 Insufficient oxygen for complete combustion;
 in many cases, this will reduce POHC ORE
 and increase propensity for PIC formation

 High air levels and associated gas flows lead
 to temperature quenching and flameouts.

 Many  PICs  require higher  destruction
 temperature than parent POHCs, thus  low
 destruction efficiency for POHCs and higher
 PIC emission rates.

 Leads to overloading combustion system and
 incomplete combustion (starved air condition).
 Also, can lead to fugitive emissions as a result
 of sudden pressurization of the system. High
 CO and THC levels can result

 Optimum  combustion of all organics  not
 achieved. PICs can be formed from the onset
 of pyrolysis within the  system. Localized
 oxygen-starved stoichiometries'lower POHC
 ORE and increase PIC formation. CO levels
 increase

 Droplets too large  for vaporization in flame'
 zone or droplet trajectories penetrate flame
 zone.

 Can  cause   severe  damage to  the
 refractory. Quenches combustion reactants
 before combustion is complete. PICs and CO
 levels can increase

 This can result in the release of PICs and
 unburned POHCs into the environment.
 Refractory can also be damaged

 PICs are absorbed on  soot particles that
are normally collected in the APC system.
This condition will increase these particulate
emissions.  Dioxin formation can occur in
this way

Insufficient time for complete burning, most
critical when stable PICs are formed from
POHC combustion.

Highly chlorinated POHCs and  PICs are
more difficult to oxidize than less chlorinated
or unchlorinated derivatives
a Sources:  ASME 1988; Daniels 1989; Dellinger, Taylor, and Tirey 1989.
 Also, Santoleril 989

 The above table is not all inclusive and appropriate care should be given to
 make certain that incinerator designs have a minimum of failure modes
 which could result in PIC formation. As an added precaution, secondary
 combustion chambers should always be used since they have been shown
 to reduce the toxicity of organic emissions from incinerators. (Limeux, 1990)
                                                 Table 9. Reaction Products Observed from Thermal
                                                   Decomposition of Various Materials in UDRI Flow
                                                                       Reactor Studies0
                                                                               Parent (POHC)
                                                                      Product (PIC)
                                            Condition
                                                                               Carbon Tetrachloride
                       Tetrachloroethene
                       Hexachloroethane
                       Hexachlorobutadiene
 Pentachlorobenzene     Hexactilorobenzene
 Chloroform
                                                                               Chloroform
CHC!3
CH2CI2
CH3CI
 CCI4  '
 1,2-C2H2CI2
 C2HCI3
 C2CI4
 C2HCI5
 C2CI2
 C2H2CI4
 C3CI4
                      Carbon Tetrachloride
                      Trichloroethene
                      Pentachloroethane
                      Dichloroethyne
                      Tetracfiloroethene
                      Tetrachloropropyne
                      1,1,2,4-Tetrachloro-
                         1-buteri-3~yne
                      Hexachlorobutadiene
 Air atmosphere, tr* = 2.0



 Air atmosphere, tr=2.0s

 o = 0.67, tr=2.0s
                                                                                                                           o=0.76 and Nitrogen
                                                                                                                           atmospheres
Mixture of
CCI4 53% (mole)       CCI4
33%
7%
7%
C2CI2  ,
1,1-C2H2CI2
C2HCI3
C2Cl4
C2CI6
C3CI4
C4CI4
                      C6CI6
                      C.CL
Pyrolytic,tr= 2.0s
CHCI3
CH2CI2
CH3CI
                                               ' This table was excerpted from a table appearing in a UDRI report on
                                                 PIC minimization entitled Minimization and Control of Hazardous
                                                 Combustion Byproducts Final Report and Project Summary prepared
                                                 for U.S. EPA under cooperative agreement CR-813938-01 -0
                                                 summarizing the results of flow reactor studies conducted at the
                                                 University of Dayton Research Institute. The complete table can be
                                                 found in the above listed reference.
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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 Table 10. Maintenance Checklist For A Rotary Kiln
                    Incinerator0
Item Procedure
Shredder

Kiln feeder

Kiln burner

Other atomizers
Kiln speed
Kiln drive

Kiln refractor

Kiln seals

Ash gates
Ash conveyor

Afterburner refractory

Afterburner burners

Quench


Waste heal boiler


Particular scrubber


Absorber


Fabric filter system

Inspect
Lubricate
Inspect
Lubricate
Check flame
Remove, inspect atomizer
Remove, inspect
Check
Inspect
Lubricate
Inspect visually
Repair
Inspect
Replace
Inspect
Inspect
Lubricate
Inspect visually
Repair
Check flame
Remove, inspect atomizer
Check for leaks
Check outlet temperature
Remove, inspect atomizers
Check steam pressure
Check pressure drop
Inspect tubes
Check pressure drop
Check water level
Lubricate throat drive
Check pressure drop
Inspect packing
Remove, inspect nozzles
Check pressure drop
Inspect bags
Frequency
Daily
Weekly
Daily
Weekly
Each shift
Quarterly
Quarterly
Daily
Daily
Weekly
Each shift
As needed
Each shift
As needed
Daily
Daily
Weekly
Each shift
As needed
Each shift
quarterly
Each shift
Each hour
quarterly
Each hour
Each shift
Each 6 months
Each shift
Each shift
Monthly
Each shift
Each 6 months
quarterly
Each shift
Each 6 months
Lubricate discharge mechanism Monthly
Main fan


Pumps


Control instruments

Analytical instruments
Limit controls
Emergency vent
Check motor amperage
Lubricate bearings
Check vibration
Check motor amperage
Lubricate
Check discharge pressure
Calibrate

Calibrate
Test
Test
Daily
Weekly
Daily
Weekly
Weekly
Daily
Per manufacturer's
instructions
Daily
Daily
Quarterly
* Source: Brunner 1988b.
                                    INCINERATION EXPERIENCE

                                        Incineration has been a popular method of disposing of
                                    unwanted  materials for  many years.  Several incinerator
                                    manufacturers such as Combustion Engineering and Vulcan
                                    Iron Works have been in business for 100 years.  With the
                                    advent of RCRA, the Comprehensive Environmental Response
                                    and Compensation  and Liability  Act (CERCLA), and the
                                    Superfund Amendments  and  Reauthorization  Act of  1986
                                    (SARA),  developments in incineration have  evolved with
                                    changing environmental concerns. Manufacturers have had to
                                    modify their incinerators to ensure complete destruction of all
                                    the hazardous constituents found in the variety of mixed wastes
                                    on a Superfund site. More commercial facilities were established
                                    to deal with the quantity of wastes being generated or found.
                                    The concern over transporting wastes from a hazardous waste
                                    site to a commercial facility led to the development of mobile
                                    treatment technologies, which allowed the waste to be treated
                                     onsite and thus prevented the  spread of contamination. The
                                    full-scale thermal remediation  projects  included later in this
                                     section were all performed onsite with mobile or transportable
                                     equipment. When site conditions precluded the use of mobile
                                     equipment, commercial facilities were used.  The Records of
                                     Decision listed in Table 13 all used some form of incineration or
                                     thermal treatment.  Last,  but  not least,  are the  SITE
                                     Demonstrations, where new, innovative modifications such as
                                     oxygen  enrichment are made to the incineration process to
                                     develop alternative  systems for effectively cleaning the
                                     environment.
                                                             Onsite Mobile Treatment

                                                                 When Congress authorized SARA in 1986, one of their
                                                             goals was to  prevent the possible spread  of contamination
                                                             resulting from transportation of untreated wastes.  According
                                                             to  SARA, "The offsite  transport  and  disposal of hazardous
                                                             substances or contaminated materials...  should be the least
                                                             favored alternative remedial action where practicable treatment
                                                             technologies are available." Because SARA also emphasizes the
                                                             use of a permanent solution, incineration has become the most
                                                             used method  for treating hazardous  waste.  Using a mobile
                                                             incinerator not only satisfies both of the SARA requirements, it
                                                             provides a proven technology that is capable of quickly and
                                                             effectively achieving a high level of waste destruction with no
                                                             long-term liability.  Existing technologies have demonstrated
                                                             the capability  of achieving >99.9999% destruction of organics
                                                             while producing an organic-free ash suitable for backfilling at
                                                             the site. Because onsite cleanups can be conducted without
                                                             Federal, state, or local  permits, the time required for start-up
                                                             can usually be reduced.

