&EPA
           United States
           Environmental Protection
           Agency
           Risk Reduction
           Engineering Laboratory
           Cincinnati OH 45268
EPA/540/5-88/002a
September 1988
           Superfund
Technology Evaluation
Report SITE Program
Demonstration Test,
Shirco Infrared
Incineration System
Peak Oil, Brandon,
Florida

Volume I
SUPERFUND INNOVATIVE
TECHNOLOGY EVALUATION

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                                        EPA/540/5-88/002a
                                           September 1988
    Technology Evaluation Report
 SITE Program Demonstration Test,
Shirco InfraredJncineratlonJjysterri
      Peak Oil, Brandon, Florida

                 Volume I
                     by

               Seymour Rosenthal
             Enviresponse, Incorporated
               Livingston, NJ 07039

         Cooperative Agreement 68-03-3255

               SITE Project Manager

                 Howard Wall
         Risk Reduction Engineering Laboratory
               Cincinnati, OH 45268
      Risk Reduction Engineering Laboratory
       Office of Research and Development
       U.S. Environmental Protection Agency
             Cincinnati, OH 45268

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                             NOTICE
The information in this document has been funded by the U.S.
Environmental Protection Agency under Contract No. 68-03-3255
and the Superfund Innovative Technology Evaluation (SITE)
Program.  It has been subjected to the Agency's peer review
and administrative review, and it has been approved for
publication as an EPA document.  Mention of trade names or
commercial products does not constitute an endorsement or
recommendation for use.
                               ii

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                           FOREWORD
     The Superfund Innovative Technology Evaluation  (SITE) program
was authorized in the 1986 Superfund amendments.  The program  is  a
joint effort between EPA's Office of Research and Development  and
Office of Solid Waste and Emergency Response.  The purpose of  the
program is to assist the development of hazardous waste treatment
technologies necessary to implement new cleanup standards which
require greater reliance on permanent remedies.  This is accomp-
lished through technology demonstrations which are designed  to
provide engineering and cost data on selected technologies,

     This is the first in a series of reports which  will be  prepared
by the SITE program.  The report provides documentation of the first
innovative technology demonstration which took place at the  Peak  Oil
Superfund site in Brandon, Florida.  Observation and sampling  of  a
Shirco infrared incinerator took place during the course of  a  removal
operation conducted by EPA Region IV.  The SITE effort was directed
at obtaining information on the performance cost of  the unit for
use in assessments at other sites.

     Additional copies of this report may be obtained at no  charge
from EPA's Center for Environmental Research information, 26 West
Martin Luther King Drive, Cincinnati, Ohio, 45268, using the EPA
document number found on the report's front cover.   Once this  supply
is exhausted, copies can be purchased from the National Technical
Information Service, Ravensworth Bldg., Springfield, VA, 22161,
(702) 487-4600.  Reference copies will be available  at EPA
libraries in their Hazardous Waste collection,  you  can also call
the SITE Clearinghouse hotline at 1-800-424-9346 or  382-3000 in
Washington, D.C. to inquire about the availability of other  reports.
Tho
Office of Program Management
  and Technology
U*AA»*JlA
er, Dir>3<
   H.  Skinner, Director
 ice of Environmental
 ngineering and Technology
Demonstration

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                            ABSTRACT

A critical assessment is made of the performance of the
transportable Shirco Infrared Thermal Destruction System
during three separate test runs under actual  operating
conditions.  The unit was being operated as part of an
emergency cleanup action at the Peak Oil Superfund site in
Brandon, Florida.  An evaluation is provided  of the
feasibility of utilizing the system as a hazardous waste
treatment alternative at other sites throughout the country.
A comprehensive process description of the unit includes a
diagram of the unit at the Peak Oil site.   Field operations
documentation includes a discussion of the operational history
during the test program, a summary of operating conditions,
and the operating log data.  The sampling  and analytical
procedures are summarized, and the final sampling and
analytical report and the quality assurance project plan as
prepared by the sampling and analytical  contractor are
provided.  Performance data are discussed  in  detail,  and the
unit's ability to effectively destroy hazardous constituents
in the Peak Oil waste feed is evaluated.  Unit cost elements
are discussed along with an overall cost evaluation of the
transportable Shirco Infrared Thermal Destruction Unit.
Operations problems that occurred during the  test program are
addressed.  Mechanical and process problems that occurred
during the operation of the unit under start-up and site
emergency cleanup conditions are also discussed.  Based on the
above information, the report provides the initial data and
evaluative criteria to enable the EPA to determine the
applicability of the Shirco technology to  Superfund site
investigations and cleanups throughout the country.
                               i v

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                       VOLUME  I  CONTENTS*
                                                        Page
Foreword	   iii
Abstract	    iv
Figures	    vi
Tables	   vii
Acknowledgments	    ix

1.  Introduction 	     1
2.  Executive Summary  	     3
3.  Process Description  	     9
    3.1  General Process Description 	     9
    3.2  Detailed Process Description  	    11
4.  Field Operations Documentation 	    17
    4.1  Operational History 	    17
    4.2  Operating Conditions Summary  	    20
    4.3  Operating Log Data	    21
5.  Sampling and Analysis Program  	    30
    5.1  Sampling Procedures 	    35
    5.2  Analytical  Procedures 	    46
6.  Performance Data Evaluation  	    54
    6.1  Introduction	    54
    6.2  Destruction and Removal
           Efficiency (ORE)  	    54
    6.3  Acid Gas Removal  	    58
    6.4  Particulate Emissions 	    58
    6.5  Leaching Characteristics  	    63
    6.6  Products of Incomplete Combustion 	    63
    6.7  Ambient Air Sampling and Mutagenic Testing   .    65
    6.8  Material Balances 	    66
7.  Economics	    77
    7.1  Introduction	    77
    7.2  Cost Elements	    78
    7.3  Overall Cost Evaluation	    84
8.  Problems During  Testing  	    88
    8.1  Demonstration Test Problems 	    88
    8.2  Overview of Unit Problems	    88
    Volume II contains Appendices A, B, and C:  Operating Data
    Log; Sampling and Analytical Report; and Quality Assurance
    Project Plan/Test Plan, respectively.

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                            FIGURES
Number                                                  Page
3.1      Peak Oil Incinerator Unit	   10
5.1      Sampling Locations  	   36
6.1      Memo:  Mutagenicity of Peak Oil
         Soil Samples	   67
                               vi

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                             TABLES
Number                                                  Page
2.1      SITE Demonstration Test Results Summary  ...    5
4.1      Chronological Operational History 	   18
4.2      Unit Operating Conditions - Control  Room
         Data - 8/1/87	   22
4.3      Unit Operating Conditions - Field Data
         8/1/87	   23
4.4      Unit Operating Conditions - Control  Room
         Data - 8/2/87	   24
4.5      Unit Operating Conditions - Field Data
         8/2/87	   25
4.6      Unit Operating Conditions - Control  Room
         Data - 8/3/87	   26
4.7      Unit Operating Conditions - Field Data
         8/3/87	   27
4.8      Unit Operating Conditions - Control  Room
         Data - 8/4/87	   28
4.9      Unit Operating Conditions - Field Data
         8/4/87	   29
5.1      Summary of Sampling and Analytical Program for
         the Peak Oil Site, Brandon, Florida	   31
6.1      Destruction and Removal Efficiency of PCBs   .   56
6.2      Results of PCB Analyses on Solid Streams  .  .   57
6.3      Results of TCO and Gravimetric Analyses  ...   59
6.4      Results of Proximate and Ultimate Analyses
         of Solids Streams	   60
6.5      Stack Gas HC1, S02, and Acid Gas Removal
         Efficiency	   61
6.6      Particulate Loading 	   62
6.7      Disposition of Lead in the System	   64
6.8      Material Balance - 8/1/87	   69
                              VI 1

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                       TABLES  (continued)
Number                                                  Page

6.9      Material Balance - 8/2/87	 .   71
6.10     Material Balance - 8/3/87 .  .  .	   73
6.11     Material Balance - 8/4/87	   75
7.1      Overall Cost Element Breakdown  . . . ....   79
7.2      Economic Model for Shirco Unit,  Peak Oil ...  85
                              viii

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                        ACKNOWLEDGMENTS
This document was prepared under the Superfund Innovative
Technology Evaluation (SITE) program by Enviresponse, Inc. for
the U.S. Environmental Protection Agency under Contract No.
68-03-3255.

Enviresponse, Inc. would like to thank Mr. Howard Wall of the
EPA, the overall SITE Project Manager; Mr. Fred Stroud of EPA
Region IV, the On-scene Coordinator for the cleanup operation;
Mr. John Gilbert of the EPA, Chief, Operations Support Section
of the Environmental Response Branch supporting the cleanup
operation; and other contributors from the EPA's Office of
Research and Development,  Office of Solid Waste and Emergency
Response, and Region IV Office.

In addition, we extend our appreciation to contributors from
Haztech, Inc., Shirco Infrared Systems Incorporated, and
Radian Corporation, the sampling and analytical contractor.
                               ix

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                           SECTION 1

                          INTRODUCTION
Beginning in the 1950s Peak Oil, an oil rerefiner, operated a
used oil processing facility in Brandon, Florida.  Various
waste streams from the rerefining operation were dumped into a
natural  lagoon located on the property.  The lagoon quickly
became contaminated with PCBs and lead contained in the waste
and, as  has occurred in the majority of Florida's delicate and
shallow  aquifer systems, the result was contamination of local
drinking water supplies.  The United States Environmental
Protection Agency (EPA) ranked the site on the National
Priorities List (NPL) primarily due to the contamination of
groundwater by PCBs.

Because  of the existence of an imminent hazard, EPA Region IV
initiated and supervised a removal action at the site.  The
Region contracted with Haztech, Inc., an emergency removal
cleanup  contractor.

The waste oil sludge residue from the oil reclaiming process,
although high in organic content, could not be reclaimed or
recycled.  With PCB contents ranging up to 100 ppm, the
removal  action called for mitigation of the human-direct
contact  threat through the thermal destruction of the waste
oil sludge in a high temperature incinerator capable of
destroying the PCB contaminants in a cost-effective and
environmentally sound manner.  Metals that concentrated in the
ash would then be dealt with after the thermal destruction of
the waste oil sludge was completed.

Initial  efforts required that the lagoon be drained of water
and mixed with sand, soil, and lime to form a waste soil
matrix that could be negotiated by earth-moving equipment.
The lime, in addition to providing binding to the moisture-
laden soil, also counteracted and neutralized the highly
acidic waste produced by the acid-based rerefining process.

In November 1986, Haztech began setting up a transportable
thermal  destruction system developed by Shirco Infrared
Systems, Inc., of Dallas, Texas.  Each component of the Shirco
system is secured on a wheel-mounted skid and was easily
transported by road to the Peak Oil site.

Coincident to this removal action, the EPA had initiated a
major new program to further the acceptance and use of
alternative and innovative treatment technologies at Superfund
sites.  The program, called the Superfund Innovative
Technology Evaluation, or SITE Program, had been established

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In accordance with the Superfund Amendments and
Reauthorization Act of October 17, 1986.  It is jointly
sponsored by the EPA's Office of Research and Development
(ORD) and Office of Solid Waste and Emergency Response
(OSWER).  One of the specific projects under this SITE Program
is the technology evaluation of the transportable Shirco
infrared thermal system by the EPA's ORD.

With the removal action already underway at the Peak Oil site,
it seemed to be an ideal opportunity for the SITE Program to
interact with the removal action and evaluate the Shirco
system under actual operating conditions.

With the Shirco^unit fully operational at the Peak Oil site,
it was the intent of the SITE Program to observe the unit
operation, collect data, document the mechanical operating
history of the system, and, under rigorous QA/QC protocols,
obtain samples and perform definitive analyses of the solid
waste feed, stack gas, furnace ash, scrubber liquid effluent,
scrubber water inlet, scrubber effluent solids, and ambient
air during a series of three replicate test runs.

This report is based on monitoring of the unit's operation and
discussions with Haztech and Shirco, Inc.  Also utilized are
existing project cost data and interpretations of the results
of sample analyses.  The report has been prepared to establish
reliable performance and cost information in order to evaluate
the applicability of the Shirco technology at the Peak Oil
site as well as for use at other sites and applicability with
other waste matrices.

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                           SECTION 2

                       EXECUTIVE SUMMARY
The SITE Program demonstration test of the Shirco infrared^
Incineration system was conducted at the Peak Oil Superfund
site in Brandon, Florida during a removal action by EPA Region
IV.  The Region had contracted with Haztech, Inc., an
emerge_ncjr_rejnp_v_a_l cleanup contractor, to incinerate
approximately 7,000 tons of waste oil sludge contaminated with
PCBs and lead.  The ongoing removal action offered an ideal
opportunity for the SITE program to obtain specific operating,
design, analytical, and cost information to evaluate the
performance of the unit under actual operating conditions.
The SITE program also could study the feasibility of utilizing
the Shirco transportable infrared incinerator as a viable
hazardous waste treatment system at other sites throughout the
country.  To this end, specific test objectives were:

o   To determine the destruction and removal efficiency (ORE)
    for PCBs in the Shirco system.

o   To report the unit's ability to decontaminate the solid
    material being processed and determine the destruction
    efficiency (DE) for PCBs based on the PCB content of the
    furnace ash.

o   To evaluate the ability of the unit and its associated air
    pollution control/scrubber system to limit hydrochloric
    acid and particulate emissions.

o   To determine whether heavy metals contaminants in the
    waste feed are chemically bonded or fixated to the ash
    residue by the process.

o   To determine the effect that the thermal destruction
    process has in producing combustion byproducts or products
    of incomplete combustion (PICs).

o   To determine the impact of the unit operation on ambient
    air quality and potential mutagenlc exposure.

o   To develop a set of material balances that defines the
    major unit stream material flows and componential
    breakdowns.

o   To provide sufficient unit cost to effectively develop a
    cost/economic analysis for the unit.

o   To document the mechanical operations history of the unit
    and analyze and provide potential solutions to chronic
    unit mechanical problems.

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The SITE test program at Peak Oil was conducted from July 31,
1987 to August 4, 1987.  During this period, EPA observed the
unit operation, collected data, and documented the mechanical
operating history of the system and the problems encountered
in operating this type of full-scale incineration unit.

The overall  program consisted of three separate test runs
conducted under the normal  operating conditions of the unit;
during one of these runs, a duplicate set of samples was taken
and analyzed.to satisfy rigorous quality assurance/quality
control (QA/QC) protocols.   EPA documented all operating
conditions during the test runs and conducted extensive
sampling of the solid waste feed, stack gas, furnace ash,
scrubber liquid effluent, scrubber water inlet, scrubber
solids, and ambient air.  QA/QC audit teams observed and
evaluated QA/QC protocols for both the sampling and analytical
phases of the test program.  The final Quality Assurance
Project Plan/Test Plan is presented in Appendix C (Volume II).

Section 4 presents a detailed account of test conditions, and
Appendix A (Volume II) contains both operator input and
computer spreadsheet data.

Section 5 of this report presents the complete results of all
analytical work performed on the samples, including
discussions  of the sampling and analytical protocols.
Appendix B (Volume II) contains the complete Sampling  and
Analytical Report.

SUMMARY OF RESULTS

Presented below is a summary of the results related to each of
the above-defined objectives for the test program.  A  summary
of the key test data is presented in Table 2.1.

o   ORE

    As discussed in Section 6.2, the Shirco unit achieved a
    ORE for PCBs in excess  of 99.99%.  It was not possible to
    calculate the ORE beyond two decimal places because of the
    analytical procedures employed.

o   Decontamination of Solid Waste and Destruction Efficiency
    (DE)

    The Shirco unit was operated to produce an ash that
    contained 1 ppm or less of PCB.

    Residual  PCBs in the ash were less than the 1 ppm
    operating standard.  They varied between 7 ppb on  August 1
    and 900 ppb on August 3.  As discussed in Section  6, the
    DE for PCBs based on the PCB content of the furnace ash
    ranged from 83.15% to 99.88%.

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TABLE 2.1   SITE DEMONSTRATION TEST RESULTS SUMMARY

Waste Feed Characteristics
Moisture, wt.%
Ash, wt.%
HHV,Btu/lb
PCB.ppm
Pb.ppm
Chlorine, ppm
Sulfur, ppm
Chlorine (as HCl),kg/hr
Sulfur (as S02),kg/hr
EP Tox(Pb),mg/L.ppm
TCLP(Pb),mg/L,ppm
Stack Gas
HCl.ppmv
S02,ppmv
HCl,g/hr
S02,g/hr
Particulates (S)7%02},mg/dscm
PCB,ug/hr
Ash
PCB.ppm
Pb.,ppm
EP Tox (Pb),mg/l,ppm
TCLP (Pb),mg/l.ppm
Operating Conditions
Waste Feedrate (avg. daily), kg/hr
ORE (PCB),ut.%
DE (PCB),wt.%
Primary Combustion Chamber
Exhaust Temperature (avg.),F
Residence Time.min.
Secondary Combustion Chamber
Chamber Temperature (avg.),F
Residence Time, sec.
Acid Gas Removal Efficiency, wt.%
S02
8/1/87

16.63
69.77
2064
5.850
5900
<1000
25300
<5
200
27.00
8.60

<0.051
0.99
<0.8
27.40
358
57.70

0.01
7100
25.0
0.01

3328
99.99967
99.88

1797
19

1886
>3

>99.9
5=====================:
8/2/87

16.06
69.80
1639
3.850
4900
<1000
17800
<5
132
29.00
2.50

0.60
41.80
8.60
1070.0
211
174.50

0.240
6000
28.0
0.01

3287
99.99880
93.77

1836
19

1887
>3

>99.1
£=============
8/3/87

14.24
72.40
1728
5.340
5000
<1000
18900
<5
138
-
3.00

0.22
0.96
2.90
22.0
173
58.10

0.900
6400
36.0
0.02

3626
99.99972
83.15

1922
18

1889
>3

>99.9
===============
8/4/87

14.37
75.21
2018
3.480
4400
<1000
16700
<5
125
24.00
3.50

0.20
0.91
2.70
20.6
171
126.20

0.540
6200
36.0
0.01

3600
99.99905
84.48

1885
19

1907
>3

>99.9

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Participate Emissions

Over the three test days in which EPA measured stack gas
particulate loadings, the results were 358 mg/dscm
(8/1/87), 211 mg/dscm (8/2/87),  173 mg/dscm (8/4/87), and
171 mg/dscm (8/4/87).  Emissions control system
modifications and maintenance on August 2 appear to have
lowered particulate emissions to less than the RCRA
standard of 180 mg/dscm (@ 7 vol.% 02).

The data to date, however, indicate the extreme difficulty
in meeting particulate emissions requirements and in most
instances the inability of the unit's emissions control
system to meet particulate emissions requirements of less
than 180 mg/dscm, probably due to the excessive fines
loading at the emissions control equipment.  Section 6.4
and Section 8.2.4 contain detailed discussions of this
problem.

Acid Gas Emissions

During the demonstration tests,  HC1 and S02 emissions
rates were minimal.  Since the chlorine concentration in
the waste feed was below the 0.1 wt.% detection limit, an
actual HC1 removal efficiency could not be determined.
The more difficult to remove SO? constituent, however,
was reduced by more than 99.9 wt.%, which indicates
satisfactory acid gas removal efficiencies.  Section 6.3
contains a detailed discussion on the acid gas emissions
and removal criteria.

Metals Fixation and Ash Leaching

One of the objectives of this test program was to
determine whether heavy metal contaminants in the waste
feed will fixate in the ash residue, rendering the ash
nonleachable.  The solid waste feed, furnace ash, and
scrubber solids were subjected to both the proposed
Toxicity Characteristic Leaching Procedure (TCLP) and the
EP Toxicity Test Procedure (EP Toxicity) leaching tests.
Whereas the TCLP tests produced  leachates that did not
exceed any of the proposed toxicity characteristic levels
(except for one waste feed sample), the EP Toxicity tests
produced leachates that exceeded regulatory levels for
lead and in some cases for cadmium.  It appears that the
differences in the test procedures provide a sufficient
difference in the pH environment that metals, particularly
lead, are rendered soluble and prone to leaching.
Sections 6.4 and 6.5 contain additional discussions on
metals disposition and leaching  characteristics.

Products of Incomplete Combustion

Small quantities of tetrachlorodibenzofuran (2.1 ng) were

                           6

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detected In stack gas sampled on August 2.  Low levels of
some semivolatile organic compounds were identified in all
streams and appeared to be related more to external
contamination than process contamination and PIC
formation.   A wide variety of volatile species at low
concentrations were present in the stack gas.   Their
concentrations increased from August 1 to August 4 as the
unit operation DE of PCBs and overall combustion
efficiency decreased under a lower oxygen availability
(reducing conditions) in the primary combustion chamber
(PCC), producing higher levels of PICs.

Ambient Air Sampling and Mutagenic Testing

Ambient air stations placed upwind and downwind of the
Shirco unit detected quantities of airborne PCB
contaminants.  Based on the downwind sampler data it
appears the the Peak Oil site boundaries limited the
location of the downwind sampler to an area that was
significantly exposed to fugitive emissions during the
transport-of ash from the asJr pad to the ash storage area.

Waste feed and ash samples that were collected on August 2
were not mutagenic based on the standard Ames  Salmonella
mutagenicity assay.

Material Balances

Based on the operating log data presented in Volume II,
Appendix A, and the analytical results presented in Volume
II, Appendix B, a series of material balances  were
developed for each of the test runs conducted  on August
1-4, 1987.   The balances provide material flows and
component breakdowns for the major process streams
consistent with a series of defined bases and  assumptions,
as presented in Section 6.8.

