EPA542-R-98-016
September 1998
Remediation Case Studies:
On-Site Incineration
Volume 12
Federal
Remediation
Technologies
Roundtable
Prepared by the
Member Agencies of the
Federal Remediation Technologies Roundtable
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Remediation Case Studies:
On-Site Incineration
Volume 12
Prepared by Member Agencies of the
Federal Remediation Technologies Roundtable
Environmental Protection Agency
Department of Defense
U S Air Force
U S. Army
U.S Navy
Department of Energy
Department of Interior
National Aeronautics and Space Administration
Tennessee Valley Authority
Coast Guard
September 1998
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NOTICE
This report and the individual case studies and abstracts were prepared by agencies of the U S
Government Neither the U S Government nor any agency thereof, nor any of their employees, makes any
warranty, express or implied, or assumes any legal liability or responsibility for the accuracy,
completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that
its use would not infringe privately-owned rights Reference herein to any specific commercial product,
process, or service by trade name, trademark, manufacturer, or otherwise does not imply its endorsement,
recommendation, or favoring by the U S Government or any agency thereof The views and opinions of
authors expressed herein do not necessarily state or reflect those of the U S Government or any agency
thereof
Compilation of this material has been funded wholly or in part by the U S Environmental Protection
Agency under EPA Contract No 68-W5-0055
11
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FOREWORD
This report is a collection of sixteen case studies of on-site incineration projects prepared by federal
agencies The case studies, collected under the auspices of the Federal Remediation Technologies
Roundtable, were undertaken to document the results and lessons learned from technology applications
They will help establish benchmark data on cost and performance which should lead to greater confidence
in the selection and use of cleanup technologies
The Roundtable was created to exchange information on site remediation technologies, and to consider
cooperative efforts that could lead to a greater application of innovative technologies Roundtable member
agencies, including the U S Environmental Protection Agency, U S Department of Defense, and U S
Department of Energy, expect to complete many site remediation projects in the near future These
agencies recognize the importance of documenting the results of these efforts, and the benefits to be realized
from greater coordination
The case study reports and abstracts are organized by technology in a multi-volume set listed below
Remediation Case Studies, Volumes 1-6, and Abstracts, Volumes 1 and 2, were published previously, and
contain 54 case studies Remediation Case Studies, Volumes 7-13, and Abstracts, Volume 3, were
published in September 1998 Volumes 7-13 cover a wide variety of technologies, including on-site
incineration technologies (Volume 12) The 16 on-site incineration case studies in this report include
completed full-scale remediations and large-scale field demonstrations In the future, the set will grow as
agencies prepare additional case studies
1995 Series
Volume 1 Bioremediation, EPA-542-R-95-002, March 1995, PB95-182911
Volume 2 Groundwater Treatment, EPA-542-R-95-003, March 1995, PB95-182929
Volume 3 Soil Vapor Extraction, EPA-542-R-95-004, March 1995, PB95-182937
Volume 4 Thermal Desorption, Soil Washing, and In Situ Vitrification, EPA-542-R-95-005,
March 1995, PB95-182945
1997 Series
Volume 5 Bioremediation and Vitrification, EPA-542-R-97-008, July 1997, PB97-177554
Volume 6 Soil Vapor Extraction and Other In Situ Technologies, EPA-542-R-97-009,
July 1997, PB97-177562
1998 Series
Volume 7 Ex Situ Soil Treatment Technologies (Bioremediation, Solvent Extraction,
Thermal Desorption), EPA-542-R-98-011, September 1998
Volume 8 Soil Vapor Extraction, EPA-542-R-98-012, September 1998
111
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1998 Series (continued)
Volume 9 Groundwater Pump-and-Treat (Chlorinated Solvents), EPA-542-R-98-013,
September 1998
Volume 10 Groundwater Pump-and-Treat (Nonchlorinated Contaminants), EPA-542-R-98-014,
September 1998
Volume 11 Innovative Groundwater Treatment Technologies, EPA-542-R-98-015,
September 1998
Volume 12 On-Site Incineration, EPA-542-R-98-016, September 1998
Volume 13 Debris and Surface Cleaning Technologies, and Other Miscellaneous
Technologies, EPA-542-R-98-017, September 1998
Abstracts
Volume 1 EPA-542-R-95-001, March 1995, PB95-201711
Volume 2 EPA-542-R-97-010, July 1997, PB97-177570
Volume 3 EPA-542-R-98-010, September 1998
Accessing Case Studies
The case studies and case study abstracts are available on the Internet through the Federal Remediation
Technologies Roundtable web site at http //www frtr gov The Roundtable web site provides links to
individual agency web sites, and includes a search function The search function allows users to complete
a key word (pick list) search of all the case studies on the web site, and includes pick lists for media treated,
contaminant types, and primary and supplemental technology types The search function provides users
with basic information about the case studies, and allows them to view or download abstracts and case
studies that meet their requirements
Users are encouraged to download abstracts and case studies from the Roundtable web site Some of the
case studies are also available on individual agency web sites, such as for the Department of Energy
In addition, a limited number of hard copies are available free of charge by mail from NCEPI (allow 4-6
weeks for delivery), at the following address
U S EPA/National Center for Environmental Publications and Information (NCEPI)
PO Box 42419
Cincinnati, OH 45242
Phone (513) 489-8190 or
(800) 490-9198
Fax (513) 489-8695
IV
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TABLE OF CONTENTS
Section Page
INTRODUCTION 1
ON-SITE INCINERATION CASE STUDIES 9
Baird and McGuire Superfund Site, Holbrook, Massachusetts 10
Bayou Bonfouca Superfund Site, Shdell, Louisiana 25
Bridgeport Refinery and Oil Services Superfund Site,
Logan Township, New Jersey 39
Celanese Corporation Shelby Fiber Operations Superfund Site,
Shelby, North Carolina 53
Coal Creek Superfund Site, Chehahs, Washington 65
FMC Corporation - Yakuna Pit Superfund Site, Yakuna, Washington 79
Former Nebraska Ordnance Plant Site, Mead, Nebraska 95
MOTCO Superfund Site, Texas City, Texas 127
Old Midland Products Superfund Site, Ola, Arkansas 141
Petro Processors Superfund Site, Baton Rouge, Louisiana 155
Rocky Mountain Arsenal Superfund Site, Commerce City, Colorado 171
Rose Disposal Pit Superfund Site, Lanesborough, Massachusetts 185
Rose Township Dump Superfund Site, Holly, Michigan 199
Sikes Disposal Pits Superfund Site, Crosby, Texas 215
Times Beach Superfund Site, Times Beach, Missouri 231
Vertac Chemical Corporation Superfund Site, Jacksonville, Arkansas 247
TABLES
Table Page
1 General Information on the Selected Sites 3
2 Summary of Cost Data for Each Site 6
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This Page Intentionally Left Blank
VI
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INTRODUCTION
Increasing the cost effectiveness of site remediation is a national priority The selection and use of more
cost-effective remedies requires better access to data on the performance and cost of technologies used in
the field To make data more widely available, member agencies of the Federal Remediation Technologies
Roundtable (Roundtable) are working jointly to publish case studies of full-scale remediation and
demonstration projects Previously, the Roundtable published a six-volume series of case study reports
At this time, the Roundtable is publishing seven additional volumes of case study reports, primarily focused
on soil and groundwater cleanup
The case studies were developed by the U S Environmental Protection Agency (EPA), the U S
Department of Defense (DoD), and the U S Department of Energy (DOE) The case studies were
prepared based on recommended terminology and procedures agreed to by the agencies These procedures
are summarized in the Guide to Documenting and Managing Cost and Performance Information for
Remediation Protects (EPA 542-B-98-007, September 1998) (The September 1998 guide supersedes the
original Guide to Documenting Cost and Performance for Remediation Projects, published in March 1995 )
The case studies present available cost and performance information for full-scale remediation efforts and
several large-scale demonstration projects They are meant to serve as primary reference sources, and
contain information on site background and setting, contaminants and media treated, technology, cost and
performance, and points of contact for the technology application The studies contain varying levels of
detail, reflecting the differences in the availability of data and information Because full-scale cleanup
efforts are not conducted primarily for the purpose of technology evaluation, data on technology cost and
performance may be limited
The case studies in this volume describe a wide variety of incinerators, including rotary kiln (13),
horizontal liquid injection (1), submerged quench (1), and infrared (1) Air pollution controls include
secondary combustion chambers (SCC), quench towers, baghouses, cyclone separators, wet scrubbing
systems, gas conditioners, mist eliminators, and cooling towers Contaminants treated by the incinerators
included dioxins, volatile organic compounds (VOCs), polycychc aromatic hydrocarbons (PAHs),
pesticides, and explosives and propellants Relatively small and large incineration projects are included,
with the quantity of material treated ranging from 4,660 to 496,000 tons of solid material (soil, sludge, and
debris) and from 213,000 to 350,000,000 gallons of liquids
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Table 1 provides a summary including information on technology used, contaminants and media treated,
and project duration for the 16 on-site incineration projects in this volume This table also provides
highlights about each application Table 2 summarizes cost data, including information on quantity of
media treated In addition, Table 2 shows a calculated unit cost for some projects, and identifies key
factors potentially affecting project cost (The column showing the calculated unit costs for treatment
provides a dollar value per unit of soil or liquid treated ) Cost data are shown as reported in the case
studies and have not been adjusted for inflation to a common year basis The costs should be assumed to
be dollars for the time period that the project was in progress (shown on Table 1 as project duration)
While a summary of project costs is useful, it may be difficult to compare costs for different projects
because of unique site-specific factors However, by including a recommended reporting format, the
Roundtable is working to standardize the reporting of costs to make data comparable across projects In
addition, the Roundtable is working to capture information in case study reports that identify and
describe the primary factors that affect cost and performance of a given technology Key factors that
potentially affect project costs for incineration projects include economies of scale, concentration levels
in contaminated media, required cleanup levels, completion schedules, matrix characteristics such as soil
classification, clay content and/or particle size distribution, moisture content, total organic carbon, Btu
value, halogen content, and metal content, and other site conditions
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Table 1. Summary of Remediation Case Studies: On-Site Incmeration
?^%f gvI^^W^ S^tj^^:
V f'f^'^1'^ "• *% "^K"'^! •» ''
Baird & McGmre, MA
Bayou Bonfouca, LA
Bridgeport Refinery and Oil
Services, NJ
Celanese Corporation Shelby
Fiber Operations, NC
Coal Creek, WA
FMC Corporation - Yatama,
WA
^^-"^"C'^l^-'giiF^<'"«S |p".
Rotary kiln, SCC,
quench tower, baghouse,
wet scrubbing system
Rotary kiln, SCC,
quench system, gas
conditioner, scrubber,
mist eliminator
Rotary kiln, SCC,
cyclone separator,
ventun quench, packed
tower scrubber, mist
eliminator
Rotary tain, SCC,
quench duct, baghouse,
packed bed scrubber
system
Rotary tain, SCC,
baghouse, scrubber
Rotary tain, SCC,
quench tank, ventun
scrubber, cooling tower,
packed bed adsorber,
ionizing wet scrubber
Dioxm
VOCs
Polynuclear aromatic
hydrocarbons (PAHs)
Pesticides
PAHs
PCBs
VOCs
Ethylene glycol
VOCs
PAHs
Phenol
PCBs
Pesticides
*4f?'"f.-; v $\ \ , / ?
SS^fe^6:
Soil (210,000 tons)
Sediment (1,500 cubic
yards)
Sediment (250,000 tons)
Lagoon sediment and sludge
(138,350 tons)
Debris (13,000 tons)
Levee material (12,550
tons)
Lagoon oil (3,850 tons)
Soil (4,250 tons)
Soil and sludge (4,660 tons)
Soil (9,715 tons)
Soil (5,600 cubic yards or
7,840 tons)
''">»%:,
, ">^wraiw%//<
3/95 - 3/97
11/93-7/95
12/91 - 1/96
4/91 - 12/91
1/94 - 5/94
1/93-5/93
l^-HSisfeVcV?
Successfully treated a wide variety
of contaminants in soil and
sediment, including dioxins, VOCs,
PAHs, and pesticides
Project completed 18 months ahead
of schedule for this relatively large
quantity of waste
Inadequate design caused numerous
mechanical problems during the
treatment of a variety of matrices,
including sludge, sediment, debris,
oil, and soil, contaminated with
VOCs and PCBs However, all
performance standards and
emissions requirements were met
during the 50 months of operation
The project was completed within
nine months
Incineration operated under a
TSCA permit, therefore,
compliance with DRE requirements
was allowed to be demonstrated
without spiking
Frigid ambient air temperatures
caused delays in setting up the
incinerator, as shakedown activities
occurred during the winter months
(shakedown and testing originally
had been scheduled for spring and
summer)
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Table 1. Summary of Remediation Case Studies: On-Site Incineration
Former Nebraska Ordnance
Plant -OU1, ME
MOTCO.TX
Old Midland Products, AR
Petro Processors, LA
Rocky Mountain Arsenal, CO
Rose Disposal Pit, MA
1 J Incineration System
: r , * Design
Rotary kiln, SCC,
baghouse, quench tank,
scrubber
Rotary kiln, SCC,
second incinerator with
single liquid injection
combustion chamber,
both had quench system,
gas conditioner, wet
scrubber, mist eliminator
Rotary kiln, SCC,
quench tower, ventun
scrubber, baghouse, wet
scrubber
Honzontal liquid
injection incinerator,
quench tank, wet
scrubber, paniculate
scrubber, entrainment
separator
Submerged quench
incinerator, quench
chamber, spray dryer,
ventun scrubber, packed
tower scrubber
Rotary bin, SCC,
cyclone separator,
baghouse, quench
towers, wet scrubbing
system
Principal
Explosives and
propellants
Styrene tars
VOCs
Pentachlorophenol
PAHs
Chlonnated
hydrocarbons
PAHs
Oils
Organochlonc and
organophosphoric
pesticides
PCBs
VOCs
-9 i-*
Media (Quantity)
Soil and debns (16,449
tons)
Soil (4,699 tons)
Sludge (283 tons)
Organic liquids (7,568 tons)
Aqueous waste (10,471
tons)
Soils, sludges, and
sediments (102,000 tons)
Organic liquids and fumes
(213,376 gallons, as of June
1997)
Liquids (10 9 million
gallons)
Soil (51,000 tons)
Project
Duration
9/97 - 12/97
5/90 - 12/91
6/92-5/93
(Ongoing
report covers
11/94
through 5/97)
7/93-7/95
2/94-7/94
•Hv ^s^ l-f «
Project completed within three
months
Mechanical problems, caused in
part by the lack of accurate waste
charactenzahon, were encountered
On-site incineration was stopped m
December 1991 because of a
dispute between the contractor and
the responsible party (RP), the
remedy was changed to off-site
incineration, in part because of the
dispute and mechanical problems
According to project managers, this
incineration project encountered
few problems because of good
waste charactenzation
Incineration was used to treat free
product and emissions from a
groundwater pump and treat
system
Submerged quench incinerator used
to treat liquid pesticide wastes
Innovative design was used to
capture metal particulates
Incinerator used to treat more than
50,000 tons of soil contaminated
with high levels of PCBs (400,000
mg/kg)
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Table 1. Summary of Remediation Case Studies: On-Site Incineration
N " fr^\',, "' NVt/,'ha|V,
H^'«-S|te;ffame,Stote> *" •
Rose Township Dump, MI
Sikes Disposal Pits, TX
Times Beach, MO
Vertac Chemical Corporation,
AR
c stiitiijerati i
Infrared incinerator,
SCC, quench, ventun
scrubber, packed-column
scrubber
Rotary kiln, SCC,
quench section, ventun,
two-stage scrubber
Rotary kiln, SCC,
quench section, ventun,
two-stage scrubber
Rotary kiln, SCC,
cyclone separators, wet
scrubbers
^ V £wwajw$f\*i, ^
' . fiCoiitanupatjIs >sss"
PCBs
VOCs
Semivolatile organic
compounds (SVOCs)
Organic and phenolic
compounds
Dioxm
Dioxm
VOCs
Pesticides
'•vSt. U,«^^JSI
Soils and debns (34,000
tons)
Soil and debns (496,000
tons)
Contaminated water (350
million gallons)
Soil and debns (265,000
tons)
Still bottom waste and soil
in drums (9,804 tons)
•f ;, "T''!Cr*"'"'r'
*>..t
rjpBmflMW-.,'-
9/92-10/93
2/92 - 6/94
3/96 - 6/97
1/92 - 9/94
^'•'%1J&, "^^:^.l^:.Jfy91^^^S'ff^
^''\^^K'-^lf"Li'^J »,s, \.\J, ",' -•<,•,! * ,
t'K "''*•-; ^X-Z'/^Ji&
•'^•Mm:, m^^^"?M^
Infrared incinerator used to treat
contaminated soil and debns
Weather-related operational
problems led to delays in the
project schedule
Two SCCs in parallel were
required to maximize throughput of
incinerator Steam generated by
quenching of slag caused
overpressunzation in the kiln
The incinerator was used as a
central treatment facility for 27
sites in the state of Missoun that
were contaminated with dioxin
Two temporary restraining orders
were filed to stop the incineration
project in light of public concern
about the incineration of dioxin-
listed waste, on-site incineration
proceeded with non-dioxm wastes
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Table 2. Remediation Case Studies: Summary of Cost Data
: -rr
: SiteNaiffiet r
State i -
Bairdfe
McGuire, MA
Bayou Bonfouca,
LA
Bndgeport
Refinery and Oil
Services, NJ
Celanese
Corporation, NC
Coal Creek, WA
FMC
Corporation-
Yakima, WA
Former Nebraska
Ordnance Plant -
OU1.NE
MOTCO, TX
:--=•—-* Project Cost
Treatment
NA
$72,000,000
NA
$1,900,000
NA
NA
$6,479,245
$31,000,000
Total
$133,000,000
$110,000,000
NA
$5,300,000
$8,100,000
$6,000,000
$10,700,000
$76,000,000
Quantity and
Media
Incinerated
213,000 tons of
soil and
sediment
250,000 tons of
sediment
172,000 tons of
sediment, sludge,
debris, oil, and soil
4,660 tons of soil
and sludge
9,715 tons of soil
7,840 tons of soil*
(5,600 cubic yards)
16,449 tons of soil
and debris
23,021 tons of soil,
sludge, organic
liquid, and
aqueous waste
Calculated Unit
Cost for
Treatment**
NA
$288/ton
NA
$410/ton
NA
NA
$394/ton
$l,346/ton
Total
Unit Cost
$620/ton
$440/ton
NA
$l,000/ton
$830/ton
$770/ton
$650/ton
$3,300/ton
~ ~ -— - - -- _ - 5--
Key Factors Potentially Affecting Project -
Cost
No comments
EPA paid for the incineration on the basis of dry
weight of the ash instead of the weight of the
feed material It therefore was more desirable to
the contractor to optimize the process train and
guard against the unnecessary incineration of
moisture
SCC supports required rebuilding to repair loss
of structural integrity Slag falling into ash
quench caused damage to ash and feed augers
requiring numerous repairs
The site operator believes on-site incineration
was uneconomical, compared with off-site
incineration because a relatively small amount of
waste was treated
No comments
Statistical methodology used to minimize the
amount of soil excavated
Project costs were higher than expected due to
the increased volume of contaminated soil than
was encountered during excavation Additional
costs were also incurred due to shutdown of the
system during a period of inclement winter
weather
Inaccurate initial characterization of the waste
stream resulted in many mechanical problems
during incineration operation
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Table 2. Remediation Case Studies: Summary of Cost Data
S%, ' **S. 1 ,, ""*, 'i.r
^4'-f V\i'£%V';I
-ji-«-, . «• -• B|a|% , • ^H!|
Old Midland, AR
Petro Processors,
LA
Rocky Mountain
Arsenal, CO
Rose Disposal
Pit, MA
Rose Township
Dump, MI
Sikes Disposal
Pits, TX
Times Beach,
MO
fl? . *%5 ,,""%, S _ .?!