                                                                 Even  though permits may  not be required for onsite
                                                             cleanups, the substantive technical requirements  of a permit
                                                             must still be met. Offsite commercial incinerators must comply
                                                             with the "offsite" policy. (OSWER Directive 9330.2-1)

                                                                 Onsite incineration  includes mobile units, which are
                                                             transported to a  site fully operational. A unit is used to treat
                                                             wastes at one site and, when the job  is finished, it is moved to
                                                             another site.  Transportable incinerators are  those which are
 10
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

-------
transported to a site and are erected onsite.  At some very large
sites where the cleanup will require a number of years, it may
be feasible to actually build an incinerator onsite. Once, erected.
they cannot be  moved from the site without first  being
dismantled to  some extent.  Transportable incinerators are
generally larger than mobile  units and are  best used for long
term cleanups in which a relatively large amount of material will
be treated. Economic considerations are often the key factor in
determining whether,  mobile, transportable, fixed or  offsite
commercial  incineration will be used at a given site. Cost for
onsite and offsite thermal treatment vary widely.  In choosing
between onsite and offsite incineration, factors which affect the
economics of incineration  are the type, physical form, and
quantity of contaminants; applicable site cleanup criteria; and
the availability of offsite incineration, including the capacity and
proximity of the commercial unit, container requirements, and
the method of transportation (McCormick and Duke 1989).

    Based  in  part on  a survey  conducted by McCoy and
Associates, Inc. (1989), the following companies offer mobile or
transportable thermal treatment of hazardous wastes:

    The EPA Regional  contacts listed later in this report may
have more specific information concerning the capabilities of
each vendor.
Chemical Waste Management

  • 3003 Butterfield Road
   Oak Brook, IL 60521
   Contact: Ray Bock
   Phone: (708)218-1675

   Technology: Transportable rotary kiln incinerator
   Setup time: 2 monthsWaste/Media: Soils, sludges, and other
      solids; unit
 .  Typical cost: $200-300/ton can also burn incidental liquids'
   Limitations: 20-30 tons/hour; 82 million Btu/hour; minimum
      quantity of 10,000 tons to justify mobilization; 20,000 tons or
      more preferred

Environmental Systems Co. (ENSCO)
   333 Executive Court
   Little Rock, Arkansas 72205
   Contact: Steve Hardin
   Phone: (501)223-4100

   Setup time: 4 to 6 weeks
   Typical cost:  Varies, depending on waste stream

   Technology: MWP-2000 modular incinerator; rotary kiln
   Waste/Media: Solids and liquids (RCRA and TSCA)
   Limitations: 40 million Btu/hour; no radioactive waste or ;
      fluorinated compounds

Harmon Environmental (Williams)
   1550 Pumphrey Avenue
   Auburn, Alabama  36830
   Contact: Bill Webster
   Phone: (205)821-9253

   Setup time: 4 hours
   Typical cost: $55-75/ton
  Technology: Mobile rotary kiln
  Waste/Media: Light fuels, diesel, gasoline
  Limitations: 8 tons/hour; 24 million Btu

Haztech (Westinghouse Environmental Services)
  5304 Panola Industrial Blvd., Suite E
  Decatur, Georgia 30035-4013
  Contact Carol Renfroe
  Phone:  (404)593-3464     --

  Setup time: 4-6 weeks
  Typical cost: $200-300/ton

  Technology: Transportable infrared conveyor system
  Waste/Media: Organic soils and sludges
  Limitations: 100-175 tons/day; feed stream must be chopped/
      shredded to less than 1-in. pieces

International Technology Corporation

  23456 Hawthorne Blvd.
  Torrance, California 90505
  Contact: Kevin R. Smith
  Phone:  (615)690-3211

  Setup time: 3 weeks
  Typical cost: $150-450/ton

  Technology: Hybrid Thermal Treatment System (HTTS);
      transportable rotary kiln
  Waste/Media: Solids,  sludges, and liquid wastes, including light
      contaminated materials up to heavy organics
  Limitations: 56 million Btu/hour

Ogden Environmental Services, Inc.
  P.O. Box 85178
  San Diego, California  92138-5178
  Contact: Robert C. Haney
  Phone:  (619)455-3045

  Setup time: 2-3 weeks
  Typical Cost: $100-300/ton

  Technology: Transportable circulating-bed combustor
  Waste/Media: Soils, sludges, and liquids containing hazardous
      and toxic constituents including PCBs, hydrocarbons, oil, and
      munitions

O.H. Materials Corp.
   16406 U.S. Route 244 East
   Findlay, Ohio 45840
   Contact: Greg McCartney
   Phone:  (419)423-3526

   Setup time: 7 days
  Typical cost: $150-250/ton

   Technology: Mobile infrared hazardous waste incinerator
   Waste/Media: Soils, sludges, and sediments contaminated with
      halogenated and nonhalogenated organics
   Limitations:  200 tons/day; limited to solid/semisolid waste media

Thermodynamics Corporation
   P.O. Box 369
   Bedford Hills, New York 10507
   Contact: Mark Wolstencroft
   Phone: (914)666-6066
 Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

-------
   Setup lime; 2 days
   Typical cost: $400Aon
      (depends onsite and material)

   Technology; Mobile rotary-kiln incinerator
   Waste/Media; Handles all mediums
   Limitations; 9 million Btu/hour (however, larger unit may be
      available in the future); solids must be crushed or shredded to
      1-sn, size

VESTA Technology,  Ltd.
   1670 West McNab Road
   Ft, Lauderdale, Florida 33309

   Contact: TriciaP. Jack
   Phone; (305)978-1300

   Setup lime: 8 hours; 24-48 hours

   Typical cost: $450-750/ton;
    S250-600/ton

   Technology: Mobile rotary-kiln incinerator (small or large unit)
   Waste/Media; Liquids, solids, and sludges
   Limitations: 8 million Btu/hour; 12 million Btu/hour; cannot handle
      heavy metals, arsenic, or mercury

Waste-Tech Services, Inc.
   18400 W, 10th Avenue
   Golden, Colorado 80401

   Contact: John Wurster
   Phone; (303)279-9712

   Setup time: 3 days
   Typical cost: $700Aon

   Technology: Trailer-mounted fluidized-bed incinerator
   Waste/Media: Solids, liquids, sludges, slurries, soils, and gases;
      hatogenated and nonhalogenated wastes
   Limitations; 1,5 million Btu/hour; 600 pounds/hour; solid wastes
      with greater than 3-cubic-inch particle size require size-
      reduction pretreatment step

Weston Services, Inc.

   Weston Way
   West Chester, Pennsylvania 19380

   Contact; John W. Noland
   Phone; (215)430-3103

   Setup time: 6 weeks
   Typical cost; S250/ton

   Technology: Transportable Incineration System (TIS); rotary kiln
   Waste/Media: Hazardous soils, sludges, and liquids
   Limitations: 7 tons/hour; 20 million Btu/hour in kiln and 20 million
      Btu/hour in afterburner
                                         Offsite Commercial  Facilities

                                             Although onsite treatment is the preferred remediation
                                         method for Superfund wastes, site conditions might preclude
                                         the use of mobile or transportable incinerators. (OSWER Directive
                                         9355.3-01) In these cases, the wastes must be transported to a
                                         commerical incinerator which is in compliance with the "offsite-
                                         policy". Currently, only 9 companies, operating 14 commerical
                                         facilities in 8 states, are capable of handling the wide spectrum
                                         of wastes that might  be found  at  a  CERCLA site.  Current
                                         information regarding these facilities'  compliance with the
                                         "offsite-policy" should be obtained prior to use.  The following
                                         list contains the companies,  incinerator location, and type of
                                         incinerator used:
                                         Chemical Waste Management, Inc.

                                          Incinerator location:  Port Arthur, TX      Phone:
                                          Technology:  Rotary kiln

                                          Incinerator Location:  Sauget, IL         Phone:
                                          Technology:  Rotary kiln

                                          Incinerator Location:  Chicago, IL        Phone:
                                          Technology:  Rotary kiln

                                         ENSCO, Inc.