Cost/Economic Analysis

Several cost scenarios are presented based on  a model for
a Shirco unit operation equivalent in processing capacity
to the unit that operated at Peak Oil, and based on cost
data available from Shirco and other sources.   The
economic analysis presented in Section 7 concludes that in
using currently available Shirco transportable infrared
incineration systems, commercial incineration  costs will
range from an estimated $196 per ton for a Shirco unit
operation at an 80% on-stream capacity factor  to an
estimated $795 per ton for the operation at the Peak Oil
site at a 19% on-stream capacity factor.  A normalized
total cost per ton of $416 represents a more realistic
interpretation of the costs accrued to the Peak Oil
cleanup action based on a 37% on-stream capacity factor.

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Unit Problems

A review of the Haztech, EPA Technical Assistance Team
(TAT), and EPA logbooks and progress reports, plus
discussions with unit and project personnel, provided a
summary of mechanical and operating problems encountered
in this first application of a full-scale commercial
Shirco incineration system at a Superfund site.  These
problems were categorized by unit operating sections, and
a profile of the major problem areas within the unit were
defined and analyzed to ascertain the reasons for and
possible solutions to these specific operational
difficulties.  The waste feed and materials preparation
and feed handling, and emissions control systems were the
two main problem areas that limited the operation of the
unit.  The solidified sludge waste feed continually
agglomerated, clogged, bridged, and jammed feed
preparation and handling equipment.  High levels of lead
salts contamination and calcium and magnesium salts
carryover appeared to have been a continuous source of
problems for the emissions control system, which had
difficulty in meeting stack emissions criteria.  Pretest
analysis of the waste feed matrix for its handling and
preparation characteristics and effect on incineration
system chemistry and processing must be conducted so that
the unit is equipped with the proper feed preparation
system, materials handling capabilities, and emissions
control equipment.

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                           SECTION 3

                      PROCESS DESCRIPTION
3.1  GENERAL PROCESS DESCRIPTION

Solid waste processed at the Peak Oil site was incinerated in
a transportable infrared incinerator, designed and
manufactured by Shirco Infrared Systems, Inc. of Dallas, Texas
and operated by Haztech, Inc. of Decatur, Georgia.  The
overall incineration unit consists of a waste preparation
system and weigh hopper, infrared primary combustion chamber,
supplemental propane fired secondary combustion chamber,
emergency bypass stack, venturi/scrubber, exhaust system, and
data collection and control systems all mounted on
transportable trailers.  The system process flow and the
overall test site layout are presented schematically in Figure
3.1.

Solid waste feed material is processed by waste preparation
equipment designed to reduce the waste to the consistency and
particle sizes that can be processed by the incinerator.
After transfer from the waste preparation equipment, the solid
waste feed is weighed and conveyed to a hopper mounted over
the furnace conveyor belt.  A feed chute on the hopper
distributes the material across the width of the conveyor
belt.  The feed hopper screw rate and the conveyor belt speed
rate are used to control the feedrate and bed depth.

The incinerator conveyor, a tightly woven wire belt, moves the
solid waste feed material through the primary combustion
chamber where it is brought to combustion temperatures by
infrared heating elements.  Rotary rakes or cakebreakers
gently stir the material to ensure adequate mixing,  exposure
to the chamber environment, and complete combustion.  When the
combusted feed or ash reaches the discharge end of the
incinerator, it is cooled with a water spray and then is
discharged by a screw auger/conveyor to an ash hopper.

The combustion air to the incinerator is supplied through a
series of overfire air ports located at various locations
along the incinerator chamber and flows countercurrent to the
conveyed waste feed material.

Exhaust gas exits the primary combustion chamber into the
secondary combustion chamber where propane-fired burners
combust any residual organics present in the exhaust gas.  The
secondary combustion chamber burners are set to burn at a
predetermined temperature.  Secondary air is supplied to
ensure adequate excess oxygen levels for complete combustion.
Exhaust gas from the secondary combustion chamber then is

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                                             CONTROL
                                              VAN
                       FEED HOPPER
                       & FEED MODULE

                                                              ASH
                                                              DISCHARGE
                    CONVEYOR
                Propane Fuel

              FORCED AIR |—T	H
              BLOWER   I_J  P
               COMBUSTION AIR
               BLOWER
•fi
                         ID FAN
                       EXHAUST
                       STACK
                                   n a p
              f  t   t   t   t  ±
                                       PRIMARY
                                       COMBUSTION
                  STION CHAMBER      I i
                  mo  LJ  cns-p

                                          BELT
                                          CONVEYOR
                                                                              ASH
                                                                              BIN
                                          COMBUSTION
                                          AIR BLOWER
               SECONDARY
               COMBUSTION CHAMBER
CRUBBER
II!
i|
X
i

1
4
VENT
                  m-
                  CHEMICAL CHEVRON
                  RECYCLE RECYCLE!
                  PUMPS   PUMPS
                      o
                                        WATER
                                        CONDITIONER!
                                                                       EMERGENCY
                                                                       BYPASS
                                                                       STACK
                                                                                    Fresh
                                                                                    Water

                                                                         CLARIFIER     unit
                                                                               Sludge
                                                                        ACTIVATED
                                                                        CARBON
                                                                        FILTER
                                                                         Slowdown Water to POTW
                                                                          City Water
Figure  3.1.    Peak  Oil  incinerator unit.
                                            10

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quenched by a water-fed venturi/scrubber to remove particulate
matter and acid gases and then transferred to the exhaust
stack by an induced draft fan where the gas is discharged to
the atmosphere.

The main unit controls and data collection indicators
comprising the data collection and control system are housed
in a specially designed van.

An emergency bypass stack is mounted in the system directly
upstream of the venturi/scrubber for the diversion of hot
process gases under emergency shutdown conditions.

3.2  DETAILED PROCESS DESCRIPTION

The transportable incineration unit consists of the following
major mechanical subunits and components:

o   Haztech-Supplied Systems

              Waste Preparation Unit/Weigh Hopper

              Water Systems

o   Shirco-Supplied Systems

              Primary Combustion Chamber (PCC)

              Secondary Combustion Chamber (SCC)

              Emergency Bypass Stack

              Venturi/Scrubber

              Exhaust System

              Systems Control Van

The Haztech-supplied waste preparation unit and weigh hopper
and Shirco-supplied waste feed hopper are site- and waste-
specific:  they may vary according to the specific matrix
being processed.

3.2.1  Waste Preparation Unit/Weigh Hopper

As part of the overall site remediation the sludge lagoon was
drained of water and mixed with sand, soil, and lime to form a
conditioned waste soil matrix.  The lime, in addition to
providing a binding medium for the wet matrix, neutralized the
highly acidic wastes in the lagoon, the original site
contaminant produced as a by-product of the acid-based oil
rerefining operation.


                               11

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The conditioned soil is transferred from the lagoon to the
material stockpile area by front-end loaders; a loader then is
used to transfer the waste feed to the power screen.  The
gross waste feed is loaded onto a tipping reject grid where
large rocks and debris are rejected.  The bulk of the feed
falls through the grid to a belt feed hopper.  The waste feed
then passes through a shredding system and is conveyed to the
vibrating power screen assembly.  The shredding system and the
vibrating screens provide an aerated and conditioned waste
feed sized to less than 1 inch while rejecting larger pieces
of rocks, roots, and other materials that were not removed at
the tipping reject grid.

The prepared waste feed is then loaded into the weigh hopper
utilizing a track loader until a predetermined weight is
attained.  At that time waste feed to the weigh hopper is
stopped and waste is conveyed from the weigh hopper to the
primary combustion chamber feed hopper by an inclined conveyor
belt.

The subsystems described below were transported individually
to the Peak Oil  hazardous waste site, assembled into one unit,
and used to thermally remediate the site.  Upon completion of
site cleanup the unit was disassembled into its component
subsystems and moved to the next scheduled site.   This cycle
can continue as  long as periodic inspections and maintenance
of all mechanical  systems are accomplished on site and during
installation and disassembly.

3.2.2  Primary Combustion Chamber

The primary combustion chamber consists of six electrically
powered combustion modules, one feed module, and one discharge
module constructed of mild carbon steel.   These modules are
bolted together  and mounted on a skid that has a removable
"goose neck" and transportation dolly attached for towing to
each designated  site.

Each module is insulated with a 1-in layer of ceramic fiber
blanket and a 3-mil stainless steel  vapor barrier next to the
steel shell with additional "Z Block" fiber insulation added
as the interior  temperature barrier.  The interior steel
surface of each  module is sprayed with stilastic before the
insulation is installed to further protect the shell from
corrosive volatiles, which might penetrate the insulation at
process temperatures.  The exterior shell is primed and
painted with high-temperature-resistant paint to provide a
durable protective surface.

The six electrically powered combustion modules are fired by
transversely mounted silicon carbide resistance heating
elements, which  are insulated from the steel shell  with

                               12

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ceramic sleeves.  Electrical connections to the heating
elements are made by attaching braided steel straps to their
aluminized ends with spring tensioned C-clamps.   These
electrical connections are protected by ventilated wireways.

The feed material enters the primary combustion chamber
through the feed hopper located above the feed module.  The
feed hopper consists of six 9-in screw augers, which feed the
waste in consistent depth across the width of the primary
combustion chamber.

Chain-driven cakebreakers are mounted in the powered modules
to stir the feed material periodically and increase process
efficiency.  The cakebreakers are rollers with an array of
high-temperature alloy "fingers," which slowly rake through
the material on the belt as it moves through the six fired
zones (Al to A3 and Bl to B3) in the primary combustion
chamber.

The processed feed material drops off the end of the belt in
the discharge module, where it is quenched with water sprays
prior to being discharged by the screw conveyor system to the
ash bin.  The floor of the primary chamber consists of hoppers
and external screw conveyors to collect and remove residual
ash from the system.  Each hopper has a small vibrator
attached to the bottom cleanout tube to assist in the removal
of ash into the center-mounted collector screw.

As the ash inventory increases in the ash bin, a Bobcat
front-end loader transfers the ash to the ash pad where it is
stored pending analysis for PCBs and Pb.  If the ash meets the
required specifications, it is transferred to the ash storage
area; if the ash is still contaminated, it is returned to the
material stockpile for reprocessing.

The combustion air for the primary combustion chamber is
provided by a blower mounted on the skid underneath the last
powered module at the discharge end.  The combustion air is
carried by ducting up both sides of the chamber, along the top
edges of the chamber, and into the chamber at strategically
located ports.  Manually operated gate valves are used to
control the flow of combustion air into the primary chamber.
The combustion airflow within the chamber is countercurrent to
the waste feed flow.

The exhaust gases from the primary chamber exit through the
top of the chamber just prior to reaching the feed material
inlet chute.  They are directed to the adjacent secondary
combustion chamber by insulated crossover ducting.

3.2.3  Secondary Combustion Chamber

The secondary combustion chamber shell is constructed and
insulated in a manner very similar to the primary combustion

                               13

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chamber.  Its purpose Is to thermally destroy the combustible
offgas compounds carried in the exhaust gases from the primary
chamber.  The secondary combustion chamber is fired by four
propane or natural gas burners mounted on the inlet end of the
chamber.

Combustion air is provided by a blower, duct work, and plenum
chamber mounted on the inlet end of the chamber.  The four
burner blocks also have an independently mounted combustion
air blower and duct work for controlling burner flame
patterns.

The primary combustion chamber exhaust gases enter the
secondary combustion chamber from the top just above the
burner flames.  The resultant flow turns 90° and passes
through a series of unpowered silicon carbide rods.  This
increases combustion efficiency by creating turbulence.  The
waste gases then continue to the downstream end of the chamber
where they exit through the top of the chamber into a
crossover duct leading to the base of the emergency bypass
stack.

3.2.4  Emergency Bypass Stack

An emergency bypass stack is mounted between the secondary
combustion chamber and the venturi/scrubber.  It is designed
to divert the high temperature gases more than fifty feet
above ground level during an emergency shutdown.

The emergency bypass stack is a vertically mounted rectangular
carbon steel shell, insulated in the same manner as the
primary and secondary combustion chambers.  It is sealed at
the top with counterweighted doors, which are opened by a
compressed air cylinder during an emergency.

3.2.5  Venturi/Scrubber

The normal flow of exhaust gases from the secondary combustion
chamber is through the base of the emergency bypass stack
where the waste gases are split into two separate streams
prior to entering the venturi/scrubber section.   Both streams
exit the emergency bypass stack into stainless steel quench
tubes where the hot waste gases are cooled with quench water
sprays prior to entering the dual fiberglass-reinforced
plastic (FRP) Venturis.

There are several sources of liquid to effect the gas quench.
During normal operation the first liquid to contact the hot
gas is fresh water sprayed into the gas stream.   The next
liquid to contact the gas is recycle from the scrubber's
chevron recycle pump.  By utilizing several independent quench
liquids, the downstream scrubber equipment, fabricated in
corrosion-resistant resins, is effectively protected from
thermal damage.


                               14

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Water injected into the venturi throats atomizes and increases
particulate precipitation as the gases enter the front section
of the crossflow-packed scrubber.  The particulate entrapped
in water droplets drains into an open blowdown holding area in
the bottom of this section of the unit.  The particulate-free
waste gases continue into the downstream section of the
scrubber where a caustic wash liquid is injected to neutralize
acid vapor in the stream.  The neutralized and cleaned gas
stream exits the scrubber in a single duct leading to the
induced draft blower.

The scrubber consists of four major sections:   the quench
section where the gases are cooled or quenched by direct
evaporation of water, the venturi section where particulate is
processed by wetting and agglomeration, the chevron section
where the processed particulate is scrubbed out by recycled
liquor, and the packed section where the gas is scrubbed of
acid gases by recycled chemical liquor.

A chemical mix tank and associated pumps supply an alkali and
water solution to the crossflow packing.  The  chemical
solution is added to control system pH.  The solution is
injected into the recycle stream going to the  top of the
packing.

The recycle liquors emerge from two banks of pumps.  Each bank
of pumps consists of two pumps mounted on a skid.  Each pump
acts as a spare for the other.  The first bank takes suction
from the chevron recycle sump.  This chevron recycle is pumped
to the quench section, the venturi section, the chevron
section, and the blowdown drain valve.  The next bank of pumps
takes suction from the crossflow scrubber sump.  This scrubber
recycle is directed back to the top of the crossflow packing.
In addition, as level is built up in the chemical sump due to
addition of chemicals and makeup water, it internally
overflows into the chevron sump.  The blowdown drain valve is
activated by a level controller in the chevron recycle sump.

3.2.6  Exhaust System

The induced draft fan draws the scrubbed gases from the
scrubber and propels them up the FRP exhaust stack.  The
exhaust stack is mounted on a pad as a freestanding unit with
sampling ladder, platform, and EPA sampling ports attached.

In addition to providing the draft for the transport of the
combustion gases from the primary and secondary combustion
chambers through the venturi/scrubber system to the exhaust
stack, the induced draft fan imparts a slight  negative
pressure to the entire system.  This negative  pressure ensures
that any system leakage will result in an inflow of ambient
air to the unit instead of a leakage of hazardous vapors into
the atmosphere.
                               15

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3.2.7  Systems Control Van

The systems control van is a specially designed unit built to
house the primary controls required to start, run, and shut
down all subsystems. The control cabinet is located in the
rear of the unit and contains all system alarms, annunciators,
recorders, manual/off/auto switches, process controllers, and
process indicators.  The stack gas analyzer and solid state
belt drive controller are located in the middle section, and
the motor control center is mounted in the front.  All
electrical power leads and control wiring exit the van through
a conduit mounted in the flooring.

Additional facilities that have been constructed at the site
include an overall  water makeup and scrubber effluent blowdown
system.

3.2.8  Water Systems

Makeup city water is first treated in a water conditioner to
remove calcium and magnesium salts.  As the overall solids
content of the recycled water streams increases, scrubber
liquid effluent must be removed from the system and replaced
with fresh water to prevent excessive solids buildup, which
will plug spray nozzles and packing in the venturi/scrubber.
The scrubber liquid effluent contains a high solids content
due primarily to lead salts carry-over from the lead contained
in the waste feed.   The effluent first is sent to a clarifier
for gross solids removal.   The clarified effluent then is
pumped to the effluent holding tank; it is further treated in
an activated carbon filter and sent to a holding tank where it
is pH-adjusted with muriatic acid.  It is tested for
compliance with standards for local publicly owned treatment
works (POTW), and if acceptable is sent to the POTW.
                               16

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                           SECTION 4

                 FIELD  OPERATIONS  DOCUMENTATION
4.1  OPERATIONAL HISTORY

The overall SITE test program at Peak Oil was initiated on
July 31, 1987 at 1316 hours and concluded on August 5, 1987 at
0020 hours.  Table 4.1 provides a chronological  operational
history of the overall program.  The table indicates the time
frame for each of the stack sampling procedures  as described
in Section 5, and the several incidents or interventions in
unit operations that occurred during the sampling, as
discussed below.  Additional information that chronicles the
SITE demonstration program, particularly as it impacted on the
sampling activities, is provided in the trip log section of
the Sampling and Analytical Report in Appendix B (Volume II).

o   On July 31, 1987, at 1626 hours, the feedrate to the unit
    decreased, and the unit stopped for 30 seconds.  Although
    this interrupted the initial stack sampling  activities,
    stack sampling resumed with no apparent problems.  At 1702
    hours severe weather conditions caused a power outage and
    a general unit power failure, which adversely affected the
    stack sampling activities and caused a cessation of the
    day's overall sampling program; all data and samples taken
    were judged invalid.

o   On August 1, 1987, at 1500 hours, a severe thunderstorm
    with accompanying lightning arrived at the site.  The unit
    feed and SASS (PCBs) sampling operations were shut down
    from 1503 to 1543 hours to protect personnel  from the
    severe electrical nature of the storm.  The  SASS stack
    sampling activities for PCBs (1420 to 1920 hours) were not
    adversely affected by the minimal feed interruption.
    Sampling resumed after operating personnel stated that the
    unit was running at normal steady-state conditions.
    Sufficient sample volume was obtained to ensure a
    successful PCB analysis within the QAPP guidelines.

    During this initial SASS sampling collection  volume was
    reduced due to an inability of the SASS cooling system to
    maintain the sorbent module below 20°C.  This reduced
    volume may have affected the detection of low
    concentration organics.  A more detailed discussion of
    this problem is provided in Section 5.

o   The initial particulate emissions data from  the August 1
    EPA Method 5 stack sampling (0830 to 1030 hours) indicated
    a particulate emissions rate of 0.1590 grains/dscf.  From
    0135 to 0625 hours on August 2, the unit was  shut down in
    order to flush the entire scrubber, ID fan,  and exhaust

                               17

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         TABLE  4.1
           CHRONOLOGICAL OPERATIONAL  HISTORY
    Hours

July 31, 1987

    1316 - 1626
    1626 - 1700

    1700 - 1702

    1702 - 1800



    1800 - 2400


August 1, 1987

    0830 - 1030
    1420
    1503
    1650
    1710
    2121
1920
1543
1925
2010
0130
August 2, 1987

    0135-0625

    0625
    1100-1615
    1202-1442
    1410-1755
    1800-2211

    2000-2211
August 3, 1987

    0352-0530
    1015-1550
    1713-1945
          Activity
          Initiated stack sampling
          Feed rate decreased - Reason unknown -
          Stopped stack sampling
          Unit operation stable - Resumed stack
          sampling
          Power  outage - Severe weather conditions
          - Power failure - Sampling equipment
          failure - Declared data and sampling
          collection for 8/31 invalid
          Unit operation resumed with no data or
          sampling collection
EPA Method 5 sampling = Particulates,
HC1,  volumetric flowrate,  moisture,
metals on particulate
SASS  sampling - PCBs
Feed  interruption due to severe weather
EPA MM5 sampling - Soluble chromium
VOST  sampling - Volatile PP + 10
SASS  sampling - PCDD/PCDF, semivolatile
PP +  10.
          Stopped feed unit to flush scrubber
          system and add chevron demisters
          Unit start-up
          SASS sampling - PCBs
          EPA MM5 sampling - Soluble chromium
          VOST sampling - Volatile PP + 10
          SASS sampling - PCDD/PCDF, semivolatile
          PP + 10
          EPA Method 5 sampling - Particulates,
          HC1, volumetric flowrate,  moisture,
          metals on particulate
          ID fan and stack wash
          SASS sampling - PCBs and duplicate
          EPA MM5 sampling - Soluble chromium
          duplicate
                                    and
                               18

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                     TABLE  4.1   (continued)
August 4, 1987

    0410 - 0600      ID fan and stack wash
    0930 - 1445      SASS sampling - PCDD/PCDF, semivolatile
                     PP + 10, and duplicates
    1550 - 1746      EPA Method 5 sampling - Participates,
                     HC1, volumetric flowrate, moisture,
                     metals on particulate, and duplicates
    2007 - 0020      VOST sampling - Volatile PP + 10 and
                     duplicate
Abbreviations

HC1     Hydrochloric Acid
SASS    Source Assessment Sampling System
PCB(s)  Polychlorinated biphenyl(s)
MM5     Modified Method 5 sampling train
VOST    Volatile Organic sampling train
PP+10   Priority Pollutants Plus 10 highest peaks
PCDD    Polychlorinated Dibenzodioxin
PCDF    Polychlorinated Dibenzofuran
ID      Induced Draft
                               19

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    stack system and install additional chevron demisters at
    the scrubber outlet.  The unit was restarted at 0625 hours
    with SASS stack sampling for PCBs beginning at 1100
    hours.  EPA Method 5 stack sampling activities that were
    initiated at 2000 hours indicated a distinct improvement
    in particulate emissions rate at 0.0939 grains/dscf.  On
    August 3 and 4, at 0352 to 0530 tours and 0410 to 0600
    hours, respectively, on-stream ID fan and stack wash
    procedures were employed.  The August 3 particulate
    emission* rate was 0.0768 grains/dscf, and the August 4
    duplicate sample particulate emissions rate, 0.0761
    grains/dscf.