$22,500,000
(excavate,
incinerate,
backfill)
$4,800,000
through 5/97
$58,000,000
NA
NA
$81,000,000
Confidential
'•<-. • • ."V fff'f, '1
^;:%tei-%^
$27,100,000
$59,220,000
through 5/97
$93,000,000
NA
$12,000,000
$115,000,000
(total includes
$11, 000,000 in
miscellaneous
O&M costs)
$110,000,000
•WL^&^p'^
>j^,|^iaBtrtyi^ttd[ >
•4%> . wl?>,t-fe
,.,'- 'J^citter^ed^,
102,000 tons of
soil, sludge, and
sediment
213,376 gallons of
organic liquid and
fumes (as of June
1997)
10 9 million
gallons of liquid
5 1,000 tons of soil
34,000 tons of soil
and debris
496,000 tons of
soil and debris
265,000 tons of
soil and debris
f'CMcljateA TJnJitj
^^Shw-^l""
$3&&£&9&£
$220/ton
(excavate,
incinerate,
backfill)
$21/gal
$5/gal
NA
NA
$160/ton
Confidential
• ,&$£>•>} ~'*i!%
$264/ton
$280/gal
$9/gal
NA
$350/ton
$230/ton
$800/ton
'.; '-1^^i-%^>;
\^\; r^t "'^^^^J^''S' •^tf«\:.*> "•**
The cntenon for dioxm and furans in ash was
raised from 0 1 to 1 0 ppb, reducing residence
time and increasing throughput Amount of
contaminated soil underestimated
No comments
Heavy rainfall increased volume of liquid
requiring treatment The construction of a
special holding pond was required, increasing
"before treatment" capital costs Before
treatment costs were $14,800,000, after
treatment costs were $18,900,000
Operating in the winter caused weather-related
difficulties, resulting m suspension of the
operation until spring
An estimated 600 tons of incinerator ash required
remcineratton because it did not meet criteria for
on-site disposal
Completed 18 months ahead of schedule because
the contractor supplied a larger incinerator
Before treatment costs were $20,000,000, after
treatment costs were $3,000,000
An estimated 1,900 tons of incinerator ash
required remcineration because it did not meet
catena for backfilling
-------
Table 2. Remediation Case Studies: Summary of Cost Data
Site Name,
State
Vertac Chemical
Corporation, AR
Project Cost
Treatment
NA
Total
$31,700,000
Quantity and
Media
Incinerated
9,804 tons waste
and soil
Calculated Unit
Cost for
Treatment**
NA
Total
Unit Cost
$3,200/ton
Key Factors Potentially Affecting Project
Cost
The mixed solid and liquid waste stream had a
variable Btu content, creating difficulties in
maintaining optimal temperature in the kiln
Because of low pH of waste stream issues related
to worker health and safety arose Residual ash
was disposed of in a facility permitted under
RCRA Subtitle C, thereby increasing disposal
costs
Quantity reported as cubic yards Tons were calculated by multiplying cubic yards by an average density value of 1 4
Calculated unit cost for treatment provided for applications where a cost for on-site incineration was available separately from costs for other activities at a site such as
Rl/FS or remedial design
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On-Site Incineration
Case Studies
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This Page Intentionally Left Blank
10
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On-Site Incineration at the
Baird and McGuire Superfund Site
Holbrook, Massachusetts
11
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Incineration at the Baird and McGuire Superfund Site
Holbrook, Massachusetts
Site Name:
Baird and McGuire Superfund
Site
Location:
Holbrook, Massachusetts
Contaminants:
Dioxms, volatile organic
compounds (VOCs),
polynuclear aromatic
hydrocarbons (PAHs),
pesticides, and heavy metals,
including lead and arsenic
Period of Operation
March 1995 to March 1997
Cleanup Type*
Remedial action
Site General Contractor
OHM Remediation Services
Corporation
16406 US Route 224 East
Fmdlay, OH 45839
(419)423-3526
SIC Code:
2879 (Pesticides)
2841 (Soaps)
2842 (Floor Wax)
2869 (Solvents)
Technology
• Removal of moisture from
soil using rotary dryer
• Combustion of contaminants
in dry soil using rotary kiln
• System designed to treat 25
tons of contaminated soil per
hour
• Ash and flue gases
discharged from kiln
• Residuals generated from
incinerator returned to
excavated areas on site
Cleanup Authority.
CERCLA
• ROD signed in September
1986 (soil)
• ROD signed in September
1989 (sediment)
• US Corps of Engineers
Lead
Point of Contact
Chet Janowski
U S EPA Region 1
John F Kennedy Building
One Congress Street
Boston, MA 02203
Waste Source:
Land disposal of process
wastes
Type/Quantity of Media Treated
Soil (210,000 tons) and sediment (1,500 cubic yards)
Purpose/Significance of
Application:
Treats wide range of
contaminants in soil and
sediment, including dioxm,
VOCs, PAHs, and Pesticides
Regulatory Requirements/Cleanup Goals
Destruction and Removal Efficiency (ORE) of 99 99% for principal organic hazardous constituents
(POHCs) as required by Resource Conservation and Recovery Act (RCRA) incinerator regulations in
40 CFR part 264, subpart O
Results:
Trial burn data indicate that all ORE emission standards were met
12
-------
Incineration at the Baird and McGuire Superfund Site
Holbrook, Massachusetts
(Continued)
Description
Between 1912 and 1983, the site was operated as a chemical mixing and batching company During
a remedial investigation at the site, dioxm concentrations in the soil were measured as high as
27 8 yug/kg A Record of Decision (ROD) signed in 1986 specified on-site incineration as the selected
remedy for the contaminated soils at the site A second ROD signed in 1989 specified on-site
incineration as the selected remedy for the contaminated sediments of the nearby Cochato River
The incineration system included a rotary dryer for removal of moisture from the soil The dried soil
was fed to the rotary kiln where the contaminants in the soil were volatilized and destroyed From
March 1995 through March 1997, the incinerator processed approximately 210,000 tons of
contaminated soil and 1,500 cubic yards of contaminated sediment All of the residuals generated
from the incineration and subsequent ancillary operations, including ash and wastewater treatment
sludge, were landfilled on site Treatment performance and emissions data collected during this
application indicated that all required performance standards and emissions requirements were
achieved
The total cost for remediation using the incineration system was approximately $133,000,000
13
-------
Baird and McGuire Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site incineration of
contaminated soil at the Baird and McGuire
Superfund site (Baird and McGuire) in Holbrook,
Massachusetts A rotary kiln incinerator was
operated from March 1 995 through March 1 997
as part of a remedial action Contaminants of
concern in the soil were dioxins, volatile organic
compounds (VOCs), polynuclear aromatic
hydrocarbons (PAHs), pesticides, and heavy
metals, including lead and arsenic
The Baird and McGuire site was operated as a
chemical mixing and batching company from
1912 to 1983 Some of the raw materials used
on site were stored in a tank farm and piped to
on-site laboratory and mixing buildings Other
raw materials were stored in drums During the
remedial investigation, dioxm concentrations in
the soil were measured as high as 27 8
A
A Record of Decision (ROD) signed in 1986
specified on-site incineration as the selected
remedy for the contaminated soils at the site
second ROD signed in 1989 specified on-site
incineration as the selected remedy for the
contaminated sediments of the nearby Cochato
River Both RODs set standards requiring a
destruction and removal efficiency (ORE) of
99 9999% for principal organic hazardous
constituents (POHCs)
The remediation activities performed at Baird
and McGuire also included the construction and
operation of a groundwater treatment system
Only issues relating to on-site incineration are
discussed in this report
All of the material that was incinerated was
mechanically screened to remove debris
before incineration The incineration system
included a rotary dryer for removal of
moisture from the soil The dried soil was
fed to the rotary kiln where the
contaminants in the soil were volatilized and
destroyed Off-gases from the rotary kiln
were then routed to a secondary combustion
chamber (SCC)
The exhaust gas from the rotary kiln was
directed to an air pollution control system
(ARCS) consisting of a baghouse for
particulate removal, a quench tower, a wet
scrubber for fine particulate removal
Wastewater from the ARCS was treated in
an on-site wastewater treatment system
All of the residuals generated from the
incineration and subsequent ancillary
operations, including ash and wastewater
treatment sludge, were landfilled on site
During two years of operation, the
incinerator processed approximately
210,000 tons of contaminated soil, and
1,500 cubic yards of contaminated
sediment Treatment performance and
emissions data collected during this
application indicated that all performance
standards and emissions requirements were
achieved
The total cost for remediation using the
incineration system was approximately
$133,000,000
US ENVIRONMENTAL PROTECTION AGENCY
Office of Sohd Waste and Emergency Response
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Baird and McGuire Superfund Site
SITE INFORMATION
Identifying Information
Baird and McGuire Superfund Site
Holbrook, Massachusetts
CERCLIS # MAD001041987
ROD Date September 30,1986 (soil)
September 14, 1989 (sediment)
Treatment Application
Type of action Remedial (on-site rotary
kiln incineration)
Period of operation March 1995 - March
1997
Quantity of material treated 210,000 tons
of contaminated soil and 1,500 cubic yards
of contaminated sediment
Background
Historical Activity that Generated
Contamination at the Site Mixing, packaging
and distribution of pesticides, disinfectants,
soaps, floor waxes and solvents
Corresponding SIC Codes: 2879 - Pesticides,
2841 - Soaps, 2842 - Floor Wax, and 2869 -
Solvents
Waste Management Practice That
Contributed to Contamination Land disposal
of process wastes
Site History
• The site operated from 1912 until its closure
in 1983 During this period, activities at the
site included mixing, packaging, storing and
distribution of various products, including
pesticides, disinfectants, soaps, floor waxes,
and solvents
The Baird and McGuire site is located
near the western bank of the Cochato
River in northwest Holbrook, Norfolk
County, Massachusetts The site
consists primarily of coniferous
woodlands and wooded wetlands
Approximately two-thirds of the site is
within the 100-year floodplam of the
Cochato River
Contamination at the site has been
attributed to the direct discharge of
process wastes to soils, a nearby brook
and wetlands, and a former gravel pit,
all of which are within the current site
borders
Soil and sediment at Baird and McGuire
was contaminated with dioxm, VOCs,
PAHs, other organic compounds,
pesticides, and heavy metals such as
lead and arsenic
A site inspection was conducted in
January 1984 and a Remedial
Investigation (Rl) and a Feasibility
Study (FS) were conducted in 1985 and
1986 respectively
U S ENVIRONMENTAL PROTECTION AGENCY
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Baird and McGuire Superfund Site
SITE INFORMATION (CONT.)
Background (Cont
The highest concentrations of contaminants
were under and around former process
buildings In this area, soil sampling and
subsequent analysis did not show any
discernable decrease in contamination with
depth Contamination was assumed to exist
to bedrock at a depth of approximately 15
feet [3]
Elevated concentrations of contaminants
were also found in the area used as an on-
site disposal area for a removal action in
1983-1984 This area was fenced and
capped after EPA removed approximately
1,000 cubic yards of contaminated soil [3]
Based on the results of an Rl and FS, a
ROD was signed on September 30,1986
specifying excavation and on-site
incineration of contaminated soils at the
site. Another ROD was signed on
September 14,1989 specifying excavation
and on-site incineration of contaminated
sediment at the site
It was estimated that 191,000 cubic yards of
soil would be excavated for incineration
This quantity included only the "Hot Areas"
which were established such that the
contaminant concentrations in the remaining
soils would be one to two orders of
magnitude less than those to be excavated
[1]
Between 1995 and 1997, an on-site rotary
kiln incinerator was employed to remediate
the excavated soil and sediment
During two years of operation, the
incinerator processed approximately
210,000 tons of contaminated soil and
1,500 cubic yards of contaminated
sediment
Regulatory Context
• A ROD signed in September 1986 (soil)
and a ROD signed in 1989 (sediment)
specified on-site incineration as the
selected remedy for both contaminated
soil and contaminated sediment
• Compliance standards for the
incineration were set based on the
Resource Conservation and Recovery
Act (RCRA) regulations for incinerators
in 40 CFR part 264 subpart O
• Site activities were conducted under the
authority of the Comprehensive
Environmental Response
Compensation, and Liability Act of 1980
(CERCLA), as amended by the
Superfund Amendments and
Reauthorization Act of 1986 (SARA)
and the National Contingency Plan (40
CFR part 300)
Remedy Selection On-site incineration
was selected as the remedy for
contaminated soil and sediment at the Baird
and McGuire Superfund site because it was
a cost-effective alternative that was
protective of human health and the
environment [1,2]
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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Baird and McGuire Superfund Site
SITE INFORMATION (CONT.)
Table 1 Timeline [1,2,10]
* 'JflP^iffiiZ* *$**&• :
«-> Mff^.i.jK *!(Patj».# «, ^* , *W>-
1912-1983
May 1981
March 1983
July 1985
May 1985 - August 1986
September 1986
September 1989
January 1995
March. 1995 - March 1997
jS/fc
Chemical mixing and batching occurs at Bard and McGuire site
Site Investigation
EPA-imttated immediate removal action Removal of approximately 1 ,000 cubic yards of
contaminated soil and construction of a clay cap
Site sampling and analysis revealed the presence of dioxin
Remedial Investigation/Feasibility Study
Records of Decision signed
Trial burn
Rotarv kiln incinerator operational
Site Logistics/Contacts
Site Management. United States Army Corps
of Engineers-lead
Oversight. United States Environmental
Protection Agency
Remedial Project Manager
Chet Janowski
U S EPA Region 1
John F Kennedy Building
One Congress Street
Boston, MA 02203
Treatment System Vendor
OHM Remediation Services Corporation
16406 US Route 224 East
Fmdlay, OH 45839
(419)423-3526
Matrix Identification
MATRIX DESCRIPTION
Type of Matrix Processed Through the
Treatment System: Soil and sediment
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Baird and McGuire Superfund Site
MATRIX DESCRIPTION (CQNT.)
Contaminant Characterization
Primary Contaminant Groups: Dioxin, VOCs
PAHs, other organic compounds, pesticides,
and heavy metals such as lead and arsenic
Matrix Characteristics
The contaminant of greatest concern
was dioxm The maximum
concentration detected was 28 7 ug/kg
in the soil beneath the process
buildings [3]
The matrix characteristics that most significantly affect cost or performance at this site and their
measured values are presented in Table 2 The results of these measurements were obtained based
on the analysis of contaminated soil incinerated during the trial burn
Table 2 Matrix Characteristics of Soil [10]
Parameter " "*w
Moisture Content
Heat Content
Ash Content
Chloride Total
Total Chrornatographica! Orgamcs (TCO)
*P 1,4, ^tipwgsi&i- . •* isx ,, -
*'#Ha»*.3,.*, TOn* ,y ^ C •**<.
9%
430 BTU/lb
97%
0 06 %
5,600 mg/kg
TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
Rotary Kiln Incinerator, including
• Rotary dryer
• Rotary kiln incinerator
Secondary combustion chamber
Supplemental Treatment Technology
Pre-treatment (soil): Screened and dried
Post-treatment (air). Air Pollution Control
System, including
• High temperature baghouse
• High energy wet scrubbing system
• Quench tower
Post-treatment (water)- On-site
wastewater treatment for treatment of
wastewater from wet scrubbing and
quenching
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Baird and McGuire Superfuncf Site
MATRIX DESCRIPTION (CONT.)
System Description and Operation
• The excavated soil was mechanically
screened to remove debris prior to
incineration The excavated sediment was
placed into specially designed containers and
trucked to the incinerator Feed soils and
sediments were dried in a rotary dryer before
being processed in the incinerator
• A flow diagram of the incinerator system is
presented as Figure 1
• The dried material was fed to the rotary kiln
via a drag-chain conveyor The organic
contaminants were volatilized and partially
destroyed in the kiln chamber
• The kiln was manufactured by OHM
Remediation Services Corporation and had a
length of 40 feet and an inside diameter of 8
feet The kiln was lined with high-density
castable refractory brick and was designed
such that the optimal throughput of
contaminated soil was approximately 25 tons
per hour
• The kiln was rated at 32 million BTU/hr The
kiln drive system employed a 40 hp motor
and rotated at a maximum rate of 120
revolutions per hour
• Kiln ash was quenched in a water bath and
discharged to a storage area Settled solids
were continually removed from the ash
quench bath by a drag-chain conveyor
• The exhaust gas from the rotary kiln was
routed through the rotary dryer to provide
heat for soil drying After passing through
the dryer, the exhaust gas entered the
baghouse through an internal, 180-degree
bend knockout chamber The exhaust gas
then passed through 456 bag modules
• The baghouse was rated for a gram loading
of treated exhaust gas less than or equal to
0 02 grains per dry standard cubic foot (dscf)
The air to cloth ratio was 4 40 to 1 The
design operating conditions for exhaust gas
flow rate and exit temperature were 24,000
actual cubic feet per minute (acfm) and
350 °F
Dust removed by the baghouse was
treated in an indirect-fired rotary
chamber Exhaust gas from this unit
was fed back to the rotary dryer
Exhaust gas leaving the baghouse
entered the downf low quench tower
then passed through 3 levels of quench
sprays The gas was directed by a
contactor tube to impact sump water at
the base of the quench tower [10]
The gas then passed into a 23 5-foot-
long mobile mounted, two-stage Hydro-
Sonic Scrubber where chemical
(caustic) and particulate scrubbing
occurred [10]
Exhaust gas from the scrubber was
routed to the SCC for further
combustion of volatilized
contaminants The SCC operated at
approximately 1,950°F The exhaust
gas residence time in the SCC was a
minimum of 2 seconds
Combustion gas was drawn through
the incinerator by an induced draft fan
(resulting in a constant negative
pressure throughout the system) and
was exhausted through a 100-foot
stack Stack gas flow rate was 44,435
acfm and the stack exit temperature
was approximately 175°F
All of the residuals generated from
incineration and subsequent operations
were returned to the excavated areas
on site' This included the quenched
ash from the rotary kiln, ash from the
incineration of baghouse dust, and
wastewater treatment sludge
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
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Baird and McGuire Superfund Site
MATRIX DESCRIPTION (CONT.)
Figure 1 Incineration Flow Diagram, Baird & McGuire Superfund Site, Holbrook, Massachusetts
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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Baird and McGuire Superfund Site
MATRIX DESCRIPTION (CONT.)
Table 3 Summary of Operating Parameters
if jf^*S *$*m&dl&B$*Vf^~*r ^'"' ^"<
Residence Time
System Throughput
Kiln Discharge Temperature
r^ V . ', ,/
Not Available
25tph
1,233°F
TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards
• The cleanup goals and standards were
specified in the RODs Compliance
standards for the incineration were
established based on the RCRA incinerator
regulations in 40 CFR part 264 subpart O
[1,2]
• The RODs required a ORE of 99 9999% for
principal organic hazardous constituents
(POHCs)
• No quantitative soil cleanup standard was
set The limits of excavation were
established such that contaminant
concentrations in remaining soils were one
to two orders of magnitude lower than the
concentrations in the excavated soils
According to the findings of a risk
assessment performed for the site, the
remaining areas of contamination after
excavation presented an excess lifetime
cancer risk between 1x 104 and 1x 107
Treatment Performance and Compliance
Incineration performance requirements
included
99% removal of HCI,
- 99 99% ORE of all POHCs,
particulate emissions less than 180
mg/dscm (corrected)
- 99 9999% ORE of dioxm surrogate
[10]
Site-specific criteria for arsenic and lead
were developed by USAGE based on the
results of site-specific air modeling The
requirements specify a maximum stack
emission rate for arsenic and lead of
0 00793 g/s and 0 00231 g/s, respectively
[10]
A trial burn was conducted from January 24,
1995 through January 26, 1995 The trial
burn was conducted at conditions that would
reflect worst-case destruction and removal
of all constituents of concern Naphthalene
and monochlorobenzene were selected as
the POHCs 1,2,4,5-tetrachlorobenzene
(TeCB) was selected as a surrogate for
dioxm Naphthalene and TeCB were spiked
into the waste feed soil as solids and
monochlorobenzene was spiked as a liquid
The spiking occurred as the waste feed
entered the dryer The data for the DREs is
included in Table 4
The incinerator operated within the
operating limits established during the trial
burn, signifying that all cleanup
requirements were met The AWFCOs
limits that were used during the operation
of the incinerator are shown in Table 5
Information regarding the frequency of
AWFCOs was not available Trial burn
operating parameters are shown in Table
6 (Information regarding actual values
for operating parameters was not
available)
The residual ash was tested for each of
the POHCs These data are presented in
Table 7
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Baud and McGwre Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 4 Average Destruction and Removal Efficiencies from Trial Bum [10]
Contaminant
Naphthalene
Monochlorobenzene
1 ,2,4,5-Tetraohlorobenzene
Average Contaminant Feed
Rate in Soil (Ib/hrr-' -
20521
163
2037
Average Contaminant Stack QaS
^I^EmlsstbialBat^db^hr} - ~'.
