Superfund Engineering Issue: Issues Affecting the Applicability and Success of Remedial/Removal Incineration Project

&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
Issues Affecting the Applicability and Success of Remedial/Removal Incineration Projects
-------

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

Ogden

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

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

Project
status
Ongoing

Ongoing

Finished

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

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

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

<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

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

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 264.347
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
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 165.9
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
-------
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
-------
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
-------
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.