4.2  OPERATING CONDITIONS SUMMARY

Since the SITE demonstration test program was conducted during
the actual removal action, the operating conditions that were
recorded during the SITE program and the normal process
conditions employed by Haztech during the site cleanup are
identical.  The actual  unit log data, as compiled by Haztech,
is presented in Appendix A (Volume II).  Tables 4.2 to 4.9
present spreadsheet summaries of the Haztech operating log
data,  discussed below,  taken during the validated SITE test
program period from August 1 to August 4, 1987.

4.2.1   Waste Feed Rate

Although waste feedrates varied at times because of short-term
power outages and equipment problems, as chronicled in Section
4.1, the average waste feedrate to the primary combustion
chamber (PCC) remained fairly constant at 3.6 to 4.0 tons/hr.

4.2.2     PCC Residence Time

With the waste feedrate remaining fairly constant,  the solids
were retained on the movable woven wire belt in the PCC for
approximately 18 to 19 minutes as they were thermally
decontaminated.

4.2.3     PCC Temperature

The PCC temperatures were controlled, through addition of
combustion air and use of auxiliary electric power to the
infrared heating rods,  at between 1470°F and 1790°F in
Zone A and 1740°F and 1340°F in Zone B.  The temperature
of the PCC exhaust vapors to the secondary combustion chamber
(SCC)  was maintained between 1830°F and 1920°F.

For the August 1 operation, where the waste feed heating value
was 20-25% greater than the heating value of the waste feed to
the unit during  the August 2-4 operations, the PCC infrared
rods were not in use;  the PCC was operating in an autogenous

                               20

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mode with higher combustion air flows.  With the reduction in
waste feed heating value during the August 2-4 operations,
supplemental electrical energy input to the infrared rods
through the heating element power centers (HEPC) was employed
to maintain PCC temperatures.

4.2.4  SCC Temperature and Residence Time

The SCC employed on the Shirco unit, which is heated by
propane burners under SCC temperature control, was maintained
between 1840°F and 1910°F.  SCC residence times, based on
estimated SCC gas flows and an effective SCC gas residence
volume, were consistently above 3 seconds.

4.2.5  SCC Propane Fuel Usage

With the SCC operating temperatures remaining fairly constant
during the test period and the fuel flow to the SCC under
temperature control, changes in fuel usage should only occur
because of changes in the overall heating requirements of the
SCC based on variations in flow or heating value.  For the
August 2 operation, the waste feed heating value, on average,
was approximately 15% lower than the heating value of the
waste feed to the unit on August 1, 3, and 4.  Consistent with
this lower heating value, the propane fuel usage to the SCC on
August 2 was higher.

4.3  OPERATING LOG DATA

In addition to the selected operating conditions and data that
are presented in Tables 4.2 to 4.9, the following operating
log data and supporting information is included in this report
as Appendix A (Volume II).

o   Operating log data including board-mounted and local
    instrument readings.  Data is presented on actual  operator
    and computer input sheets.

o   A summary of the operator feed tabulation forms presenting
    waste feedrates.

o   Graphical presentation of total daily waste feedrates for
    each month of unit operation.
                               21

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                                             TABLE 4.2
                                  SITE DEMONSTRATION TEST PROGRAM
                                     UNIT  OPERATING CONDITIONS
                                CONTROL ROOM MOUNTED INSTRUMENT DATA
AUGUST 1, 1987
Feedrate,Ib/hr
                                                                                Standard  Coefficient
                                                      Average  Maximum  Minimum Deviation of Variance
7335.83 10496.00
0.00  2791.38    38.05
Primary
Chamber
Secondary
Chamber

Scrubber
Stack
Exhaust
Temp. , F Zones






A1
A2
A3
B1
B2
B3
Exhaust
Residence Time, rain.
Temp.,F

Delta P.in. H20

Temp.,F

Flow.GPM





PH
Level



Temp.,F
Velocity.ft/min
Chamber
Exhaust
Venturi 1
Venturi 2
Quench 1
Quench 2
Quench H20 1
Quench H20 2
Quench Recycle
Venturi Recycle
Chevron Recycle
Chemical Recycle


02, X
C02.X
CO.ppmv


1623.42
1747.79
1787.38
1741.75
1725.38
1341.38
1797.33
18.77
1885.79
1846.46

19.31

182.38

17.92
33.04
138.02
16.72
418.00
8.04
11.55
5.83
9.31
5.92
179.75
2158.33
1800.00
1841.00
1858.00
1793.00
1813.00
1626.00
1936.00
20.00
1940.00
1901.00

21.60

185.00

19.32
33.04
140.00
17.92
420.00
8.30
12.50
13.50
10.00
8.00
188.00
2900.00
1330.00
1507.00
1574.00
1601.00
1590.00
1202.00
1323.00
13.90
1780.00
1757.00

14.40

168.00

17.36
33.04
135.80
15.68
416.00
7.00
11.20
4.50
7.00
4.00
165.00
700.00
111.83
82.44
64.56
47.20
40.71
87.14
121.83
1.15
35.45
31.28

1.78

3.97

0.40

1.56
0.85
2.00
0.24
0.23
1.81
0.92
1.08
4.59
432.21
6.89
4.72
3.61
2.71
2.36
6.50
6.78
6.15
1.88
1.69

9.24

2.18

2.26

1.13
5.10
0.48
3.04
2.00
31.04
9.90
18.20
2.56
20.03
                                                22

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AUGUST 1, 1987
                                             TABLE  4.3
                                  SITE DEMONSTRATION  TEST  PROGRAM
                                     UNIT OPERATING CONDITIONS
                                   FIELD MOUNTED INSTRUMENT DATA
                                                                                Standard  Coefficient
                                                      Average  Maximum  Minimum  Deviation of Variance
Primary
Chamber
Secondary
Chamber
Quench
Tubes
Scrubber
HEPC


























Chevron

Chemical
Demister
Total
Zone A Volts A
B
C
Amps A
B
C
Zone B Volts A
B
C
Amps A
B
C
Draft, in. H20
Combustion Air, PS!
Combustion Air.SCFM
Quench Air.SCFM
Quench Water, GPM
Combustion Air.PSI
Combustion Air.SCFM
Forced Draft Air.PSI
Forced Draft Air.SCFM
Propane, PS I
Propane, SCFH
Chamber Draft, in. H20
Emergency Quench Water, PSI
Venturi 1, Delta P in. H20
Venturi 2, Delta P in. H20
Delta P.in. H20
Bloudown.GPM
Delta P.in. H20
Delta P.in. H20
Delta P.in. H20
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.06
3.20
1657.38
0.00
0.00
3.88
3639.42
>20.00
1536.82
9.54
1220.83
<0.25
76.33

20.71
0.19

1.20
0.16
1.55
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.10
4.00
1743.39
0.00
0.00
5.00
3940.09
>20.00
2264.72
11.00
1900.00
<0.25
79.00

23.50
0.65

1.50
0.23
1.96
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.06
2.40
1441.19
0.00
0.00
3.00
3341.10
19.50
835.58
8.00
550.00
<0.25
72.00

10.00
0.00

0.50
0.10
1.15












0.01
0.39
83.59


0.57
176.35

600.93
1.28
542.55

1.65

3.62
0.17

0.26
0.06
0.25












17.38
12.24
5.04


14.64
4.85

39.10
13.44
44.44

2.16

17.48
89.04

21.78
39.17
15.97
                                                23

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                                             TABLE  4.4
                                  SITE DEMONSTRATION  TEST  PROGRAM
                                     UNIT OPERATING CONDITIONS
                                CONTROL ROOM MOUNTED  INSTRUMENT DATA
AUGUST 2, 1987
Feedrate,Ib/hr
                          Standard  Coefficient
Average  Maximum  Minimum Deviation of Variance

7245.79 10702.00   862.00  2185.83    30.17
Primary
Chamber
Secondary
Chamber

Scrubber
Stack
Exhaust
Temp. , F Zones






A1
A2
A3
B1
B2
B3
Exhaust
Residence Time.min.
Temp.,F

Delta P.in. H20

Temp..F

Flow.GPM





pH
Level



Temp.,F
Velocity,ft/min
Chamber
Exhaust
Venturi 1
Venturi 2
Quench 1
Quench 2
Quench H20 1
Quench H20 2
Quench Recycle
Venturi Recycle
Chevron Recycle
Chemical Recycle


02, X
C02,%
CO.ppmv


1516.21
1638.26
1772.74
1681.95
1696.32
1443.00
1836.32
18.87
1886.53
1837.21

19.56

193.58

18.21
33.04
128.80
16.21
360.63
8.44
11.57
5.14
8.46
6.16
184.79
1924.21
1660.00
1897.00
1838.00
1864.00
1747.00
1603.00
1940.00
20.30
1938.00
1883.00

23.40

207.00

18.48
33.04
140.00
17.08
416.00
9.80
12.00
6.00
10.00
7.00
190.00
2500.00
1261.00
1544.00
1696.00
1591.00
1663.00
1335.00
1651.00
17.90
1845.00
1799.00

9.60

184.00

17.92
33.04
119.00
15.12
344.00
5.00
11.50
4.50
4.00
3.00
179.00
1200.00
122.48
73.41
39.87
59.01
25.94
73.05
89.95
0.46
25.10
23.75

2.81

7.01

0.21
0.00
7.74
0.67
19.69
1.06
0.11
0.36
1.50
0.87
4.03
327.39
8.08
4.48
2.25
3.51
1.53
5.06
4.90
2.44
1.33
1.29

14.37

3.62

1.17
0.00
6.01
4.11
5.46
12.55
0.97
7.07
17.79
14.20
2.18
17.01
                                                24

-------
AUGUST 2, 1987
                                             TABLE 4.5
                                  SITE DEMONSTRATION  TEST PROGRAM
                                     UNIT OPERATING CONDITIONS
                                   FIELD MOUNTED  INSTRUMENT DATA
                                                                                Standard  Coefficient
                                                     Average  Maximum  Minimum  Deviation of Variance
Primary
Chamber
Secondary
Chamber
Quench
Tubes
Scrubber
HEPC












Zone A Volts


Amps


Zone B Volts


Amps


Draft, in. H20
A
B
C
A
B
C
A
B
C
A
B
C

Combustion Air.PSI
Combustion Air.SCFM


Quench Air.SCFM
Quench Water ,GPM


79
74
86
283
277
383
0
0
0
0
0
0
0
1
1166
0
0
.17
.17
.67
.33
.50
.33
.00
.00
.00
.00
.00
.00
.06
.62
.98
.00
.00
Combustion Air.PSI
Combustion Air.SCFM








Chevron

Chemical
Demister
Total
Forced Draft Air
Forced Draft Air
Propane, PSI
Propane, SCFH
Chamber Draft, in
Emergency Quench
Venturi 1, Delta
Venturi 2, Delta
Delta P,in. H20
Slowdown, GPM
Delta P,in. H20
Delta P,in. H20
Delta P,in. H20
,PSI
,SCFM


. H20
Water, PSI
P in. H20
P in. H20





4489
>20
1777
8
1383
<0
76

22
0

0
0
1
.42
.00
.74
.92
.33
.25
.33

.50
.24

.73
.24
.21
160.
150.
175.
600.
595.
780.
0.
0.
0.
0.
0.
0.
0.
2.
1562.
0.
0.
00
00
00
00
00
00
00
00
00
00
00
00
07
60
19
00
00
>10.00
5204.
>20.
2573.
11.
1850.
0.
80.

29
00
55
00
00
20
00

24.00
0.

1.
0.
1.
25

20
26
70
0
0
0
0
0
0
0
0
0
0
0
0
0
1
951
0
0
5
3702
19
835
8
650
0
69

20
0

0
0
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.05
.10
.16
.00
.00
.80
.30
.50
.58
.00
.00
.15
.00

.00
.22

.50
.22
0.95
79.
74.
86.
285.
279.
383.






0.
0.
195.



576.

589.
1.
459.

3.

1.
0.

0.
0.
0.
18
19
68
29
43
57






01
57
44



86

51
17
77

54

26
01

33
01
35
100.02
100.03
100.02
100.69
100.70
100.06






9.62
35.43
16.75



12.85

33.16
13.12
33.24

4.64

5.59
4.48

45.00
6.38
28.91
                                                25

-------
                                             TABLE 4.6
                                  SITE DEMONSTRATION TEST PROGRAM
                                     UNIT OPERATING CONDITIONS
                                CONTROL ROOM MOUNTED INSTRUMENT  DATA
AUGUST 3, 1987
                                                                                 Standard  Coefficient
                                                       Average  Maximum Minimum Deviation of Variance
Feedrate,Ib/hr
                                     7992.75 10104.00   1018.00  1903.83    23.82
Primary
Chamber
Temp.,F  Zones    A1
                  A2
                  A3
                  B1
                  B2
                  B3
                  Exhaust
Residence Time.min.
Secondary
Chamber

Scrubber
Te«p..F
Chamber
Exhaust
Delta P.in. H20   Venturi 1
                  Temp.,F

                  FlOM.GPM
                  pH
                  Level
Stack
Exhaust
                  Temp.,F
                  Velocity.ft/min
                  Venturi 2
                  Quench 1
                  Quench 2
                  Quench H20 1
                  Quench H20 2
                  Quench Recycle
                  Venturi Recycle
                  Chevron Recycle
                  Chemical Recycle
                  02.X
                  C02.X
                  CO.ppmv
1559.33
1687.21
1755.67
1708.75
1656.67
1349.63
1922.21
17.90
1888.63
1847.79
19.21
200.54
18.14
31.13
120.23
16.08
363.33
8.04
11.61
5.20
9.40
6.96
183.25
1812.08
1710.00
1749.00
1857.00
1831.00
1744.00
1533.00
2034.00
19.00
1943.00
1886.00
22.20
212.00
18.48
33.04
140.00
18.20
412.00
8.50
13.60
6.00
10.00
8.00
188.00
2300.00
1364.00
1606.00
1666.00
1615.00
1540.00
1208.00
1727.00
15.60
1799.00
1800.00
13.20
186.00
17.92
27.44
102.20
13.72
340.00
7.00
11.05
4.50
8.50
6.00
179.00
1400.00
110.64
36.94
46.46
66.01
64.05
80.59
85.11
0.91
29.14
21.41
2.00
8.30
0.14
1.73
12.90
1.28
30.89
0.36
0.48
0.36
0.41
0.35
2.89
311.02
7.10
2.19
2.65
3.86
3.87
5.97
4.43
5.07
1.54
1.16
10.39
4.14
0.77
5.57
10.73
7.98
8.50
4.43
4.16
6.92
4.34
5.05
1.58
17.16
                                                 26

-------
AUGUST 3, 1987
                                             TABLE 4.7
                                  SITE DEMONSTRATION TEST PROGRAM
                                     UNIT OPERATING CONDITIONS
                                   FIELD MOUNTED INSTRUMENT DATA
                                                                                 Standard  Coefficient
                                                      Average  Maximum  Minimum  Deviation of  Variance
Primary
Chamber
Secondary
Chamber
HEPC     Zone A   Volts
                                    Amps
                           Zone B   Volts
                                    Amps
         Draft.in. H20
         Combustion Air.PSI
         Combustion Air.SCFM

         Quench Air.SCFM
         Quench Water,GPM
         Combustion Air.PSI
         Combustion Air.SCFM
         Forced Draft Air.PSI
         Forced Draft Air.SCFM
         Propane,PSI
         Propane,SCFH
         Chamber Draft,in.  H20
Quench
Tubes
Scrubber
A
B
C
A
B
C
A
B
C
A
B
C


:M



:M
•SI
iCFM


H20
19.44
21.67
35.00
84.44
88.33
146.11
0.00
0.00
0.00
0.00
0.00
0.00
0.06
2.46
1482.55
0.00
0.00
7.35
5025.50
17.65
2211.12
7.04
1723.00
<0.25
105.00
105.00
165.00
410.00
420.00
700.00
0.00
0.00
0.00
0.00
0.00
0.00
0.06
3.60
1864.70
0.00
0.00
8.80
5650.37
20.00
2882.38
10.50
1900.00
<0.25
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.05
1.00
945.14
0.00
0.00
0.00
3860.02
0.00
1378.70
4.50
1000.00
0.23
37.30
40.69
65.57
158.61
165.60
274.08






0.00
0.97
361.88


2.46
449.54
5.89
408.16
2.02
258.19

191.83
187.79
187.36
187.83
187.47
187.58






8.75
39.46
24.41


33.49
8.95
33.35
18.46
28.76
14.98




Chevron

Chemical
Demister
Total
Emergency Quench Water, PS I
Venturi 1, Delta P in. H20
Venturi 2, Delta P in. H20
Delta P,in. H20
Slowdown, GPM
Delta P,in. H20
Delta P,in. H20
Delta P,in. H20
78.80

20.94
0.09
8.57
0.03
0.25
0.37
98.00

25.00
0.25
10.00
0.30
0.30
0.70
69.00

18.00
0. 00
0.00
0.00
0.20
0.20
6.94

2.34
0.09
3.50
0.09
0.02
0.15
8.81

11.17
108.62
40.82
300.00
9.36
39.79
                                                 27

-------
                                             TABLE 4.8
                                  SITE DEMONSTRATION TEST  PROGRAM
                                     UNIT OPERATING CONDITIONS
                                CONTROL ROOM MOUNTED INSTRUMENT DATA
AUGUST 4, 1987
Feedrate,lb/hr
                                                               Standard  Coefficient
                                     Average  Maximum  Minimum Deviation of  Variance

                                     7936.00 10336.00   784.00  1949.22   24.56
Primary
Chamber
Temp.,F  Zones    A1
                  A2
                  A3
                  B1
                  B2
                  B3
                  Exhaust
Residence Time.min.
Secondary
Chamber

Scrubber
Temp.,F


Delta P,in. H20

Temp.,F

Flow.GPM
                  pH
                  Level
Stack
Exhaust
Chamber
Exhaust

Venturi 1
Venturi 2
Quench 1
Quench 2
Quench H20 1
Quench H20 2
Quench Recycle
Venturi Recycle
Chevron Recycle
Chemical Recycle
                  02,%
                  C02,%
                  CO.ppmv
                  Temp.,F
                  Velocity,ft/min
1469.92
1649.54
1730.33
1624.21
1593.13
1360.21
1884.67
18.88
1906.79
1858.42
19.59
188.54
18.15
33.01
138.31
15.28
396.17
7.94
11.55
5.27
8.80
6.88
184.83
1670.83
1555.00
1711.00
1809.00
1753.00
1653.00
1685.00
2083.00
19.30
1942.00
1898.00
23.40
194.00
18.20
33.04
140.00
16.80
408.00
8.00
15.00
6.50
10.00
7.00
187.00
2000.00
1382.00
1581.00
1647.00
1509.00
1462.00
1078.00
1264.00
17.90
1843.00
1805.00
14.40
184.00
17.64
32.48
134.40
14.56
384.00
7.50
10.00
5.00
5.00
6.00
180.00
1450.00
51.77
38.31
48.48
47.81
37.07
203.85
153.09
0.29
25.27
21.11
2.48
2.78
0.13
0.12
1.62
0.90
10.03
0.14
0.87
0.37
0.98
0.33
1.86
161.32
3.52
2.32
2.80
2.94
2.33
14.99
8.12
1.54
1.33
1.14
12.65
1.48
0.73
0.37
1.17
5.86
2.53
1.70
7.52
6.98
11.16
4.81
1.01
9.66
                                                 28

-------
AUGUST 4, 1987
                                             TABLE  4.9
                                  SITE DEMONSTRATION  TEST  PROGRAM
                                     UNIT OPERATING CONDITIONS
                                   FIELD MOUNTED  INSTRUMENT DATA
                                                                                Standard  Coefficient
                                                     Average  Maximum  Minimum  Deviation of Variance
Primary
Chamber
Secondary
Chamber
Quench
Tubes
Scrubber
HEPC


























Chevron

Chemical
Demister
Total
Zone A Volts A
B
C
Amps A
B
C
Zone B Volts A
B
C
Amps A
B
C
Draft, in. H20
Combustion Air.PSI
Combustion Air,SCFM
Quench Air.SCFM
Quench Water, GPM
Combustion Air.PSI
Combustion Air.SCFM
Forced Draft Air.PSI
Forced Draft Air.SCFM
Propane, PSI
Propane, SCFH
Chamber Draft, in. H20
Emergency Quench Water, PS I
venturi 1, Delta P in. H20
Venturi 2, Delta P in. H20
Delta P,in. H20
Slowdown, GPM
Delta P,in. H20
Delta P,in. H20
Delta P,in. H20
90.83
91.67
112.08
356.67
378.75
474.17
231.67
231.67
231.67
231.67
231 .67
231.67
0.05
2.22
1272.80
0.00
0.00

4088.58
>20.00
1909.89
8.79
1533.33
<0.25
76.17

20.08
0.18
35.42
0.00
0.25
0.43
170.00
170.00
175.00
660.00
660.00
760.00
720.00
720.00
720.00
720.00
720.00
720.00
0.07
4.80
2138.91
0.00
0.00
>10.00
4867.17
>20.00
2676.49
11.00
1850.00
0.25
80.00

22.00
0.30
80.00
0.00
0.30
0.60
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.04
0.60
921.06
0.00
0.00
6.80
3143.04
19.50
1044.47
8.00
650.00
<0.25
72.00

14.00
0.00
15.00
0.00
0.20
0.20
63.40
60.53
69.60
240.95
247.08
294.41
284.66
284.66
284.66
284.66
284.66
284.66
0.01
1.65
327.80



615.38

385.13
0.99
349.01

2.03

2.84
0.10
19.63

0.04
0.12
69.80
66.03
62.09
67.56
65.24
62.09
122.87
122.87
122.87
122.87
122.87
122.87
13.30
74.53
25.75



15.05

20.17
11.25
22.76

2.67

14.15
53.99
55.42

15.44
29.02
                                                 29

-------
                           SECTION 5

                 SAMPLING AND ANALYSIS PROGRAM
The SITE test program on the Shirco infrared incineration
system at the Peak Oil site was conducted with the unit
operating at normal conditions as summarized in Section 4.
The overall  program consisted of three separate test runs.
During one of these three test runs, a duplicate set of
samples was  taken at each sampling location and analyzed for
all the parameters defined in the analytical protocol.  Table
5.1 presents a summary of the test program including sampling
frequencies, sampling methods, analytical parameters, and
analytical methods for each sample source.  The Sampling and
Analytical Report and the Quality Assurance Project Plan are
provided in  their entirety as Appendices B and C in Volume II
of this Technical Evaluation Report.