10x10 5
34x105
18x105
-DREW
99 999951
99 99979
99 999991
Table 5 Automatic Waste Feed Cutoffs [10]
I I I I I III
Parameter
Maximum Average Feed Rate (one hour rolling average)
Maximum Instantaneous Feed Rate (one minute average)
Minimum Kiln Discharge Temperature
Minimum Kiln Exit Pressure
Minimum SCO Gas Temperature
Draft Average SCO Exit Pressure
Minimum Exhaust Gas Oxygen
Maximum Exhaust Gas Carbon Monoxide Concentration
Minimum Scrubber Nozzle No 1 Recycle Flow Rate
Minimum Scrubber Nozzle No 2 Recycle Flow Rate
Minimum Scrubber Pressure Drop
Minimum Scrubber pH
Maximum Stack Gas Row Rate
i:- fjpf- - x- '>', >4
.-* ,l"CutIfttirnit -,. /,/
52,840 Ibs/hr
59,080 Ibs/hr
1170°F
<-0 1 inch w c
1880 °F
<-0 1 inch w c
>3%
199ppm
40gpm
32gpm
35 inch w c
60
50,000 acfm
we- Water column
Table 6 Operating Parameters [10]
| „ -"f fy ^
Parameter *$t
Waste Feed Rate
Kiln Discharge Temperature
Secondary Temperature
Secondary Oxygen
Kiln Draft
Baghouse Pressure Drop
Scrubber Pressure Drop
Scrubber pH
"**^ "*~- *""' -;•"?•":>
TriaPOTh?ValUfe., ~\. •':.-,: ~:': '?•>$
5,1 94 Ibs/hr
1233 °F
1951 °F
7 24 %
-1 42 inches w c
3 71 inches w c
46 8 inches w c
669
U S ENVIRONMENTAL PROTECTION AGENCY
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Baird and McGufre Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 6 Operating Parameters [10]
¥H vj&&& Q
Stack Temperature
Stack Flow Rate
Secondary Draft
Dryer Discharge Temperature
Baghouse Quench
Secondary Combustion Chamber Retention Time - calculated
J^^'W^Mtei^^^*:i^j'£
174 8 °F
44435 act m
-0 71 inches w c
309 1 °F
1514gpm
2 51 seconds
we -Watercolumn
Table 7 Contaminant Concen
.!* f3/£j* i£« ;., , ; '7s, Js'fafeiS'OHCs *!l'-'"'*t, ;,;,,,,_ -'*'J:
Naphthalene
Monochlorobenzene
1 .2.4.5-Tetrachlorobenzene
ration in Residual HOI
*• ^S2ifeAi{1^4':; % !S
<0316
<0810
<0422
Performance Data Quality
According to the site personnel, the QA/QC
program used throughout the remedial
action met all EPA requirements All
monitoring and sampling analysis was
performed using EPA-approved methods,
and the vendor did not note any exceptions
to the QA/QC protocols
TREATMENT SYSTEM COST
Procurement Process
USAGE contracted with OHM Remediation
Services to acquire and operate the
incinerator at the site OHM Remediation
Services used several subcontractors to
implement specific aspects of the operation
[10]
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
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Baird and McGuire Superfund Site
TREATMENT SYSTEM COST (CONT.)
Cost Data
• The estimated cost for operating the
incinerator at the site was $133,000,000
[11] A total of 213,000 tons of soil and
sediment were incinerated This
corresponds to a total unit cost for
incineration of $620 per ton A detailed
breakdown of these costs was not available
OBSERVATIONS AND LESSONS LEARNED
Observations and Lessons Learned
• Under certain unusual weather conditions,
the steam plume from the incinerator stack
touched down on nearby residences In
response to the public concern that was
generated, USAGE added 50 feet to the
height of the incinerator stack According to
EPA officials, there were no public health
reasons for this action [8]
REFERENCES
1 Superfund Record of Decision. Baird and
McGuire Site, Holbrook, Massachusetts,
September 29,1986
2 Superfund Record of Decision. Baird and
McGuire Site, Holbrook, Massachusetts,
September 14,1989
3 Remedial Investigation Report. Baird and
McGuire Site, Holbrook, MA, May 22,1985
4 Feasibility Study Report. Baird and McGuire
Site, Holbrook, MA, July 18,1986
5 Final Addendum Report Remedial
Investigation Phase II. Baird and McGuire
Site, Holbrook, MA, June 27,1986
6 EPA Supplement to the Baird and
McGuire Feasibility Study Report of
July. 1986
7 EPA Environmental News. October 2,
1985
8 EPA Environmental News. March 16,
1995
9 Superfund Progress at National
Priority List Sites. 1997 Update.
Massachusetts Baird and McGuire Site.
January, 1997
10 Trial Burn Report for the Baird and
McGuire Superfund Site. Holbrook. MA.
March 10, 1995
11 Engineering News-Record. McGraw-Hill
Companies, July 14,1997
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On-Site Incineration at the
Bayou Bonfouca Superfund Site
Slidell, Louisiana
25
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Incineration at the Bayou Bonfouca Super!und Site
Slidell, Louisiana
Site Name-
Bayou Bonfouca Superfund
Site
Location:
Slidell, Louisiana
Contaminants-
Polynuclear aromatic
hydrocarbons
benzo(a)anthracene,
benzo(a)pyrene,
benzo(b)fluoranthene,
benzo(k)fluoranthene,
ideno(1,2,3-cd)-pyrene,
chrysene, and creosote
Period of Operation:
November 1993 - July
1995
Cleanup Type:
Remedial action
Vendor:
IT Corporation
312 Directors Drive
Knoxville, TN 37923
(423)690-3211
SIC Code:
2491 (Wood Preserving)
Technology
• Sediment transported
through a feed system that
included dewatenng and
mixing
• Incineration system
consisting of rotary kiln and
secondary combustion
chamber (SCC)
• SCC operated between
1,600°Fand1,800°F
• Exhaust gases from SCC
directed through gas
cleaning system
• Residual ash was landfilled,
and an engineered cap was
placed over residual ash and
surface soil
Cleanup Authority:
CERCLA and State
Louisiana
• Phase I ROD signed
August 1985
• Phase II ROD signed
March 1987
• Fund-lead
• ESD Signed February
1990
Point of Contact:
Mark Hansen
U S EPA Region 6
1445 Ross Avenue, Suite
1200
Dallas, TX 75202
(214) 665-7548
Waste Source:
Bayou sediments - creosote
waste
Type/Quantity of Media Treated.
Sediment (169,000 cubic yards)
Contaminated material from waste piles (10,000 cubic yards)
Purpose/Significance of
Application:
Underestimated volume of
contaminated soil by a factor of
three, prompting EPA to
reevaluate remedial plans
Completed 18 months ahead of
schedule
Regulatory Requirements/Cleanup Goals
Destruction and Removal Efficiency (ORE) of 99 99% for all constituents of concern as required
by Resource Conservation and Recovery Act (RCRA) incinerator regulations at 40 CFR part 264,
subpart O
Results:
Monitoring and trial burn data indicate that all ORE and emission standards have been met
26
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Incineration at the Bayou Bonfouca Superfund Site
Slidell, Louisiana
(Continued)
Description
Between 1892 and 1970, the Bayou Bonfouca site operated as a former creosote works facility
During this period, numerous creosote releases occurred In 1970, a fire at the plant released
large amounts of creosote into the environment Sediments in Bayou Bonfouca, an adjacent
navigable waterway, were heavily contaminated with creosote (PAHs)
In August 1985, a Phase 1 Record of Decision (ROD) was signed, specifying excavation and off-
site landfilling of creosote waste piles In March 1987, a Phase II ROD was signed The remedial
actions for the Phase II ROD included the excavation and on-site incineration of sediment and the
contents of surface waste piles with placement of an engineered cap over residual ash and
surface soils During 1988, a detailed design investigation showed that the volume of
contaminated sediment was underestimated by a factor of three The volume increase resulted
in a cost increase and prompted EPA to issue an Explanation of Significant Difference (ESD) in
February 1990
The selected incineration system consisted of a feed system, a rotary kiln, a secondary
combustion chamber (SCC) and a gas cleaning system Sediment was dewatered and then
mixed before being fed to the incinerator During its operation, the incinerator processed
approximately 250,000 tons (169,000 cubic yards) of contaminated sediments and waste pile
material Treatment performance and emissions data collected during this application indicated
that all performance standards and emissions requirements were met
The actual cost for remediation using the incineration system was approximately $110,000,000
27
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Bayou Bonfouca Superfund Site
EXECUTIVE SUMMARY;
This report presents cost and performance data
for the application of on-site incineration at the
Bayou Bonfouca Superfund site in Slidell,
Louisiana A rotary kiln incinerator was
operated from November 1993 through July
1995 as part of a remedial action
Contaminants of concern at the site included
specific polynuclear aromatic hydrocarbons
(PAHs)
The Bayou Bonfouca site was a former creosote
works facility that operated from 1892 until its
closure in 1970 During this period, numerous
creosote releases occurred In 1970, a fire at
the plant released large amounts of creosote
into the environment Sediment at the Bayou
Bonfouca site was contaminated with PAHs
In August 1985, a Phase I Record of Decision
(ROD) was signed, specifying excavation and
off-site landfilling of creosote waste piles In
March 1987, a Phase II ROD was signed The
remedial actions for the Phase II ROD included
the excavation and on-site incineration of
sediment and the contents of surface waste
piles with placement of an engineered cap over
residual ash and surface soils
The matenal specified for excavation and
incineration included approximately 165,000
cubic yards of bayou sediments contaminated
with PAHs in excess of 1,300 mg/kg and 10,000
cubic yards of contaminated material from
waste piles The ROD also specified incinerator
requirements that included a destruction and
removal efficiency (ORE) of 99 99% for each
contaminant of concern
During 1988, a detailed design investigation
showed that the volume of contaminated
sediment was underestimated by a factor of
three The volume increase resulted in a cost
increase and prompted EPA to issue an
Explanation of Significant Difference (ESD) in
February 1990
The ESD divided the Phase II ROD
remedial action into two operable units a
groundwater and a source control operable
unit On-site incineration was a component
of the response for the source control
operable unit
The selected incineration system consisted
of a feed system, a rotary kiln, a secondary
combustion chamber (SCC) and a gas
cleaning system Sediment was dewatered
and then mixed before being fed to the
incinerator
A countercurrent kiln lined with castable
refractory brick was used at the Bayou
Bonfouca site The resulting ash was
discharged from the kiln and quenched
outside of the kiln, while exhaust gases
were channeled to the SCC The SCC
provided additional combustion of organics
in the exhaust gas which was subsequently
quenched with water
The gas cleaning system consisted of a
quench system, a combustion gas
conditioner, a Hydro Sonic® scrubber, and a
vane separator Particulate matter and acid
gasses were removed throughout the gas
cleaning system
During its operation, the incinerator
processed approximately 250,000 tons
(over 170,000 cubic yards) of contaminated
sediments Treatment performance and
emissions data collected during this
application indicated that all performance
standards and emissions requirements were
met
The actual cost for remediation using the
incineration system was approximately
$110,000,000
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
28
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Bayou Bonfouca Superfund Site
SITE INFORMATION
Identifying Information
Bayou Bonfouca Superfund Site
Slidell, Louisiana
CERCLIS # LAD980745632
Phase II ROD Date March 31,1987
Treatment Application
Type of action: Remedial (on-site
incineration)
Period of operation* November 1993 -
July 1995
Quantity of material treated.
approximately 250,000 tons of
contaminated sediments
Background
Historical Activity that Generated
Contamination at the Site: Creosote plant that
treated pilings for use in railway construction
Corresponding SIC Code- 2491 (Wood
Preserving)
Waste Management Practice That
Contributed to Contamination Improper
waste storage and disposal practices
Site History
• The Bayou Bonfouca Superfund site is
characterized by standing water and
saturated surface soil
• The northern section of the site is heavily
wooded and the remainder of the site is
bordered by a drainage ditch, a creek, and
the Bayou Bonfouca
• The site operated as a creosote works
facility from 1892 until it was closed as the
result of a fire in 1970 During this period,
numerous creosote releases occurred,
contaminating the area with PAHs [4] The
fire in 1970 released large amounts of
creosote into the environment
• In 1976, the Coast Guard investigated the
Bayou Bonfouca waterway The creosote in
the bayou sediments was so concentrated
that Coast Guard divers received second-
degree chemical burns and found that the
bayou was biologically sterile The initial
investigation was supplemented in 1978 by
a study conducted by EPA, the Coast
Guard, and the National Oceanic and
Atmospheric Administration The
Remedial Investigation (Rl) and
Feasibility Studies (FS) were completed
in 1987
In 1988, design investigations showed
that the volume of waste was
approximately three times the amount
previously estimated This resulted in a
dramatic increase in cost These two
factors led EPA to divide the remedial
action into two operable units, allowing
remediation of the groundwater
operable unit to continue while further
investigating the source control
operable unit At the same time, EPA
conducted a Value-Engineering (V-E)
study to ensure that the remedy
selected was still the most appropriate
Incineration operations began in
November 1993 when a trial burn was
conducted Incineration was completed
July 1995,18 months ahead of
schedule
Approximately 250,000 tons of
contaminated sediment were
incinerated between November 1993
and July 1995
Remedial actions were funded by EPA
through the Superfund program and by
the state of Louisiana
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
29
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Bayou Bonfouca Superfund Site
SITE INFORMATION (CONT.)
Background (Cont.)
Regulatory Context:
• In September 1983, the Bayou Bonfouca
site was placed on the National Priorities
List (NPL)
• A ROD for Phase I was signed in August
1985, specifying excavation and off-site
landfilhng of creosote waste piles and
contaminated on-site soil, and the disposal
of contaminated water by deep-well
injection at an approved Resource
Conservation and Recovery Act (RCRA)
facility
• A ROD for Phase II was signed in March
1987, specifying excavation and on-site
incineration of sediment from the Bayou
Bonfouca
• EPA issued an ESD in February 1990, as a
result of the discovery of more waste than
estimated by the RI/FS and the subsequent
increase in cost The ESD upheld the
decision to use on-site incineration, but
divided the Phase II remedial action into two
operable units groundwater and source
control
Timeline
• The DREs were set in accordance with
RCRA incinerator regulations in 40 CFR
part 264, subpart O, §264 343
• Site activities were conducted under the
provisions of the Comprehensive
Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), as amended by the
Superfund Amendments and
Reauthonzation Act (SARA) of 1986,
and the National Contingency Plan, 40
CFR 300 [1]
Remedy Selection: On-site rotary kiln
incineration was selected as the remedy for
contaminated sediment at the Bayou
Bonfouca Superfund site based on the site
investigation, feasibility study, Health
Assessment, Technical Assistance
Memoranda for Development of Record of
Decision, and Reports on Public Hearings
Table 1 Timeline [2J
Date
1892-1970
1976
September 1983
August 1985
1987
March 31, 1987
1988
February 1990
November 1993
November 1993-JuIy 1995
Activity r^ 'm& W *& & i
The facility on the Bayou Bonfouca site produced creosote
Coast Guard investigated Bayou Bonfouca waterway
Site was placed on the NPL
Record of Decision for Phase I signed
Remedial Investigation/Feasibility Study completed
Record of Decision for Phase II signed
Design investigations revealed volume of waste material was three times
previous estimates
ESD divided the remedial action into two operable units
Trial burn performed
Rotary kiln incinerator operated
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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Bayou Bonfouca Superfuntf Site
SITE INFORMATION (CoNT.)
Site Logistics/Contacts
Site Management: EPA-Lead
Oversight Louisiana Department of
Environmental Quality (LDEQ)
Remedial Project Manager:
Mark Hansen
U S EPA Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 665-7548
State Contact:
Duane Wilson
Louisiana Department of Environmental
Quality
Inactive and Abandoned Sites Division
7290 Bluebonnet Drive
Baton Rouge, LA 70810
(504) 765-0463
Treatment System Vendor
IT Corporation
312 Directors Drive
Knoxville, TN 37923
(423) 690-3211
MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed
Through the Treatment System: The
primary feed for the incinerator was
dewatered bayou sediment Small amounts
of creosote generated from groundwater
treatment at the site and contaminated soil
also were incinerated
Contaminant Characterization
Primary Contaminant Group Polynuclear
aromatic hydrocarbons (PAHs)
• The contaminants of greatest concern were
benzo(a)pyrene, benzo(a)anthracene,
benzo(b)fluoranthene, benzo(k)-
fluoranthene, mdeno(1,2,3-cd)-pyrene,
and chrysene
The maximum concentration of PAHs
detected at the site was 13,450 mg/kg
Matrix Characteristics Affecting Treatment Cost or Performance
Table 2 presents the matrix characteristics
that most significantly affected cost or
performance at the site and their measured
values
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
31
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Bayou Bonfouca Superfund Site
MATRIX DESCRIPTION (CONT.)