                                          Incinerator Location:  El Dorado, AK
                                          Technology:  Liquid injection, Rotary kiln

                                         GSX/Thermal Oxidation Corporation

                                          Incinerator Location:  Roebuck, SC
                                          Technology:  Liquid injection

                                         L.W.D., Inc.  *
                                          Incinerator Location:  Calvert City, KY
                                          Technology:  Liquid injection, Rotary kiln

                                         Olin Chemicals

                                          Incinerator Location:  Brandenburg, KY    Phone:
                                          Technology:  Liquid injection
                                             800/843-3604
                                             409/736-2821

                                             800/843-3604
                                             618/271-2804

                                             800/843-3604
                                             312/646-5700
                                     Phone:  501/223-4160
                                     Phone:  803/576-1085
                                     Phone:  502/395-8313
                                             800/227-7592
                                             502/422-2101
                                         Rhone-Poulenc Basic Chemical Company

                                           Incinerator Location: Baton Rouge, LA    Phone:   713/688-9311
                                           Technology: Liquid injection
                                                                                       713/683-3314
                                                                                       713/683-3315
 Incinerator Location:  Houston, TX   ',     Phone: •
 Technology:  Liquid injection

Rollins Environmental Services, Inc.

 Incinerator Location:  Baton Rouge, LA    Phone:  504/778-1234
 Technology:  Liquid injection, Rotary kiln

 Incinerator Location:  Bridgeport, NJ      Phone:  609/467-3105
 Technology:  Liquid injection, Rotary kiln

 Incinerator Location:  Deer Park, TX  ,     Phone:  713/930-2300
 12
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

-------
 Technology:  Liquid injection, Rotary kiln,
 Rotary reactor
 Ross Incineration Services, Inc.

 Incineration Location: Grafton, Ohio      Phone:  216/748-2171
 Technology:  Liquid injection, Rotary kiln
Thermal KEM, Inc.
  Incinerator Location: Rock Hill, SC
  Technology: Fixed hearth
   Phone:   803/328-9690
'(Contact Betty Willis, EPA Region IV, regarding the permit status of this
incinerator. She can be reached at FTS 257-3433)
Incinerator Manufacturers

    Incinerators can be distinguished from each other primarily
by the design of their combustion chambers. Each type operates
under a specific set of conditions designed to achieve maximum
efficiency for the quantity and type of wastes it wi|l handle.
Many of the major incinerator manufacturers conduct extensive
onsite demonstrations of their incinerator equipment to ensure
maximum operating efficiency. Table 11 lists the manufacturers
of the major incinerator types. These firms can be contacted
individually for further information (see listing following table).
                                        Table 11. Manufacturers of Incinerators0
  Hearth
  incinerators
Liquid injection
incinerators
     Rotary kiln
     incinerators
Fluidized bed
incinerators
  Basic Environmental
   Engineering
  Bayco
  Burn-Zol
  Cleaver-Brooks
  Econo-Therm Energy
   Systems, Inc.
  Epcon Industrial
   Systems, Inc.
  Int'l Waste Ind.
  Kennedy Van Saun
Brule
Burn-Zol
Coen Co.
Hirt Combustion Engineers
McGill, Inc.
Met-Pro Corp.
Peabody Int'l
Prenco,  Inc.
Process Combustion
Sur-Lite
Trane Thermal
John Zink Co.
     Boliden Allis, Inc.
     CE Raymond
     Deutsche-Babcock
     Environmental Elements Corp.
     Fuller Company
     Industronics, Inc.
     Int'l Waste Energy Systems
     Kennedy Van Saun Corp.
     ThermAII, Inc.
     U.S. Smelting Furnace
     vonRoll, Ltd.
     Vulcan Iron Works
CE Raymond
Dorr Oliver
Fuller Company
Sur-Lite
a Source: U.S. Environmental Protection Agency 1986b.
    The locations and telephone numbers of the manufacturers
listed in Table 11 are as follows:

 Basic Environmental Engineering, Inc.
 Glen Ellyn, IL
 (312)469-5340

 Bayco Industries of California
 San Leandro, CA
 (415)562-6700

 Boliden Allis, Inc.
 Milwaukee, Wl
 (414)475-2690

 Brule C.E. & E., Inc.
 Blue Island,  IL
 (312)388-7900

 Burn-Zol Corporation
 Dover, NJ
 (209)931-1297
                               CE Raymond
                               Combustion Engineering, Inc.
                               Lisle, IL
                               (708)971-2500

                               Cleaver-Brooks
                               Milwaukee, Wl
                               (414)962-0100

                               Coen Company
                               Burlingame, CA
                               (415)697-0440

                               Deutsche-Babcock
                               (Ford, Bacon & Davis)
                               Salt Lake City, UT
                               (801)583-3773

                               Dorr Oliver, Inc.
                               Stamford, CT
                               (203) 358-3741
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects
                                                                                     13

-------
Econo-Therm Energy Systems Corp.
Tutsa, OK
1-800-322-7867

Environmental Elements Corp.
Baltimore, MD
(301)368-7166

EPCON Industrial Systems, Inc.
The Woodlands, TX
(713) 353-2319

Fuller Company
Bethtehem, PA
(215)264-6011

Hirt Combustion Engineers
Montebello, CA
(213)728-9164

Industronics, Inc.
S. Windsor, CT
(203) 289-1551

International Waste Energy Systems, Inc.
St. Louis, MO
(314)389-7275

International Waste Industries
Bluo Bell, PA
(215)643-2100

Kennedy Van Saun Corp.
Danville, PA
(717)275-3050

McGill, Inc.
Tulsa, OK
 (918)445-2431

 Mat-Pro Corp.
 Harleysville, PA
 (215) 723-6751

 Paabody International Corporation
 Stamford, CT
 (203)327-7000

 Prenco, Inc.
 Madison Heights. Ml
 (313) 399-6262

 Process Combustion
 Pittsburgh, PA
 (412) 655-0955

 Sur-Lite Corporation
 Santa Fe Springs, CA
 (213) 693-0796

 ThormAII, Inc.
 Peapack, NJ
 (201) 234-1776

 Trane Thermal Company
 Conshohocken, PA
 (215) 828-5400
                                      U.S. Smelting Furnace
                                      Belleville, IL
                                      (618)233-0129

                                      vonRoll, Ltd.
                                      Cranford, NJ
                                      (201)272-1555

                                      Vulcan Iron Works, Inc.
                                      Wilkes-Barre, PA
                                      (717)822-2161

                                      John Zink Co.
                                      P.O. Box 702220
                                      Tulsa, OK 74170
                                      (918)747-1371
                                      Full-Scale, Onsite Thermal Remediation
                                      Projects

                                          Mobile and transportable thermal treatment methods are
                                      being used at several contaminated sites throughout the United
                                      States. Table 12, adapted from a list developed by James Cudahy
                                      of Focus Environmental, contains information about completed,
                                      ongoing,  or contracted full-scale commercial cleanups in the
                                      United States using mobile or transportable thermal equipment.
                                      In this context, a mobile thermal treatment system is defined as
                                      a truck or skid-mounted system which takes two weeks or less
                                      for field  erection and minimal foundations; a  transportable
                                      system requires more than two weeks of field erection and
                                      substantial foundations.  The list does not contain any pilot-
                                      scale remediation efforts or fixed-treatment methods (such as
                                      cement kilns or commercial incinerators).  Of those reporting
                                      onsite problems, materials handling ranked the highest, followed
                                      by the weather. More details on each site can be obtained by
                                      contacting the responsible EPA  Regional Office  and the
                                      contractor.
 U
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-------
I
                                                    Table 12. Full-Scale Onsite Thermal-Remediation Projects  (continued)
Contractor
Ogden

Ogden


O.H. Materials


O.H. Materials

O.H. Materials

O.H. Materials

O.H. Materials

O.H. Materials

Site Reel.
Systems
Site Reel.
Systems
Site name,
location, state
Swanson River, Kenai,
AK
Stockton, Stockton.CA