It should be noted that in the discussions that follow,
references to various sampling and analytical  protocols are
included.  These recommended methods for sampling and
analyzing samples are coded as follows:
    "
 A" and "S" refers to Arthur D. Little, Inc., "Sampling
and Analysis Methods for Hazardous Waste Combustions," EPA
600/8-84-002, PB84-155845, February,  1984.

"ASTM" refers to American Society for Testing Materials,
"Annual Book of ASTM Standards," Philadelphia,
Pennsylvania.

"EPA Method" refers to Code of Federal Regulations 40CFR
Part 60, Appendix A, Revised as of July 1, 1985.

"M" refers to USEPA "Methods for Chemical  Analysis of
Water and Wastes," EPA-600/4-79-020,  March, 1979.

"SW" refers to USEPA, "Test Methods for Evaluating Solid
Waste-Physical/Chemical  Methods," SW-846,  Third Edition,
1986.

"SASS" refers to USEPA,  "Modified Method 5 Train and
Source Assessment Sampling System Operator's Manual
EPA-600/8-85-003, February, 1985
                                                        "
    --,   eruar,      .

" refers to USEPA, "Protocol  for the Collection and
sis of Volatile POHCs Using VOST,"  EPA-600/8-85-003,
ary,  1985.
    "VOST
    Analys
    February, 1985
                               30

-------
                     TABLE 5.1.   SUMMARY OF SAMPLING AND ANALYTICAL PROGRAM  FOR THE
                                     PEAK OIL  SITE, BRANDON, FLORIDA
Source
       Sample
Collection Frequency
Sampling Method
Analysis Parameters
Analysis Method
Stack Gas
Composite over 3- to
6-hour period
EPA Method 5
with 0.1 N NaOH
                            Composite over 3- to
                            6-hour period

                            Composite over 3- to
                            6-hour period
                            Composite over 4 hour
                            period
                             SASS with XAD-2 (SU0020)
                             SASS with XAD-2 (SW0020)
                             Modified Method 5
                             (No filter/0.1 N NaOH)

                             Gas bag (Grab)
Participate matter
HCl
Volumetric flowrate
Moisture
Metals (particulate
on filter)

PCS
                           PCOD/PCOF
                           Senivolatile Priority
                           Pollutants (plus 10
                           higher  peaks)

                           Soluble Chromium
EPA Method 5
Ion Chromatography
EPA Methods 1-4
EPA Method 4
SU 6010,7060.7041,7421
7740,7470/7471

EPA 680
                          SU 8280
                          SU 8270
                          M218.4
                                                                                                              EPA Method 3
6 pairs of samples over VOST (SU0030)
2-hour period (one
aqueous condensate)
Continuous Continuous emission
monitors


Volatile Priority
Pollutants (plus 10
highest peaks)
°2
COj
CO
THC
MOX
SU 8240


Paramagnetic
NOIR
NDIR
FID
Chemi luminescence
                                                               (continued)

-------
                                                           TABLE  5.1   (continued)
    Source
       Sample
Collection Frequency
Sampling Method
Analysis Parameters
to
ro
                                                           TCLP (Proposed)

                                                           EP Toxicity
                                                           Volatile Priority
                                                           Pollutants (plus 10
                                                           highest peaks)

                                                           Semivolatile Priority
                                                           Pollutants (plus 10
                                                           highest peaks)
                                                           Moisture, Ash
                                                           Ultimate
                                                           Higher Heating Valve
                                                           TCO - Organics
                                                           GRAV - Organics
Analysis Method
Solid Waste Feed



Grab sample once S007
per hour and composite


Chlorine
PCDD/PCDF
PCB
Metals
A003
SH8280
EPA 680
SU 6010,7060,7041,
                                                                                                                        7421,7740,7470/7471

                                                                                                                        Fed.  Reg. Vol. 51,
                                                                                                                        No. 114
                                                                                                                        C004,SW1310
                                                                                                                        SWB240
                                                                                                                        SWB270
                                                                                                                        A001
                                                                                                                        A003
                                                                                                                        A006
                                                                                                                        A011
                                                                                                                        A012
     Scrubber Solids
Grab sample once per
hour and composite
S007
PCB
PCDD/PCDF
Chlorine
Metals

EP Toxicity
TCLP (Proposed)

Volatile Priority
Pollutants (plus 10
highest peaks)
EPA 680
SW8280
A003
SU 6010,7060,7041
7421,7740,7470/7471
C004, SU1310
Fed. Reg. Vol. 51,
No. 114
SW 8240
                                                                      (continued)

-------
                                                           TABLE  5.1   (continued)
    Source
       Sample
Collection Frequency
Sampling Method
Analysis Parameters
Analysis Method
                                                                                            Semivolatile Priority       SU 8270
                                                                                            Pollutants (plus 10
                                                                                            highest peaks)
                                                                                            Ash                         A001
                                                                                            Ultimate                    A003
    Scrubber Water inlet
Grab sample every
15 minutes and composite
S004
to
co
                            PCB
                            PCDD/PCOF
                            PH
                            Chloride
                            Metals

                            Volatile Priority
                            Pollutants (plus 10
                            highest peaks)
                            Semivolatile Priority
                            Pollutants (plus 10
                            highest peaks)
                            Total Organic Carbon
                            Total Suspended Solids
                            Total Dissolved Solids
                           EPA 680
                           EPA 8280
                           M150.1
                           Ion Chromatography
                           SW 6010,7060,7041,
                           7421,7740,7470/7471
                           SW 8240
                                                                                      SW 8270
                                                                                                                        M415.1
                                                                                                                        M160.1
                                                                                                                        M160.2
    Ambient Air
Continuous over 24-hour
period; one upwind and
one downwind
General Metal Works
Model PS-1 Air Sampler
w/ Polyurethane Foam
(PUF) Plugs and Florisil
Sorbent
                                                                                            PCB
                            EPA 680
     Furnace Ash
Grab sample once per
hour and composite
S007
                                                                                             PCB
                                                                                             PCDD/PCDF
                                                                                             Metals
                            EPA 680
                            SW 8280
                            SW 6010,7060,7041,7421
                            7740,7470/7471
                                                                      (continued)

-------
                                                         TABLE 5.1    (continued)
Source
       Sample
Collection Frequency
Sampling Method
Analysis Parameters
Analysis Method
Scrubber Liquid Effluent
Grab sample once per
hour and composite
S004
EP Toxicity
TCLP (Proposed)

Volatile Priority
Pollutants (plus 10
highest peaks)
Semivolatile Priority
Pollutants (plus 10
highest peaks)

Moisture, Ash
Chlorine
TCO - Organics
GRAV - Organics

PCB
PCDD/PCOF
PH
Chlorine
Metals
                                                                                        EP Toxicity
                                                                                        TCLP (Proposed)

                                                                                        Volatile Priority
                                                                                        Pollutants (plus 10
                                                                                        highest peaks)
                                                                                        Semivolatile Priority
                                                                                        Pollutants (plus 10
                                                                                        highest peaks)
                                                                                        Total Organic Carbon
                                                                                        Total Suspended Solids
                                                                                        Total Dissolved Solids
                                                                                                                    C004, SW1310
                                                                                                                    Fed. Reg. Vol. 51,
                                                                                                                    No. 114
                                                                                                                    SW 8240
                                                                                                                    SW827D
A001
A003
A011
A012

EPA 680
EPA 8280
M150.1
Ion Chromatography
SU 6010,7060,7041,
7421,7740,7470/7471

COCK, SW1310
Fed. Reg. Vol. 51,
No. 114
SU 8240
                                                                                      SW 8270
                                                                                      M415.1
                                                                                      M160.1
                                                                                      M160.2

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o   "EPA" refers to USEPA, "Methods for Organic Chemical
    Analysis of Municipal and Industrial Wastewater,"
    EPA-600/4-82-057.

5.1  SAMPLING PROCEDURES

5.1.1  Sampling Locations

The sampling locations are depicted in Figure 5.1.  The
streams sampled were:

    1.   Stack Gas

    2.   Solid Waste Feed

    3.   Furnace Ash

    4.   Scrubber Liquid Effluent

    5.   Scrubber Effluent Solids

    6.   Scrubber Water Inlet

    7.   Ambient Air

5.1.1.1  Stack Gas

Secondary combustion chamber gases were drawn through the
scrubber unit by an induced draft fan and exhausted out a
fiberglass-reinforced plastic (FRP) stack.  The stack was
mounted on a pad as a freestanding unit and had a diameter of
32 in.  Two orthogonal stack sampling ports with 4-in flanged
extensions were approximately 34.5 ft from ground level.  Two
additional orthogonal 3-in ports were located about 2 ft above
the 4-in ports.  Haztech's continuous monitors utilized one of
the 3-in ports.  A sampling platform accessible by a ladder
was at the sampling level.

5.1.1.2  Solid Waste Feed

The solid waste feed samples were obtained at the point where
the waste feed transferred from the weigh hopper to the
conveyor belt, which services the incinerator feed hopper.
The solid waste feed dropped from the weigh hopper directly
onto the feed hopper conveyor, providing an easily accessible
point.  Grab samples were taken hourly in one-liter amber
glass bottles.

5.1.1.3  Furnace Ash

Primary furnace ash was augered from the primary combustion
chamber to a metal holding bin.  The ash was removed from the
bin by a front-end loader and deposited on a concrete pad
prior to disposal.  The ash samples were scooped directly from

                               35

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  Propane Fuel

FORCED AIR
BLOWER
 COMBUSTION AIR
 BLOWER
                                       SECONDARY
                                  H—•"  COMBUSTION CHAMBER
0
©
©
©
0
©
©
(5)
STACK GASES
SOLID WASTE FEED
FURNACE ASH
SCRUBBER LIQUID
EFFLUENT
SCRUBBER SOLIDS
SCRUBBER
WATER INLET
AMBIENT AIR
(DOWNWIND)
AMBIENT AIR
(UPWIND)
                          ID FAN
CRUBBER
j
-I
X
j


VENT
^
^
                                          CHEMICAL CHEVRON
                                          RECYCLE RECYCLE
                                          PUMPS  PUMPS
Figure  5.1.   Sampling  locations.
                                            36

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the ash bin.  Grab samples were taken hourly in one-liter
amber glass bottles.

5.1.1.4  Scrubber Liquid Effluent

Scrubber liquid effluent was recycled to the utilized venturi
throat and quench tubes and chevron section of the scrubber.
A portion of the effluent was collected and was blown down to
a clarifier for solids separation before being transferred to
the effluent holding tank.  Samples of the scrubber liquid
effluent were obtained from a tap at the discharge of the
chevron recycle pump.  Grab samples were taken hourly in 50-mL
amber glass bottles and two 40-mL volatile organic analysis
(VOA) vials.

5.1.1.5  Scrubber Effluent Solids

Particulate matter and salts were removed from the exhaust
combustion gas by the venturi/scrubber system.  Scrubber water
was periodically blown down to a clarifier where the
particulate matter and salts settled out and collected at the
bottom of the clarifier.  Grab samples from the clarifier were
taken hourly in one-liter amber glass bottles.

5.1.1.6  Scrubber Water Inlet

A sample of the scrubber makeup water was taken at the
conclusion of the test program from the hose outlet of the
fresh water pump discharge to the makeup water tank .   The
sample was collected in a one-liter amber glass bottle.

5.1.1.7  Ambient Air

Ambient concentrations of PCBs were monitored during testing
at site boundaries.  One upwind and one downwind ambient air
sample were collected over a 24-hour period.

5.1.2  Process Data

Haztech operating personnel recorded process data during the
test periods at hourly intervals.  Selected process data is
tabulated in Section 4.  The actual operating log data,
process data sheets, and a summary of the waste feedrate
tabulation forms are included in Appendix A (Vol. II).

5.1.3  Stack Gas Sampling Procedures

Sampling procedures for collection of stack gas samples  are
described in the following sections.

5.1.3.1  EPA Method 5

The stack gas was sampled for measurement of particulate
matter, HC1, volumetric flowrate, moisture, and metals using

                               37

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an EPA Method 5 sampling train.  The method was modified by
Including 0.1 N NaOH in the impingers to collect HC1 .

Based on EPA Method 5,  a sample of particulate-1aden flue gas
was withdrawn isokinetically using a gooseneck nozzle  and
heat-traced glass-lined probe.  The particulate matter was
collected on a glass fiber filter maintained at a temperature
in the range of 248 ± 25°F.  The particulate mass was
determined gravimetrically from the residues collected on the
filter, in the probe,  and in associated glassware prior to the
filter.  Exiting the filter, the flue gas entered a chilled
impinger train where HC1 was collected in the first two
Greenburg-Smith impingers,  containing 200 ml of 0.1 N  NaOH.  A
third dry impinger was  employed to collect condensate  or mist
carry-over from the previous impingers.  The third impinger
was a modified Greenburg-Smith type.  The fourth impinger
contained a known weight of silica gel desiccant to collect
remaining moisture.  A  pump and dry gas meter were used to
control and monitor the gas flowrate.

During collection of EPA Method 5 samples, S-type pitot
measurements were taken at traverse points in the flue gas
duct to determine the  isokinetic sampling rate.  The pitot
differential pressure  measurements, along with the flue gas
composition (C02, 02,  N2, H20) were also used to
determine the volumetric flue gas flowrate by correlation to
the cross-sectional area of the duct at the sampling
location.  Grab samples of the stack gas were collected to
determine the concentrations of C02 and 02 directly and
No by difference, in accordance with EPA Method 3 protocol.
The moisture content of the sample gas was measured during the
runs following EPA Method 4 protocol.

At the end of the sampling period, the nozzle, probe liner,
and glassware preceding the filter housing were rinsed with
acetone and deionized  water to remove particulate matter.  The
resulting wash was evaporated, and the mass of particulate
residue was determined  gravimetrically.  The glass fiber
filter was removed from the filter holder, desiccated  for 24
hours, and weighed to  determine the mass of particulate on the
filter.  The total mass of particulate present on the  filter
and in the probe then  was divided by the total volume  of gas
sampled to determine the particulate loading.

The impingers used during particulate sampling were weighed
before and after sampling to determine the moisture content of
the flue gas.  The HC1  concentration of the flue gas was
determined by analyzing two sodium hydroxide impingers for
chloride.  Since the impinger solutions are caustic, C02 was
also removed.  To account for the C02 removal, the 0.1 N
NaOH impinger solutions also were analyzed for carbonate.  The
metered gas sample volume was adjusted using the carbonate
analytical values.


                               38

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The particulate matter collected on the glass fiber filter was
analyzed for metals.  The measured metals concentration along
with the particulate loading and flue gas flowrate were used
to determine the emission rates of those metals.

5.1.3.2  Source Assessment Sampling System (SASS)

A SASS train was used to collect samples of the stack gases
for the determination of PCBs, SV-PP+10, PCDDs, and PCDFs.

The sampling system consisted of a heated probe, a heated
filter, a condenser, a sorbent module containing an organic
adsorption resin (XAD-2) that was used for efficient
collection of vapor phase organics, and a pumping and metering
unit.  Because of the low particulate loading in the gas
stream, the three cyclones of the SASS were removed from the
train for sampling.  The probe was a stainless steel sheath,
which contained a heat-traced stainless steel sample liner.  A
gooseneck nozzle of proper size to allow near-isokinetic
sample collection was attached to the probe.   The flue gas
velocity was measured at the nozzle tip by an S-type pitot.
Either an oil manometer or MagnehelicK differential pressure
gauge was used to measure the pressure drop of the pitot.  The
probe was fixed to the heated enclosure, which housed a high-
efficiency glass fiber filter.  The enclosure was maintained
at a temperature of 400°F.

From the heated filter, the sample gas entered a water-cooled
condenser, then the XAD-2 sorbent module, and then a
condensate trap, which collected the aqueous  condensate.

From the condensate trap the gas entered three dry impingers,
which collected any mist carry-over from the  condensate trap.
A fourth impinger containing a desiccant dried the sample gas
prior to metering.  The sample gas was drawn  by two double
diaphragm pumps, and the sample gas volume was measured using
a dry gas meter.

The design of the SASS train precluded traversing of the
stack.  Sample collection was performed at a  fixed point of
average gas velocity, selected based on previously determined
velocity traverse data.  The SASS probe included an S-type
pitot and thermocouple to measure sample gas  velocity to
determine the isokinetic flowrate.

During the initial test with the SASS train it was noted that
the temperature beinq maintained around the XAD-2 cartridge
was approximately 30°C.  The method specifically states the
XAD-2 temperature must not exceed 20°C for efficient capture
of semivolatile organics.  The SASS run was stopped until the
proper temperature could be achieved.  The problem was linked
to the stack gas temperature and sampling rate and the
condenser chiller, which seemed to be functioning marginally.

                               39

-------
At a sampling rate sufficient to collect 30 m  of gas in 6
hours as called for in the QAPP, the SASS chiller could not
maintain the XAD-2 cartridge below 20°C.

The decision was made to sample at a lower flowrate that would
permit sufficient cooling of the stack gases.  Due to the
heavy participate loading in the gas it was not possible to
compensate for the lower flowrate by increasing the sampling
time, as the filter would clog with particulates.   The net
result of this problem was that each SASS test collected less
than the desired 30 m3 of gas.  This smaller sample volume
may have affected the detection of low concentration organics.

Based on the above, six SASS samples were collected with gas
volumes ranging from 7.31 to 12.06 m3 (258 to 426  ft3).
Sample collection times were approximately five hours for each
SASS sampling period.

5.1.3.3  Soluble Chromium

Soluble chromium (hexavalent chromium) sampling was conducted
according to the procedures (with modifications) currently
being used by the EPA's Emission Measurement Branch (EMB) for
sampling hexavalent chromium emissions from municipal  waste
incinerators.  This procedure involves the use of  an EPA
Method 5 sampling train with the following modifications:

o   0.1 N NaOH impingers in place of water

o   No filter

o   A glass nozzle in place of stainless steel

o   0.1 N NaOH rinse to recover the sample

o   Minimal 0.1 N NaOH in the sample recovery process

The nozzle, probe liner, and pre-impinger glassware rinse were
added to the impinger catches, and the sample was  analyzed by
atomic absorption spectroscopy.   The soluble chromium sampling
train was run approximately 4 hours at a fixed point of
average flue gas velocity in order to achieve adequate
analytical sensitivity.

5.1.3.4  Volatile Organic Sampling Train (VOST)

The stack gas was sampled for volatile organic compounds and
priority pollutants (plus the 10 highest peaks) using  the VOST
(Volatile Organics Sampling Train).  The VOST was  designed to
collect volatile organics with boiling points at around  or
below 100°C using a pair of adsorbent resin traps  in series.


                              40

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Volatile organics were removed from the gas in sorbent resin
traps maintained at 68° F.  The first resin trap contained
Tenax, and the second trap contained Tenax followed by
petroleum-based charcoal.  After sampling, the resin traps
were sealed and returned to the laboratory for analysis.  A
20-L sample of gaseous effluent was collected using a
glass-lined probe.  A dry gas meter was used to measure the
volume of gas passed through the pair of traps.

During the test, the VOST run consisted of collecting six
pairs of traps, with each pair of traps exposed to sample gas
for 20 minutes at the 1.0 L/min flowrate.  After daily
sampling, two 40-ml VGA vials were used to collect the aqueous
condensate collected in the condenser.  Three analyses were
performed on the six resin trap pairs and on one of the
aqueous condensate vials.  The samples were collected at a
fixed point of average gas velocity in the duct. Isokinetic
sampling was not required since the volatile POHCs are in the
gas phase.

5.1.3.5  Molecular Weight

Stack gas was collected at a fixed point in the stack gas bags
for determination of Q£ and C02 concentrations.  The
samples were extracted through a stainless steel probe and
passed through a silica gel impinger to dry the gas before
collection in the gas bag.  Analysis was conducted by EPA
Method 3.

5.1.3.6  Continuous Emission Monitors (CEMs)

CEMs were used during the demonstration test to continuously
monitor the concentrations of CO,  C02, 02, NOX, and THC
at the stack.  Stack gas was withdrawn from the stack and
transported to the instrumentation located at ground level.  A
stainless steel probe was inserted into the stack, and a
heat-traced Teflon sample line was used to transport the
sample to the instrumentation.  The sample line was maintained
at a temperature of 300°F.  The stack gas was conditioned
prior to analysis, removing both particulate matter and water.

Stack gas first entered an impinger train having a series of
short-stemmed impingers (as condensers) immersed in an ice
bath.  After the impinger train, particulate matter was
removed by a glass fiber filter.  After filtration, the stack
gas was further dried using a Perma-Pure dryer, which utilizes
a water vapor permeable membrane.

The stack gas was drawn by a TefIon -coated diaphragm pump
located between the filter and the Perma-Pure dryer.   Stack
gas for the five instruments discussed below was drawn from a
manifold downstream of the pump.