Table 2 Matrix Characteristics
Parameter
Moisture (%)
Ash (%)
Total Chloride (%)
Sulfur (%)
Carbon (%)
Oxygen (%)
Hydrogen (%)
Nitrogen (%)
Bayou Sediments
Maximum
Value
77
810
029
1 24
605
252
814
161
Minimum
Value 1'
17
36
002
004
03
03
001
002
Average >
r*VValue,.^
52
40
007
025
92
68
24
042
-ISSreWoteVfoste^ltelL **fe, **»
Maximum^
ValiftS*
NA
NA
1 42
079
963
1978
456
143
NA
NA
002
004
317
055
064
010
NA
NA
017
024
45
76
24
064
Note NA - Not Available
TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
Rotary kiln incineration, including
• Rotary kiln, and
• Secondary combustion chamber
System Description and Operation
• The rotary kiln incineration system used at
the Bayou Bonfouca site consisted of two
chambers (the kiln itself and a secondary
combustion chamber) and a gas cleaning
system consisting of a quench system, a
combustion gas conditioner, a Hydro Sonic®
scrubber, and a vane separator
• Turbidity curtains, silt curtains, and
absorbent booms were placed along the
bayou prior to dredging The curtains were
manufactured from synthetic materials
which allowed the passage of water but
prevented the flow of soil particles
• Sediments were pumped through an 18-inch
pipeline from the bayou into a water
retention basin Sediment was then moved
to a feed preparation building where it was
Supplemental Treatment Technology
Pre-Treatment (solids) Dewatermg and
mixing
Post-Treatment (air)
• Quench system,
• Combustion Gas Conditioner,
Hydro Sonic® Scrubber, and
• Vane Separator
Post-Treatment (water) Oil water separator
and carbon adsorption
dewatered in a filter press The filter
cakes were mixed to create a
homogeneous matrix Prepared solid
waste was transferred to mass flow
feeders by front-end loaders The waste
was then moved by a transfer conveyor
to a slmger belt conveyor, which fed the
waste into the kiln The transfer
conveyor and slmger belt conveyor
were completely enclosed and under
negative pressure
The countercurrent rotary kiln had a
length of 75 feet, with an inside
diameter of 12 feet and a volume of
8,475 cubic feet The kiln was a carbon
steel chamber lined with 9 inches of
super-duty castable refractory and was
operated in an oxidative mode
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Technology Innovation Office
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Bayou Bonfouca Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
Hot ash from the kiln was discharged to an
ash pan conveyor and then transferred to
the ash cooler where the ash was quenched
A slag removal system was installed in case
slagging occurred The system consisted of
a slag quench chamber, a slag roller
crusher, and a dewatermg slag removal
screw According to site personnel,
slagging was not a problem
Flue gases from the kiln were routed to the
SCC for additional combustion of volatilized
contaminants The SCC operated between
1,600°F and 1,800°F, with an average
oxygen content of 4 to 8 percent The
inside diameter of the SCC was 10 feet, 6
inches, and the minimum off-gas retention
time was 2 seconds
The exhaust gases from the SCC were
directed through a gas cleaning system
First, the gases were channeled through the
quench system to cool the off-gases and
remove particulates and acid gas Flue gas
from the quench system then flowed into the
gas conditioner, where additional paniculate
and acid gas were removed
Gas leaving the gas conditioner entered a
Hydro-Sonic® scrubber where caustic
solution was sprayed into the gas stream
The gas stream entered the vane separator,
where the spray solution from the scrubber
was removed
The incinerator system was equipped
with an emergency relief vent system to
treat off-gases from the kiln during
emergency shutdowns The
Environmentally Safe Temporary
Emergency Relief System® (ESTER®)
received electricity from a battery-
powered unmterruptable power source,
so the off-gases were treated even
during power outages The ESTER
system consisted of a natural gas ring
burner, two continuous gas pilots, and
two natural draft air dampers The
system was designed to be a complete
stand-alone combustion system in
emergency shutdown situations [5]
Combustion gases were drawn through
the kiln system and gas cleaning system
by an induced draft fan, resulting in a
constant negative pressure throughout
the system Gases were exhausted
through a 100-foot stack
Residual ash was required to meet a
goal of 10 mg/kg PAH or less before
land disposal Residual ash was
landfilled on-site, and an engineered
cap was placed over residual ash and
surface soils
Water from the sediment was treated by
sand-bed filters, with oil/water
separation and carbon adsorption The
treated water was discharged into the
bayou
Table 3 Summary of Operating Parameters
>/V \i -* *-<*' ^ Parameter '«,,"-' ",.
Residence Time (Solids)
System Throughput
Kiln Temperature
_„ " : ~ -•*•' '"-" -Value "-r ' \ 'r „,,<
30 - 40 minutes
25 tons/hr
1,200°F
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
33
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Bayou Bonfouca Superfund Site
TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards
The cleanup goals and standards were
specified in the Phase II ROD
• The sediment cleanup level was 1,300
mg/kg of PAHs
• Residual on-site soils containing greater
than 100 mg/kg PAHs and less than 1,000
mg/kg were collected and landfilled on-
site Soils less than 100 mg/kg were left
in place and those greater than 1,000
mg/kg were incinerated All ash had to be
less than 10 mg/kg PAHs before on-site
landfillmg
The required ORE was 99 99% for each
contaminant of concern
The ESD re-evaluated the cleanup levels
presented in the ROD The levels
represented a lifetime increased cancer
risk of less than 1x104 which conformed
to the acceptable health risk criteria
contained in the National Contingency
Plan
Treatment Performance and Compliance
• The trial burn conducted at the Bayou
Bonfouca site was designed to operate the
incineration system at conditions that
reflected worst-case destruction and
removal of all constituents of concern
• Anthracene, naphthalene, and toluene were
selected as the POHCs for the Bayou
Bonfouca site The reported ORE for each
POHC are included in Table 4
The incinerator operated within the
operating limits established during the trial
burn, signifying that all performance
requirements were met Table 5 presents
the AWFCO limits during the operation of
the incinerator Information regarding the
frequency of AWFCOs was not available
AWFCOs occurred occasionally
throughout the project primarily due to
electrical power interruptions from the
regional electric power provider, CLECO
Table 6 presents values for operating
parameters measured during the trial burn
and subsequent operations
Table 4 Average Destruction and Removal Efficiencies from Compliance Testing
Contaminant
Toluene
Naphthalene
<\nthracene
Average Contaminant
Peed Rate In Soil (Ib/hr)
2336
8309
7987
Average Contaminant Rile
Stack Gas Emissions (Ib/hr)
87E-5
2 18E-3
1 99E-3
00004
00068
<0 0804
BfiE ("4 ,
>99 9996
>99 997
>99 998
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
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34
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Bayou Sonfouca Superfuncf Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 5 Automatic Waste Feed Cutoffs [2]
,^^-rTt
Maximum kiln feed rate, 15-mmute rolling average
Maximum instantaneous kiln pressure
Minimum kiln off-gas temperature, 1-hour rolling average
Minimum kiln off-gas temperature, instantaneous
Minimum SCC off-gas temperature, 10-minute rolling average
Minimum SCC off-gas temperature, instantaneous
ESTER® pilot out
Maximum quench outlet gas temperature
Minimum GCS differential pressure, 10-minute rolling average
Maximum stack gas flow, 10-minute rolling average
Maximum stack CO, 1-hour rolling average corrected to 7% O2
Maximum stack gas CO, instantaneous corrected to 7% O2
Maximum stack gas THC, 1-hour rolling average as propane, corrected to 7% O2
Minimum stack gas O, , 1 -minute rolling average
': '' ^ 1| *& HutoJijLhnif *r -^
29 05 tph
-0 02 in w c
1,088°F
1,088°F
1,689°F
1,689°F
400°F
220° F
21 2 in W c
45,580 acfm
100ppm
500 ppm
20ppm
3 % dry volume
Table 6 Operating Parameters [2]
1 'ii *^ *ff -*""" •*"*« >.^ ?*•'••* f .£,«,„_ , ,-;,.-»• N
'• r* -.-i. ' Parameter^*-- ^',,k.^C
Minimum kiln off-gas temperature, instantaneous
Kiln Pressure, 15-mmute rolling average
Minimum SCC off-gas temperature, instantaneous
Maximum stack gas flow, 10-minute rolling average
Maximum kiln feed rate, 15-mmute rolling average
Minimum scrubber change in pressure, 10-minute rolling average
Minimum Hydro-1 Recycle flow rate
Maximum stack gas CO, 60-mmute rolling average, corrected to 7% oxygen
Maximum stack gas THC, 60-mmute rolling average, corrected to 7%
oxygen
Stack gas CO2
Stack gas O2 , 1 -minute rolling average
HCI Emissions
Particulate Matter Concentration
- 9
1,094°F
NA
1,689°F
45,580 acfm
29 05 tph
212
396
100
20
NA
NA
NA
NA
** ifti «ar -* JSu y§
SiTrial BftrnwlBelt
1053°F
-1 49 in w c
1626°F
45,050 acfm
30 79 tph
24 15 in we
396 gpm
2 ppm
15 ppm
9 78% dry volume
10 31% dry volume
0 036 Ib/hr
0 0059 gr/dscf
'Anticipated values from the trial burn report
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
35
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Bayou Bonfouca Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Completeness
• Data are available for concentrations of
contaminants in the incinerator residue
These data were collected at the end of four
separate runs during the trial burn
Performance Data Quality
• The Quality Assurance/Quality Control
(QA/QC) program used throughout the
remedial action met the EPA and the state
of Louisiana requirements
Procurement Process
TREATMENT SYSTEM COST
The prime contractor was a joint venture, IT
Corporation (68%) and O H Materials,
Incorporated (32%)
The estimated total cost for operating the
incinerator at the site was $110,000,000,
with a cost of $72,000,000 for thermal
treatment A total of 179,000 tons of
sediment and waste pile material were
incinerated This corresponds to a total unit
cost of $440 per ton, and a unit cost for
thermal treatment of $288 per ton
Table 7 Costs
WBS Number
331
331
331
331
331
331
331
331
01
01
01
02
02
02
02
03
01
02
03
03
05
06
09
03
Description J&fl^
Mobilization of construction equipment and facilities
Mobilization of personnel
Submittals/implementation plans
Air monitoring and sampling
Sampling surface and groundwater
Sampling soil and sediment
Laboratory chemical analysis
Earthwork (i e , excavating, stockpiling)
Miscellaneous
Total Capital Costs
Annual Operating and Maintenance Cost
Total Operation and Maintenance Costs
i
$21 million
$0 5 million
$2 0 million
$4 million
$0 8 million
$0 5 million
$2 5 million
$20 million
$3 million
$54 million
$18million/yr
$30 million
Cost Data Quality
• Cost data was provided by IT Corporation
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
36
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Bayou Bonfouca Superfund Site
OBSERVATIONS AND LESSONS LEARNED
Cost Observations and Lessons Learned
• EPA chose an innovative approach to pay
for the incineration by paying on the dry-
weight basis of the ash instead of on the
weight of the feed material This helped to
prevent the incineration of unnecessary
moisture by placing the responsibility on the
contractor to optimize the process tram
After incineration of the waste at Bayou
Bonfouca was completed, the incineration
system was used to incinerate waste from
Southern Shipbuilding, a site less than
two miles away According to site
personnel, reusing the system at Bayou
Bonfouca instead of building a new one at
Southern Shipbuilding saved at least $20
million
Other Observations and Lessons Learned
Approximately 96% of the AWFCOs were
due to momentary power glitches partially
attributable an old system of power lines
These were not true power outages, but
the sensitive equipment would register the
glitch as a break in power, resulting in an
AWFCO
Public Involvement
The Bayou Bonfouca site had some
problems with power outages that
occurred during storms To prevent this
from being a problem, wastes were not
fed to the unit during storms
A stack/ID fan silencing system allowed
24-hour operation without disturbing local
residents
A Community Involvement Plan was
developed April 1984 and revised in
August 1985 Twenty open houses and
workshops were held for the public
between 1985 and 1996 Several fact
sheets were mailed to the 318 citizens on
the mailing list
A high level of interest existed in the
community according to site personnel
Nearby residents were generally
supportive of EPA's efforts because they
wanted the source of contamination to be
addressed
REFERENCES
1 Superfund Record of Decision Operable
Unit 1. Bayou Bonfouca, Slidell,
Louisiana, August 1985
2 Superfund Record of Decision Operable
Unit 2. Bayou Bonfouca, Slidell,
Louisiana, March 1987
3 Explanation of Significant Differences.
Bayou Bonfouca, Slidell, Louisiana,
February 1990
4 Public Health Assessment Addendum.
Bayou Bonfouca, Slidell, Louisiana,
December 1993
Bayou Bonfouca Trial Burn Report. IT
Corporation, January 1994
EPA Region VI Superfund Homepage,
lnternet,(http //www epa gov /earth 1 r6/6sf/
b-bonfou pdf) March 24, 1997
Personal communication with Kevin
Smith, IT Corporation, April 3,1997
Personal communication with Mark
Hansen, USEPA, Region 6, June 1997
U S ENVIRONMENTAL PROTECTION AGENCY
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37
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This Page Intentionally Left Blank
38
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On-Site Incineration at the
Bridgeport Refinery and Oil Services Superfund Site
Logan Township, New Jersey
39
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Incineration at the Bridgeport Refinery and
Oil Services Superfund Site
Logan Township, New Jersey
Site Name:
Bridgeport Refinery and Oil
Services Superfund Site
Location:
Logan Township, New Jersey
Contaminants
Polychlormated biphenyls
(PCBs), volatile organic
compounds (VOCs), and metals
benzene
cadmium
methylene chloride
chromium
toluene
barium
acetone
zinc
lead
Period of Operation
December 1991 to January
1996
Cleanup Type
Remedial action
Vendor:
ENSCO, Inc
SIC Code:
NA
Technology
On-site Incineration
• Incineration using direct-
fired rotary kiln
• Screening and mixing of
contaminated sediments
prior to incineration
• Quenching of kiln ash in
water bath
• Treatment of wastewater
from system on-site and
discharge to nearby creek
• Combustion of remaining
VOCs and PCBs in
secondary combustion
chamber (SCC)
Cleanup Authority
CERCLA
• ROD signed 1984
• EPA-lead, managed
by U S Army Corps of
Engineers
Point of Contact
Don Lynch
U S EPA Region 2
290 Broadway
New York, NY 10007-1866
212-637-4419
Waste Source:
Lagoon Sediments-waste oil
storage and reprocessing
operations waste
Type/Quantity of Media Treated
Lagoon sediments and sludges, debris, levee material, lagoon
oil, and soil (172,000 tons)
Purpose/Significance of
Application:
Inadequate design caused
numerous mechanical
problems, incineration
operation suspended twice
because of mechanical
problems, problems with
demulsifymg complicated
dewatermg of sediment
40
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Incineration at the Bridgeport Refinery and
Oil Services Superfund Site
Logan Township, New Jersey
(Continued)
Regulatory Requirements/Cleanup Goals
• Destruction and Removal Efficiency (ORE) of 99 99% for VOCs as required by Resource
Conservation and Recovery Act (RCRA) incinerator regulations in 40 CFR Part 264, Subpart O,
The ORE of 99 9999% for RGBs and ash residual as required by Toxic Substances Control Act
(TSCA) regulations in 40 CFR Part 761
Results:
• Emissions and trial burn data indicate that all ORE and emission standards have been met
Description:
Between the 1960s and continuing through 1981, an on-site lagoon was used for disposal of
wastes from waste oil reprocessing operations conducted on site Lagoon sediment was
contammatecTwith PCBs at concentrations greater than 500 mg/kg, as well as VOCs and metals
In 1984, EPA signed a Record of Decision (ROD) specifying on-site incineration as the selected
remedy for the sludge, sediment, soil, debris, and lagoon oil at the site Remedial actions were
managed by the U S Army Corps of Engineers (COE) under the oversight of EPA Region II
The material to be incinerated was excavated from the lagoon, and screened and mixed before
incineration The material was then conveyed into a rotary kiln by a screw auger The
incineration system also included a secondary combustion chamber (SCC) to provide further
destruction of any VOCs and PCBs Kiln ash was quenched in a water bath Wastewater from
the incinerator was treated in an on-site wastewater treatment system and discharged to a nearby
creek Exhaust gas from the kiln was directed to an air pollution control system (APCS) The
APCS consisted of a cyclone separator for removal of larger particulates, a secondary
combustion chamber (SCC) for destruction of any remaining VOCs and PCBs
During its 50 months of operation, the incinerator processed over 172,000 tons of sediment,
sludge, debris, oil, and soils Treatment performance and emissions data collected during this
remedial action indicated that all performance standards and emissions requirements were
achieved
The actual cost for remediation using the incineration system was approximately $187,000,000
(includes costs associated with treatment of lagoon water and removal of tank farm)
41
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Bridgeport Refinery and Oil Service Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site incineration at the
Bndgeport Rental and Oil Services Superfund
Site (Bridgeport site) in Logan Township, New
Jersey A rotary kiln incinerator operated at the
Bridgeport site from December 1991 through
January 1996 as part of a remedial action
Beginning in the 1960s and continuing through
1981, an on-site lagoon was used for disposal of
wastes from waste oil reprocessing operations
conducted on site Lagoon sediment was
contaminated with RGBs at concentrations
greater than 500 mg/kg, as well as VOCs and
metals
Because responsible parties could not be
identified quickly enough to adequately address
threats to human health and the environment
posed by the site, EPA initiated remedial actions
at the site In 1984, EPA signed a Record of
Decision (ROD) specifying on-site incineration
as the selected remedy for the sludge,
sediment, soil, debris, and lagoon oil at the
Bridgeport site Performance standards for the
incineration included a destruction and removal
efficiency (ORE) of 99 9999% for PCBs and
99 99% for VOCs [2]
Remedial actions were managed by the U S
Army Corps of Engineers (COE) under the
oversight of EPA Region II The material to be
incinerated was excavated from the lagoon, and
screened and mixed before incineration The
matenal was then conveyed into a rotary kiln by
a screw auger
The incineration system also included a
secondary combustion chamber (SCC) to
provide further destruction of any VOCs and
PCBs Kiln ash was quenched in a water bath
Wastewater from the incinerator was treated in
an on-site wastewater treatment system and
discharged to a nearby creek
Exhaust gas from the kiln was directed to an
air pollution control system (APCS) The
APCS consisted of a cyclone separator for
removal of larger particulates, a waste heat
recovery boiler to reduce the temperature of
the SCC exit gas, a ventun quench to
further cool the gas stream, start the gas
absorption process, and remove some of
the entrained solids, a packed tower for
additional scrubbing, and an educator
scrubber for removal of acid fumes Dust
removed by the cyclone separator was
discharged to the kiln ash quench
During its 50 months of operation, the
incinerator processed over 172,000 tons of
sediment, sludge, debris, oil, and soils
Treatment performance and emissions data
collected during this remedial action
indicated that all performance standards
and emissions requirements were achieved
Detailed cost information was not available
for on-site incineration at the Bridgeport site
The actual cost for remediation at the site
was approximately $187 million This figure
includes costs associated with treatment of
lagoon water and removal of the tank farm
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
42
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Bridgeport Refinery and Oil Service Superfuntf Site
identifying Information
Bridgeport Rental and Oil Superfund Site
Logan Township, New Jersey
CERCLISt NJD053292652
ROD Date December 31,1984
SITE INFORMATION
Background
Historical Activity that Generated
Contamination at the Site. Waste oil storage
and reprocessing
Corresponding SIC Code: NA
Waste Management Practice That
Contributed to Contamination- Waste
disposal in an on-site lagoon
Site History
• The Bridgeport site occupies a 30-acre
parcel of land which includes a 13-acre
waste oil and wastewater lagoon, and a tank
farm consisting of 90 tanks and process
vessels
The lagoon was used for the disposal of
wastes from on-site waste oil reprocessing
and storage performed on site from the
1960s through 1981 The tank farm was
used for waste oil storage and recovery
• The lagoon depth reached 21 feet in some
areas, with the bottom 13 feet in contact
with groundwater The volume of
contaminants disposed of in the lagoon is
not known,
Treatment Application
Type of action Remedial (on-site rotary
kiln incineration)
Period of operation
1991-January 1996
December
Quantity of material treated during
application 172,000 tons, including
138,350 tons of lagoon sediment and
sludge, 13,000 tons of debris, 12,550 tons of
levee material, 3,850 tons of lagoon oil, and
4,250 tons of soil
In the early 1970s, the eastern dike of
the lagoon was breached, contaminating
3 acres of land with waste oils The
remedial action that is the subject of this
report did not include soil from this
3-acre area
In the spring of 1981 the liquid level
began to rise in the lagoon and
threatened to overflow the dike for the
lagoon The U S Coast Guard
increased the height of the dike by 5
feet
In the spring of 1982 and again in the
spring of 1983 the liquid level in the
lagoon rose and liquids threatened to
overflow the lagoon's dike During
those two periods, EPA initiated
emergency response actions at the site
These actions consisted of reducing the
level of liquids in the lagoon by pumping
the aqueous phase through a mobile
activated carbon system and
discharging the treated water to a
nearby stream under a National
Pollutant Discharge Elimination System
(NPDES) Permit The lagoon level was
reduced by approximately 2 feet in each
instance
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
43
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Bridgeport Refinery and Oil Service Superfund Site
SITE INFORMATION (CoNhr.)