Gas station, Cocoa, FL


Rail yard, PA

Twin City AAP, New
Brighton, MN
Rail yard, PA

Florida Steel,
Indiantown, FL
Rail yards, Cleveland,
OH
Koch Chemical, KS

Gulf Oil, multiple
sites, FL
Site size,
tons
80,000

16,000


1,000


1,500

2,000

1,300

18,000

1,500

700

18,000

Source of Contaminant
contamination/ concentration
indicator in treated soil,
compound mg/kg
Oil pipeline <0.1
compressor oil/ PCBs
Underground tank oil <1.0
leak.total
hydrocarbons
Petroleum tank <0.01
leak/benzene, toluene,
xylene
Repetitive spills/diesel <100.0
oil
Munitions plants/ <2.0
PCBs
Diesel tank spill/ <100.0
diesel oil
Steel mill used <2.0
oils/PCBs
Petroleum <50.0
hydrocarbons
Tank bottoms/
toluene, xylene
Benzene, toluene, <1.0
xylene
Combustion
equipment
Circulating fluid bed

Circulating fluid bed


Low-temperature
direct desorber

Low-temperature
.direct desorber
Infrared conveyor
furnace
Low-temperature
direct desorber
Infrared conveyor
furnace
Low-temperature
direct desorber
Low-temperature
direct desorber
Low-temperature
direct desorber
Thermal
capacity,
106Btu/h
10

10


12


20

30

20

30

20

47

25

Particulate
emissions,
APC gr/dscf at
equipment 7% 02
Baghouse <0.05

Baghouse <0.08


Venturi . 0.011


Cyclone, venturi

Venturi, packed bed

Cyclone, venturi

Venturi, packed bed 0.056

Cyclone, venturi 0.039

Baghouse

Baghouse

Project
status
Ongoing

Ongoing


Finished


Finished

Finished

Finished

Finished

Finished

Contracted

Contracted


-------
                                                    Table 12. Full-Scale Onslte Thermal-Remediation Projects  (continued)
Contractor
Site Reel.
Systems
Soil Remediation
Co.
Soiltech
TDI Services
Thermodynamics
Corp.
U.S. Waste
Thermal Proc.
U.S. Waste
Thermal Proc.
U.S. Waste
Thermal Proc.
Vertac Site
Contractors
VESTA
Site name,
location, state
Sun Oil, multiple sites
Multiplesites.SC
Waukegan Harbor,
Waukegan, IL
Chevron Refinery, El
Segundo, CA
S. Crop Services,
Delray Beach, FL
Gas station, Temecula,
CA
CA
San Bernardino, CA
Vertac, Jacksonville,
AR
Nyanza, Ashland, MA
Source of
contamination/
Site size, Indicator
tons compound

3,000 Gas and oil leaks,
spills/petroleum
hydrocarbons
20,000 Marine motor
manufacturing/ PCBs
30,000 API sludges
1,800 Crop-dusting
operation/
pentachlorophenol
1,000 Petroleum tank
leak/total
hydrocarbons
7,500 Total hydrocarbons
540 Total hydrocarbons
6,500 Chemical manu-
facturing/dioxins
1,000 Dye manufactur-
ing/nitrobenzene
Contaminant
concentration
in treated soil, Combustion
ing/kg equipment
Low-temperature
direct desorber
<50.0 Low-temperature
direct desorber
High-temperature in
direct desorber
BOAT High-temperature
indirect desorber
0.003 Rotary kiln
<10.0 Infrared conveyor
furnace
Infrared conveyor
furnace
<10.0 Infrared conveyor
furnace
Rotary kiln
Rotary kiln
Thermal
capacity,
10*Btu/h
25
48
14

7
10
10
10
35
8
Particulate
emissions,
APC gr/dscf at
equipment 7% 02
Baghouse
Cyclone, baghouse
Baghouse, cyclone,
scrubber
Condensation, carbon
Wet scrubber 0.035
Calvert scrubber 0.008
Calvert scrubber
Calvert scrubber
Spray dryer, 0.08
baghouse, scrubber
Wet scrubber 0.02
Project
status
Contracted
Finished
Contracted
Contracted
Finished
Finished
Contracted
Finished
Contracted
Finished
I
I
i
t
I
 If

 i
 9.
 3"
 o

-------
I
                                                        Table 12.  Full-Scale Onsite Thermal-Remediation Projects (continued)
Contractor
VESTA

VESTA

VESTA

VESTA

Westinghouse/
Haztech
Westinghouse/
Haztech
Weston

Weston

Weston -

Weston

Site name,
location, state
Rocky Boy, Havre, MT

S. Crop Services,
Delray Beach, FL
American Crossarm,
Chehalis, WA
Fort A.P. Hill, Bowling
Green, VA
Peak Oil, Tampa, FL

LaSalle,
LaSalle, IL
Revenue, Springfield,
IL
Tinker AFB, Oklahoma
City, OK
Paxton Avenue,
Chicago, IL
Lauder Salvage,
Beardstown, IL
Site size,
tons
1,800

1,800

900

200

7,000

30,000

1,000

1,000

16,000

8,500

Source of
contamination/
indicator
compound
Wood treatment/
pentachlorophenol
Crop-dusting
operation/DDT
Wood treatment/
dioxin
Army Base/dioxin

Used oil
recycling/PCBs
Transformer
reconditioning/ PCBs
PAHs

Aircraft maintenance
trichloroethylene
Waste lagoon/ RCRA
constituents
Metal scrap
salvage/PCBs
Contaminant
concentration
in treated soil, Combustion
mg/kg equipment
Rotary kiln

<0.2 Rotary kiln

<0.001 Rotary kiln

<0.001 Rotary kiln

<1 .0 Infrared conveyor
furnace
<2.0 Infrared conveyor
furnace
<0.33 Low-temperature
indirect desorber
Low-temperature
indirect desorber
Rotary kiln

<2.0 Rotary kiln

Thermal
capacity,
106Btu/h
12

12

12

12

30

30

12

12

35

35

Particulate
emissions,
APC gr/dscf at
equipment 7% 02
Wet scrubber

Wetscrubber 0.03

Wetscrubber 0.011

Wetscrubber 0.02

Wetscrubber ,0.08

Wetscrubber <0.08

Baghouse

Baghouse, wet
scrubber
Baghouse, packed
bed
Baghouse, packed 0.02
bed
Project
status
Contracted

Finished

Finished

Finished

Finished

Finished

Finished

Finished

Contracted

Finished

I
9.
Q.
Q'
(D
             aSource: Cudahy and Troxier 1990.

-------
Records of Decision

    The Superfund RODs for fiscal years (FYs) 1985 through
1988 indicate the increasing use of incineration as a remediation
method.  In 1984, only 8.0 percent of the total number of
RODs  (including  action memos,  enforcement decision
documents, and negotiation documents) involved incineration.
In 1989, 30 percent of the source control RODs that selected
treatment specified incineration/thermal destruction as all or
part of the remediation effort. More than half of those were for
onsite treatment (U.S.  EPA 1990).

    The RODs listed in Table 13 all recommended the use of
incineration/thermal destruction  as part of the site remediation.
More information on  any of these sites can be obtained by
requesting  a full copy of the ROD from any EPA library or by
contacting  the appropriate EPA Regional Office.
SITE Program

    In response to a requirement of SARA, the EPA established
a  program called the Superfund Innovative Technology
Evaluation (SITE) Program to encourage the development and
use of innovative technologies to clean up hazardous waste
sites.  Two of the major components of the SITE Program are
the Emerging Technologies  Program and the Demonstration
Program.  During the Emerging Technologies Program,  the
basic concepts of a new technology are validated through
bench and pilotscale testing. If the technology shows promise,
it  may advance to the Demonstration Program.  Along with
other technologies selected through annual solicitation,  the
performance of these technologies is evaluated under  field
conditions.  Reports discussing the procedures, sampling and
analytical data, results, etc., are prepared after each step. When
the demonstration is completed, an Applications Analysis Report
is prepared to evaluate all the information available on a particular
process and to analyze the applicability of the process to other
sites, waste types, and media. Also, each year EPA publishes a
document describing all  the technologies  that have been
evaluated under the SITE Program. Further information on the
SITE Program can be obtained from:

   Robert A, Olexsey, Division Director
   Superiund Technology Demonstration Division
   513/569-7861    FTS: 684-7861

   Stephen C. James, Chief
   SITE Demonstration & Evaluation Branch
   513/569-7877   FTS: 684-7877

   Norma M. Lewis, Chief
   Emerging Technology Section
   513/569-7665   FTS: 6847665