                               41

-------
A Bendix Model 85-105CA analyzer was used to measure CO
concentration in the stack gas.  This instrument is a
nondispersive infrared (NDIR) analyzer,  which measures the
concentration of CO by infrared absorption at a characteristic
wavelength.  To measure the CO? concentration in the stack
gas, an MSA Model 303 NDIR analyzer was  used.  This instrument
measures the concentration of C02 by infrared absorption at
a characteristic wavelength.

A Taylor Model 540A oxygen analyzer was  used to determine the
Q£ concentration of the stack gas.  The  Taylor 540A measures
oxygen concentrations on the basis of the strong paramagnetic
properties of 02 compared to other compounds present in
combustion gases.  In the presence of a  strong magnetic field,
02 molecules become temporary magnets.   The Taylor 540A
determines the sample gas 02 concentration by detecting the
displacement torque of the sample test  body in the presence of
a magnetic field.

A TECO Model 10 analyzer was used to measure the concentration
of NOX  present in the stack gas.  This  instrument
determines NOX concentrations by converting all nitrogen
oxides present in the sample gas to nitric oxide and then
reacting the nitric oxide with ozone.  The reaction produces a
chemi 1 uminescence proportional to the NOX concentration in
the sample gas.  The chemi 1 uminescence  is measured using a
high-sensitivity photomul tip!ier.

A Beckman Model 400A was used to continuously measure the
concentration of hydrocarbons present in the flue gas.  The
analyzer utilizes a hydrogen flame ionization detector.  The
sensor is a burner; a regulated flow of  sample gas passes
through a flame sustained by regulated  flows of a fuel gas and
air.  Within the flame, the hydrocarbon  components of the
sample stream undergo a complex ionization that produces
electrons and positive ions.  Polarized  electrodes collect
these ions, causing current to flow through an electronic
measuring circuit.  The ionization current is proportional to
the rate at which carbon atoms enter the burner and is,
therefore, a measure of the concentration of hydrocarbons in
the original sample.

5.1.4  Solid and Liquid Sampling Procedures

Sampling procedures used to collect samples from solid and
liquid streams are described in this section.

5.1.4.1  Solid and Liquid Sample Container Preparation

Sample containers for the solid and liquid samples were
organic-free and sealed prior to receipt in the field.  All
sample bottles used for solid and liquid samples were amber
glass with TeflonK cap liners.


                               42

-------
All sample bottles were purchased new from I-Chem Research,
Inc. In Hayward, California.  Each sample bottle that was used
to store samples for organic analysis was pre-cleaned using
the following procedure: clean initially with a phosphate-free
soap; rinse three times with tap water; rinse three times with
deionized water; rinse with nitric acid; rinse three times
with deionized water; rinse with methylene chloride; bake in
an oven for 6 hours at 200°C; allow to cool,  and then cap.

5.1.4.2  Solid Sampling Procedures

Samples of the solid waste feed, furnace ash, and scrubber
solids were collected using a trowel or scoop as specified in
Method S007.

Solid grab samples were taken at one-hour intervals.
Approximately 1000 g of solid waste feed were collected for
each grab sample.  The individual solid grab samples from each
run were composited into a single sample prior to analysis.
The total mass of the composited solid sample was no less than
1000 g.

5.1.4.3  Liquid Sampling Procedures

Scrubber liquid effluent and scrubber water inlet samples were
collected using the tap sampling procedure Method S004.
Liquid samples were collected hourly during each sampling
period.  The sample tap was flushed each time (allowed to flow
briefly) before the sample was collected.  This ensured that
any stagnant accumulation of solids or other contaminants
present in the tap would not affect the sample integrity.

For the integrated grab sample,  a minimum of 100 mL was
collected from each grab subsample; the total grab sample
volume for the run was about 1 to 2 L.

At each sample collection, two 40-mL VOA sample vials were
also collected for analysis of V-PP+10.  The vials were filled
completely and no air bubbles allowed to remain in the
bottles.  The VOA samples were composited at the time of
analysis by syringe accumulation from the selected subsamples,
thus producing one sample per test period for analysis.

5.1.5  Ambient Air Sampling Procedures (PCBs)

Ambient air both upwind and downwind of the test site was
sampled and analyzed for PCBs during the program.  The upwind
and downwind General Metals Works Inc. (GMW)  Model PS-1 air
samplers were placed based on wind direction.  The wind
direction was checked at least once per hour.  Since samplers
could not be moved once sampling began, if the average wind
direction deviated by more than  90°, ambient sampling was
terminated for that period.  Ambient PCB concentrations were
determined using the polyurethane foam (PUF)  technique.

                              43

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5.1.6  Sampling Equipment Calibration Procedures

An important function in maintaining data quality is the
check-out and calibration of the source sampling equipment.
Using referenced procedures, the equipment was calibrated
prior to field sampling at the Radian laboratories, and the
results have been properly documented and retained.

5.1.6.1  S-Type Pitot Tube

The EPA has specified guidelines, as presented in Section
3.1.1 of EPA Document 600/4-77-027b, "Quality Assurance
Handbook for Air Pollution Measurement Systems," August, 1977,
concerning the construction and geometry of an acceptable
S-type pitot tube.  Only S-type pitot tubes meeting the
required EPA specifications were used during this project.
Prior to the field sampling, the pitot tubes were inspected
and documented as meeting EPA specifications.

5.1.6.2  Sampling Nozzle

EPA Method 5 prescribes the use of stainless steel gooseneck
nozzles for isokinetic particulate sampling.   All nozzles
used for the EPA Method 5 particulate sampling and Modified
Method 5 sampling were thoroughly cleaned, visually inspected,
and calibrated according to the procedure outlined in Section
3.4.2 of EPA Document 600/4-77-027b.

5.1.6.3  Differential Pressure Gauge

Magnehelic" gauges were used during this project to measure
differential and static pressures.   In Section 3.1.2 of EPA
Document 6QO/4-77-027b, the technique used to calibrate the
MagnehelicK is described.  The MagnehelicK gauges were
calibrated prior to field sampling and checked at a single
representative value following the field sampling.

5.1.6.4  Temperature Measuring Device

During source sampling, accurate temperature measurements are
required.   Thermocouple temperature sensors were calibrated
using the  procedure described in Section 3.4.2 of EPA Document
600/4-77-027b.  All sensors were calibrated prior to field
sampling.

5.1.6.5  Dry Gas Meter

Dry gas meters (DGMs) were used in the SASS, Modified Method
5, Method  5, and VOST trains to monitor the sampling rate and
to measure the sample volume.  All  dry gas meters were
calibrated (documented correction factor at standard
conditions) just prior to the departure of the equipment to
the field.  A posttest calibration check was performed after

                               44

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the equipment was returned to Radian in Austin, Texas.  The
pretest and posttest calibrations should agree within 5
percent.

The dry gas meters used in the SASS, Modified Method 5, and
Method 5 trains were calibrated using the calibration system
procedure outlined in Section 3.3.2 of EPA Document
600/4-77-027b.

Rockwell DGMs were used during the SASS, Modified Method 5,
and Method 5 tests.  A Singer Model DTM-115 low flow DGM was
used during the VOST testing.

5.1.6.6  Analytical Balance

During the field measurement program, the analytical balances
were calibrated over the expected range of use with standard
weights (NBS Class S) on a daily basis.  Measured values were
required to agree within iO.l mg.

5.1.6.7  CEMs

Calibrations of all continuous monitors were accomplished by
introducing .standard gases at the front end of the CEM
sampling probe prior to and after daily sampling.  This
allowed for the assessment of any impact by the sample gas
conditioning system, including the heat traced sample line, on
the pollutants being monitored.  All instruments underwent
multipoint linearity checks (two points plus zero), bracketing
the predicted sample values.  These checks were performed at
the beginning and end of the sampling program.

An analytical blank and a single-point response factor (RF)
standard was analyzed daily prior to testing for all
continuous monitors.  A single-point drift check was 'also
performed by analyzing the same standard used for the
single-point RF determination at the end of each day of
testing.

5.1.6.8  PUF Ambient Air Sampler Calibration

Calibration of the General Metal Works (GMW) PS-1 sampler was
performed using a GMW Model 40 orifice calibration unit
(OCU).  The GMW PS-1 samplers were calibrated prior to
inception of the project, and recalibrated at the end of the
project.  The calibration information was recorded on a
standardized data form.

5.1.7  Sample Custody

Sample custody procedures for this program were based on EPA-
recommended procedures.  Since samples were analyzed on site,
as well as at Radian's permanent laboratory facilities and at
Huffman Labs, the custody procedures used emphasize careful

                               45

-------
documentation of monitoring, sample collection, field
analytical data, and the use of chain-of-custody records for
samples being transported.

The field sampling leader was responsible for ensuring that
proper custody and documentation procedures were followed for
the field sampling and field analytical efforts.  He was
assisted in this effort by the sampling personnel involved in
sample recovery.

All sampling data, including sampling times, locations, and
any specific considerations associated with sample
acquisition, was recorded on Preformatted data sheets.
Following sample collection, all samples were logged into a
master logbook (bound notebook) and given a unique
alphanumeric identification number.  Any specific sample
preservation, storage, or on-site analysis information was
also noted.  Sample labels and chain-of-custody seals were
completed and affixed to the sample container.  Finally,
chain-of-custody forms were completed by any personnel
handling samples.

Each shipment of samples to be analyzed by Huffman Labs was
given a batch number.  Shipping containers were sealed using a
chain-of-custody seal.  Samples were shipped to Huffman Labs
in ice chests and were kept cool (approx. 4°C) with "blue
ice" packs surrounding them.  Transportation of the samples
was accomplished via overnight courier.  A sample custodian
tracked the samples sent to Huffman from receipt through
analyses by a computerized chain-of-custody program developed
for Huffman Labs.

5.2  ANALYTICAL PROCEDURES

Samples of solid waste feed, scrubber liquid effluent,
scrubber effluent solids, scrubber water inlet, furnace ash,
liquids and solids from stack gas, and ambient air were
analyzed for parameters as specified in Table 5.1.  The
analytical scheme and descriptions of the analytical methods
follow.

5.2.1  Solid Streams Analysis

Solid streams including solid waste feed, furnace ash, and
scrubber effluent solids were analyzed for PCBs, PCDD/PCDF,
metals, V-PP+10, SV-PP+10, TCLP and EP Toxicity toxicity
characteristics, chlorine, moisture, ash, higher heating
value, and ultimate analysis.  The solid waste feed and
furnace ash also were analyzed for total chromatographable and
gravimetric organic content (TCO and GRAY).


                               46

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5.2.2  Liquid Streams Analysis

The scrubber water samples including scrubber liquid effluent
and scrubber water inlet were analyzed for PCB, PCDD/PCDF, pH,
chlorine, metals, V-PP +10, SV-PP+10, total organic carbon,
total suspended solids, and total dissolved solids.  The
scrubber liquid effluent also was analyzed for TCLP and EP
Toxicity toxicity characteristics.

5.2.3  Stack Gas Analysis

Stack gases were analyzed using continuous emission monitoring
systems (CEMs) for carbon monoxide, carbon dioxide, oxygen,
nitrogen oxides, and total hydrocarbons.  Grab samples also
were collected during each test run and analyzed for carbon
dioxide and oxygen using an Orsat analyzer (EPA Method 3).

EPA Method 5 samples were collected for analysis of
particulate matter, moisture, flowrate, and HC1.

Four sets of VOST samples were collected for analysis of
V-PP+10.  Six VOST tube pairs and two condensate vials were
collected for each VOST sample, for a total of 24 tube pairs
and 8 condensate vials.  Three analyses were obtained from
each set of six VOST tube pairs collected; one condensate vial
also was analyzed.

EPA Modified Method 5 (MM5) samples were collected for
analysis of soluble chromium.

SASS samples were collected and analyzed for PCBs, PCDD/PCDF,
and SV-PP+10.

5.2.4  Ambient Air

Ambient air samples were collected daily upwind and downwind
of the incineration system using a PUF (polyurethane foam)
sampler.  PUF samples were analyzed for PCBs.

5.2.5  V-PP+10 Analysis

V-PP+10 analyses were conducted on several types of samples,
including solid, liquid, and gas phase samples.  The solid and
liquid incinerator samples include:

o   Solid Waste Feed

o   Furnace Ash

o   Scrubber Liquid Effluent

o   Scrubber Water Inlet
                               47

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o   Scrubber Effluent Solids

The gas phase samples include stack gas samples collected by
VOST.  V-PP+10 analysis of each type of sample used the
following techniques.

5.2.5.1  Stack Gas Analysis for V-PP+10

The VOST was. used to collect samples of the stack gases for
quantitation of the V-PP+10.  The Tenax and Tenax/charcoal
sorbent traps were analyzed according to SW-5040.  Volatile
compounds were separated and detected using GC/MS as outlined
in SW-8240.

5.2.5.2  Liquid and Solid Sample Analysis for V-PP+10

V-PP+10 compounds in liquid and solid samples were analyzed
using SW-8240.  The method details the purge and trap
procedure for preparing field samples for GC/MS analysis.

5.2.6  SV-PP+10 Analysis

SV-PP+10 analyses were conducted on all samples streams.

5.2.6.1  Stack Gas Analysis for SV-PP+10 Analysis

SV-PP+10 analysis using SW-8270 was performed on the stack gas
samples collected using the SASS.  SV-PP+10 and PCDD/PCDF were
analyzed in the same SASS sample.  Surrogates applicable to
both analyses were injected into the samples prior to
extraction.  SV-PP+10 analyses were completed prior to
initiation of cleanup steps for the PCDD/PCDF analysis.

5.2.6.2  Liquid and Solid Sample Analysis for SV-PP+10

Samples of the solid waste feed, scrubber liquid effluent,
scrubber water inlet, scrubber effluent solids, and furnace
ash were analyzed by SW-8270.  Liquid samples were extracted
using SW-3520.  Solid samples were extracted using SW-3540.
Extracts of liquid and solid samples were analyzed for
semivolatile organic contaminants using GC/MS.

5.2.7  PCB Analysis

EPA 680 was used to analyze stack gas,  PUF ambient air
samples, and solid and liquid samples for PCBs  by GC/MS.
GC/MS analysis using selected ion monitoring is superior for
PCB analysis of gas samples.  This type of analysis monitors
for ions indicative of biphenyls with two chlorines, three
chlorines, etc.  The results are usually quantitated as
chorinated biphenyl cogeners instead of by Aroclor number
(1254, 1260, etc.), as is common in GC/ECD analysis.
                              48

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5.2.7.1  Stack Gas Analysis for PCBs

Samples of the stack gases were collected using a SASS train
with XAD-2 as the adsorbent resin for PCB analysis.  The
samples were recovered using methanol and methylene chloride.
The SASS train provides three subsamples: the glass fiber
filter; methanol and methylene chloride rinses of the probe,
the filter holder, and the condenser/resin trap; and the
aqueous condensate.  These subsamples were extracted
separately and then combined for analysis.

5.2.7.2  Liquid, Solid, and Ambient Air Sample Analysis for
PCBs

EPA 680 was used to analyze the solid waste feed, furnace ash,
scrubber liquid effluent, scrubber water inlet, and scrubber
solids, and the ambient air PUF plugs for PCBs.  Solid samples
and PUF plugs were Soxhlet-extracted using SW-3540.  Liquid
samples were extracted using SW-3520.

5.2.8  PCDDs and PCDFs Analysis

All sampled streams were analyzed for PCDDs and PCDFs.

5.2.8.1  Stack Gases Analysis for PCDDs and PCDFs

Stack gas samples for analysis of PCDDs and PCDFs collected
using a SASS train were analyzed according to SW-8280.
PCDD/PCDF analyses were performed on the same SASS samples
that were analyzed for SV-PP+10.

The XAD-2 resin and filter were Soxhlet-extracted using
SW-3540.  The aqueous condensate was extracted by SW-3520,
which is a continuous liquid/liquid extraction.

5.2.8.2  Liquid and Solid Samples Analysis for PCDDs and PCDFs

The liquid and solid samples collected for PCDDs and PCDFs
measurements were analyzed using SW-8280.  Aqueous samples
were extracted by continuous liquid/liquid extracting
according to SW-3520.  SW-3540, which is a Soxhlet extraction
technique, was used to extract solids.

5.2.9  Metals

Samples of the stack gas particulate matter,  solids, and
liquids were analyzed for metals by inductively coupled argon
plasma emission spectroscopy (ICAP) using SW-6010,  and by
atomic absorption spectroscopy (AAS) using SW-7060, 7041,
7421, 7740, and 7470/7471.  The solid samples and particulate
matter collected on the filter of the EPA Method 5 train were
solubilized using SW-3050.  Prior to analysis, liquid samples

                               49

-------
were prepared by using SW-3020.  Lithium metaborate and sodium
carbonate fusion techniques were used to recover silicon and
boron.

The samples were analyzed for a total of thirty-one elements.
The volatile elements (lead, arsenic, antimony, selenium, and
mercury) were analyzed by AAS.  Arsenic, antimony, lead, and
selenium were determined using graphite furnace techniques
(SW-7060, 7041, 7421, and 7740, respectively).  Mercury was
determined by the cold vapor technique (SW-7470/7471).
Aqueous samples (SW-7470) were acidified prior to analysis.

5.2.10  Soluble Chromium

Stack gas samples were analyzed for soluble chromium
(hexavalent chromium) using EPA 218.4.  By this method, the
hexavalent chromium is chelated using ammonium pyrrolidine
dithiocarbamate.  The chelated chromium is then extracted from
the sample medium using methyl ethyl ketone.  The solvent
extract is then analyzed by flame atomic absorption
spectroscopy.

The stability of hexavalent chromium is not completely
understood, and EPA 218.4 recommends chelation and extraction
as soon as possible.  The stack gas samples for soluble
chromium analysis were chelated and extracted on site after
sample collection.

5.2.11  EP Toxicity Test Procedure

All samples with the exception of scrubber water inlet  and
stack gas were analyzed by SW-1310.  The method involves the
acidic extraction of solid samples followed by analysis of
specific trace metals.  The EP Toxicity Test Procedure  was
performed for trace metals only, specifically arsenic,  barium,
cadmium, chromium, lead, mercury, selenium, and silver.

5.2.12  Toxicity Characteristic Leaching Procedure

All samples with the exception of scrubber water inlet  and
stack gases were analyzed by the proposed Toxicity
Characteristic Leaching Procedure (TCLP).  TCLP was proposed
by EPA to expand toxicity characteristic analyses to include
additional chemicals and to incorporate a new extraction
procedure.  Extraction for volatiles involves acidic
extraction in a zero headspace extractor, which is rotated in
an end-over-end fashion at 30+.2 rpm.  Extraction for metals
and semivolatiles uses the same procedure except that it is
done in a glass container rather than in the zero headspace.
The metals were analyzed as described for EP Toxicity.   The
organic contaminants were analyzed using SW-8240 and 8270.


                               50

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5.2.13  Subcontract Analysis

Huffman Labs analyzed the solid waste feed, furnace ash, and
scrubber effluent solids for chlorine, ash, and ultimate
analysis, and the solid waste feed for higher heating value.

5.2.13.1  Chlorine Analysis

Chlorine analyses of the solid waste feed, furnace ash, and
scrubber effluent solids were performed using ASTM D808.  The
samples were combusted in an oxygen bomb containing an
alkaline solution.  The alkaline solution was analyzed for
chlorine (as chloride) using titration.

5.2.13.2  Ash Analysis

The ash content of the solid waste feed, furnace ash, and
scrubber effluent solids was determined using ASTM D3174.  The
sample is ignited, and after burning is ashed at 1427°F in a
muffle furnace.  The residue then is weighed.

5.2.13.3  Ultimate Analysis (C, H, 0, S, N, Moisture)

The solid waste feed, furnace ash, and scrubber effluent
solids were analyzed for elemental concentrations using A003
for ultimate analysis.  The procedure involves the analysis of
carbon, hydrogen, nitrogen, sulfur, and moisture.  Oxygen is
determined by difference.  A003 is a conglomerate of ASTM
methods.  ASTM D3178 analyzes for carbon and hydrogen by
burning the samples in a combustion system followed by
fixation of the products of combustion in an absorption train
for analysis.  Nitrogen is analyzed by ASTM D3179.  The
nitrogen in the sample is converted to ammonium salts by
destructive digestion.  Ammonia is recovered and analyzed
titrimetriclly.  ASTM D3177 is used to measure sulfur using
bomb calorimetry.  The recovered sulfur is precipitated as
BaS04 and determined gravimetrically.  Moisture is
determined by ASTM D3173, which is a gravimetric technique
involving drying of the sample.

5.2.13.4  Higher Heating Value Analysis

The higher heating value (HHV) of the solid waste feed was
determined using a bomb calorimeter, according to ASTM
D2015-77.

5.2.14  TSS and TDS Analysis

The concentration of Total Suspended Solids (TSS) and Total
Dissolved Solids (TDS) present in the scrubber liquid effluent
and scrubber water inlet was determined using gravimetric
procedures EPA M160.1 and M160.2, respectively.
                               51

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5.2.15  pH Analysis

The pH of the scrubber liquid samples was determined using a
portable pH meter in accordance with EPA M150.1.

5.2.16  Particulate Matter

Particulates were measured in the stack gas using EPA Method
5.

5.2.17  Flue Gas Moisture

The moisture content of the gas streams was determined using
the technique specified in EPA Method 4.

5.2.18  HC1 Determination

For the determination of HC1  in the stack gas, samples of gas
were passed through a series  of impingers immersed in an ice
bath.  The first two impingers contained 200 ml of 0.1 N NaOH
and were Greenburg-Smith-type impingers.  Following the first
two impingers were a dry, modified Greenburg-Smith impinger
and an impinger containing a  desiccant.  The sample was
analyzed using an ion chromatograph following Method 27 from
the "FGD Chemistry and Analytical Methods Handbook" Volume 2,
Radian Corporation, 1984.