Background (Cont)
• In late 1983 and early 1984, under an initial
removal action at the site, EPA reduced the
level of liquids in the lagoon by 8 feet by
pumping the aqueous phase through a
treatment system consisting of oil/water
separation, flocculation/sedimentation, sand
filtration, and granular activated carbon
adsorption
• A Phase I Remedial Investigation/Feasibility
Study (RI/FS) was completed by EPA in 1984
to determine the nature and extent of soil
contamination caused by operations related
to the lagoon and tank farm and to evaluate
remedial alternatives for these two areas of
contamination A Phase II RI/FS was initiated
in September 1988 to determine the extent of
groundwater contamination and to evaluate
remedial alternatives for the groundwater and
any remaining hazards posed by the site
Work to date has been performed by EPA,
however, due to negotiations between EPA
and the Potentially Responsible Parties
(PRPs), work on the Phase II RI/FS has been
suspended
• Based on the results of the Phase I RI/FS, a
ROD was signed on December 31,1984
specifying remediation through excavation
and on-site incineration of contaminated
sludge, sediment, soil, debris, and oil from
the lagoon and tank farm The ROD
specified that contaminated areas would be
excavated until the material removed was no
longer visibly contaminated with oil, followed
by additional sampling to determine the need
for additional excavation to meet cleanup
goals
• A trial burn was conducted in March and April
of 1991, which demonstrated that the on-site
incinerator could meet the performance
requirements specified in the ROD
• The incineration took place from
December 1991 through January 1996
Contaminated material treated by
incineration at the Bridgeport site
included sludge and sediments from the
lagoon, the oil on the surface of the
lagoon, lagoon levee material, drums
and debris excavated from the lagoon,
and soil surrounding the lagoon
Regulatory Context.
• In 1983 the Bridgeport site was placed
on the National Priorities List (NPL)
• Because responsible parties could not
be identified before a response was
necessary to protect human health and
the environment, no cooperative
agreements for remedial actions at the
Bridgeport site were reached for the
early actions
• The ROD signed in 1984 mandated that
the lagoon sediments and sludge be
removed until there was no evidence of
oil staining in soils below the sludge
layer
The selected remedy is consistent with
the Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), the Superfund
Amendments and Reauthonzation Act
of 1986 (SARA) and the National
Contingency Plan (NCP) in 40 CFR part
300
Remedy Selection EPA determined that
on-site incineration was technically feasible,
reliable, and provided adequate protection
on human health and the environment
EPA also determined that on-site
incineration was the lowest cost alternative
that provided a solution to the problems and
potential problems posed by the Bridgeport
site [4]
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
44
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Bridgeport Refinery and Oil Service Superfund Site
SITE INFORMATION (CONT.)
Table 1 Timeline
'" , VH '.^ X. *"?< "' lfc\~** *• "^< ' " ^-'^ »K
v «y>' wi -j->> iJuate;st is-w;,^
1960-1981
1981
1982
1983
1983
1983-1984
1983-1984
December 31, 1984
March-April 1991
November 1991
January 1 996
September 1996
*f ,^^i- &fevi&^ ^^ If *.«:££ J«
Lagoon used for waste disposal at the Bridgeport site
U S Coast Guard emergency response increases height of lagoon dike 5 feet
EPA emergency response reduces lagoon liquid level 2 feet
Site placed on NPL
EPA emergency response reduces lagoon liquid level 2 feet
EPA initial remedial action reduces lagoon liquid level 8 feet
EPA performs Phase I RI/FS
Record of Decision signed
Trial Burn
Excavation and incineration operations begin
Incineration operations completed
Site restoration and demobilization activities completed
Site Logistics/Contacts
Site Management: EPA-lead
Mark Wheeler
U S Army Corps of Engineers
609-241-1673
Oversight EPA Region 2
Remedial Project Manager.
Don Lynch
US EPA Region 2
290 Broadway
New York, NY 10007-1866
212-637-4419
Treatment System Vendor:
ENSCO, Inc
Address NA
NA
MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System: Lagoon sediments and
sludges, debris, levee material, lagoon oil, and
soil
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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Bridgeport Refinery and Oil Service Superfund Site
MATRIX DESCRIPTION (Cokr.)
Contaminant Characterization
Primary Contaminant Groups: Material
incinerated at the Bridgeport Site was
contaminated with PCBs, VOCs, and metals
• The contaminants of greatest concern were
PCBs, benzene, methylene chloride,
toluene, acetone, lead, cadmium,
chromium, barium, and zinc
Lagoon sediment contained PCBs at
concentrations over 500 mg/kg, VOCs
including benzene, methylene chloride,
and toluene at concentrations up to 1
mg/kg, and acetone at levels up to 70
mg/kg In addition, metals, including
lead, cadmium, chromium, barium, and
zinc were found at the site
Matrix Characteristics Affecting Treatment Costs or Performance
Information on matrix characteristics such as
soil density, particle size, and soil moisture
content was not available
TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
ENSCO Modular Waste Processor (MWP)-2001
Rotary kiln Incineration System, including
• Waste feed handling system
• Rotary kiin incinerator
• Secondary combustion chamber
Supplemental Treatment Technology
Pretreatment (solids)
• Screening
• Mixing
Post Treatment (air)
Cyclone separator
Ventun quench
Packed tower scrubber
Educator scrubber
Demister
Stack
Post Treatment (water)
• pH adjustment and clarification
(scrubber wastewater)
• Oil/water separation, flocculation,
sedimentation, sand filtration, and
activated carbon adsorption (quench
wastewater)
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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Bridgeport Refinery and Oil Service Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation
Soils and lagoon material lying above the
groundwater table at the Bridgeport Site
were excavated using backhoes and
bulldozers Lagoon sludge that was not
mixed with debris was excavated using a
barge- mounted hydraulic dredge Sludge
that contained too much debris to be
effectively excavated by the dredge was
removed by large land-based cranes and an
amphibious excavator
Debris was separated from excavated
material using a vibrating bar screen
Larger pieces of debris and unshreddable
debris were removed and disposed of off-
site The remaining debris were shredded
and incinerated
To provide a homogenous feed, matenal
was mixed prior to incineration in ponds
constructed on-site for this purpose
Material to be incinerated entered the rotary
kiln at the flame end via screw auger,
sludge lance, or ram feeder, then traveled
through the kiln concurrent with the
combustion gas In the direct-fired rotary
kiln, the PCBs and VOCs were volatilized
and destroyed Ash and exhaust gas were
discharged from the kiln
Kiln ash was quenched in a water bath and
then sent through a filter press Ash was
analyzed for heavy metals, a select list of
organic compounds, and total PCBs Ash
that exhibited a characteristic of a
hazardous waste for organic compounds or
that contained greater than 2 mg/kg PCBs
was incinerated a second time Ash that
exhibited a characteristic of a hazardous
waste for metals was stabilized to remove
the characteristic Approximately 64,000
tons of ash were stabilized All ash that met
the treatment criteria, including ash that was
retreated or stabilized, was then backfilled
into the excavated lagoon
The rotary kiln had an inside diameter
of 8 5 feet, an outside diameter of 10
feet, and a combustion chamber volume
of 4,103 cubic feet The kiln was limited
to a throughput rate of 24 tons of
contaminated material per hour
The kiln was designed to heat feed
material to 1,200 to 1,400°F and
combustion gas to 1,400 to 1,600°F
The kiln was heated by two 30 million
BTU/hr Lmde "A" burners fired with pure
oxygen and fuel, and was designed to
rotate at a rate of 1 to 2 rpm The
design residence time for solids in the
kiln was 40 to 80 minutes
The off-gas from the kiln then was
routed to the SCC, which provided
further destruction of remaining
contaminants The SCC was 103 feet
long and had an internal diameter of 6 5
feet The SCC was equipped with a 30
million BTU/hr Lmde "A" burner fired by
an oxygen/fuel mixture The SCC was
designed to operate at a minimum
temperature of 2,012° F and provide a
minimum residence time of 2 seconds
Off-gas from the SCC passed through a
duct equipped with a water spray header
and a fire-tube boiler to reduce the
exhaust gas temperature to
approximately 500-700°F
Off-gas from the SCC was directed to a
cyclone separator for removal of larger
particulates Particulate matter
extracted from the exhaust gas fell to
the bottom of the cyclone and was
transported to the kiln ash quench bath
The off-gas was then passed to a
venturi quench where water was
sprayed into the gas stream to reduce
the temperature to less than 190°F
The off-gas continued to the packed
tower
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
47
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Bridgeport Refinery and Oil Service Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
escription and Oeration Cont
The packed tower removed any remaining
particulate matter The packed tower was
72 inches in diameter with space for as
much as 1 0 feet of packing The packing
was continuously wetted by a water spray
Off-gas exited the packed tower to the inlet
of an induced draft fan The induced draft
fan provided a negative pressure throughout
the system to prevent fugitive emissions
From there the off-gas passed through a
Hydrosonic® educator scrubber, a demister,
and a stack The educator was designed to
remove additional acid fumes while the
demister was designed to remove water
vapor from the gas Off-gas exited the
stack with a temperature of 180 to 200° F
and at a flow rate of 20,000 to 37,000 acfm
Scrubber water streams were
recirculated through a sump which
provided pH adjustment and
clarification During the remedial action
at the Bridgeport Site, sump bottoms
and quench solids were filter pressed
and used as lagoon backfill on site
Quench water from the incinerator was
treated in an on-site wastewater
treatment system and discharged to a
nearby creek
TREATMENT SYSTEM PERFORMANCE
.Cleanup Goals/Standards
• The cleanup goals and standards were
specified in three documents the ROD, the
contract plans and specifications, and an
incinerator "Permit Equivalency" document
• The ORE and ash residual management
standards for VOCs and metals were based
on RCRA regulations (40 CFR § 264 343 for
the DREs and 40 CFR § 261 24 for ash
residuals) The DRE standards for PCBs
were based on regulations issued under the
Toxic Substances Control Act (TSCA) (40
CFR part 761)
• The ROD required that the lagoon
sediments and sludge be removed until no
oily soils were observed beneath the sludge
layer The ROD did not specify numerical
limits for remedial action at the site, but
required that sampling and analysis would
be conducted once visibly contaminated
material was removed The sampling
results were to be reviewed by EPA to
determine whether removal of additional
material was required
The DRE requirements for the
incinerator were set at 99 9999% for
PCBs and 99 99% for VOCs
For VOCs and metals, ash was subject
to the Toxicity Characteristic Leaching
Procedure (TCLP) test The maximum
permissible concentration of PCBs in
the residual ash was set at 2 mg/kg
The maximum permissible
concentrations of metals were the
applicable regulatory threshold
concentrations in 40 CFR § 261 24
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
48
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Bridgeport Refinery and Oil Service Super-fund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Treatment Performance and Compliance
• The trial burn at the Bridgeport site,
conducted from March 12 through April 7,
1991, was designed to operate the
incineration system at conditions that would
reflect worst-case destruction and removal
of all constituents of concern
• The POHCs selected for the trial burn were
carbon tetrachlonde and
monochlorobenzene, which acted as
surrogates for the VOCs found at the site
• Soil excavated in the tank farm area and
clean fill material from off-site were used as
incinerator feed in the trial burn Known
quantities of PCBs (in tnchlorobenzene),
POHCs (carbon tetrachlonde and
monochlorobenzene), and a metals slurry
(arsenic trioxide, calcium oxide, and a
potassium dichromate) were spiked into the
incinerator feed During the trial burn,
concentrations of spiked contaminants in
the waste feed and stack gas were
measured These data were used in
conjunction with flow rate data to calculate a
ORE for each of the spiked contaminants
The reported DRE for each of the spiked
contaminants are included in Table 2 The
DREs for the constituents of concern are
assumed to be greater than those of the
spiked contaminants
During the trial burn DREs exceeded
99 9999% for PCBs and 99 99% for
monochlorobenzene and carbon
tetrachlonde Metals removal
percentages were in excess of 99% [3]
AWFCO limits used during operation of
the incinerator are shown in Table 4,
information on the frequency of
AWFCOs was not available Trial burn
and typical operating parameters are
shown in Table 5
The incinerator at Bridgeport operated
within the operating limits established
during the trial burn, signifying that all
cleanup requirements established in the
ROD were met
The residual ash was tested by TCLP to
see if it was in compliance with the on-
site land disposal requirements Data
from the TCLP analyses were not
available Approximately 8,800 tons of
ash were incinerated a second time
because it failed to meet the PCB
concentration requirement of less than 2
mg/L Approximately 64,000 tons of
ash were stabilized because they failed
the TCLP test for heavy metals
Table 2 Average Destruction and Removal Efficiencies and Removal Percentages from
Trial Burn Compliance Testing [1]
: y •£ ¥' ~7 *
"\ ,,* v- £- ^x •;
^~ Contaminant «*
Concentrations In *
Asfcfcte/LK *
<0 0001
<10
NA
<0012
<0005
0041
*"' ' ' <"•* ."" - , ,:'
<* " i*» '*"" rir v""
£ ^ 3jf . S$r -, v»
'", DRE(%)S /
>99 99997
>99 99989
>99 99998
>9992
9968
9999
aThis represents a removal percentage only and not a true DRE
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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Bridgeport Refinery and Oil Service Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 3 Automatic Waste Feed Cutoffs [2]
J'jii' ,:'„ ","•; ,;'! I;; ' Parameter , | , , „ ' ,„<
SCO Temperature
Kltn Exit Temperature - No Flame
Kiln Exit Temperature - With Flame
Kiln Exit Draft
CO in Stack - 1 hour average
CO In Stack - 10 minute average
Oxygen in Stack
Steam Drum Level
Loss of Power
Loss of Induced Draft Fan
Loss of Water Flow To Quench Nozzle
" jf;x * v* "'casruwK £r -^ & ~?~.
<2,066deg F
Not applicable
<1,200,>1,580deg F
>-0 1 in w c
>100ppmv
>500 ppmv
<3 5%
<25%
Not applicable
Not applicable
Not applicable
N/A- Not Available
Table 4 Operating Parameters [2]
I Paramefer
Contaminated Soil Feed Rate
Secondary Combustion Chamber Temperature
Secondary Combustion Chamber Residence Time
Kiln Exit Temperature
Arsenic in Feed
Cadmium In Feed
Chromium in Feed
Lead in Feed
Mercury in Feed
Nickel In Feed
Beryllium In Feed
^cumgrue f£fc.
<21, 800,000 grams/hr
>2066deg F
>2 seconds
>1580deg F
10mg/kg
10mg/kg
130 mg/kg
1 0,000 mg/kg
1 mg/kg
40 mg/kg
1 mg/kg
Maximum Allowable Emission Rate
P articulate
Sulfur Dioxide
Nitrogen Oxide
CO
Hydrocarbon
Arsenic
Beryllium
Chromium
Lead
Mercury
Nickel
PCBs
HCI
2,600 grams/hr
4,900 grams/hr
11, 400 grams/hr
4,500 grams/hr
1,400 grams/hr
3 3 grams/hr
1 6 grams/hr
2 6 grams/hr
522 grams/hr
10 9 grams/hr
3 9 grams/hr
0 0045 grams/hr
1 ,800 grams/hr
.*?' ' Trial Burft'V J|e ""I
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
332 grams/hr
227 grams/hr
NA
NA
NA
<0 14 grams/hr
<0 3 grams/hr
0 2 grams/hr
1 6 grams/hr
015 grams/hr
0 31 grams/hr
<0 0082 grams/hr
35 grams/hr
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
50
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Bridgeport Refinery and Oil Service Superfund Site
OBSERVATIONS AND LESSONS LEARNED (CONT.)
Table 4 Operating Parameters [2]
?Jfli;-;- IS
Dioxins and Furans
Benzene
Carbon Tetrachlonde
Chloroform
Ethylene Dichlonde
1 ,1 ,2,2-Chloroethane
Tetrachloroethylene
1 ,1 ,2-Trichloroethane
Trichloroethylene
Dioxane
Ethylene Amine
Ethylene Dibromide
•jCt-fr ^..,\ »^*.v r- ^pjip^Slj; _ '8£|£si5 '; = s
*& ^v^^^m^^ v»
0 000045 grams/hr
109grams/hr
4 5 grams/hr
1 4 grams/hr
0 14 grams/hr
0 0045 grams/hr
3 6 grams/hr
0 045 grams/hr
0 91 grams/hr
0 045 grams/hr
0 045 grams/hr
0 045 grams/hr
•$
NA
NA
0049
NA
NA
NA
NA
NA
NA
NA
NA
NA
TREATMENT SYSTEM COST
No information was available on the costs of on-site incineration at the Bridgeport site
OBSERVATIONS AND LESSONS LEARNED
Observations and Lessons Learned
Significant difficulty was encountered
excavating material from below the water
table because of debris and structural
instability of soils at the lagoon bottom
Large cranes with excavating buckets and
an amphibious excavator were employed in
addition to the barge-mounted, hydraulic
dredge originally planned
• Passage of heavy equipment over the site
resulted in an oily material rising from
underground up to the surface Where this
oily material surfaced, approximately 230
cubic yards of soil were excavated and
incinerated The resulting holes were
backfilled with clean material from an
off-site source
The sediment excavated from the
lagoon could not be dewatered as
originally anticipated The sediment
was an emulsified mixture of soil, water,
and oil, and was difficult to demulsify
Sedimentation in ponds, flocculation
with polymers, screening, and
centrifugation were all attempted but did
not show satisfactory separation of
water In addition, the properties of the
sludge varied significantly Ponds
initially constructed for dewatermg of
sludge were used to mix the sludge to
achieve some homogenization prior to
incineration
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
51
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Bridgeport Refinery and Oil Service Superfund Site
OBSERVATIONS AND LESSONS LEARNED (CONT.)
Debns in the sediment caused problems
and delays and made excavation of material
more difficult than anticipated Intact
drums, large and unshreddable pieces of
debris, and a large amount of municipal
solid waste discovered during excavation of
the lagoon were disposed off site In
addition, special handling was required of
some intact drums that were found to
contain sulfunc acid
The incinerator experienced a number of
mechanical difficulties, including jams in the
feed auger, jams in the incinerator ash
auger, failure of the ash removal system at
the ash quench, overpressunzation of the
kiln, induced draft fan failures, loss of boiler
water, slag build-up in the kiln and
secondary combustion chamber, and
excursions outside permitted operating
parameters These problems resulted
in reduced performance and down time
On one occasion, a release of ash to
the atmosphere occurred when a slide
gate became disengaged from the
cyclone
Incineration was suspended in order to
conduct repairs from February to April
1995 and again from July to August
1995
REFERENCES
1. ENSCO MWP-2001. Trial Burn Report.
March 12 through April 7.1991 ENSCO,
Inc. July 18,1991
2 Operable Unit Remedial Action Report.
Laaoon and Protect Site Cleanup.
Bridgeport Rental and Oil Services Site
U S EPA Region II Undated
3. Remedial Action Update. Bridgeport Rental
and Oil Services U S EPA Region II
Februarys, 1996
Superfund Record of Decision.
Bridgeport Rental and Oil Services
Site, Logan Township, New Jersey,
December 31, 1984
USEPA National Priorities List.