   John F. Martin, Chief
   Demonstration Section
   513/569-7758   FTS: 684-7758
                                             Table 13. Superfund Records Of Decision
                                          Recommending the Use Of Incineration/Thermal
                                                  Destruction For Site Remediation
                                       Region I
                                          Ottati and Goss
                                          Re-Solve, Inc.
                                          Davis Liquid Waste
                                          Cannon Engineering Corp.
                                          Rose Disposal Pit
                                          Charles George Landfill No. 3
                                          Pinette's Salvage Yard
                                          Wells G&H
                                          Baird & McGuire
                                          O'Connor Company Site
                                          Norwood PCBS
                                          W. R. Grace
                                        Region II
                                          Volney Landfill
                                          Williams Property
                                          Renora, Inc.
                                          Brewster Wellfield
                                          Ewan Property
                                          Reich Farms
                                          KinBuc Landfill
                                          Bog Creek Farm
                                          Claremont Polychemical
                                          Fulton Terminals
                                          Pepe Field
                                          Port Washington Landfill
                                          Vineland State School
                                        Region III
                                          Ordnance Works Disposal
                                          Douglassville Disposal
                                          Westline Site
                                          Wildcat Landfill
                                          Southern Maryland Wood
                                          Berks Sand Pit
                                          Drake Chemical Pit
                                          Avtex Fibers, Inc.
                                          Tyson Dump No. 1
                                          MW Manufacturing Site
                                          Douglassville Disposal
                                        Region IV
                                           Geiger (C&M Oil) Site
                                           Tower Chemical
                                           Martin MariettaSodyeco
                                           Zellwood Groundwater
                                           Chemtronics, Inc.
                                           Alpha Chemical Corp.
                                           Celanese Corp, Shelby Fiber
                                           Amnicola Dump
                                           Aberdeen Pesticide Dumps
                                           Newsom Brothers Old
                                              Reichold
                                           Carolawn
                                           Smith's Farm Brooks
Region V
   Laskin/Poplar Oil
   Liquid Disposal
   Seymour Recycling Corp.
   Pristine, Inc.
   LaSalle Electrical Utilities
   Forest Waste Disposal
   Belvidere Municipal Landfill
   Summit National Disposal
      Service
   Fort Wayne Reduction
   Laskin/Poplar Oil
   Wedzeb Enterprises, Inc.
   Ninth Avenue Dump
   Miami County Incinerator
   Alsco Anaconda
   Cliff/Dow Dump
   Cross Brothers Pail Recycling
   Big D Campground
   Twin City Army Ammo Plant
Region VI
   Hardage/Criner
   Cleve Reber
   Bayou Bonfouca
   Brio Refinery Co., Inc.
   Koppers Co.
   South Cavalcade Street
   Gurley Pit
   Sheridan Disposal Services
   Motco, Inc.
   United Creosoting Co.

 Region VII
   Minker/Stout/Romaine
   Times Beach
   Hastings Groundwater
 Region VIII
   Broderick Wood
   Products Co.
   Libby Groundwater
   Woodbury Chemical Co.
   Sand Creek Industrial
 Region IX
    Lorentz Barrel and Drum Co.


 Region X
    Pacific Hide & Fur
    Northwest Transformer
 20
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

-------
COMPLIANCE WITH FEDERAL AND STATE ARARs
State Laws
Federal Laws

    Section 121 of CERCLA requires that any Superfund action
that results in a hazardous substance or contaminant remaining
onsite attain a level of control that is at least equivalent to any
Federal standard, criteria, or limitation considered applicable or
relevant and appropriate (ARARs). Applicable requirements are
those standards,  criteria, or limitations that address a specific
hazardous  substance, pollutant, action,  location, or  other
circumstance at a site. Relevant and appropriate requirements
are those standards, criteria, or limitations  that  deal  with
problems or situations sufficiently similar to those encountered
at the site to be considered both relevant and appropriate.

    CERCLA actions  conducted entirely onsite  must comply
only with the substantive requirements of ARARs, not the
administrative requirements. Thus, CERCLA exempts any onsite
action from having to obtain a Federal, state,  or local permit;
however, the action is not exempt from complying with the
substantive portions of the same laws that the permits enforce.
Remedial actions that use offsite facilities during the cleanup
must comply with both the substantive and the administrative
portions  of all legally applicable requirements.  Also,  these
actions must be conducted only at facilities that are in compliance
with all applicable Federal and state requirements.

    Remedial actions also must consider nonregulatory guidance
manuals or advisories issued by Federal or state agencies. These
"to-be-considered" (TBC) materials are important because they
provide interpretation and analysis of ARARs.

    ARARs can be chemical-specific, location-specific, or action-
specific. Chemical-specific ARARs, such as the RCRA or the Safe
Drinking Water Act Maximum Contaminant Levels (MCLs), and
location-specific ARARs, such as Wetlands or Wilderness area
standards, are  too site-specific to be dealt with  here.   More
information on  these subjects  can be obtained  from  the
document entitled CERCLA Compliance With Other Laws Manual:
Interim Final, which  is listed  in  the selected  bibliography of
guidance and resource documents (see page 27).

        Action-specific ARARS are standards or requirements
related to technology- or activity-based remedial alternatives,
such as incineration.  Table 14 lists potential  ARARs that are
applicable to onsite incineration  as a CERCLA  remedial action
under EPA's HSWA omnibus authority. As new statutes are
passed or  regulations  promulgated, other action-specific
requirements will need to be added to this list. The proposed
amendments to  the hazardous waste  incinerator regulations
(55 FR 17862, April 27,  1990) and the proposed procedures
and technical  requirements  for corrective action at waste
management sites (55 FR 30798, July 27,1990) will be important
potential ARARs when promulgated.
    State regulations that are more stringent than Federal
standards must also be met during CERCLA actions if they are
identified in a timely manner by the state and if they meet the
criteria of being promulgated, generally applicable, and legally
enforceable.  Whether the state is the  lead or the support
agency, it is solely responsible for identifying potential state
ARARs and  documenting the  particular sections that  are
applicable to the site under remediation.  The EPA, however,
always retains  the responsibility for the final  decision on  the
applicability or the possible waiver of ARARs. Examples of state
laws that are potential ARARs include:

    •    Siting Requirements:   Most states  have locational
         standards that are more restrictive than the Federal
         regulations and that are specific to a site's topographic,
         hydrologic,  or  geologic  characteristics.   Remedial
         activities, such  as the  use of a mobile incinerator,
         could be subject to siting  limitations established for
         that type of facility or that area if those limitations are
         based on the protection  of  human health and  the
         environment.

    •    Discharge of Toxic Pollutants to Surface Waters:
         The Clean Water Act required states to adopt numeric
         criteria for the discharge "or presence of toxic pollutants
         applicable to the water body and sufficient to protect
         the designated use.  A proposed discharge  of
         incineration  scrubber water into surface water could
         be in  conflict with state regulations.

    •    Cleanup Standards:  States may enact more stringent
         cleanup standards than those required under Federal
         law. For example, under Federal law cleanup of releases
         of hazardous substances must leave no more than 25
         ppm  polychlorinated  biphenyls (PCBs)  in  the area;
         however, under Texas  law, cleanups must leave no
         more than 1  ppm.

    Generally, CERCLA actions  need  not comply  with local
laws;  however, the  laws  may  be part of a regional plan
enforceable by the state and, as such, are potential state ARARs.
Table 14 lists potential incineration ARARs.

         State standards are an integral part of determining the
remediation alternatives and  the level of control.  The public
comment period is not the time to identify conflicts  between a
selected remedial action and a state regulation. The document
CERCLA Compliance with Other Laws Manual, Part II, contains
detailed information on identifying and  complying with state
ARARS.
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects
                                                     21

-------
                                            TABLE 14.  POTENTIAL INCINERATION ARARSa-b
Prerequisite for Applicability
                   Requirement
                                                                                                                          Citation
RCRA

RCRA hazardous waste
                   Analyze the waste feed to determine physical and chemical composition limits.

                   Dispose of all hazardous waste and residues, including ash, scrubber water, and
                   scrubber sludge, according to applicable requirements.