5.2.19  Carbon Dioxide

During the sampling for HC1 the collection of CC^ in the 0.1
N NaOH impinger is a consideration to be addressed.  Because
the impinger solutions are caustic, C02 was also removed
from the stack gas.  Thus, the metered sample gas volume was
low by the amount of C02 removed by the impinger solutions.

5.2.20  Oxygen and Carbon Dioxide Analysis

Grab bag samples were collected in the field according to EPA
Method 3 for C02 and Q^'  These samples were analyzed
within 3 hours of collection  using an Orsat analyzer.

5.2.21  Total Chromatographable and Gravimetric Organic
        Contents

To further support the results of the proximate and ultimate
analyses of the solid waste feed and furnace ash, samples of
these matrices also were analyzed for total Chromatographable
organics (TCO), which have boiling points between 100°C and
300°C, and gravimetric (GRAV) components, which have boiling
points in excess of 300°C.
                               52

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5.2.22  Total Organic Carbon

Total organic carbon in the scrubber liquid effluent and
scrubber water inlet was determined using EPA method 415.1.
During analysis the sample is converted to CO? by catalytic
combustion, which is measured directly by an infrared
detector.  The amount of C02 formed is directly proportional
to the organic carbon content.
                              53

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                           SECTION 6

                  PERFORMANCE DATA EVALUATION
6.1  INTRODUCTION

Based on the operating data presented In Section 4 and
Appendix A (Volume II) and the analytical results presented In
Appendix B (Volume II), an evaluation was conducted to
determine the effectiveness of the Shirco transportable
infrared incinerator in treating the waste feed matrix at the
Peak Oil site and the feasibility of employing similar units
as hazardous waste treatment systems at other sites throughout
the country.  To this end, the following evaluation objectives
were established:

    o   To determine ORE levels for PCBs.

    o   To demonstrate the success of the unit in
        decontaminating the solid material being processed and
        to determine the DE levels for PCBs.

    o   To evaluate the ability of the unit and its associated
        air pollution control/scrubber system to limit
        hydrochloric acid and particulate emissions.

    o   To determine whether heavy metals contaminants in the
        waste feed are chemically bonded or fixated to the ash
        residue by the process.

    o   To determine the effect that the thermal destruction
        process has in producing combustion by-products.

    o   To determine the impact of the unit operation on
        ambient air quality and potential mutagenic exposure.

    o   To develop unit material balances that define the
        overall stream and component flows through the unit
        during the SITE demonstration runs.


6.2  DESTRUCTION AND REMOVAL EFFICIENCY (ORE)

6.2.1  PCB Destruction and Removal Efficiency

PCBs were analyzed in the solid waste feed, furnace ash,
scrubber effluent solids, stack gas, scrubber liquid  effluent,
                               54

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and scrubber water inlet
based on the following:

                 ORE  =
                  The ORE calculation for PCBs is
                "in - "out
                          W
                           in
       where: W
              W
      in
      out
   =  mass rate of
    mass emission
PCBs
rate
                                           100
fed to incinerator
of PCBs in stack gas
As shown in Table 6.1, the unit achieved a ORE for PCBs of
99.99%.  It was not possible to calculate the ORE beyond two
decimal places because of the analytical procedures employed.

It should be noted that the unit was operated to produce an
ash that contained 1 ppm or less of PCB.  The PCB
concentration in the waste feed to the unit varied from 5.85
to 3.48 ppm during the tests.  These low PCB concentrations in
the waste feed were the result of mixing the original oily
waste having up to 100 ppm of PCBs with the PCB-free
surrounding soil, lime, and sand so that the resulting
material could be handled and processed as a solid waste.
Because of the low PCB concentration in the resulting waste
feed matrix a unit operation based on a ORE for PCBs was
impractical because of the difficulty in measuring extremely
low PCB concentrations in the stack emissions.
6.2.2  Decontamination of
       Efficiency
                 Solid Waste and Destruction
In addition to the impractical measurement of low PCB
concentrations in the stack emissions, as discussed above, the
ORE calculation, which only considers the PCB mass rate of
flow comparison between the waste feed and the stack
emissions, does not account for the PCB mass rate of flow in
the furnace ash and scrubber effluent.

Residual PCBs in the furnace ash were less than the 1 ppm
operating standard, ranging from 0.007 ppm on August 1 to 0.9
ppm on August 3 (Table 6.2).  DE was determined by the formula
                 ORE
                win " wout
                                           100
                          W
                           in
where:  W
        W
in
out
- mass rate of PCBs
= mass rate of PCBs
  ash, and scrubber
  fed to incinerator
  in the stackgas,  furnace
  effluent
With the plant operations precluding the measurement of the
mass flowrate of the furnace ash and scrubber streams,
                               55

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                     TABLE 6.1.    DESTRUCTION AND REMOVAL EFFICIENCY OF PCBs 

Date
Stack Gas
Collection
Time
8/1
14:30-19:20
8/2
11:00-16:15
8/3
10:15-15:50
8/4
10:15-15:50
EESSEESJESSSE
;==============;
PCB
Concentration
in
Waste Feed(
(ng/g)

5850

3850

5340

3480
===============

Waste
Feed
Rate(b)
(kg/hr)

3,020

3,730

3,830

3,830
:===========
PCB
Mass
Feed
Rate
(g/hr)

17.7

14.4

20.5

13.3
==========

PCB
Concentration
in Stack Gas
(ug/m3)

0.0062

0.0220

0.0070

0.0138
:==================


Stack Gas
Flowrate
(dscfm)

5520

4670

4900

5390
============
PCB
Mass
Emission
Rate DRE
(mg/hr) (%)

0.0577 (c)

0.1745 (c)

0.0581 (c)

0.1262 (c)
=======================
(a) As calculated using 40 CFR 761.3 and 40 CFR 264.343.
(b) Determined over the respective stack gas sampling  period.
(c) DRE could only be calculated to 99.99%
because of the analytical  procedures employed.
                                                 56

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                                                            TABLE 6.2.   RESULTS OF PCB ANALYSES ON SOLIDS STREAMS

8/1
(ng/g)
Monochlorobiphenyl <60
Dichlorobiphenyl 160
Trichlorobiphenyl 820
Tetrachlorobiphenyl 790
Pentachlorobiphenyl 310
Hexachlorobiphenyl 1700
Heptachlorobiphenyl 2200
Octachlorobiphenyl <60
y, Nonachlorobiphenyl <60
-J Decachlorobiphenyl <60
Total PCB (a) 5850
Destruction Efficiency (DE),
Solid Waste Feed
8/2
(ng/g)
<50
120
720
440
270
1100
1300
<50
<50
<50
3850
wt.%(b)
8/3-4
(ng/g)
<50
190
780
830
490
1600
1600
<50
<50
<50
5340

8/3-4D(c)
(ng/g)
<40
130
570
440
200
1300
940
45
<40
<40
3480

8/1
(ng/g)
<2
<2
<2
<2
<2
<2
<2
<2
<2
<2
0

8/2
(ng/g)
<2
<2
<2
<2
<2
<2
<2
<2
<2
<2
0

Scrubber Solids
8/3-4
(ng/g)
<2
<2
<2
<2
<2
<2
<2
<2
<2
<2
0

8/3-4D
(ng/g)
<2
<2
<2
<2
<2
<2
<2
<2
<2
<2
0

Blank
(ng/g)
<2
<2
<2
<2
<2
<2
<2
<2
<2
<2
0

8/1
(ng/g)
<2
<2
<2
<2
<2
7
<2
<2
<2
<2
7
99.88
8/2
(ng/g)
<2
<2
<2
22
16
112
89
<2
<2
<2
240
93.77
Furnace Ash
8/3-4
(ng/g)
<2
<2
61
120
42
400
280
<2
<2
<2
900
83.15
8/3-4D
(ng/g)
<2
<2
28
63
46
185
213
<2
<2
<2
540
84.48
Blank
(ng/g)
<2
<2
<2
<2
<2
<2
<2
<2
<2
<2
0

(a) Total PCB calculated according to 40 CFR 761.3
(b) Destruction Efficiency (DE) = 100% x (PCB in waste feed -  PCB  in furnace  ash) / PCB  in waste  feed
(c) 8/3-40 refers to the duplicate sample collected on 8/3-4.

-------
a conservative basis for calculating DE was employed based on
the PCB concentrations in the waste feed and the furnace ash.
The DE or removal of the PCBs from the waste feed ranged from
99.88 wt.% (August 1) to 83.15 wt.% (August 3) as shown on
Table 6.2.

There was an insufficient range of operating conditions
studied during these tests to determine whether the unit can
process waste feed matrices with higher PCB contaminant levels
than those encountered at Peak Oil.  The data obtained during
the SITE program, however, do provide some insight into the
effect of process conditions on this aspect of the unit's
performance, as discussed below.

Under the processing conditions of the PCC as presented in
Appendix A and summarized in Section 4.2,  and based on the PCB
analyses presented in Table 6.2, the PCB content in the ash
residue increased as the waste feedrate increased and
combustion airflow to the PCC decreased.  This decrease in
oxygen availability resulted in a deterioration of
decontamination performance under more reducing conditions.
This conclusion is further supported by the Total
Chromotographable Organics (TCO) and Gravimetric (GRAV)
analyses of the ash, which measure extractable organics.
These correlated closely with residual PCB contents in the
ash.  As shown in Table 6.3, they increased from about 3
percent on the first day of testing to about 12 percent on the
second day to over 19 percent during the third test.  The
destruction of carbon also is consistent with this trend.  As
shown in Table 6.4, 68% of the carbon was  destroyed during the
first day of testing, and an average of 59% was destroyed
during the third day.

6.3  ACID GAS REMOVAL

Measured HC1 emission rates ranged from less than 0.8 to 8.6
g/hr.  Since the chlorine concentration in the solid waste
feed was below the 0.1% detection limit, it is impossible to
determine actual HC1 removal efficiency.  However, SO?
emissions were less than 1100 g/hr with an average 149 kg/hr
SOo feedrate giving an average removal of  SO? in excess of
99%, as shown in Table 6.5.  SOg is more difficult to remove
than HC1 in a caustic scrubber, and the tests show that HC1
removal should be in excess of the 99% determined for S02
removal.

6.4  PARTICULATE EMISSIONS

As shown in Table 6.6, the emissions during the first day were
358 mg/dscm.  The unit was cleaned and mechanical adjustments
were made resulting in a 211 mg/dscm emission rate during the
second day.  The unit finally passed the RCRA particulate
emissions standard of 180 mg/dscm on the third day with a 172
mg/dscm (average of duplicate measurements) emission rate.


                               58

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                   TABLE 6.3.  RESULTS OF TCO AND GRAVIMETRIC ANALYSES

                                                         Total
Total
Chromatographable Gravimetric
Organic (ug/g) (g/g)
Solid Waste Feed
8/1
8/2
8/3-4
8/3-4D(a)
Furnace Ash
8/1
8/2
8/3-4
8/3-4D

343
322
212
222

41.90
7.14
29.10
16.50

0.1266
0.0887
0.0906
0.0934

0.0042
0.0109
0.0174
0.0167
Extractable
Organics
(wt.%)

12.7
8.9
9.1
9-3

0.4
1.1
1.7
1.7
Percent
of Feed
(wt.X)

100
100
100
100

3.3
12.2
19.2
17.9
(a) 8/3-4D refers to the duplicate sample collected on 8/3-4.
                                        59

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                           TABLE  6.4.   RESULTS  OF  PROXIMATE  AND ULTIMATE ANALYSES OF SOLIDS STREAMS
Solid Waste Feed
Ash
                                                                                                          Scrubber Effluent Solids (a)










en
o

Components, wt.%
Moisture
Carbon
Hydrogen
Oxygen
Nitrogen
Sulfur
Chlorine
Ash
HHV (Btu/lb)
8/1

16.63
7.61
2.18
17.85
0.06
2.53
<0.10
69.77
2064
8/2

16.06
6.94
2.16
19.26
0.06
1.78
<0.10
69.80
1639
8/3-4

14.24
7.77
2.3
15.59
0.05
1.89
<0.10
72.40
1728
8/3-4D(b)

14.37
6.97
2.00
14.10
0.05
1.67
<0.10
75.21
2018
8/1

17.91
2.43
1.61
13.31
0.02
2.85
0.19
79.59

8/2

16.01
2.06
6.85
15.02
0.02
2.33
<0.01
79.72

8/3-4

16.82
3.53
1.70
13.52
0.02
2.29
0.26
78.68

8/3-4D

16.11
2.57
1.44
13.88
0.02
2.25
0.21
79.63

8/1

55.64
1.03
0.40
<0.50
0.03
10.33
<0.10
102.39
s— s:s=r:— s==s
8/2

47.43
1.27
0.33
<0.50
0.03
9.76
0.10
92.24

8/3-4

49.94
2.48
0.27
<0.50
0.02
7.30
<0.10
92.15

8/3-4D

46.72
3.23
0.34
<0.50
0.03
6.41
<0.10
89.62

(a) Analyses of scrubber effluent solids are on a dry basis.
(b) 8/3-4D refers to the duplicate sample collected on 8/3-4.

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                        TABLE 6.5.   STACK GAS HCl,  S02, AND ACID GAS REMOVAL EFFICIENCY



Date
8/1
8/2
8/4
8/4D(a)



Time
08:30-10:23
20:00-22:11
15:50-17:44
15:52-17:46
Sample
Total
Cl
(mg)
<0.092
0.960
0.340
0.300
Sample
Total
S02
(mg)
3.13
118.00
2.60
2.35
=S=B&BBB=SS

Sample
Volume
(dscf)
41.44
36.93
35.54
33.82
=sss=a=s=s

Stack Gas
Flowrate
(dscfm)
6040.00
5590.00
5000.00
4930.00
==25=3:======!

HCl
Cone.
(ppmv)
<0.051
0.600
0.220
0.200

S02
Cone.
(ppmv)
0.99
41.80
0.96
0.91
HCl
Emission
Rate
(g/hr)
<0.8
8.6
2.9
2.7
==========:
S02
Emission
Rate
(g/hr)
27.4
1070.0
22.0
20.6
==========
(a) 8/4D refers to the duplicate sample collected  on 8/4.
            Average     Ultimate Analysis   Input  To Scrubber   Removal Efficiency
           Feedrate      Solid Waste Feed      HCl       S02       HCl       S02
Date
8/1
8/2
8/4
(kg/hr)
3953
3696
3655
8/4D(a) 3738
=============-===;
.00
.00
.00
.00
sssss
(wt.
2.
1.
1.
1.
% S)
53
78
89
67
(wt.% Cl)
<0.
<0.
<0.
<0.
r=s====
10
10
10
10
====:
NA
NA
NA
NA
(kg/hr)
200
132
138
125

NA
NA
NA
NA
(wt.%)
>99
>99
>99
>99

.9
.1
.9
.9
(a) 8/4D refers to the duplicate sample  collected on 8/4.
                                                  61

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                                            TABLE 6.6   PARTICULATE LOADING
Saaasaaaasaaassaasaa==aaa=aaaasaa=ssaaa=saas=sasa3:asa=saaa=:ssa==saaas:aaa=aaa=saa=saaa=aa=a3:aa=saaasaaa=aa==saassaaas2aaasaa=s=aa5=ap==
                                                                                                      Participate
                                                                     Particulate                        Loading
                        Sample   Stack Gas       Particulate         Emission         02              Corrected
                        Volume   Flowrate          Loading             Rate         Content           to 7% 02 (b)         Isokinetic
     Date      Time     (dscf)    (dscfm)   (grains/dscf)  (mg/dscm)  (kg/hr)      (vol.%) (a)   (grains/dscf)  (mg/dscm)     (%)
8/1
8/2
8/4
8/4D(d)
08:30-10:23
20:00-22:11
15:50-17:44
15:52-17:46
41.444
36.932
35.536
33.822
6,040
5,590
5,000
4,930
0.1432
0.0866
0.0696
0.0689
322
195
157
155
3.36
1.88
1.35
1.32
8.39
8.09
8.31
8.32
0
0
0
0
:=====
.1590
.0939
.0768
.0761
358
211
173
171
90.7
88.2 (c)
93.9
90.7
(a) Measured by continuous monitor.
(b) Calculated using the following formula: corr.=act.x14/21-y , where y equals measured 02 concentration.
(c) Outside acceptable limit.
(d) 8/4D refers to the duplicate sample collected on 8/4.

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As presented in Table 6.7, lead concentrations averaged 0.65%
in the ash, 10% in the scrubber effluent solids, and 58% in
the stack gas particulate.

6.5  LEACHING CHARACTERISTICS

The solid waste feed, furnace ash, and scrubber effluent
solids were subjected to the EP Toxicity and proposed TCLP
tests to evaluate the toxicity characteristics of these
materials.

The EP Toxicity and the TCLP data present a contradictory
picture regarding the effect of the process on leaching
characteristics.  The EP Toxicity data did not indicate that
the process "encapsulates" or ties up heavy metals (lead) in
the ash to prevent leaching.  The EP Toxicity data,  presented
in Appendix B,  Volume II, Table 2-24, show that lead content
in the ash exceeded the 5 ppm toxicity characteristic
standard.  The  measured lead content of leachates for feed
material and ash are almost equal, indicating that the process
appears not to  affect leaching characteristics for lead.

In contrast to  the EP Toxicity data, the TCLP data show that
the lead content for both the feed and ash were less than the
proposed toxicity characteristic standard of 5 ppm,  as shown
in Appendix B,  Volume II, Table 2-23.  Measured lead
concentrations  were an order of magnitude lower in the TCLP
leachate (about 2 ppm compared to about 30 ppm for EP
Toxicity).

The significant differences in results from these two
analytical techniques have been documented in a recent Oak
Ridge National  Laboratory report (ORNL, "Leaching of Metals
from Alkaline Wastes by Municipal Waste Leachate,"
ORNL/TM-11050,  March, 1987).  It appears that the differences
in the test procedures and alkalinity of the matrix  provide a
difference in the pH environment that is sufficient  to affect
the solubility  and Teachability of heavy metals, particularly
lead.

6.6  PRODUCTS OF INCOMPLETE COMBUSTION

Small quantities of products of incomplete combustion (PICs)
were identified in the s.ampled streams from the unit.  No
polychlorinated dibenzodioxins (PCDDs) or polychlorinated
dibenzofurans (PCDFs) were identified in any of the  sampled
streams above detection limits with the exception of trace
quantities (2.1 ng) of tetrachlorodibenzofuran (TCDF) found in
the stack gas sampled on August 2 (See Appendix B, Volume II,
Table 2-6).
                               63

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               TABLE 6.7.   DISPOSITION  OF  LEAD  IN THE SYSTEM
                                       	(wt.X)	

    Stream              Location           8/1       8/2     8/3-4  8/3-4D(a)

  Solid waste       Before Primary        0.59      0.49      0.50       0.44
                     Chamber

     Ash            After Primary         0.71      0.60      0.64       0.62
                     Chamber

  Scrubber solids   Scrubber              8.90      9.00      9.00      13.00


  Stack gas           Stack              60.00     54.00     60.00      58.00

(a) 8/3-4D refers to the duplicate sample collected on 8/3-4.
                                       64

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Low levels of some semi volatile organic compounds were
identified in all streams.  These compounds were primarily
phthalates, which may be the result of contamination from
plastic components in the process, sampling equipment, or
laboratory apparatus.  Other semivolatile compounds included
aromatic, polyaromatic, and chlorinated aromatic
hydrocarbons.  Low levels of pyrene, chrysene, anthenes,
naphthalenes, and chlorinated benzene were identified in the
waste feed stream; although possible PICs, they must be
discounted to some extent, based on their original
introduction to the unit with the waste feed.  These results
are presented in Appendix B, Volume II, Tables 2-8, 2-9, and
2-10.

Low concentrations of volatile organics were measured in the
stack gas, as shown in Appendix B, Volume II, Table 2-13.
They include halogenated methanes, chlorinated organics, and
aromatic hydrocarbons including BTX compounds.  These volatile
organics increased in the stack gas from August 1 to August 4
and followed a similar trend for the carbon and TCO/GRAV
destruction observed in the ash (See Section 6.2.2).  This is
consistent with the PCC operating under a decreased oxygen
availability (reducing conditions), producing higher levels of
PICs and reduced decontamination efficiencies.

No volatile organics were identified in the water streams.
Low levels (ppb) of chlorinated hydrocarbons and BTX compounds
were measured in all solid streams as shown in Appendix B,
Volume II, Table 2-11.

Low levels of BTX compounds, carbon disulfide, chloroform, di-
and trichlorofluoromethane, di- and trichloroethane, and
methylene chloride were identified in the waste feed.
Methylene chloride, a solvent used during testing,  was also
detected in laboratory and field blanks.  Based on  the above,
these compounds, although possible PICs, must be discounted to
some extent based on their introduction to the unit from an
external source and because of possible contamination.

6.7  AMBIENT AIR SAMPLING AND MUTAGENIC TESTING

Information and data compiled during the SITE program test
runs has resulted in the following summary discussions
concerning the ambient air monitoring and mutagenic exposure
that is associated with the operation of the transportable
Shirco Infrared Thermal Destruction Unit.

6.7.1 Ambient Air Sampling

Ambient air monitoring stations placed upwind and downwind of
the Shirco unit, as discussed and illustrated in Section 5,
were designed to collect airborne PCB contaminants.  The
sampling modules were analyzed for PCBs; the results are
presented in Appendix B, Volume II, Table 2-4.  Based on the

                               65

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downwind sampler data, it appears that the Peak Oil site
boundaries limited the location of the downwind sampler to an
area that was significantly exposed to fugitive emissions
during the transport of ash from the ash pad to the ash
storage area.