Bridgeport Rental and Oil Services
Fact Sheet US EPA, August 1996
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
52
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On-Site Incineration at the
Celanese Corporation Shelby Fiber Operations Superfund Site
Shelby, North Carolina
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
53
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Incineration at the Celanese Superf und Site
Shelby, North Carolina
Site Name:
Celanese Superfund Site
Location:
Shelby, North Carolina
Contaminants
Ethylene glycol, volatile organic
compounds, metals,
polynuclear aromatic
hydrocarbons, and phenol
• Trichloroethylene, benzene,
phenols, lead, chromium, and
antimony
• Maximum concentrations of
ethylene glycol (12,000
mg/kg) antimony (3,000
mg/kg), lead (2,041 mg/kg)
and chromium (40 mg/kg)
Period of Operation
April 1991 to December
1991
Cleanup Type
Remedial action
Vendor:
Terry Elmaggar
GDC Engmeenng, Inc
822 Neosho Avenue
Baton Rouge, LA 70802
(504) 383-8556
SIC Code:
2824 (Manufacturing manmade
organic fibers)
Technology:
On-Site Incineration
• Solids pretreated with
screening and mixing with
sawdust
• Incineration system consisting
of rotary kiln and secondary
combustion chamber (SCC)
• Soil residence time of 45
minutes, kiln temperature of
1,500°F, SCC temperature of
1,900°F
• Treated soil and sludge
(incineration ash) discharged
into a wet ash collection
system
Cleanup Authority
CERCLA and State North
Carolina
• ROD Date 3/28/89
• PRP-Lead
Point of Contact
McKenzie Mallary
U S EPA Region 4
Atlanta Federal Center
100 Alabama Street
Atlanta, GA 30303-3104
(404) 562-8802
Waste Source:
Disposal of waste sludges
Purpose/Significance of
Application:
Lowest volume incinerated for
all of the case studies
Type/Quantity of Media Treated
Sludge and Soil
• 4,660 tons of sludge and soil
• Moisture content sludge - 25%
Regulatory Requirements/Cleanup Goals
• Destruction and Removal Efficiency (ORE) of 99 99% for each constituent of concern as
required by Resource Conservation and Recovery Act (RCRA) incinerator regulations in 40
CFR part 264, subpart O
Results:
• Emissions and trial burn data indicate that all ORE and emission standards were met
» Analytical data of residuals indicate that cleanup goals were met
U S ENVIRONMENTAL PROTECTION AGENCY
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Technology Innovation Office
54
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Incineration at the Celanese Superfund Site
Shelby, North Carolina
(Continued)
Description
The site began operation in April 1960 and is still operating Between 1960 and the early 1980s,
plant wastes from the production of polyester raw-material were disposed of in burn pits and
sludge was buried in trenches Between 1970 and 1978, drums of waste chemicals and solvents
were stored on site A site investigation was conducted in 1981 A Record of Decision (ROD),
signed in March 1989, specified on-site incineration as the remediation technology for the
excavated sludge and soil Site cleanup goals and ORE standards of 99 99% for constituents of
concern were specified in the ROD
On-site incineration began in April 1991 During its period of operation, the incinerator processed
4,660 tons of sludge and soil The treatment system consisted of a rotary kiln and an SCC An
enclosed conveyor moved the soil and debris to the kiln for treatment Treated ash from the
incinerator was discharged to a wet ash collection system The system used an air pollution
control system that consisted of a baghouse and a packed-bed scrubber Incineration achieved
the soil cleanup goals specified in the ROD
The total cost of the remedial action was approximately $5,800,000, including $3,925,000 in
capital costs and $1,875,000 m operation and maintenance costs
U S ENVIRONMENTAL PROTECTION AGENCY
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Technology Innovation Office
55
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Celanese Corporation Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site incineration at the
Celanese Corporation Shelby Fiber Operations
(Celanese) Superfund site in Shelby, North
Carolina A rotary kiln incinerator was operated
from April 1991 through December 1991 as part
of a remedial action Contaminants of concern
at the site were trichloroethyiene (TCE),
benzene, phenols, polynuclear aromatic
hydrocarbons (PAHs), lead, chromium, ethylene
giycol, and antimony
The Celanese site is a polyester raw-material
production facility that began operation in April
1960 Between 1960 and the early 1980s,
various wastes were stored and disposed of on-
site in unlmed pits and trenches In March
1988, a Record of Decision (ROD) for Operable
Unit 1 (OU-1) was signed that required
treatment of contaminated groundwater
In March 1989, a ROD for OU-2 was signed
The remedial actions for OU-2 included the
excavation and incineration of Giycoi Recovery
Unit (GRU) sludges and associated soil; and the
excavation, solidification, and disposal of plastic
chips, burn pit residuals, and stream sediments
The remainder of this report will address the
incineration specified in OU-2, unless otherwise
stated
The ROD specified the excavation and
incineration of approximately 1,500 cubic yards
of GRU sludge plus an additional foot of soil
below the sludge/soil interface The ROD also
specified incinerator requirements that included
a destruction and removal efficiency (ORE) of
99 99% for each constituent of concern
The selected incineration system consisted of a
feed system, a rotary kiln, a secondary
combustion chamber (SCC) and an air pollution
control system (APCS) [2]
Before entering the feed system, waste
sludge and soil were mixed with sawdust to
facilitate materials handling The mixture
passed through a separator to remove any
pieces of metal, then was conveyed to a
weigh hopper, and finally to the kiln
The kiln used at the Celanese site was lined
with refractory brick The rotary kiln
volatilized and partially destroyed organic
compounds from the contaminated material
Ash generated in the incinerator was
collected in a wet ash collection system and
conveyed out of the system for solidification
and disposal, while exhaust gases were
drawn into the SCC The SCC provided
further combustion of organics in the off-
gases which were then quenched with
water
The APCS consisted of a baghouse and a
packed-bed scrubber Particulate removal
occurred in the baghouse, and gas polishing
and acid neutralization occurred in the
scrubber
During the nine months of operation, the
incinerator processed 4,660 tons of GRU
sludge and associated soil [2] During
excavation, several drums containing a tar-
like substance were found The drum
contents also were incinerated Treatment
performance and emissions data collected
during this application indicated that all
performance standards and emissions
requirements were met
The actual cost for remediation using the
incineration system was approximately
$5,800,000, consisting of $3,925,000 in
capital costs and $1,875,000 in operation
and maintenance costs
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
56
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Ce/anese Corporation Superfunof Site
SITE INFORMATION
Identifying Information
Celanese Corporation Shelby Fiber Operations
Superfund Site, Shelby, North Carolina
CERCLIS # NCD003446721
OU-2 ROD Date- March 28, 1989
Background
Historical Activity that Generated
Contamination at the Site: Manufacturing of
polyester polymer resin and filament yarn
Corresponding SIC Code: 2824 (Organic
Fibers)
Waste Management Practice That
Contributed to Contamination Storage and
land disposal of wastes generated from the
manufacturing process
Site History
The Celanese Corporation Superfund site is
located on the 469-acre property of an
operating polyester raw-material production
facility in south central Cleveland County
The site began operation in April 1960
• Between 1960 and the early 1980s, plant
wastes were disposed of in burn pits and
GRU sludge was buried in trenches
Between 1970 and 1978, drums of waste
chemicals and solvents were stored on site
• The primary contaminants of concern in the
soil and sludges were ethylene glycol,
volatile organic compounds (VOCs)
including TCE and benzene, phenols, PAHs,
and metals including lead, chromium, and
antimony
Treatment Application
Type of action- Remedial (on-site
incineration)
Period of incinerator operation April
1991 - December 1991
Quantity of material treated during
application 4,660 tons of GRU sludge and
associated soil incinerated
A site investigation was conducted in
1981 and a Remedial Investigation (Rl)
was completed in June 1986 A
Feasibility Study (FS) for OU-1 was
completed in February 1988, and the
FS for OU-2 was completed in April
1989
Remedial action related to the GRU
sludge and associated soil (waste)
began in January 1991 when the
responsible party (RP) began
excavating the waste Beginning in
April 1991, a rotary kiln incinerator was
used to remediate the excavated waste
A period of optimization was followed by
a mini-burn and then a trial burn The
mini-burn was conducted in April 1991
to provide enough data for tentative
approval from EPA The trial burn was
conducted in June 1991
Approximately 4,660 tons of waste were
processed between April 1991 and
December 1991 By August of 1992, all
remediation activities for OU-2 were
complete
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
57
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Celanese Corporation Superfund Site
SITE INFORMATION (CONT[)
Background (Cont)
Regulatory Context:
• In June 1986, the Celanese Corporation
site was placed on the National Priorities
List (NPL)
• A ROD was signed in March 1989,
specifying a remedial action that included
excavation and on-site incineration to
reduce the concentration of chemical
contaminants at the site Ground water
remediation was addressed by OU-1, and
source remediation was addressed by
OU-2
• The selected remedy was conducted
under the provisions of the
Comprehensive Environmental Response,
Compensation,
and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments
and Reauthonzation Act (SARA) of 1986
and the National Oil and Hazardous
Substances Contingency Plan in 40 CFR
part 300 [1]
• The DREs were set in accordance with
Resource Conservation and Recovery Act
(RCRA) incinerator regulations in 40 CFR
part 264, subpart O
Remedy Selection: On-site rotary kiln
incineration was selected as the remedy for
contaminated soil and sludge at the Celanese
Superfund site based on the results of the
RI/FS and long-term economic considerations
Timeline
Table 1 Timeline [21
\* , Date,
Apnl 1960 - Ongoing
1981
June 1986
June 1986 - Apnl 1989
March 28, 1989
April 1991
June 1991
January 1991 - March 1992
April 1991 - December
1991
March 1992 - August 1992
^ ,._^£^ ,^ ,"' '&**•
The facility on the Celanese site is in operation
Initial site investigation
Site placed on the NPL
Remedial Investigation/Feasibility Study
Record of Decision for OU-2 signed
Mini Burn
Trial Burn
GRU sludge and soil are excavated for incineration and/or solidification
Rotary kiln incinerator operational
Decontamination and demobilization of the incinerator
Site Logistics/Contacts
Site Management: RP-Lead
Oversight: EPA
Remedial Project Manager
McKenzie Mallary
US EPA Region 4
Atlanta Federal Center
100 Alabama Street, S W
Atlanta, GA 30303-3104
(404) 562-8802
Treatment System Vendor
Terry Elmaggar
GDC Engineering, Inc
822 Neosho Avenue
Baton Rouge, LA 70802
(504) 383-8556
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
58
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Celanese Corporation Superfund Site
MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed
Through the Treatment System
• GRU sludges and associated soil were
excavated Metal was removed, solidified
and disposed on site The sludge and soil
were mixed with sawdust prior to
incineration
Contaminant Characterization
Primary Contaminant Groups: Ethylene
glycol, VOCs, metals, PAHs, and phenol
• The contaminants of greatest concern were
VOCs (including TCE and benzene),
phenols, PAHs, lead, chromium, and
antimony
• Waste feed samples were collected and the
concentrations of ethylene glycol and total
antimony were measured The average
concentration of ethylene glycol was
1,740 mg/kg with a range of 43 to
12,000 mg/kg The average
concentration of antimony was 694
mg/kg with a range of 190 to 3,000
mg/kg [2] The maximum GRU sludge
concentrations for lead and chromium
were 53 mg/kg and 40 mg/kg,
respectively The maximum
concentration of lead in the soil was
2,041 mg/kg
Matrix Characteristics Affecting Treatment Cost or Performance
The major matrix characteristics that most significantly affected cost or performance at the site and
their measured values are presented in Table 2
Table 2 Matrix Characteristics
'.^ '**Ctf:' -v? f?aramet«e ^ ';: - T±
Sludge Classification
Sludge Moisture Content
Average Upper Heating Value of Sludge
^ ^-- T^j £< -$hie ^ ^ ff ';; "£.;•*{',
Mixture of semi-viscous sludge and dry, hard material
25%
5,400 BTU/lb
TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
Rotary kiln incineration including
• Rotary kiln,
• Secondary combustion chamber, and
• Quench duct
Supplemental Treatment Technology
Pretreatment (solids) Mixed with sawdust
and screened
Air pollution control system including
• Baghouse, and
Packed bed scrubber system
Post-Treatment (water) Neutralization
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
59
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Celanese Corporation Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation
• The rotary kiln incineration system
employed at the Celanese site consisted of
two chambers (the kiln itself and a
secondary combustion chamber) and an air
pollution control system consisting of a
baghouse and a packed-bed scrubber
system
• Overburden material at the site (those
matenals not collected for incineration
and/or solidification) were removed and
stockpiled The GRU sludges and soil were
mixed with sawdust in a pugmill to facilitate
material handling The waste feed was
screened before being fed to the rotary kiln
by a feed screw
• The kiln had a length of 45 feet and an inner
diameter of 6Vz feet The kiln was lined with
refractory bnck rotating on a slight incline (2
degrees)
- The kiln was rated at 20 MBTU/hr The kiln
rotated at a maximum rate of 0 98
revolutions per minute
• Residual ash from the kiln was collected in
a wet ash collection system and was
solidified with 15 to 20 percent Portland
cement and then used for backfill
Flue gases from the kiln were routed to
the SCC for additional combustion of
volatilized contaminants The SCC
operated at approximately 1,900°F and
an average percent oxygen between 4
and 8 percent
The exhaust gas from the SCC was
channeled through the quench duct and
then to the system's baghouse The
design operating condition exit
temperature for the baghouse was
approximately 350° F
Combustion gases were drawn through
the kiln system and baghouse by an
induced draft fan (resulting in a constant
negative pressure throughout the
system) and were exhausted through a
69-foot reinforced concrete stack
Typical stack gas velocity was between
1,143 and 1,750 feet per second and
the typical stack exit temperature was
below 180°F
Scrubber water effluent was treated by
an on-site neutralization system
Table 3 Summary of Operating Parameters
II"1'1 " » i "" " >» •> Parameter ' J*^
Residence Time
System Throughput
Kiln Temperature
~~ '%&".*&*' J?**"
45 minutes
2 3 tons/hour
1,500°F
Cleanup Goals/Standards
The required ORE was 99 99% for each
constituent of concern
The OU-2 ROD originally established a
remedial action that included excavation
and incineration of approximately 1,500
cubic yards of GRU sludge plus an
additional foot of soil below the sludge/soil
interface Other wastes and sediments
excavated on site were to be solidified
and disposed of on site
Waste was excavated to the visual
sludge/soil interface and an attempt was
made to excavate to an additional one
foot below the sludge/soil interface [2]
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
60
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Ce/anese Corporation Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
• Due to the hardness of the clay and
bedrock beneath the GRU sludge, the
removal of an additional one foot of soil
was not always possible
• Sampling was not performed in the
excavated pits because the intent of the
remediation was not to provide
cleanclosure The groundwater treatment
system was expected to treat any
remaining contaminants [2]
Treatment Performance and Compliance
Residual ash was solidified and disposed
of on site The maximum allowable
ethylene glycol concentration for all
material
A trial burn conducted at the Celanese
Corporation site was designed to operate
the incineration system at conditions that
would reflect worst-case destruction and
removal of all constituents of concern
Tetrachloroethene was selected as the
POHC for the Celanese Corporation site
Naphthalene was initially chosen as the
POHC, but problems occurred with cross
contamination The calculated ORE for
tetrachloroethene is shown in Table 4
The incinerator operated within the
operating limits established during the trial
burn, signifying that all cleanup
requirements were met The limits
established for the AWFCOs are shown in
Table 5 Information on the frequency of
AWFCOs was not available Trial burn
and typical operating parameters are
shown in Table 6
The residual ash was sampled and
analyzed for ethylene glycol and toxicity
characteristic leaching procedure metals
Workers were required to maintain level D
protection through the remedial action
Table 4 Average Destruction and Removal Efficiencies from Compliance Testing
ant
Average Cor^arriin
Werage Contaminant
in $taek Gas Emissions
"" '
Tetrachloroethene
8,163
00415
NA
99 9995
Table 5 Automatic Waste Feed Cutoffs {21
It- -J """ ,.;i-;-.,x
Minimum Secondary Combustion Chamber Oxygen
Maximum CO (rolling average)
Minimum Primary Combustion Chamber Temperature
Minimum Secondary Combustion Chamber Temperature
Minimum Scrubber pH
Maximum System Draft
Minimum Baghouse Differential Pressure *
Minimum Stack Velocity
sit f8*^ O $5»8fti«S &. * ^:n r? '•'"
3 0% O2
SOppm
1430°F
1840°F
65
-0 1 inch in w c
4 0 inch H2O
1750 feet/mm
we = Water column
* Note Limit for baghouse differential pressure not activated until 6 hours after incinerator start-up
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
61
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Celanese Corporation Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
Table 6 Operating Parameters 121
| ' < Parameter
Contaminated Soil Feed Rate
Primary Combustion Chamber Temperature
Secondary Combustion Chamber Temperature
Averags percent oxygen in secondary chamber
Kiln draft average
Baghouse pressure drop average
CO emissions
Percent oxygen In stack
Percent carbon dioxide average
Scrubber pH
2 5 tons/hr
1,487°F
1,880°F
5 07%
-0 17 in we
4 76 in w c
NA
NA
NA
92
?%&%,, ... %%? i^i^ii^g^
BorwJtfaius^liil
immT ^» lliP?