                   (Note: No further requirements for wastes that are listed as hazardous solely because
                   they exhibit one or more of the characteristics of ignitability, corrosivity, reactivity or
                   because they fail the TCLP leaching test and a waste analysis demonstrates no
                   Appendix VIII constituent is present that might reasonably be expected to be present.)
                   Such wastes may also be exempted if Appendix VIII constituents are not present at
                   significant levels.l

                   Performance standards:

                         Achieve a destruction and removal efficiency (ORE)  of 99.99 percent for each
                         principal organic hazardous constituent designated  in the waste feed and
                         99.9999 percent for dioxins and PCB contaminated  liquids.

                         Reduce hydrogen chloride emissions to 1.8 kg/hr or to 1 percent of the HCI in
                         the stack gas before entering any pollution control device.

                         No release of particulates >180 mg/dscm (0.08 gr/dscf) corrected to 7%
                         Oxygen.

                         Emissions of CO must be <100 ppm and emissions of THC must be <20 ppm
                         corrected to 7% Oxygen.

                         Metals emissions less  than those established using the tiered approach outlined
                         in the document  "Guidance on Metal and HCI Emissions for Hazardous Waste
                         Incinerators" August 1989.

                         Trial Burn Requirements

                         All residues must meet the RCRA Land Disposal Restrictions

                    Control fugitive emissions by:

                         Keeping combustion zone sealed; or Maintaining combustion-zone pressure
                         lower than atmospheric pressure.

                    Use automatic cutoff system to stop waste feed when  operating conditions deviate or
                    exceed established limits.

                    Monitor various parameters  during operation, including combustion temperature,
                    waste feed rate, indication of combustion gas velocity, and carbon monoxide in stack
                    gas.
40 CFR 264.341

40 CFR 264.351


40 CFR 264.340
                                                                                                                          RCRA Omnibus
                                                                                                                          Authority
                                                                                                                           40 CFR 270.62

                                                                                                                           40 CFR 268



                                                                                                                           40 CFR 264.345


                                                                                                                           40 CFR 264.345


                                                                                                                           40 CFR 264.347
 CAA

 Air emissions
                     Remediation activities must comply with the National Ambient Air Quality Standards
                     (NAAQS). Compliance should be determined in cooperation with the appropriate
                     state government agency. An air permit from the state may be required.
 40 CFR 50
22
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

-------
                                           TABLE 14.  POTENTIAL INCINERATION ARARSa-b (Cont.)
 Prerequisite for Applicability
Requirement
Citation
 TSCA

 Liquid PCBs at concentration of 50 ppm or greater.
 Non-liquid PCBs, PCB articles, PCB equipment, and
 PCS containers at concentrations of 50 ppm or
 greater.
Performance standards:

   2-second residence time at 1200°C (±100°C) and 3 percent excess oxygen in
   stack gas; or

   1.5-second residence time at 1600°C and 2 percent excess oxygen in stack gas.

   Combustion efficiency of at least 99.90 percent.

   DRE>99.9999%

Rate and quantity of PCBs fed to the combustion system shall be measured and
recorded at regular intervals of no longer than 15 minutes.

Temperature of incineration shall be continuously measured and recorded.

Flow of PCBs to incinerator must stop automatically whenever the combustion
temperature drops below specified temperature."

Monitoring must occur:

   When the incinerator is first used or modified; monitoring must measure for 02,
   CO, C02, oxides of nitrogen, HCI, RCI, PCBs, total particulate matter.

   Whenever PCBs are being incinerated, the 02, CO, C02, oxides of nitrogen and
   CO levels must be continuously checked; C02 must be periodically checked.

Water scrubbers must be used for HCI control.

Mass air emissions from the incinerator shall be no greater than O.OOIg PCB per kg
of the PCBs entering the incinerator (99.9999 percent ORE).
                                               Requirements as listed for liquid PCBs.
40CFR761.70
                                                                                                                         40CFR761.70


                                                                                                                         40CFR761.70

                                                                                                                         40CFR761.70


                                                                                                                         40CFR761.70

                                                                                                                         40CFR761.70
40CFR761.70

40CFR761.70



40CFR761.70
  FIFRA

  Organic pesticides, except organic mercury, lead,
  cadmium, and arsenic (recommended).
  Metallo-organic pesticides, except mercury, lead,
  cadmium, or arsenic compounds (recommended).

  Combustible containers that formerly held organic
  or metal lo-organic pesticides, except organic
  mercury,  lead, arsenic, and cadmium
  (recommeded).
Performance standards:

    2-second residence time at 1000°C (or equivalent that will assure complete
    destruction).

Meet requirements of CAA relating to gaseous emissions.

Dispose of liquids, sludges, or solid residues in accordance with applicable Federal,
State, and local pollution control requirements.

Chemically or physically treat pesticides to recover heavy metals; incinerate in same
manner as organic pesticides.

Incinerate in same manner as organic pesticides.
40 CFR 165.8
40 CFR 165.1

40 CFR 165.8

40 CFR 165.8


40 CFR 165.8


40 CFR 165.9
  OSHA

  Remediation activities
All remediation activities must comply with the policies and programs established for
worker safety.
 29 CFR 1910
 29 CFR 1926
l_
a Source:  U.S. Environmental Protection Agency 1988a and 1989a.    .
b The regulations cited herein may contain special provisions or variances applicable to the specific site under remediation. In all circumstances the actual
 •egulations should be consulted before any decisions are formulated.
   Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects
                                                                                           23

-------
COST OF INCINERATION
                                                   SOURCES OF INFORMATION
    Incineration costs will vary significantly from site to site.
Unfortunately, costs are often sources of controversy during site
remediation.  The relatively high cost of incineration often
eliminates it as a treatment option.  This being the case, it is
very Important to conduct an accurate cost assessment. Since
detailed cost estimation is not within the scope of this document,
the RPM/OSC is urged to work in close coordination with the
RCRA  incineration contacts in each Region during  the
development of cost estimates for incineration projects.   To
provide some preliminary background information on this topic,
the following information is provided.

    The cost of an incineration system varies with several factors,
Including:
    •   System capacity
    •   Types of feedstocks being fed
    •   Regime (i.e., slagging vs. ashing)
    •   Length-to-diameter (L/D) ratio for rotary kilns
    •   Type of solids discharge system
    •   Type and capacity of afterburner
    •   Type of auxiliary fuel used
    •   Regulatory climate

    These costs in turn affect the cost of waste treatment by
incineration.   Table  15 presents the estimated costs of
Incinerating contaminated soils  in  both onsite and offsite
incineration systems. These costs do not include transportation,
storage, or removal of  the soil from the ground.  The total cost
of waste treatment would vary considerably from site to site,
and any estimate should include the following (Evans 1990):
        Site preparation
        Permitting and regulatory requirements
        Capital equipment
        Startup
        Labor
        Consumables and supplies
        Utilities
        Effluent treatment and disposal
        Residuals/waste shipping and handling
        Analytical services
        Maintenance and modifications
        Demobilization
                                       Technical Specialists
                                           Communication between the RPM, the EPA Regional office,
                                       and the  corresponding state environmental office is  critical.
                                       More importantly,  communication with the  RCRA
                                       incineration experts and technical contacts in each Regional
                                       office who have extensive incineration expertise is vital to
                                       the  success  of  remedial/removal activities involving
                                       incineration. Any remediation plans  involving an incinerator
                                       should be sent to the Regional RCRA  incinerator permit office
                                       for review.  Getting this office involved early in the remediation
                                       selection process can prevent costly delays later.  Each Regional
                                       office has an incinerator expert available as a technical specialist
                                       to advise and assist the RPM.  Many states also have technical
                                       contacts with extensive experience in incineration. The following
                                       is a list of the EPA Headquarters and Regional incinerator experts
                                       and the corresponding state expert. If a state does not have an
                                       incinerator expert on their staff, the RPM is referred to the
                                       Regional office.
Table 15. Typical Costs of Incineration of Contaminated
                         Soils0-"
Incineration system
capacity Unit cost
(tons/h) ($/ton)
Centralized rotary kiln system
Onsite Incineration
Small site (<5.000 tons)
Medium site (5,000 to 10,000 tons)
Large site (>30,000 tons)
Commercial unit 300 to 650
<5 1000 to 1500
5 to 10 300 to 800
>10 100 to 400
* Estimated costs are in 1988 dollars. They do not include the cost of
 transportation, removal of soils from the ground, or storage.
b Sources: Cudahy, Decicco, and Troxler 1987; Tillman, Rossi, and Vick 1990;
 U.S. Environmental Protection Agency 1988.
24
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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  Contact
  Headquarters
      Sonya Sassevilie, Chief
      Alternative Technology and
      Support Section