6.7.2  Mutagenic Testing

Samples of the waste feed and ash were collected on August 2
and forwarded to the EPA Health Effects Laboratory, Research
Triangle Park, North Carolina for mutagenic testing.  The
results of these tests indicate that although the samples
contain hazardous contaminants, they are not mutagenic based
on the standard Ames Salmonella mutagenicity assay.  The
confirmation memo attesting to these activities is provided
here as Figure 6.1.

6.8  MATERIAL BALANCES

Tables 6.8 to 6.11 present material balances of the Shirco
SITE test runs conducted on August 1-4, 1987.  The tables are
based on the operating log data presented in Appendix A and
the analytical results presented in Appendix B, Volume II.  In
order to provide a series of consistent and closed balances,
the following bases were established and assumptions made in
developing the material flows and component breakdowns.

o    The total solid waste feedrate is based on a 24-hour
     average hourly rate for the specified test day.

o    Measured stack gas flowrates and oxygen concentrations
     were assumed to be accurate based on the defined
     protocols for the measurement of particulate emissions to
     demonstrate compliance with government regulatory
     standards.

o    Measured propane fuel flows to the secondary combustion
     chamber were assumed to be accurate.

o    The difference between the oxygen concentrations of the
     secondary combustion chamber exit gas and the stack gas
     was used to determine air leakage into the system through
     the safety vent and the scrubber system.  No additional
     air leakage into the system was assumed.

o    Combustion airflows were adjusted to meet the measured
     stack gas flowrates.

o    The ultimate analysis of the waste feed was adjusted to
     be consistent with the gas stream oxygen concentration at
     the secondary combustion chamber exit.  It is based on
     the combustion of carbon and hydrogen to carbon dioxide
     and water.
                               66

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               HEALTH EFFECTS RESEARCH LABORATQRY
                                     RESEARCH TRIANGLE PARK
                                      NORTH CAROLINA 27711
   DATE:  January 13,  1988

SUBJECT:  Mutagenlcity of  Peak  Oil  Soil  Samples

   FROM:  David M.  DeMarini,  Ph.D.
          HERL/GTD/GBB (MD-68)

     TO:  Howard Wall
          HWERL
This memo is Co confirm that  we  received  and  tested two soil  samples  from the
Peak Oil Superfund site in Tainpa,  FL.   One  sample  was  soil  from the site
before it was treated in the  incinerator.   The  second  sample  was soil  after
it had been treated in the incinerator.   We extracted  both  samples with
dichloromethane to extract the  organic  components  from the  soils.  GC  analysis
showed a series of peaks similar to what  one  might expect with an oil  sample.
This is consistent with the fact that  the soil  was contaminated with  waste
oil.  The incineration procedure had a  clear  effect on reducing the amount of
extractable organic material  in  the soil.   The  "before" soil  had 6.25% of
extractable organic material, but the  "after" soil had only 0.14%.  This  is  a
considerable reduction and supports continued use  of the incineration  process.

The dichloromethane extracts  were concentrated, solvent exchanged into
dimethyl sulfoxide, and tested  in the  standard  Ames Salmonella mutagenicity
assay.  The results were negative for  both  samples, i.e., the samples  were
not mutagenic, and the highest  doeses  tested  were  10 mg of  organic extract
per petri dish, which is an exceedingly high  dose.  One might interpret  the
results of the "after" soil sample as  weakly  positive  because there  is a
two-fold increase over the control (30 vs.  61 rev/plate at  2000 ug/plate).
However, this is a very weak response  at  a  very high dose and not terribly
significant.  It is, however, reproducible.  The S9 used was  from rat  liver,
and S9 is a portion of homogenized rat  liver  containing enzymes that  can
metabolize chemicals in the sample to  electrophilic compounds that could
interact with DNA. and cause nutation.   An example  of some of  the results  in
strain TA98 of Salmonella is  presented below.  If  you  have  any questions,
please give me a call at FTS 629-1510.
  Dose
(ug/plate)
     TA98 +S9
 Re vertants/plate
Before        After
    0 (control)
         30
500
1000
2000
3000
4000
5000
43
45
48
43
39
34
33
56
61
51
44
40
        Figure  6.1.  Memo:  Mutagenicity of  Peak  Oil  soil  samples
                                        67

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The ash component of the solid waste feed is the total
inorganic ash content of the feed.

The ash plus scrubber solids outlet stream includes the
total inorganic ash content from the solid waste feed
less the particulates exiting with the stack gas.  The
ash plus scrubber solids stream also includes the
non-combusted organics that originally entered the unit
with the solid waste feed.
       •

The stack gas stream components include:

       Water which consists of the water  entering the
       system plus the water produced in  the combustion
       process

       The elemental constituents of the  C02, S02,
       02, and N£ flows.

Chlorine and HC1  flows were insignificant and were not
accounted for in  the balances.
                          68

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                                                                      TABLE 6.8
                                                                   MATERIAL BALANCE
                                                                    AUGUST 1,  1987
Oi
to
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL

SOLID WASTE QUENCH
FEED WATER
1219.95 12311.83
1127.79
323.07
0.00
5.36
252.71
0.00
4406.95
PRIMARY SECONDARY
COMBUSTION COMBUSTION + FORCED
AIR AIR DRAFT AIR



4734.17 1308.52
15590.24 4309.24




AIR TOTAL
PROPANE LEAKAGE IN
13531.78
115.64 1243.43
25.90 348.97
1170.24 7212.93
3878.76 23783.60
252.71
0.00
4406.95
                                 7335.83
12311.83
                                                         20324.41
                                                                                       5617.76
                                                                 141.54
                                                                                                                         5049.00
50780.37

-------
                                                              TABLE 6.8 (CONT.)
                                                           MATERIAL BALANCE
                                                            AUGUST 1, 1987
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL
SCRUBBER
ASH + SOLIDS
0.00
198.16
131.29
0.00
3.73
232.42
0.00
4399.54
STACK
GAS
15478.16
1045.27
0.00
5484.16
23784.34
20.27
0.00
7.41
TOTAL
OUT
15478.16
1243.43
131.29
5484.16
23788.07
252.69
0.00
4406.95
4965.14
45819.61
                                                                           50784.75

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                                                                 TABLE 6.9
                                                              MATERIAL BALANCE
                                                               AUGUST 2, 1987
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL

SOLID WASTE QUENCH
FEED WATER
1163.67 11004.63
874.54
272.19
0.00
5.29
199.96
0.00
4730.14
PRIMARY SECONDARY
COMBUSTION COMBUSTION + FORCED
AIR AIR DRAFT AIR PROPANE

131.01
29.34
4095.84 1308.52
13488.20 4309.24




AIR TOTAL
LEAKAGE IN
12168.30
1005.55
301.53
904.07 6308.43
2997.43 20800.16
199.96
0.00
4730.14
7245.79
                                          11004.63
17584.04
5617.76
                                                                                                           160.35
                                                                                             3901.50
                                                                              45514.07

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                                                                                      TABLE  6.9  (CONT.)
                                                                                   MATERIAL  BALANCE
                                                                                    AUGUST 2,  1987
ro
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL
SCRUBBER
ASH + SOLIDS
0.00
175.96
72.60
0.00
1.71
199.02
0.00
4725.99
STACK
GAS
14215.17
829.60
0.00
4490.43
20800.56
0.94
0.00
4.15
TOTAL
OUT
14215.17
1005.56
72.60
4490.43
20802.27
199.96
0.00
4730.14
                                                             5175.28
40340.85
45516.13

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                                                                           TABLE  6.10
                                                                       MATERIAL  BALANCE
                                                                        AUGUST 3,  1987
u>
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL

SOLID WASTE QUENCH
FEED WATER
1344.38 9209.45
948.15
280.66
0.00
4.86
211.28
0.00
5203.42
PRIMARY SECONDARY
COMBUSTION COMBUSTION + FORCED
AIR AIR DRAFT AIR



3111.76 1308.52
10247.54 4309.24




AIR TOTAL
PROPANE LEAKAGE IN
10553.83
163.18 1111.33
36.55 317.21
1063.61 5483.89
3526.39 18088.03
211.28
0.00
5203.42
                                 7992.75
9209.45
                                                         13359.30
                                                                                       5617.76
                                                                199.73
                                                                                                                         4590.00
                                                                                                                                             40968.99

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                                                               TABLE 6.10  (CONT.)
                                                            MATERIAL BALANCE
                                                            AUGUST 3,  1987
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL
SCRUBBER
ASH + SOLIDS
0.00
321.02
154.60
0.00
1.82
208.26
0.00
5200.44
STACK
GAS
12008.20
790.32
0.00
4192.08
18087.92
3.02
0.00
2.98
TOTAL
OUT
12008.20
1111.34
154.60
4192.08
18089.74
211.28
0.00
5203.42
5886.14
35084.52
40970.66

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                                                                           TABLE 6.11
                                                                        MATERIAL BALANCE
                                                                         AUGUST 4, 1987
en
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL

SOLID WASTE QUENCH
FEED WATER
1334.84 9458.93
971.07
287.45
0.00
4.83
209.78
0.00
5128.03
PRIMARY SECONDARY
COMBUSTION COMBUSTION + FORCED
AIR AIR DRAFT AIR



3244.75 1308.52
10685.46 4309.24




AIR TOTAL
PROPANE LEAKAGE IN
10793.77
145.24 1116.31
32.53 319.98
1010.43 5563.70
3350.07 18349.60
209.78
0.00
5128.03
                                  7936.00
9458.93
13930.21
                                                                                  5617.76
                                                                                                                 177.77
                                                                              4360.50
                                                                             41481.17

-------
en
COMPONENTS, LB/HR

WATER
CARBON
HYDROGEN
OXYGEN
NITROGEN
SULFUR
CHLORINE
ASH

TOTAL
TABLE 6.11 (CONT.)
MATERIAL BALANCE
AUGUST 4, 1987
SCRUBBER
ASH + SOLIDS
0.00
316.86
152.60
0.00
1.80
205.56
0.00
5125.12
STACK
GAS
12290.77
799.46
0.00
4234.03
18349.57
4.22
0.00
2.91
TOTAL
OUT
12290.77
1116.32
152.60
4234.03
18351.37
209.78
0.00
5128.03
                                                             5801.94
35680.96
41482.90

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                           SECTION 7

                           ECONOMICS
7.1  INTRODUCTION
The classical cost analysis addresses the cost aspects of a
capital facility in two main categories: capital costs, and
operating and maintenance costs.

Capital costs include both depreciable and nondepreciable cost
elements.  Depreciable costs include direct costs for site
development, capital equipment, and equipment installation.
Indirect costs include 1) engineering services prior to unit
construction, such as feasibility studies and consultant
costs; 2) administrative tasks, such as permitting; 3)
construction overhead and fee; and 4) contingencies.
Nondepreciable costs include start-up costs for vendor
personnel and operator training, trial or test run expenses,
working capital, and land purchase, which is a direct cost
that is nondepreciable.

Operating and maintenance costs include variable,
semivariable, and fixed cost elements.  Variable operating
cost elements include utilities and residual/water disposal
costs.  Semivariable costs include unit labor and maintenance
costs, and laboratory analyses.  Fixed costs include
depreciation, insurance, and taxes.

The above breakdown of cost elements, however, is based on a
permanently sited hazardous waste incinerator.  The Shirco
thermal destruction unit as employed at the Peak Oil site is a
transportable skid-mounted unit that will not be located
permanently at a site.  Cost analysis, therefore, is based on
different sets of cost elements.

In general, the costs for a transportable thermal hazardous
waste destruction facility fall into three categories:
capital costs, mobilization/demobilization, and operations.
Capital costs include all costs that can be amortized over the
service life of the unit and can be subdivided into direct,
indirect, and nondepreciable cost elements.  Mobilization/
demobilization costs are associated with start-up and shutdown
at a given site, and can be accrued as semivariable operating
and maintenance costs.  They can be amortized while the unit
is transported to and located and operated at a given site.
Operating costs include variable utility costs, semivariable
labor and maintenance costs, and fixed costs such as
depreciation, insurance, and taxes.
                               77

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In addition, for a mobile unit, several capital cost elements
defined for the permanently sited unit should be redefined
into a different cost element category.  These include the
direct costs for site development and the direct costs for
engineering studies, which now will be accrued on a site-
specific basis and as such become mobilization/demobilization
costs.  They now fall under semivariable operating and
maintenance costs.

Based on the above, an overall cost element breakdown, as
illustrated in Section 7.2, Table 7.1, can be developed.

Included in Section 7.3, Table 7.2 is an economic model for a
current-case ideal Shirco transportable unit operation that is
equivalent in processing capacity to the unit that operated at
the Peak Oil site.  It should be noted that cost data on  the
operations at Peak Oil reflect extremely high, indirect and
nondepreciable capital costs and variable and semivariable
operating and maintenance costs, due to the first-of-a-kind
start-up nature of the Shirco unit at the Peak Oil emergency
cleanup site.  Under more normal operating conditions, the
unit, with a nominal capacity of 100 tons per day, should have
remained at the Peak Oil site for a maximum of four months in
order to treat the approximately 7,000 tons of waste feed.
Instead the unit remained at the site for approximately 12
months, which included 9 months of actual operation under
intermittent conditions caused by a series of operating
problems, as discussed in Section 8.2.

7.2  COST ELEMENTS

A detailed discussion of each of the cost elements defined in
Table 7.1 is provided in the following:

7.2.1  Capital Costs: Direct Costs

The current costs for the design, engineering, materials  and
equipment procurement, fabrication, and installation of the
Shirco transportable infrared incinerator are included as
direct costs.  These costs include all the subsystems and
components installed on their respective skids and trailers,
but do not include the costs of the tractors for the transport
of the trailers.  Waste preparation equipment, ash conveyors,
and auxi1iary equipment such as an air compressor or water
treatment facilities are not included.

7.2.2  Capital Costs: Indirect Costs

7.2.2.1  Administrative/Permitting

Administrative costs associated with regulatory compliance
issues for an incinerator are numerous and varied.  The costs
that are being accrued under this cost element reflect overall
non-site-related regulatory activities.  These activities

                               78

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           TABLE 7.1. OVERALL COST ELEMENT BREAKDOWN




CAPITAL COST

  Direct - Depreciable                 Direct - Nondepreciable

     o  Equipment Fabrication/           o  Land Purchase
          Construction

  Indirect - Depreciable

     o  Engineering
     o  Administrative/Permitting
     o  Contingency

  Indirect - Nondepreciable

     o  Operations Procedures/Training
     o  Initial Start-up/Shakedown
     o  Trial Burns
     o  Working Capital

OPERATING AND MAINTENANCE COSTS

  Variable

     o  Fuel
     o  Power
     o  Water
     o  Chemicals
     o  Residue/Water Disposal

  Semi variable

     o  Labor
     o  Maintenance
     o  Analyses
     o  Mobilization/Demobilization

           Site Preparation/Logistics
           Transportation/Setup
           On-Site Checkout
           Site-Specific Permitting/Engineering Services
           Working Capital
           Decent amin ation/Demobi1ization

  Fixed

     o  Depreciation
     o  Insurance
     o  Taxes
                               79

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include establishing national or regional permit requirements,
preparing initial permit applications, and supporting permit
application information throughout the permit issuance
process.  Once the final permits are issued, recordkeeping,
inspection, survey response to permitting agencies, and
additional reporting activities may be required.

Reporting activities include the preparation of technical
support data; the trial burn results, sampling and analysis
plan, and quality assurance project plan by in-house
engineering personnel; and RCRA/TSCA permit forms by a senior
engineering consultant working with in-house staff.
Administrative costs associated with reporting activity cover
time, travel, and per diem for consultant and in-house staff
interfacing with Federal EPA officials; and in-house
administrative and clerical staff functions.  The preparation
of the final  trial burn report by in-house engineering
personnel would also be included.

7.2.2.2  Contingency

In any cost estimate, contingency costs approximating 10% of
the direct capital cost is an acceptable factor; this allows
for unforeseen or poorly defined cost definitions.

7.2.3  Capital Costs: Nondepreciable Costs

7.2.3.1  Operations Procedures and Training

In order to ensure the safe, economical, and efficient
operation of the unit, operating procedures and a program to
train operators are necessary.  These associated costs will
accrue:  the preparation of a unit health and safety and
operating manual; and the development and implementation of an
operator training program, equipment decontamination
procedures,  and automated management and reporting  procedures.

7.2.3.2  Initial  Start-up/Shakedown

After the incineration system has been fabricated and
operations procedures and operator training has been
completed, the overall unit must be initially started and
operated to check the mechanical and technical  integrity of
the equipment and its controls.   The unit would first be
operated without the use of the infrared rods or the secondary
combustion chamber burners in order to check the movement of
solids through the unit in a "cold" mode.  The unit then would
be operated on a nonhazardous feed matrix under a "hot"  mode,
with the infrared rods and the secondary combustion chamber
burners in operation.  Both Shirco and customer personnel
would participate in this start-up/shakedown.
                               80

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7.2.3.3  Trial Burns

Under current TSCA regulations, hazardous waste incineration
facility owner/operators usually are required to perform a
trial burn as the final step in obtaining an operating permit.

In addition to the administrative and permitting costs defined
in Section 7.2.2.1, costs are accrued for the execution of the
TSCA trial burn to prove overall system performance.

The costs for such a trial burn includes labor and materials
for the sampling and analysis activities, travel and per diem
for the sampling team, and other miscellaneous costs that may
be attributable to the execution of the trial burn exclusive
of administrative support.

It should be noted that these nondepreciable capital costs
only are accrued for TSCA trial burn activities; site-specific
permit and trial burn activities are considered semivariable
operating costs that accrue under the mobilization/
demobilization cost element breakdown discussed in Section
7.2.5.4.

7.2.3.4  Working Capital

Although the unit is a transportable system, it will require a
supply of maintenance materials attributable to a
nondepreciable capital cost.  Maintenance materials account
for approximately one-half of the total maintenance cost, and
three-month inventories are usually maintained.

Other working capital includes fuel and chemicals inventory,
which are obtained at each site and will accrue as a
semivariable operating and maintenance cost under the
mobilization/demobilization cost element breakdown.

7.2.4  Operating and Maintenance Costs: Variable Costs

Variable operating cost elements for this unit include fuel,
power, water, chemicals, and residue/water disposal.  They are
defined as variable operating cost elements because they can
usually be expressed in terms of dollars per unit flow of
waste disposed, and as such, these costs are more or less
proportional to overall facility utilization during specific
site operations.

7.2.4.1  Fuel

The fuel requirements for the unit include natural gas or
propane fuel for the secondary combustion chamber heating
requirements.


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7.2.4.2  Power

The power requirements for the unit include the electrical
requirements for the motors that power the pumps, fans,
augers, mixers, and primary combustion chamber belt drive.
Also included is the electrical requirement for the primary
combustion chamber infrared rods, which supply the initial
combustion heat to the waste feed.  One of the factors
affecting the electrical  requirement of these infrared rods is
the heating value of the waste matrix being incinerated.

Although not reflected in this more generalized economic/cost
model of the Shirco unit, the Peak Oil operation, during the
SITE test program, was operating in an autogenous mode.  Once
the primary combustion chamber had reached its operating
temperature, the waste feed was of sufficiently high heating
value to self-sustain primary combustion without the use of
the infrared rods and their electrical power heat source.

Auxiliary electrical requirements for trailer power, site
lighting, etc., are minimal and are assumed to be included in
the total power needs.

7.2.4.3  Water

Water use is based on an estimate of the blowdown requirements
from the scrubber system, water losses due to evaporation, and
carry-over with the stack gas and ash residue.  All other
water needs are satisfied through the internal recirculation
of water from the scrubber system.

7.2.4.4  Chemicals

The main chemical requirement is caustic soda solution for
acid gas scrubbing.

7.2.4.5  Residue/Water Disposal

Costs will accrue for the disposal of ash in a suitable
landfill.  Unit disposal  costs for landfilling depends on
location and on whether toxic metals are present.  If toxic
metals are present, secure landfilling is required.

Scrubber water blowdown will be routed to a municipal or
regional treatment facility if the wastewater meets the
treatment facility's specifications.

7.2.5  Operating and Maintenance Costs: Semivariable Costs

7.2.5.1  Labor

Operating personnel for the Shirco unit, based on three
shifts, totals 22 persons.  This includes 16 process
operators, 3 supervisors, and 3 laboratory and safety persons.


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7.2.5.2  Maintenance

Maintenance materials and labor costs are extremely difficult
to estimate and cannot be predicted as functions of a few
simple waste and facility design characteristics, because a
myriad of site-specific factors can dramatically affect
maintenance requirements.  The discussions in Section 8.2
clearly show the impact of site-related factors on the various
problems encountered during the operation of the unit that
required constant maintenance activities.

7.2.5.3  Analyses

In order to ensure that the unit is operating efficiently and
meeting environmental standards, a program for continuously
analyzing waste feed, ash, and water quality is required.