2 5 tons/hr
1,500°F
1,850°F
4 3% to 7 8%
-0 19to-02l in we
275to724inwc
0 5 ppm to 3 4 ppm
11 7% to 130%
4 8% to 6 8%
3 7 to 101
we = Water column
•Proposed operating parameters based on the results of the trial bum
Performance Data Available
• Verification sampling was not performed on
excavated pits because clean closure was
not the intent of the remediation for OU-2
[2]
• Initial contaminant concentrations are
included in the RI/FS and the Treatabihty
Study Investigation
For each day the incinerator was
operating, one incinerator ash sample
was analyzed for total ethylene glycol
Excluding mini-burn and trial burn
samples, 137 samples were taken Of
the 137 samples taken, only three
samples had ethylene glycol
concentrations above the detection limit
of 10 mg/kg The concentrations of
those samples were 31, 47, and 10
mg/kg [2]
Performance Data Quality
• The Quality Assurance/Quality Control
(QA/QC) program used throughout the
remedial action met the EPA and the State
of North Carolina requirements All QA
auditing and monitoring were performed by
SEC Donohue and RP personnel [2]
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
62
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Celanese Corporation Superfund Site
TREATMENT SYSTEM COST
Procurement Process
• The RP contracted with SEC Donohue to
develop the remedial design and oversee
the remedial work The RP also retained
GDC Engineering, Inc to conduct the
remedial work
Cost Data
The cost of incineration at the Celanese
Corporation site was reported as
$5,300,000 The capital costs for the
incineration system were $3,425,000 and
operations and maintenance (thermal
treatment) costs totaled $1,875,000 A
total of 4,660 tons of soil and sludge were
incinerated This corresponds to a total
unit cost of $1,000 per ton, and a unit cost
for thermal treatment of $410 per ton
Table 7 Capital Costs [6]
331
331
331
331
331
331
331
331
331
01
01
01
02
02
02
02
03
03
01
02
03
03
05
06
09
03
05
,?•".. /r^" .V ^-~ -f
Mobilization of construction equipment and facilities
Mobilization of personnel
Submittals/implementation plans
Air monitonng and sampling
Sampling surface and groundwater
Sampling soil and sediment
Laboratory chemical analysis
Earthwork (i e , excavating, stock piling)
Fencing
Incineration equipment
Trial bum
Set up/construct temporary facilities
Total Capital Costs
;'* ;'f %Cos*£'4<> -''
$100,000
$50,000
$250,000
$300,000
$500,000
$25,000
$2,000,000
$100,000
$100,000
$3,425,000
Table 8 Operation and Maintenance Costs [6]
•^'/-
342
14
T* J- ™^&,t&MeS& *" .?, •' ";; •
i •*?»§&• •* , , , «•?«.•"• ^-as«' ^ s f#*>£> •— * f
Thermal treatment
• Labor
• Direct operating cost
• Permitting
• Overhead
Total Operation and Maintenance Costs
-- ,-- ^ Cost, >*_ , ^
$750,000
$750,000
$25,000
$350,000
$1,875,000
Cost Data Quality
• Cost data was provided by Hoechst Celanese
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
63
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Celanese Corporation Superfund Site
OBSERVATIONS AND LESSONS;|_EARNED
Cost Observations and Lessons Learned
• In relation to off-site incineration, on-site
incineration is most economical with large
volumes of waste Because the amount
incinerated at Celanese was comparatively
not very large, off-site incineration would
have been more economical
Other Observations and Lessons Learned
• The initial estimate of 1,500 cubic yards of
GRU sludge and 500 cubic yards of soil was
exceeded The treatment performance data
indicate that the incinerator processed 4,549
tons of sludge, 111 tons of soil, and 1,200
tons of sawdust [2]
Initially, clay in the waste feed was collecting
on the walls of the kiln resulting in a reduction
in throughput This was remedied by mixing
the waste with sawdust and optimizing the
waste feed rate
• Initially, problems occurred with naphthalene,
the first POHC, cross contaminating the
blanks In response, naphthalene was
replaced with tetrachloroethene
Public Involvement
Weekly field reports identified difficulty
with the feed screw as the cause of
many AWFCOs Other AWFCOs were
caused by loss of burner flame in the
kiln and SCC caused by a faulty relay,
weigh cells around the line hopper
failing to operate properly, and quench
nozzles breaking The actual number
of AWFCOs was not included in these
reports
Citizens of the Earl/Shelby area expressed
interest in the remediation of the Celanese
Corporation site The group, The United
Neighbors for cleanup at Earl, was formed
because of concerns about the quality of
water in their area
At public meetings conducted by EPA,
the community favored remedial action,
but few citizens expressed a preference
for a particular process [1]
REFERENCES
1 Superfund Record of Decision Operable Unit
2, Celanese Corporation Shelby Fiber
Operations, Shelby, North Carolina, March
1989
2. Remedial Action Report Operable Unit 2
Remedial Action. Celanese Shelby Fiber
Operations Superfund Site. SEC Donohue,
June 1993
3 Personal communication with Susan
Schrader, Tetra Tech EM, Inc , Denver,
August?, 1997
4 Personal communication with Terry
Elmaggar, GDC engineering, July 16,
1997
5 Trial Burn Report Operable Unit 2
Hoechst Celanese. Westmghouse
Environmental and Geotechnical
Services, Inc , August 30,1991
6 Personal communication with Jeff
Randolph Hoechst Celanese, June
1997
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
64
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On-Site Incineration at the
Coal Creek Superfund Site
Chehalis, Washington
65
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Incineration at the Coal Creek Superf und Site
Chehalis, Washington
Site Name:
Coal Creek Superfund Site
Location:
Chehahs, Washington
Contaminants:
Polychlormated biphenyls and
lead Also other metals,
including
lead
copper
barium
mercury
cadmium
zinc
Period of Operation
January 1994 to May 1994
Cleanup Type
Remedial action
Vendor:
Matthew Beatty
Roy F Weston, Inc
1 Weston Way
West Chester, PA 19380-1499
610-692-3030
SIC Code:
4953 (Refuse Systems)
Technology
On-Site Incineration
• Soil screened prior to being
fed to incinerator
• Incineration system
consisting of a rotary kiln
and a secondary
combustion chamber (SCC)
• SCC system temperature of
2,100 °F, gas from SCC
cooled by water sprays
before being sent through
air pollution control system
• Process water was treated
by carbon filtration system
then discharged on-site
Cleanup Authority:
CERCLA
• ROD signed October
1990
• Consent Decree entered
1992
• RP-lead with EPA
oversight
Point of Contact
Bob Kievit
US EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101
360-753-9014
Waste Source:
Disposal areas - oil containing
PCBs
Type/Quantity of Media Treated
Soil (9,715 tons)
Purpose/Significance of
Application:
Because of previous
performance, and because it
had a TSCA permit, the
incinerator was allowed to
demonstrate ORE compliance
without spiking
Regulatory Requirements/Cleanup Goals:
• Destruction and Removal Efficiency (ORE) of 99 9999% for PCBs as required by Toxic
Substances Control Act (TSCA) regulations in 40 CFR part 761
66
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Incineration at the Coal Creek Superfund Site
Chehalis, Washington
(Continued)
Results:
• Emissions and performance data indicated that all ORE and emission standards were met
Description:
Between 1949 and 1983, the Coal Creek site was used for scrapping, salvaging, and repairing
electrical equipment During this time, oil containing PCBs was drained on to the ground
In October 1990, a Record of Decision (ROD) was signed, specifying excavation and on-site
incineration of soil with greater than 50 mg/kg PCBs In 1992, the responsible parties (RP)
entered into a Consent Decree with EPA, agreeing to implement the remedial action described by
the ROD
Remedial Action began in January 1994 The incineration system consisted of a feed system, a
rotary kiln, a secondary combustion chamber (SCC), and an air pollution control system (APCS)
The soil was screened before being fed to the incinerator Over a 5-month period, the incinerator
processed approximately 9,700 tons of soil Treatment performance and emissions data
collected during this application indicated that all performance standards and emissions
requirements were met
The actual cost for remediation using the incineration system was approximately $8,100,000
67
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Coal Creek Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site incineration at the
Coal Creek Superfund Site in Chehalis,
Washington A rotary kiln incinerator was
operated from January 1994 to May 1994 as
part of a remedial action Contaminants of
concern at the site included polychlormated
biphenyls (PCB) and lead
The Coal Creek site was used for scrapping,
salvaging, and repairing electrical equipment
from 1949 to 1983 During this time, oil
containing PCBs was drained on to the ground
Concentrations of PCBs were measured as high
as 21,000 mg/kg at the site
In October 1990, a Record of Decision (ROD)
was signed, specifying excavation and on-site
incineration of soil with greater than 50 mg/kg
PCBs The ROD also required a destruction
and removal efficiency (ORE) of 99 9999% for
the incineration In 1992, the responsible
parties (RP) entered into a Consent Decree with
EPA, agreeing to implement the remedial action
descnbed by the ROD
The incineration system consisted of a feed
system, a rotary kiln, a secondary combustion
chamber (SCC), and an air pollution control
system (APCS) The soil was screened before
being fed to the incinerator
In the rotary kiln, organic compounds from
the contaminated soil were volatilized and
destroyed The resulting ash was
discharged from the kiln and quenched
outside of the kiln, while exhaust gases
were routed to the SCC The SCC provided
further combustion of PCBs in the off-gas,
which was then quenched with water
The APCS consisted of a baghouse and a
scrubber, which removed particulate and
acid gas, respectively
Over a 5-month period, the incinerator
processed approximately 9,700 tons of soil
Treatment performance and emissions data
collected during this application indicated
that all performance standards and
emissions requirements were met
The actual cost for remediation using the
incineration system was approximately
$8,100,000
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
68
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Coal Creek Superfund Site
SITE INFORMATION
Identifying Information
Coal Creek Superfund Site
Chehalis, Washington
CERCLIS # WAD980726061
ROD Date- October 17,1990
Background
Historical Activity that Generated
Contamination at the Site Scrapping,
salvaging, and repairing electrical equipment
Corresponding SIC Code: 4953 (Refuse
Systems)
Waste Management Practice That
Contributed to Contamination- Improper
storage and disposal of waste
Site History
• The site is approximately one mile north of
Chehalis and covers approximately 8 acres
in the Coal Creek Valley The site is bound
by Coal Creek to the south and west
Wetlands are present on the western portion
of the site
• The first documented use of the site was in
1935 when it was occupied by a coal-fired
electrical generating plant From 1949 to
1983, the site was used for scrapping,
salvaging, and repairing electrical
equipment, including electrical transformers
» One prominent feature in the northeast
corner of the site was a mound of fill
material, which covered one-fourth of the
site The mound was comprised of two to
eight feet of fill material including soil, ash,
coal, and mixed debris from transformer
scrapping operations A one-to-two-foot-
thick sand and gravel cover was placed
over the fill as a working surface for vehicle
access during facility operation
Treatment Application
Type of action Remedial (on-site rotary
kiln incineration)
Period of operation: January 1994 - May
1994
Quantity of material treated during
application: 9,715 tons of soil
A drainage ditch extended from the fill
mound through the wetland area and
discharged to Coal Creek
Oil containing polychlormated biphenyls
(PCB) from electrical transformers was
drained on site during the salvage
operation
The ROD estimated that 8,300 cubic
yards of soil contains PCBs at
concentrations greater than 50 mg/kg
Beginning in 1979, EPA and the
Washington State Department of
Ecology conducted various inspections
and sampling and analysis of soil and
groundwater at the site In 1983 and
1984, at the request of the state,
potentially responsible parties (PRP)
stabilized the site by covering portions
of the fill mound with plastic, damming
the drainage ditch, installing ground
water monitoring wells, and securing the
site
A remedial investigation and feasibility
study (RI/FS) was performed in 1988
Remedial action took place in two
phases Phase I, which began in
February 1993, included the demolition
of a two-story concrete building and
foundation, asbestos abatement,
demolition of the site drainage system,
disposal of resulting debris, and
removal and decontamination of
underground storage tanks
Phase II began in August 1993 It
included excavation and incineration of
U S ENVIRONMENTAL PROTECTION AGENCY
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Coal Creek Superfund Site
SITE INFORMATION (CONT.)
contaminated soil, construction of a containment
cell, disposal of debris, and wetland restoration
• The erection of the incinerator and
excavation of soil for incineration were
completed in December 1993 The
performance test burn and incineration
under interim standards began in January
1994
The incineration system processed
approximately 9,700 tons of soil and
debris in the four months that it
operated Incineration was completed
in May 1994
Background
• Various RPs entered into a consent decree
with EPA in February 1988 EPA and the
settling defendants entered into a Major
Consent Decree effective February 1992
under which the settling defendants agreed
to design and implement the remedial
action described in the ROD
• The ROD was signed in October 1990,
specifying excavation of soil with greater
than 1 mg/kg PCBs, incineration of the soil
with greater than 50 mg/kg, and on-site
containment of the ash with the soil
containing 1 to 50 mg/kg PCBs
Regulatory Context:
Remedy Selection The remedial actions
selected were the only response actions planned
for the site They were intended to address the
principal threats posed by PCBs and other
contaminants
The site activities were conducted under
provisions of the Comprehensive
Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), as amended by the
Superfund Amendments and
Reauthonzation Act of 1986 (SARA),
and the National Contingency Plan
(NCP) in 40 CFR part 300
The DREs were set in accordance with
the Toxic Substance Control Act
(TSCA) regulations in 40 CFR part 761
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Coal Creek Superfuncf Site
SITE INFORMATION (CONT.)
Table 1 Timeline
Early 1900s -1983
1979
February 1988
1989
October 1990
August 1993 - December 1993
January 1994
January 1994 -May 1994
October 1994
November 1994
Ol" -> -•r,-,, ,V ifJ-A--' Activity/ l'~ '**?"'' £7*TJ^ " i~ -;
Operations performed at the Coal Creek Site
Initial site investigation
Various RPs enter into a Consent Decree to cleanup the site
Remedial Investigation/Feasibility Study
ROD is signed
Contaminated soil is excavated
Performance test bum conducted
Rotary kiln incinerator operational
Containment cell cap seeding and wetland seeding
Final site inspection
Site Logistics/Contacts
Site Management RP-lead
Oversight- EPA
Remedial Project Manager
Bob Kievit
US EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(360) 753-9014
Treatment System Vendor:
Matthew Beatty
Roy F Weston, Inc
1 Weston Way
West Chester, PA 19380-1499
(610) 692-3030
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Coal Creek Superfund Site
MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System- Contaminated soil from
the mound area
Contaminant Characterization
Primary Contaminant Groups: PCBs and
metals
• The contaminants of greatest concern were
PCBs and lead Other metals such as
copper, barium, mercury, cadmium, and
zinc were also present in soil at the site
The maximum concentration of PCBs in
the soil was 21,000 mg/kg Elevated
concentrations of copper (31,000
mg/kg), lead (3,800 mg/kg), barium
(1,200 mg/kg), mercury (20 mg/kg),
cadmium (9 mg/kg), and zinc (5,300
mg/kg) also were detected in the soil
Matrix Characteristics Affecting Treatment Costs or Performance
• Information on matrix characteristics such
as soil classification, moisture content, and
soil density was not available
TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
Incineration system including
• Rotary kiln, and
• Secondary combustion chamber (SCC)
Supplemental Treatment Technology
Pretreatment (solids) Screened and mixed
Post-Treatment (air)
• Baghouse, and
• Scrubber
Post-Treatment (water) Carbon adsorption
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Coal Creek Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation
• Approximately 28,000 tons of granular fill
was placed at the site to provide a working
surface around the incineration equipment,
and also to meet the requirement that the
incinerator be located outside of the 100-
year floodplam
• The site was excavated using a CAT 235
and a CAT 966 loader Excavated soil was
divided into two stockpiles soil with PCB
concentrations between 1 and 50 mg/kg,
and soil with PCB Concentrations greater
than 50 mg/kg A track loader and three
wide-track bulldozers were also used when
soil at the site was wet
Debris was screened from the soil At times
the soil was too wet and cohesive to allow
debris to be removed by conventional
screening operations Large debris was
hand-picked out, corn cob pellets were
mixed with soil to absorb moisture, and then
the soil was screened When corn cob
pellets were not available, wood chips were
used
• After feed preparation, the waste was
loaded into a feed hopper Screw
conveyors fed the material to the rotary kiln
• The incineration system consisted of two
chambers (the kiln itself and the SCC) and
an air pollution control system, consisting of
a baghouse and a scrubber
• The rotary kiln was 25 feet long and 7 5 feet
in diameter The maximum rotational speed
was 1 2 rpm with a minimum soil residence
time of 30 minutes The burner was rated at
33 million BTU per hour
• Ash was discharged from the kiln and
immersed in water for quenching The ash
and excavated soil containing 1 to 50 mg/kg
PCBs were disposed of in waste cells on
site
Exhaust gas from the kiln was
discharged to the SCC and heated to a
minimum temperature of 2,100°F for at
least 2 seconds The SCC was
vertically oriented to avoid slag buildup
Gas from the SCC was cooled to 450° F
using water sprays before being sent
through the air pollution control system
(APCS) Both the kiln and the SCC
were supplemented with oxygen
Exhaust gas from the SCC was
channeled to the baghouse for
particulate removal
The baghouse was rated for a gram
loading of treated exhaust gases of less
than or equal to 0 02 grains per dry
standard cubic foot (dscf) To prevent
acid condensation in the baghouse, the
unit was insulated and heat traced
Special high-temperature, acid-resistant
coatings also were applied to all interior
metal surfaces to prevent corrosion
The gas was then routed to the scrubber
system where caustic solutions were
used for neutralization The gas was
first quenched to its adiabatic saturation
temperature before entering the
fiberglass reinforced polyester scrubber
The quenched flue gases passed
through the horizontal-flow packed
tower, and finally, through a mist
eliminator prior to discharge to the
stack
Process water was treated by a carbon
adsorption system then discharged on
site
Combustion gases were drawn through
the kiln system and baghouse by an
induced draft fan (resulting in a constant
negative pressure throughout the
system) and were exhausted through a
50-foot stack Typical flue gas velocity
was 58 feet per second, and the typical
stack exit temperature was 187°F
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Coal Creek Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
Operating Parameters Affecting Treatment Cost or Performance
Table 2 Summary of Operating Parameters
pi |n IH 1 1 1 1 1 II l ' -- ^sSi ^"-
j, _ Pnwieter w*.
Retention Tima
System Throughput
Kiln Temperature
^ ,^%,^iivl&*' ~''A <• -,
30 minutes
20,000 Ibs/hr
1, 700° F to 2,000° F
TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards
Cleanup goals and standards were specified in
the ROD
• Soil with a concentration of PCBs greater
than 50 mg/kg was incinerated
• Residual ash with a concentration of PCBs
greater than 50 mg/kg was re-incinerated
until incineration operations were
discontinued, then ash with those
concentrations of PCBs was disposed of off-
site at a TSCA-approved landfill Ash with
concentrations less than 50 mg/kg PCB and
less than 500 mg/kg lead were backfilled
into an on-site waste containment cell with
no additional treatment Ash with greater
than 500 mg/kg of lead was stabilized with
Portland cement prior to backfilling
• The ROD required treatment standards that
corresponded with a 1 x 10s excess lifetime
cancer risk level
The ROD specified a 99 9999% ORE
The incineration system at Coal Creek
had a history of acceptable performance
and had demonstrated a ORE of greater
than 99 9999% in nine previous
performance tests In addition, the
concentration of PCBs was so low a trial
burn would have required spiking in
order to demonstrate compliance For
these reasons, EPA did not require a
trial burn In lieu of a trial burn, ORE
calculations for PCBs were performed
during operation of the system EPA
agreed to take into account the
limitations on data evaluation (analytical
and statistical confidence levels) posed
by the low concentrations of PCBs in
the feed soil A performance burn was
conducted to demonstrate that the
incinerator could meet the minimum
requirements
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Coal Creek Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Treatment Performance and Compliance
« An extensive sampling program was
implemented during the performance burn
which included collecting and analyzing
samples from feed soil, treated soil, spray
tower fly ash, fabric filter fly ash, scrubber
blowdown, and stack gases EPA
determined that the unit was capable of
meeting the incineration requirements and
approved full-scale operation Operating
conditions were based on the operating
limits developed during the performance
burn
• The AWFCOs could be triggered by
incinerator monitors or the CEMs The
AWFCOs limits are shown in Table 4
Information about the frequency of
AWFCOs was not available Values for trial
burn operating parameters are shown in
Table 5, information about actual values for
these parameters was not available The
incinerator at Coal Creek operated within
the operating limits established during the
performance burn, signifying that all
cleanup requirements established in the
ROD were met
• The residual ash was analyzed for PCBs,
2,3,7,8-tetrachlorodibenzo-p-dioxm(TCDD),
and for metals using the Toxicity
Characteristic Leaching Procedure (TCLP)
Samples for TCDD equivalents were
analyzed during the performance test The
results of this analysis demonstrated that
the performance criteria would be met by
the incinerator, and TCDD testing was not
required after the performance test
• Final disposal was determined based on
analysis of PCBs and metals Ash with
greater than 50 mg/kg PCBs was
reprocessed through the treatment system
Ash that was below 50 mg/kg PCBs and 500
mg/kg lead was placed in on-site waste
containment cell without additional
treatment Ash that contained more than
500 mg/kg lead was stabilized by mixing
with Portland cement prior to being
backfilled in the waste cell
An ambient air monitoring program was
implemented at the site to document
ambient air quality before, during, and
after remedial activities The
monitoring program was designed to
identify the most likely airborne
migration directions and to collect data
usmgreal-time particulate monitors and
time-integrated ambient air sampling
methods Nine air monitoring stations
were set up around the perimeter of the
site The stations collected samples to
determine airborne concentrations of
PCBs, mhalable particulate matter of 10
microns diameter or less (PM10), and
PM10 lead
Action levels were developed for
airborne concentrations of PCBs (0 95
ug/m3), PM10 (75 ug/m3), and PM10-lead
(0 75 ug/m3) Exceedance of the action
levels required implementation of dust
suppression techniques Weekly air
monitoring reports were prepared by
Weston during major excavation,
incineration, and backfilling operations
The airborne concentrations of PCBs
and PM10 lead were below site-specific
action levels during the Phase II
remedial action activities The action
level for PM10 was exceeded on one
occasion The cause of this
exceedance was thought to be
backfilling operations Additional dust
control measures (e g , use of sprayers,
ceasing backfilling operations on windy
days) were instituted after the elevated
level was recorded The action level
was not exceeded for the remainder of
the remedial action
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Coal Creek Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 3 Average Destruction and Removal Efficiencies from Compliance Testing
"rii"1,,' '»
Contaminant
Average Contaminant
Feed Rate In Soli (Ib/hr)
Average Contaminant Rate In
Stack Gas Emissions (Ib/hr)
PCS
453
2 66x10"6
NA
99 99994
Table 4 Automatic Waste Feed Cutoffs
|,i Parameter
Maximum waste feed rate
Maximum kiln temperature
Minimum kiln temperature
Maximum SCO temperature
Maximum baghouse inlet temperature
SCO retention time
Burner in kiln or SCO
Maximum Baghouse pressure drop
Minimum combustion efficiency
Maximum carbon monoxide
Maximum shield pressure
Emergency damper
Minimum scrubber pH
Minimum scrubber pack pressure drop
Minimum scrubber Inlet flow
Minimum SCO excess oxygen
Maximum stack flow rate
^ '" . ' ''r*>
5 1 tons/hr
2,000°F
1,700°F
2,100°F
450°F
2 seconds
flameout
18 inches water gauge
99 9%
100ppm
-000
open
66
2 inches water gauge
158 gallons/minute
3%
1 6,500 acfm
Table 5 Operating Parameters
j'ii '»i'''; ' " ' ' i «"' Parameter .. '"*"'
Kiln temperature
Waste feed rate
Baghouse Inlet temperature
Baghouse differential pressure
Scrubber blowdown turbidity
Scrubber pH
Stack flow rate
Scrubber Inlet flow
HCI stack emissions
Partlculate stack emissions
CO (hourly rolling average)
*- ^ ssi^> ' Trial Bdf^KfX^Sl^' ga.' f-'
1,718°F
5 1 tons/hr
411°F
2 73 inches w c
NA
667
15,074 acfm
160gpm
<0 0227 Ibs/hr
<0 00061 Ogr/dscf
nondetect
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Coal Creek SuperfuncT Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Available
Data are available for concentrations of
contaminants in the sediment before
treatment
Performance Data Quality
• An independent quality assurance team,
CH2M Hill, was tasked to ensure that the
remediation complied with the
performance standards The Quality
Assurance/Quality Control program used
throughout the remedial action was
deemed to have met the EPA and the
state of Washington requirements
Data are also available for
concentrations of contaminants in the
incinerator residue These data were
collected periodically throughout
operation of the incinerator before on-
site disposal
TREATMENT SYSTEM COST
Procurement Process
• Roy F Weston, Inc , was the remedial
contractor for Phase II, which included the
incineration
Cost Data
• The total cost was approximately
$8,100,000 A total of 9,715 tons of soil
were incinerated This corresponds to a
total unit cost of $830 per ton A detailed
breakdown of those costs was not
available
The total cost provided here is an
estimate reported in the Remedial Action
Report
OBSERVATIONS AND LESSONS LEARNED
Observations and Lessons Learned
• Before excavation began, structures on
site were torn down and removed During
this process, PCB contaminated soil was
disturbed and contamination was spread
Public Involvement
• No written comments were received
during the 60 day public comment period
on the proposed plan, but support for a
permanent and immediate solution was
voiced during public meetings The
community response to the incineration
was generally supportive
U S ENVIRONMENTAL PROTECTION AGENCY
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Coal Creek Superfund Site
REFERENCES
1 Superfund Record of Decision. Coal
Creek, Chehahs, Washington, October
1990
2. Mini-Burn #1 Test Result, Coal Creek,
January 1994
3. Memorandum from Catherine Massimmo,
Senior RCRA/Superfund, to Loren
McPhiilips, Coal Creek RPM, February
1994
Addendum 4 - Risk Assessment
Addendum, Coal Creek, February 1994
Coal Creek Remedial Action Report.