      Lionel Vega, Incineration
      Permit Assistance '
FTS

382-3132



475-8988
Commercial

202/382-31 32



202/475-8988
Region 1.
Stephen Yee
John Podgurski
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II.
John Brogard
Clifford Ng (Puerto Rico)
New jersey
New York
Region III.
Gary Gross
Delaware
Dist. of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region IV.
Betty Willis
• Alabama
Florida
Georgia
Kentucky
Mississippi
N. Carolina
S. Carolina
Tennessee
Region V.
Y. J. Kim
Juana Rojo (Illinois)
Gary Victorine (Indiana)
Lorna Jereza (Michigan)
Wen Haung (Minnesota)
Thelma Codina (Ohio)
Wen Haung (Wisconsin)
Illinois
Indiana
Michigan
Minnesota



George Dews
See Regional contact.
Stephen Dresszen
See Regional contact.
Beverly Migllore
See Regional contact.



Thomas Sherman
James Dolen


Ken Weiss
Angelo Tompros
Alvin Bowles
Joe Hayes
Karol Akers
Robert Weser


Clyde Shearer
John Griffith
Bill Mundy
Mohammed Alauddin
Steve Spengler
Bill Hamner
David Wilson
Jackie Okoree-Baah








Robert Watsort
Elaine Greg
Steve Buda
Fred Jenness

833-1644
833-1673







264-8682
264-9579



597-7940







257-3433









886-6147
886-0990
886-1479
353-5110
886-6191
886-6181
886-6191





617/573-9644
617/573-9673
203/566-2264

61 7/292-5832

401/277-2797


21 2/264-8682
212/264-9579
609/292-1 250
51 8/457-6934

21 5/597-7940
302/736-3689
202/783-31 94
301/631-3343
717/787-7381
804/225-2496
304/348-4022

404/347-3433
205/271-7700
904/488-0300
404/656-2833
502/564-671 6
601/961-5171
919/733-2178
803/734-5200
61 5/741 -3424

312/886-6147
312/886-0990
312/886-1479
312/353-5110
312/886-6191
312/886-6181
312/886-6191
217/785-8410
31 7/232-8866
51 7/373-2730
612/297-1792
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects
                                        25

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Contact
                                   EES
Commercial
       Ohio
       Wisconsin
      Bob Babik
      Ed Lynch
Region Vi.
   Henry Onsgard
   Jim Sales (Texas)
   Stan Burger (Arkansas,
   Louisiana, Oklahoma, New Mexico)
       Arkansas            Mike Bates
       Louisiana           Karen Fisher
       New Mexico         Dr. Elizabeth Gordon
       Oklahoma       .  Catherine Sharp
       Texas               Wayne Harry
                                   655-6785
                                   655-6785
                                   655-6785
Region VII.
   joe Galbraith
   Luetta Flournoy (Iowa)
       Iowa
       Kansas
       Missouri
       Nebraska

Region VIII.
   Nat Miullo
       Colorado
       Montana
       N. Dakota
       S. Dakota
       Utah
       Wyoming

Region IX.
   Larry Bowerman
       Arizona
       California
         Region 1
         Region 2
         Region 3
         Region 4
       Hawaii
       Nevada

Region X.
   Cathy Massimino
       Alaska
       Idaho
       Oregon
       Washington
                                   276-7057
                                   276-7058
      See Regional contact.
      John Ramsey
      John Doyle
      Glen Dively
      Neal Kolwey
      See Regional contact.
      See Regional contact.
      See Regional contact.
      Connie Nakahara
      See Regional contact.
      Al Roesler
      Sangat Kals
      Eric Hong
      Don F. Murphy
      Gautum Guha
      Anand Rege
      Les Segunda
      Don Gross
      David Ditraglia
      Jay Skabo
      Ed Chiong
      Cindy Gilder
                                    330-1500
                                   484-1471
                                    399-4153
614/644-2949
608/266-3084
214/655-6785
214/655-6785
214/655-6785

501/562-7444
504/342-4685
505/827-2934
405/271-7062
512/463-8173
913/551-7057
913/551-7653

913/296-1610
314/751-3176
402/471 -4176
303/330-1500
303/331-4830
801/538-6170
415/744-
602/257-
916/324-
916/855-
415/540-
818/567-
21 3/590-
808/548-
702/885-
1471
2249
9611
7726
3969
3123
4896
8837
5872
206/442-4153
907/465-2671
208/334-5879
503/229-5326
206/438-7019
26
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects

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GUIDANCE AND RESOURCE DOCUMENTS


EPA Hazardous Waste Incineration
Guidance Series

Volume I:   Guidance Manual for Hazardous Waste Incinerator
           Permits.  SW-966,  July 1983. NTIS:  PB84-100577
           (update expected late 1990)

Volume II:   Guidance on Setting  Permit Conditions  and
           Reporting Trial Burn Results.  EPA-625/6-89-019,
           January 1989.

Volume III:  Hazardous Waste Incineration Measurement
           Guidance Manual. EPA-625/6-89-021, June 1989.
           NTIS: PB90-182759.

Volume IV:  Guidance on  Metals and Hydrogen Chloride
           Controls  for Hazardous  Waste Incinerators. 1989
           Draft Report.

Volume V:   Guidance on PIC  Controls for Hazardous Waste
           Incinerators. 1989 Draft Report.

Volume VI:  Proposed Methods for Measurement of CO, O2,
           THC, HCI,  and Metals  at  Hazardous  Waste
           Incinerators. 1989 Draft Report.


Other EPA Resource Documents

CERCLA Compliance  with Other Laws  Manual:  Interim Final.
EPA 540/G-89-006. August 1988.

CERCLA Compliance with Other Laws Manual: Part II. Clean Air
Act and Other Environmental Statutes and State Requirements.
EPA 540/G-89-009, August 1989.

Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA:   Interim  Final.  EPA 540/G-89-004.
October 1988.

Engineering Handbook for Hazardous Waste Incineration.  SW-
889, September 1981. NTIS: PB81-248163. (update expected
late 1990).

Quality Assurance/Quality Control  (QA/QC) Procedures for
Hazardous Waste Incineration.  EPA-625/6-89-023,1989.

American Society of Mechanical  Engineers (ASME).   1988.
Hazardous  Waste Incineration, A  Resource Document.  The
ASME Research Committee on Industrial and Municipal Waste.
New York City.

Brunner, C.  R. 1988. Site Cleanup by Incineration. Hazardous
Materials Control Research Institute, Silver Spring, MD.

Freeman, H. M., ed.  1989. Standard Handbook of Hazardous
Waste Treatment and Disposal. McGraw-Hill New York. 1989.

Oppelt, E.T. 1987. Incineration of Hazardous Wastes, A Critical
Review. Journal of the Air Pollution Control Associates, 27(5):558-
586.
U.S. Congress, Office of Technology Assessment. 1988. Are We
Cleaning Up? 10 Superfund Case Studies-Special Report. OTA-
ITE-362. U.S. Government Print Office, Washington DC.

U.S. Congress, Office of Technology Assessment. 1986. Ocean
Incineration:  Its Role Managing Hazardous Waste. OTA-O-
0313. U.S. Government Printing Office. Washington, DC.

U.S. Environmental Protection Agency.  1986b.  Handbook-
Permit Writer's Guide to Test Burn  Data, Hazardous Waste
Incineration. EPA 625/6-86-012.
ACKNOWLEDGMENTS

The first draft of this document was prepared for the USEPA Risk
Reduction Engineering Laboratory by PEI Associates underwork
Assignment No. 19-2V of Contract 68-03-3413. The work was
done under the technical direction of Laurel Staley, with RREL.
The document received in-depth technical reviews from the
following individuals:  Ed Hanlon,  Beverly Houston, Sonya
Sasserville, Phil Taylor, Paul Leonard, Nat Muillo, Joseph Santoleri,
Robert Thurnau, Marta Richards, James Scarborough, Richard
Carnes, and Ernest Franke. Their comments are much appreciated
and have significantly improved the accuracy and completeness
of the final document.
REFERENCES

American Society of Mechanical Engineers (ASME).  1988.
Hazardous Waste Incineration,  A Resource Document.  The
ASME Research Committee on Industrial and Municipal Waste.
New York City.