7.2.5.4  Mobilization/Demobilization

As discussed in Section 7.1,  the following costs will accrue
to the Shirco unit at each specific site.  The costs are site-
specific and may vary widely depending on the nature and
location of the site.  They include site preparation and
logistics, transportation and setup, construction supervision,
on-site check-out, site-specific permitting and engineering
services, working capital, and decontamination/demobilization.

o   Site Preparation/Loqistics--The costs associated with site
    preparation and logistics include advanced planning and
    management, detailed site design and development,
    auxiliary and temporary equipment and facilities, water
    conditioning, emergency and safety equipment, and site
    staff support.  Soil excavation, feedstock preparation,
    and feed handling costs are also included.

o   Transportation and Setup—The cost of transportation and
    setup includes disassembly of the unit at its present
    location and transport to a new location.  Present Shirco
    designs are totally skid-mounted and equipped with
    hydraulic levelers.  The trailers can be moved into place
    without removing equipment, thus significantly minimizing
    setup time and costs.

o   On-site Check-out — Once the unit has been set up, it is
    necessary to shakedown the system to ensure that no damage
    occurred as a result of disassembly, transport,  and
    reassembly.

o   Site-specific permitting and engineering Services—In
    addition to the TSCA trial burn activities discussed in
    Section 7.2.3.3, site-specific permitting and trial  burn
    activities may be required.  Both in-house and consultant
    technical support and engineering services may be required
    to support these efforts.
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o   Working Capital--Fuel inventory for the secondary
    combustion chamber heat source and caustic soda solution
    inventory for the scrubber's acid gas removal operation
    are obtained at each site and as such are site-specific
    semivariable operating costs.

o   Decentamination/Demobilization--With the completion of
    activities at a specific site, the unit must be
    decontaminated and demobilized before  being transported
    to its next location.  Costs that will accrue to this cost
    element include the final burnout of residual material in
    the system, field labor and supervision, decontamination
    equipment and materials, utilities, security, health and
    safety activities, and site staff support.

7.2.6  Operating and Maintenance Costs: Fixed Costs

o   Depreciation—Because incineration is a capital-intensive
    waste treatment option, the overall costs must include an
    annualized capital investment cost or depreciation.  On a
    simplified basis, a 10-yr straight-line depreciation
    adequately addresses this fixed cost for this cost and
    economic analysis.

o   Insurance and Taxes—Depending on site location and the
    specific tax strategy employed for the ownership and
    operation of the unit, insurance and taxes will vary from
    5% to 10% of the fixed capital investment on a yearly
    basis.  For this analysis,  insurance and taxes are
    estimated to represent 10% of the direct capital cost of
    the unit.

7.3  OVERALL COST EVALUATION

An economic model for an efficiently operated  current-cost
Shirco transportable infrared incinerator unit operation
equivalent in processing capacity to the unit that operated at
Peak Oil  is presented in Table  7.2.   The model is based on an
analysis  of cost data available from several sources as
defined in the notes that accompany the table.  This model
represents an operation with an 80% on-stream capacity factor
equivalent to 292 operating days/year at 100 tons/day or
29,200 tons/year.  The total cost per ton for this model is
$196.90.

In actual  operation, the Peak Oil unit was on site for
approximately one year and processed a total of 7000 tons of
waste feed.  Assuming that only variable operating and
maintenance costs remain constant on a per ton basis,  the
remaining costs will increase because of the reduction in
annual waste feed throughput from 29,200 tons to 7,000 tons.
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         TABLE 7.2.   ECONOMIC MODEL FOR SHIRCO UNIT, PEAK OIL
CAPITAL COST

   Direct - Depreciable
     Equipment Fabr./Constr.

   Indirect - Depreciable
     Adm./Permt.  (10% Direct Costs)
     Contingency (10% Direct Cost)
                                (5% Direct Cost)

                                 Cost)
   Indirect - Nondepreciable
     Operations Proc./Training
     Initial Start-up/Shakedown
     Trial Burns
     Working Capital (10% Maint

OPERATING AND MAINTENANCE COSTS

   Variable
     Fuel ($3.50/1000 cf)
     Power ($0.04/kwh)
     Water ($0.80/1000  gal.)
     Chemicals
     Residue/Water Disposal
   Semivariable
     Labor
     Living
     Maintenance (10% Deprec.  Capital)
     Analyses
     Mobilization/Demobilization
       Site Prep.
       Transp./Setup &
        On-site Checkout (5% Direct Cost)
       Site Permit
       Working Capital
       Decon./Demobil.

   Fixed
     Depreciation (10 yrs.  St.  Line)
     Insurance & Taxes (10% Direct Cost)

       TOTAL COST PER TON
                                                  $MM/YR
                                                   3.25
                                                   0.33
                                                   0.33
0.20
0.16
0.30
0.04
                                                   0.01
                                                   0.08
                                                   0.02
                                                   0.03
                                                   0.10
                                                   0.85
                                                   0.48
                                                   0.39
                                                   0.10

                                                   0.80

                                                   0.16
                                                   0.10
                                                   0.05
                                                   0.05
                                                   0.39
                                                   0.33
          $/TON
          11.30
          11.30
 6.85
 5.48
10.27
 1.37
           0.34
           2.74
           0.68
           1.03
           3.42
          29
          16
          13
           3
           5
           3
           1
          17
   11
   44
   36
   42
          27.40
   48
   42
   71
   12
          13.36
          11.30

         196.90
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                     TABLE 7.2 (continued)
                             NOTES

1.  Unit capacity at 100 tons/day.

2.  80% on-stream factor at 292 days/yr.

3.  Total annual throughput at 29,200 tons.

4.  Equipment life at 10 years.

5.  Unit at a specific site for one year.

6.  Cost values obtained from Shirco; McCormick, R.J., et a!.,
    Cost For Hazardous Waste Incineration, Noyes Publications,
    New Jersey, 1985; Mortensen,  H., e_L aj_. ,  Destruction of
    Dioxin-Contaminated Solids and Liquids bv Mobile
    Incineration. Contract No. 68-03-3255, USEPA Hazardous
    Waste Engineering Research Laboratory, Land Pollution
    Control Division, Releases Control  Branch, Edison, NJ,
    1987.

7.  Utilities Consumption Estimate
    1,200 max installed KVA
    2,200°F Afterburner Temperature
    300 installed HP
    140 GPM water usage

8.  Labor Estimate
    16 Operators at $10.50/hr. and 2 OT hrs./wk./man
     3 Supervisors at $20.00/hr.
     3 Lab/Safety at $11.50/hr.
    50% Overhead Rate
    $75/day per diem for 16 men.
    Full year commitment to unit  by personnel.

9.  Cost data accuracy i 30%
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Based on the unit capacity of 100 tons per day, the on-stream
capacity factor is reduced from 80% or 292 operating days/year
to 19% or 70 operating days/year.  Based on the above, the
total cost per ton for this actual operating case is $795.32.

The above two cases represent the extremes of the potential
cost per ton for the overall operation of the Shirco unit as
mobilized for a cleanup action.  An analysis of the Peak Oil
on-stream time reveals that the unit actually processed waste
feed at 25 tons/day or greater for 89 days during the 243 days
of operation from February 13, 1987 to October 13, 1987, for
an average on-stream capacity factor of 37%.  It was assumed
that at 25 tons/day, the unit approached a continuous
operation rather than an unstable start-up/shutdown mode.
Based on the unit being able to operate at 100 tons/day, the
annual  throughput at a 37% capacity factor would have been
13,500 tons of waste feed.  Applying this annual throughput to
the ideal economic model presented in Table 7.2 results in a
total cost per ton of $416.

Based on the above scenarios, it can be expected that as the
Shirco unit is operated more frequently, the on-stream
capacity factor should improve as the first-of-a-kind start-up
problems are eliminated and/or minimized.  In addition, some
of the indirect and nondepreciable capital costs will
decrease.  Based on this,  the total cost per ton for employing
this Shirco unit at other cleanup sites will approach the
economic model presented in Table 7.2.  For the specific Peak
Oil emergency cleanup operation, the cost analysis that
assumes unit operation based on a 37% on-stream factor
represents a reasonable accounting of the actual costs that
accrued to this project.  Based on this assumption, the total
cost per ton for the emergency cleanup at Peak Oil is
approximately $416 +. 30%.
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                           SECTION 8

                    PROBLEMS DURING TESTING
8.1  DEMONSTRATION TEST PROBLEMS

During the SITE demonstration performed between July 31, 1987
and August 4,* 1987 several problems occurred that resulted in
possibly questionable or missing data.  These problems can be
categorized as operational events or procedural deficiencies
as described below.

8.1.1  Operational Events

During the operation of the unit, several  upsets, operating
interventions and unit shutdowns occurred.  These operational
events are presented in Section 4.1.

8.1.2  Procedural Deficiencies

With the SITE test program taking place at the Peak Oil site
emergency cleanup during a difficult first-of-a-kind start-up
of a Shirco transportable infrared incinerator, the program
encountered several problems that impacted on the collection
of data.

o   The unit instrumentation did not include the measurement
    of makeup water and scrubber blowdown  water flows.

o   Ash flowrates were not measured.

o   Although electrical consumption was metered, hourly
    readings requested by the SITE investigators were either
    erroneously taken or not taken.

o   The specific consumption of chemicals  was not recorded on
    an as-used basis.

o   Collection of cost data at the Peak Oil  site was designed
    to provide the specific information required by the EPA to
    define contract costs.  Cost data collection was not
    designed to clearly define the specific  cost elements for
    cost/economic analysis of the unit --  particularly in
    terms of this first-of-a-kind start-up operation.

8.2  OVERVIEW OF UNIT PROBLEMS

During the operating period from December  31, 1986 through
August 4, 1987 the Shirco unit experienced operating and unit
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design problems consistent with the first application of a
full-scale commercial thermal destruction unit at a Superfund
site.

A review of the Haztech, TAT, and EPA logbooks, and progress
reports provided a summary of the problems that occurred
during the start-up and operation of the unit.  The major
operating problems then were categorized by unit operating
sections; a profile of the major problem areas within the unit
then was defined and analyzed to ascertain the reasons for
these specific operational difficulties.

8.2.1  Feed Preparation Section

The feed preparation section of the system is one of the keys
to the successful operation of the Shirco unit.  The feed must
be properly prepared to meet the design requirements of the
unit.  Feed preparation to the proper size and consistency is
a direct function of the matrix's characteristics; similarly,
the feed weighing and conveying system will be impacted by the
waste's physical and handling properties.  Regardless of
whether the system is designed and provided by the unit's
operator or Shirco, preoperation analyses and materials
handling investigations must be conducted to ensure the
successful application of the myriad of materials handling
equipment and processes to the specific site waste feed
matrix.

8.2.1.1  Crusher/Shredder/Power Screen

The Peak Oil waste feed matrix was a solidified sludge that
was prone to agglomeration and caused clogging, bridging, and
jamming of the original crusher equipment.  Prior to the SITE
demonstration test (May 10, 1987), the crusher was replaced
with a power screen that shredded, screened, and aerated the
feed to a consistency and size that was accommodated by the
Shirco feeder.

8.2.1.2  Conveyor

Conveyor system problems included spillage of waste feed,
waste material sticking to the conveyor belt, and an inability
to adjust feedrate from the conveyor to the unit's feeder
system.  Modifications to the conveyor system included the
addition of a "skirt" below the conveyor to catch spillage, a
conveyor scraper that minimized sticking, and a variable speed
controller and revised motor arrangement that provided
feedrate control.

Although the overall conveyor system provided waste feed to
the Shirco unit, preoperation analyses and materials handling
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investigation must be conducted to provide a system that is
adaptable to the specific waste matrix encountered at the Peak
Oil site.

8.2.2  Primary Combustion Chamber Section

8.2.2.1  Feed Inlet

The screw augers and their motor drives experienced continuous
clogging and overload problems.  The feed system required
continuous attention by operating personnel and the addition
of "bridgebreakers" to reduce the bridging of the
agglomerating waste feed.

As is the case with the feed preparation section, the design
configuration of the feed inlet section and the screw augers
should be specific to the waste feed matrix.  The flight
pitch, height, and gear reduction of the feed auger should be
designed based on preoperation investigations and tests on
waste feed materials and feed handling.

The screw augers are designed with reversing capability, and
the motor drives are designed for a 50% overload based on
adequate feed preparation.  If the feed is not properly
crushed, screened, and prepared, the augers' materials
handling efficiency will decrease; bridging and plugging
problems, particularly with an agglomerating feed matrix, will
occur causing significant overload and eventual burnout to the
motor drives.  Again we see the need for preoperation testing
and evaluation of the waste feed matrix vis a vis the entire
feed handling system.

8.2.2.2  Ash Outlet

The ash removal  system required frequent maintenance and unit
downtime.  The cooling screw and incline screw were
continually clogging and breaking, and their motor drivers
would overload and burn out.  When the screws were reversed to
dislodge material under the screw flights, breakage and
further abuse of the motors would occur.  Significant dusting
and odor problems also were evident in and around the ash
removal system.


In addition to the design limitations discussed above, the
intermittent failure of the original feed preparation system
(i.e., crusher and screen) to deliver a consistently sized
waste feed would allow unprepared materials to enter the
unit.  The unprepared feed caused occasional jamming and
blockage of the ash discharge system.  Plugging of the incline
screw was also caused by the buildup of ash in the discharge
chute and improper control and monitoring of the ash quench
facilities.
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In early 1987 the cooling screw and incline screw design were
changed; larger motors and gear reducters were installed to
further correct overload, plugging, and motor burnout.  A
viable solution to future designs could entail the
installation of a larger diameter screw operating at lower RPM
than the small, high-RPM screw conveyor, which proved to be a
high-maintenance item subject to substantial wear over a short
period of time.

Another alternative, a wet system design, does not appear to
be viable; it brings with it substantial equipment maintenance
and environmental concerns when dealing with a liquid abrasive
ash solution.

The dusting problems that were continually present at the ash
removal system can be minimized by careful control and
monitoring of the ash quench water flow, especially during
start-up or periods of interrupted ash discharge.  Potential
odor problems are inherent to the quench operation and will
vary in severity with the waste material.  In any event, unit
and site setup should take into account these potential  health
problems; ash removal and storage should be located for
minimal exposure to operating personnel and traffic.

8.2.2.3  Miscellaneous Systems

In addition to the feed inlet and ash outlet systems, problems
also occurred with conveyor belt failures, cakebreaker
failures, and belt conveyor system maintenance.

A mobile unit moving from site to site will be subject to
metallurgical degradation if one assumes that a  single alloy
will be adequate for all applications.  Knowledge of the
physical and chemical characteristics of the feed is essential
in selecting the appropriate alloy(s).  The original belt
installed at the Peak Oil site was provided with several test
sections of various alloys.  Because of the nature of the feed
material and minimal knowledge of its chemical
characteristics, this approach was selected so that if belt
failure did occur, an appropriate alloy then could be
installed.  Due to the chlorine and sulfur content of the
initial feed material, certain test sections did fail and were
replaced with the standard Type-314 stainless steel alloy.  A
properly cured Type-314 stainless steel belt has provided
reliable service through the completion of the project.   Belt
specifications and subsequent construction materials may
require occasional changes due to the unique characteristics
of a particular feed material.

As with the belt, metallurgical considerations for the
cakebreakers are dictated by the physical and chemical
properties of the feed material and subsequent furnace
environment.  Corrosion problems are resolved through the

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selection of the appropriate alloy for the feed material
characteristics.  At Peak Oil, the original alloy was not
compatible with the waste feed.  In addition, possibly due to
the mechanical failures in feed screening and crushing noted
earlier and to the resultant feeding of unsized or
nonspecification waste material, the cakebreakers also may
have been subject to severe stress when these articles were
encountered, causing cakebreaker failure.

Although problems were encountered with the belt conveyance
system, it appears that the roller bearing specifications do
not require any changes.  Proper attention to lubricant choice
and a rigorous maintenance schedule are required to ensure a
long roller bearing and belt conveyance system operating life.

8.2.3  Secondary Combustion Chamber Section

Unlike the feed preparation and primary combustion chamber
sections, which are burdened with the processing of an
abrasive, unsized, and undefined waste feed matrix, the
secondary combustion chamber is similar to the afterburner
design of a majority of hazardous waste incinerators.  It
ensures the complete destruction of the hazardous volatiles
produced in the primary combustion chamber by combusting the
vapors at temperatures of up to 2300°F with a minimum of
maintenance problems.

For this Peak Oil operation, the only operating problem that
affected the secondary combustion chamber was the failure of
several burner blocks.  Proper curing of the burner blocks is
required prior to achieving operating temperatures.  A slow
curing of the burner blocks prior to operation may not have
been fully performed.  In addition, numerous start-ups and
shutdowns of the unit subjected the blocks to cooling and
heating cycling that adversely affected block life.  Changes
to the burner block have been incorporated in the current
design to allow for symmetrical expansion and contraction and
minimization of stress points observed at Peak Oil, and to
move the flame front farther away from the blocks, thus
extending their life.

8.2.4  Emissions Control Section

8.2.4.1  Quench/Venturi System

The original quench/venturi system design consisted of two
stainless steel quench tubes where the hot exhaust gases from
the secondary combustion chamber are cooled with quench water
sprays.  The cooled gases enter the dual fiberglass reinforced
plastic (FRP) Venturis where water injection at the venturi
throats atomizes and increases particulate precipitation as
the gases proceed into the scrubber system.  The system, as
operated, was modified to a one pass quench/venturi flow with

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a venturl pressure drop exceeding 15 psi.  There were
Indications based on the cracking and scorching of the FRP
venturi section and warpage of the scrubber internals that the
systems may have been subjected to excessive process
temperatures probably caused by a failure of the quench system
and its cooling sprays.  The high temperatures exhibited by
the gas exiting the quench system probably were the result of
low gas flow and subsequent channeling of the exhaust gas
stream through only one pass of the dual quench tubes and
Venturis.  Because of the channeling, the gas stream was not
exposed to the full cooling effect of the spray nozzles, and
damage to the downstream FRP systems resulted.

The particulate precipitation effect at the Venturis also
suffered due to the channeling of the low gas flow.  In
addition, the cracking of the FRP venturi section also may
have occurred because the anchor bolts on the venturi support
structure may not have been loosened during installation of
the system to allow for thermal expansion of the quench
tubes.  Compounding the loss in cooling and particulate
removal efficiency caused by the gas channeling was the
plugging of the water sprays, which reduced the overall quench
and venturi water flows and spray coverage.  This plugging may
have been caused by an excessive salts content in the quench
water caused by a number of factors, including the following
factors:

o   A sodium carbonate neutralizing agent in the scrubber
    packed section contained a substantial amount of inert
    materials that did not dissolve.

o   System makeup water was introduced containing calcium and
    magnesium sulfates and chlorides, which precipitated from
    solution with the addition of sodium carbonate.

o   Fines material, probably lead oxide, carried over'into the
    vapor stream and precipitated at the emissions control
    system.

o   The use of lime in the initial waste feed preparation
    neutralization introduced further salts into the system.

Based on the above it is apparent that the preoperation
testing of the waste feed matrix to determine feed preparation
and materials handling characteristics also should include a
careful study of the overall chemistry of the unit operation,
including neutralizing solutions, waste feed salts content,
and makeup water quality.  Each of the above factors was
addressed during the operation at Peak Oil to minimize their
effect on the overall system.  The unit operation was changed
over to caustic neutralization, which used a known
concentration and purity of caustic solution.  Furthermore, a
water softening system was added to treat the hardness of the

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unit's makeup water.  The spray nozzles and their installation
were also changed to alleviate this problem.

A potential solution to these problems is the clarification
and removal of salts from the scrubber water circulation and
blowdown streams.  This is a viable method of providing fresh
water makeup and a potentially closed-loop or zero-discharge
scrubbing system.  Under normal operating conditions, however,
the clarification of the recycle or recirculation water is not
required if the incoming water is properly treated and the
blowdown rate is sufficient for the removal of sludge and
particulate from the scrubber sump.

An additional solution that should be examined in future
designs is the redesign of the Venturis to accommodate a wider
range of operation and, therefore, a higher pressure drop.
This design will increase particulate precipitation and lessen
the potential carry-over of fines.  This solution, however,
will require additional design requirements for the FRP
scrubber system and ID fan to accommodate the increased vacuum
conditions.

8.2.4.2  Scrubber System

The scrubber is a horizontal  cross-flow design.  Gases pass
horizontally through the chevron section and concurrent sprays
and then through the packed section perpendicular to the
downward vertical flow of acid gas-neutralizing scrubbing
liquid.  Contact of the gas with the thin film created on the
packed section internals allows for efficient mass transfer of
contaminants from the gas to liquid phase.  The scrubbed gas
then flows through a chevron blade mist eliminator before
discharging.

The scrubber design as discussed above is a proven design that
is capable of scrubbing exhaust gases and meeting regulatory
requirements for acid gas removal and particulate loading.
The scrubber system at Peak Oil, however, apparently could not
control particulate emissions at the quantities and quality of
the particulates encountered.  The scrubber problems point out
the need to perform preoperation testing of the waste feed
matrix for overall unit chemistry impact on the water
circulation streams and scrubber design.  Because of the
excessive fines loadings and excessive salts content in the
scrubber water streams as discussed in Section 8.2.4.1, the
scrubber system not only exhibited high stack particulate
loadings, but also was burdened by the significant salts
buildup in the scrubber water streams requiring higher
blowdown and fresh makeup water rates.

Because of the critical role that the scrubber system plays in
controlling particulate emissions and the problems encountered
at Peak Oil, several design changes should be investigated

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that will enable the transportable scrubber system to
accommodate severe submicron participate and salt loadings and
effectively treat emission gases.  These changes could
incl ude:

o   The reorientation of spray and distribution
    nozzles/headers and the introduction of additional or new
    scrubber internals to effect increased scrubber
    efficiency.

o   The total  replacement of the horizontal scrubber system
    with a more efficient vertical or wet electrostatic
    precipitator design that will be transportable and provide
    the increased efficiencies that a countercurrent or
    electrostatic scrubbing system can provide over a cross-
    flow design.

8.2.4.3  Induced Draft Fan System

Because of the particulate carry-over from the scrubber,
plating of the induced draft fan blades would occur causing
blade imbalance and fan vibration.  It does not appear that
the design of the fan is contributing to the problem.  A water
spray system has been added at the fan to periodically wash
the blades of plated salts and minimize vibration problems.
Enabling the scrubber system to minimize particulate
carry-over could eliminate the chronic problems encountered at
the induced draft fan.
                              95

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