Air Pollution Control Association (APCA). 1987. Incineration of
Hazardous Waste, Critical Review Discussion Papers. Journal of
the Air Pollution Control Association  37(9):1011-1024,
September.

Brunner, C. R. 1988a. Site Cleanup by Incineration. Hazardous
Materials Control Research Institute, Silver Spring, MD.

Brunner, C. R. 1988b. Industrial Waste Incineration. Hazardous
Materials Controls 1(4):26+, July/August.

Buonicore, A. J.  1990.  Experience with Air Pollution Control
Equipment on Hazardous Waste Incinerators.  Paper No. 90-
33.2.  Presented at the 83rd Annual Meeting of the Air and
Waste Management Association held in Pittsburgh, PA, June 24-
29, 1990.

Cudahy, J., S. DeCicco, and W. Troxler. 1987. Thermal Treatment
Technologies for Site Remediation. Presented at the International
Conference on Hazardous Materials Management, Chattanooga,
TN, June 9, 1987.

Cudahy, J. ]., and W. L. Troxler.  1990.  Thermal Remediation
Industry Update-ll.  Paper presented  at the Air & Waste
Management Association  Symposium on Treatment
Contaminated Soils, Cincinnati,  Ohio, February 6,1990.

Daniels, S. L.  1989.   Products of Incomplete Combustion.
Journal of Hazardous Materials, 22(2):161-174, November.
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects
                                                   27

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Dellinger, B., P. H. Taylor, and D. A. Tiery.  1989. Pathways of
Formation of Chlorinated PICs From the Thermal Degradation
of Simple Chlorinated Hydrocarbons.  Journal of Hazardous
Materials, 22(2):175-186, November.

Dellinger, B., Torres, J.L., Rubey, W.A., Hall, D.L., Graham, J.L,
and Carries, R.A. "Determination of  the Thermal Stability of
Selected Hazardous Organic Compounds"  Hazardous Waste,
Vol.1, pp. 137-157(1984)

Dellinger, B., Taylor, P.H., and Tirey, D.A., "Minimization and
Control of Hazardous Combustion Byproducts," Final Report
and Project Sumary prepared for  U.S.EPA under cooperative
agreement CR-813938-01 -0, April 1990.

Evans, G. M. 1990.  Estimating Innovative Technology Costs for
the Site Program.  Journal  of the Air & Waste Management
Association, 40(7):1047-1051, July.

Freeman, H. M., ed. 1989. Standard Handbook of Hazardous
Waste Treatment and Disposal.  McGraw-Hill. New York.

McCormick, R. J. and M. L Duke. 1989. On-Site Incineration as
a Remedial Action Alternative. Pollution Engineering, 21 (8):68-
73, August

McCoy & Associates,  Inc.   1989.   Mobile Treatment
Technologies-Regulations, Outlook, and Directory of Commercial
Vendors. The Hazardous Waste Consultant, 7(1 ):4-1 +, January/
February.

McGraw-Hill, Inc. 1990. Superfund Cleanup Plans. Inside EPA's
Superfund Report, 4(5):32,  February 28.

Oppeit^ET. 1987.  Incineration  of Hazardous Wastes, A Critical
Review.   Journal of the Air Pollution Control Association,
27(5):558-586, May.

Santoleri,  J. J.  1989.   Design and Operating Problems of
Hazardous Waste Incinerators. Enviromental Progress, 4(4)246-
251, November.

Santoleri, J.J. 1989. "Liquid-Injection Incinerators." In: Standard
Handbook of Hazardous Waste Treatment and Disposal. H. M.
Freeman, ed. McGraw-Hill, New York.

Santoleri, J. J. 1989. Rotary Kiln Incineration Systems:  Operating
Techniques for Improved Performance.  In: Proceedings of the
Third International Conference on New Frontiers for Hazardous
Waste Management, Pittsburgh, PA,  September 10-13, 1989.
EPA/600/9-89-072.

Schaefer,  C. F., and A. A. Albert.  1989.  Rotary  Kilns.  In:
Standard  Handbooks of Hazardous Waste Treatment and
Disposal.  H. M. Freeman, ed. McGraw-Hill. New York.

Stumbar. J. P., et al. 1989. Operating Experiences of the EPA
Mobile Incineration System with Various  Feed Materials.  In:
Proceedings of the Third  International Conference on New
Frontiers for Hazardous Waste  Management, Pittsburgh, PA,
September 10-13,1989. EPA/600/9-89/072.

Taylor, P.H. and  Dellinger,  P., "Thermal Degradation
Characteristics of Chlorinated Methane Mixtures," Environmental
Sciences Technology Vol. 22, pp. 438-447 (1988).
                                     Taylor, P.H. and Dellinger,  B., "Development of a Thermal
                                     Stability  Based Ranking of Hazardous Organic Compound
                                     Incinerability,"  Environmental Science & Technology  Vol 24
                                     pp. 316-328.

                                     Tirey,  D.A., Taylor,  P.H., and  Dellinger,  B., "Products  of
                                     Incomplete Combustion from the High Temperature Pyrolysis
                                     of the Chlorinated  Methanes," in Emissions fromCombustion
                                     Processes: Origin. Measurement and Control, pp. 109-120 (Lewis
                                     Publishers: Chelsea, Ml) 1990.

                                     Tillman,  D., A. Rossi, and K. Vick.  1990.  Rotary Incineration
                                     Systems  for Solid Hazardous Wastes.   Chemical Engineering
                                     Progress, 86(7):19-30, July.

                                     U.S.   Environmental Protection Agency.  1986a.   Mobile
                                     Treatment Technologies for Superfund Waste. EPA/2-86/003(f).
                                     Office of  Solid Waste and Emergency Response, Washington, DC.

                                     U.S. Environmental Protection Agency.  1988b.  Handbook-
                                     Permit Writer's Guide  to Test Burn Data,  Hazardous Waste
                                     Incineration. EPA 625/6-86-012.

                                     U.S.  Environmental  Protection  Agency.   1988a.   CERCLA
                                     Compliance with Other Laws Manual:  Interim Final. EPA 540/
                                     G-89-006.

                                     U.S. Environmental Protection Agency. 1988b. Experience in
                                     Incineration Applicable  to Superfund Site Remediation.- Center
                                     for Environmental Research Information, Cincinnati, Ohio.

                                      U.S. Environmental Protection Agency. 1988c.  Guidance for
                                     Conducting Remedial Investigations and Feasibility Studies Under
                                     CERCLA: Interim Final.  EPA 540/G-89-004.

                                      U.S.  Environmental  Protection Agency.   1989a.   CERCLA
                                      Compliance with Other Laws Manual: Part II. Clean Air Act and
                                      Other Environmental Statutes and  state  Requirements.  EPA
                                      540/G-89-009.

                                      U. S. Environmental  Protection Agency. 1988.  Guidance for
                                      Conducting Remedial  Investigations/Feasibility Studies Under
                                      CERCLA. Interim Final  EPA 540/G-89/004.  (OSWER Directive
                                      9355.3-01)

                                      U.S.  Environmental Protection Agency. 1987 The RPM Primer:
                                      An Introductory Guide  to the Roles and Responsibilities of the
                                      Remedial Project Manager EPA540/G-87/005

                                      U.S. Environmental Protection Agency.  1989b. The Superfund
                                      Innovative Technology Evaluation Program: Technology Profiles.
                                      EPA 540/5-89-013.

                                      U.S.  Environmental Protection Agency.  1990. ROD Annual
                                      Report:  FY1989.  EPA-540/8--90-006.

                                      Weinberger, L, etal. 1984.  Supporting Documentation for the
                                      RCRA Incinerator Regulations, 40 CFR  265, Subpart O -
                                      Incinerators.  U.S.  Environmental Protection Agency Contract
                                      No. 68-01 -6901.

                                      Wilson,  R. 1978. Analyzing the  Daily Risks of Life. Technology
                                      Review,  February 1979.
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