CH2M Hill and Roy F Weston, Inc ,
December 1994
U S ENVIRONMENTAL PROTECTION AGENCY
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On-Site Incineration at the
FMC Corporation - Yakima Pit Superfund Site
Yakima, Washington
79
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Incineration at the FMC Corporation - Yakima Pit Superfund
Site Yakima, Washington
Site Name:
FMC Corporation - Yakima Pit
Superfund Site
Location:
Yakima, Washington
Contaminants
• ODD, DDE, DDT, dieldrin,
endosulfan, ethion,
malathion, parathion,
cadmium, chromium, and
zinc
• ODD concentrations of 76
mg/kg, DDE concentration of
210mg/kg, and DDT
concentrations of 210 mg/kg
• The maximum concentrations
of contaminants (mg/kg)
detected in soil were ODD
(76), DDE (28), DDT (210),
dieldrin (40), endosulfan
(7,000), ethion (180),
malathion (170,000),
parathion (3,300), cadmium
(6), chromium (320), and zinc
(1,020)
Period of Operation.
January 1993 - May 1993
Cleanup Type:
Remedial action
Vendor:
VESTA Technology Ltd
1670 West McNab Road
Ft Lauderdale, FL 33309
SIC Code:
2879 (Pesticides and
Agricultural Chemicals)
Technology
On Site Incineration
• Solids crushed and mixed
with soil
• Incineration system
consisting of co-concurrent
rotary kiln and secondary
combustion chamber (SCC)
• Enclosed twin screw
conveyor transported soil and
debris to the unit
• Soil had a through part rate
of 60 kg/mm with kiln
temperature of 650 °C, the
SCC temperature of 1,107
°C
• Ash discharged onto
conveyers, sampled and
analyzed, and then landfilled
Cleanup Authority.
CERCLA
• ROD Date 9/14/90
• EPA-lead
Point of Contact
Lee Marshall
US EPA Region 10
1200 Sixth Avenue
Seattle, Washington 98101
(206) 553-2723
80
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Incineration at the FMC Corporation - Yakima Pit Superfund
Site Yakima, Washington
(Continued)
Waste Source
Pesticide production wastes
disposed of in an unhned pit
Purpose/Significance of
Application:
Initially, was estimated in the
ROD that between 900 and
4,000 cubic yards of material
were contaminated However,
contamination extended deeper
than previously anticipated
and, as a result, over 5,600
cubic yards of material was
excavated for incineration
Type/Quantity of Media Treated-
Soil and Debris
• 5,600 cubic yards
Regulatory Requirements/Cleanup Goals.
• Destruction and Removal Efficiency (ORE) of 99 99 for all constituents of concern as required
by Resource Conservation and Recovery Act (RCRA), 40 CFR Part 264 Subpart O
Results.
• Monitoring and trial burn data indicate that all DRE and emission standards have been met
« Analytical data of residuals indicate that cleanup goals have been met
Cost Factors-
• The actual cost for remediation using the incineration system was approximately $6,000,000
Description-
Between 1952 and 1969, wastes contaminated with pesticides were disposed of on the site in an
unlmed waste disposal pit It was estimated that 2,000 pounds of material was disposed of on the
site in the pit contaminating soil with 1,1-dichloro-2,2-bis(p-chlorophenyl)ethane (ODD), 1,1-
dichloro-2,2-bis(p-chlorophenyl)ethylene (DDE), 1,1,1-tnchloro-2,2-bis(p-chlorophenyl)ethane
(DDT), and dieldnn
A Record of Decision (ROD) signed in September 1990 specified on-site incineration as the
remedial technology Site cleanup goals and destruction and removal efficiency (DRE) standards
were established for constituents of concern
On-site incineration began in January 1993 and was completed in May 1993 The treatment
system consisted of a rotary kiln and an SCC Enclosed twin screws moved the soil to the kiln for
treatment Ash was collected and flue gas was completely incinerated Incineration has
achieved the soil cleanup goals specified in the ROD
The actual cost for remediation using the incineration system was approximately $6,000,000
81
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• FMC Corporation - Yakima Pit Superfund Site
EXECUTIVE SUMMARY!
This report presents cost and performance data
for the application of on-site incineration at the
FMC Corporation - Yakima Pit (Yakima)
Superfund site in Yakima, Washington A rotary
kiln incinerator was operated from January 1993
through May 1993 as part of a remedial action
Contaminants of concern at the site included
pesticides and metals
The Yakima site was the location of a former
pesticide manufacturing plant which operated
from 1951 until its closure in 1986 Between
1952 and 1969, wastes contaminated with
pesticides were disposed of on the site in an
unlined waste disposal pit It was estimated that
2,000 pounds of material was disposed of on the
site in the pit Soil at Yakima was contaminated
with 1,1-dichloro-2,2-bis(p-chlorophenyl)ethane
(ODD), 1,1-dichloro-2,2-bis(p-
chlorophenyl)ethyiene (DDE), 1,1,1-tnchloro-
2,2-bis(p-chlorophenyl)ethane (DDT), dieldrm,
endosuifan, ethion, malathion, parathion,
cadmium, chromium, and zinc During the
remedial investigation, the maximum
concentrations of these contaminants in mg/kg
detected in the soil were ODD (76), DDE (28),
DDT (210), dieldnn (40), endosuifan (7,000),
ethion (180), malathion (170,000), parathion
(3,300), cadmium (6), chromium (320), and zinc
(1,020)
A Record of Decision (ROD) signed in
September 1990 established a Destruction and
Removal Efficiency (ORE) of 99 99% for
constituents of concern In 1991, a Consent
Decree was entered in the Eastern District of
Washington in which the Responsible Party
(RP) for the site agreed to implement the
remedial action proposed in the ROD
The RP conducted remedial activities including
the operation of a rotary kiln incinerator to
dispose of the contaminated soil The
incineration system at Yakima was comprised of
a solid waste feed system, a co-current rotary
kiln, a secondary combustion chamber (SCC),
and an air pollution control system (APCS)
The incineration equipment was located on
six flat bed trailers and several skids
Contaminated material was fed to the
incinerator by a jacketed, twin-screw
conveyor
The incinerator volatilized and partially
destroyed organic compounds from the
contaminated material Resulting ash from
the incinerator was removed by a
submerged drag conveyor while the off-gas
was drawn into the SCC The SCC was a
down-fired steel shell that provided further
combustion of contaminants in the gas
Off-gas from the SCC was then drawn into
the APCS, which was divided into three
stages The first stage, which consisted of a
quench tank and two Venturis, trapped and
collected particulate matter The second
stage, which consisted of a packed bed
adsorbei and cooling tower, removed acid
gases The third stage, which consisted of
an ionized wet scrubber, provided further
removal of particulate matter Ash collected
from the incinerator and APCS was sampled
and analyzed to determine if it was in
compliance with site-specific land disposal
requirements, at which time it was either re-
mcmerated or landfilled on the site
During the five months of operation, the
incinerator processed approximately 5,600
cubic yards of contaminated material
Treatment performance and emissions data
collected during this application indicated
that all performance standards and
emissions requirements were achieved
The actual cost for remediation using the
incineration system was approximately
$6,000,000
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• FMC Corporation - Yakima Pit Superfund Site
SITE INFORMATION
Identifying Information
FMC Corporation - Yakima Pit Superfund Site
Yakima, Washington
CERCLIS# WAD000643577
ROD Date September 14,1990
Background
Historical Activity that Generated
Contamination at the Site Manufacture of
pesticides
Corresponding SIC Code
and Agricultural Chemicals
2879 (Pesticides
Waste Management Practice That
Contributed to Contamination Waste
disposal in an unhned pit
Site History
• The site operated from 1951 until its closure
in 1986 The site has remained vacant
since its closure
From 1952 until 1969 wastes containing
pesticides were disposed of in an on-site,
unlmed waste pit and covered with soil The
waste material included raw material
containers, soil contaminated by leaks or
spills from process equipment, broken bags,
and off-specification materials [1]
• In the 1970s, liquid products were
formulated on-site using solvents,
emulsifiers, and stabilizers Spills and leaks
of these materials were believed to have
been a source of concrete and soil
contamination [1]
Treatment Application
Type of Action Remedial (on-site rotary
kiln incineration)
Period of operation January 1993 - May
1993
Quantity of material treated during
application 5,600 cubic yards of soil and
debris
Contamination at the site was found
within a 58,000-square-foot area on the
northeastern portion of the 10-acre site
Soil at Yakima was contaminated with
pesticides and metals including DDD,
DDE, DDT, dieldrm, endosulfan, ethion,
malathion, parathion, cadmium,
chromium, and zinc A remedial
investigation conducted in 1988 showed
elevated concentrations of DDT and
other pesticide constituents in the
former disposal pit
Removal actions in 1988 and 1989
included excavation, removal, and
disposal of 850 tons of contaminated
soil from the waste pit [1]
A ROD signed in 1990 addressed the
contamination that remained in and
around the waste pit The ROD called
for on-site incineration of contaminated
soil and debris
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
83
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1FMC Corporation - Yakima Pit Superfund Site
SITE INFORMATION (CONT.)
Background (Cont.)
• In April 1992, site mobilization began By
December 1992, incinerator shakedown had
begun using contaminated soil The trial
burn scheduled for December 1992 was
canceled due to delays in completing
incinerator instrumentation installation and
checkout The trial burn was re-scheduled
for January 1993
• In January 1993, the re-scheduled trial burn
was canceled due to mechanical difficulties
with the incinerator After extensive
incinerator modifications, the shakedown
period was extended Later in the month an
EPA-mandated 72-hour demonstration test
of the incinerator using clean soil was
completed Incineration of contaminated
soil resumed under operational guidelines
and limits established in an extended
shakedown plan
In March 1993, the extended shakedown
activities were completed The trial burn
was conducted and successfully completed
later in the month
• Between January 1993 and May 1993,
approximately 5,600 cubic yards of
contaminated material were incinerated
This amount included the material which
was incinerated during the shakedown
period
• Incinerator ash was disposed of on the
site Backfilling of the ash was
completed in June 1993 Site
demobilization activities were
completed in July 1993
Regulatory Context
• In 1983 the Yakima site was placed on
the National Priorities List (NPL)
• The selected remedy was implemented
under the provisions of the
Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by
the Superfund Amendments and
Reauthonzation Act of 1986 (SARA),
and the National Contingency Plan
(NCP) in 40 CFR part 300 [6]
• The DREs were set in accordance with
Resource Conservation and Recovery
Act (RCRA) incinerator regulations in 40
CFR part 264, subpart O
Remedy Selection On-site incineration
was selected as the remedy for
contaminated soil and debris at the Yakima
Pit Superfund site based on treatability
study results, its ability to be protective of
human health and the environment, and its
ability to comply with Applicable or Relevant
and Appropriate Requirements (ARARs)
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
84
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1FMC Corporation • Yakima Pit Superfunof Site
SITE INFORMATION (CONT.)
Timeline
Table 1 Timeline [1, 2]
If pi
1951 - 1986
1952-1969
1983
1988
1988
1989
September 1990
April 1992
January 1993
March 1993
May 1993
June 1993
July 1993
August 1993
.: /- :v>» ..^^&wr.^mi^^ - : „ - _, *~ **•*•:*. .•<*
Pesticides were manufactured at the Yakima site
Wastes from pesticide manufacturing were disposed of in an on-site unlined pit
Yakima site placed on NPL
Remedial Investigation
First Removal Action
Second Removal Action
ROD signed specifying on-site incineration
Site mobilization begins
72-hour demonstration test completed
Incineration Performance Test completed
Incineration completed
On-site backfilling of ash completed
Site was demobilized
Remedial Completion Inspection of the site
Site Logistics/Contacts
Site Management RP-lead
Oversight EPA
Remedial Project Manager:
Lee Marshall
US EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-2723
Treatment System Vendor:
VESTA Technology Ltd
1670 West McNab Road
Ft Lauderdale, FL 33309
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
85
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1FMC Corporation - Yakima Pit Superfund Site
MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System
• Soil and debris from an unlined waste
disposal pit
• Contaminated concrete from the
manufacturing plant
Contaminant Characterization
Primary Contaminant Groups Pesticides and
Metals
• The contaminants of greatest concern were
ODD, DDE, DDT, dieldnn, endosulfan,
ethion, malathion, parathion, cadmium,
chromium, and zinc
The maximum concentrations of
contaminants (mg/kg) detected in soil
were ODD (76), DDE (28), DDT (210),
dieldnn (40), endosulfan (7,000), ethion
(180), malathion (170,000), parathion
(3,300), cadmium (6), chromium (320),
and zinc (1,020)
Matrix Characteristics Affectina Treatment Costs or Performance
Information on matrix characteristics, such as
soil classification, moisture content, and
density, was not available
TREATMENT SYSTEM DESCRIPTION
primary Treatment Technology
VESTA Technology, Ltd Model 200
Transportable Hazardous Waste Incinerator
(incineration system) including
• Solid waste feed system
• Co-current, rotary kiln
• Secondary combustion chamber
Supplemental Treatment Technology
Pretreatment (solids)
• Crushing
• Mixing
Post-Treatment (air)
• Quench tank
• Venturi scrubber
• Cooling tower
• Packed bed absorber
• Ionized wet scrubber
Post-Treatment (water)
• Surge tank
• Particulate filters
• Carbon filter
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
86
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• FMC Corporation - Yakima Pit Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation
• In addition to the soil, approximately 10
cubic yards of concrete and a limited
amount of decontamination fluid was
incinerated The concrete was crushed to 1
inch pieces and mixed with the soil for
incineration Decontamination fluid,
generated from cleaning concrete and
personal protective equipment was collected
and also mixed with soil for incineration
• The mam components of the incineration
system included the rotary kiln, the SCC,
and the ARCS The equipment was located
on flat bed trailers and skids The final
system consisted of six trailers in a 100-foot
by 120-foot work area [3]
• The waste feed system consisted of a
variable speed J C Steele Feeder, a weigh
belt conveyor, an inclined drag conveyor
and a twin 6-inch screw feeder The J C
Steele Model 88C Even Clay Feeder was a
multi-shafted conveyor which included a
hopper and hopper extension to hold soil
fed to it by a mechanical loader The rate of
discharge from the feeder was controlled by
adjusting the rate at which the screws turned
[3]
• Solids from the Steele feeder fell onto a
Model MD-24T Thayer weigh belt conveyor
The belt passed over an isolated frame
connected to a load cell, which measured
the deflection caused by the weight of the
soil It then transmitted a signal to a
controller which governed the rate at which
the Steele feeder discharge soil to the feed
system [3]
• Solids fell from the weigh belt to a bottom
carry drag conveyor manufactured by
Taunton Engineering The drag conveyor
was 25 feet long and had a 12 foot high
discharge flange The conveyor was driven
by a 2 horsepower (hp) motor [3]
• Soils fell from the drag conveyor onto a
water-jacketed twin screw conveyor, which
fed the soils into the kiln The conveyor
was driven by a 6 7-hp drive motor
Water was circulated in the jacket to
protect the conveyor components from
the high temperatures generated by the
kiln
The co-current kiln was 25 feet in
length, had an inside diameter of 5 9
feet, and was lined with high-
temperature refractory The kiln was
designed to operate with excess air or
oxygen and to handle a maximum
throughput rate of 10,000 pounds per
hour
The average throughput of waste feed
was 60 6 kg/mm The kiln was rated at
105 million BTU/hr and operated at
650° C
Residual ash from the kiln fell from the
discharge end of the conveyor into the
ash drag conveyor The bottom end of
the conveyor was completely
submerged in water to cool the hot ash
The conveyor discharged the ash into a
hopper The ash was then sampled and
analyzed to determine if it met
requirements for on-site land disposal
The TCLP analyses of the ash
confirmed that it was not a RCRA
characteristic waste, and therefore
could be landfilled on site
Flue gas from the kiln was routed to the
SCC to ensure complete combustion of
volatilized contaminants The SCC
operated at approximately 1,107°C and
was equipped with an excess air burner
Air flow in the SCC was co-current to
the flue gas flow The burner was rated
at 12 5 million BTU/hr The SCC was
30 feet long and had an inside diameter
of 6 5 feet
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
87
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• FMC Corporation - Yakima Pit Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
The exhaust gas from the SCC was then
routed to the system's ARCS The ARCS
contained three distinct units The first
stage consisted of a quench tank and a
ventun scrubber to reduce flue gas
temperature and remove particulates Acid
gas was neutralized by a pH-controlled
spray in the ventun Solids were removed
from the process water by a clarifler The
clanfier used a filter press to remove solids,
and the treated water was recycled to the
ventun
The second stage of the ARCS consisted of
a packed bed absorber and a cooling tower
to subcool the off-gas The process water
for the absorber was pH controlled to ensure
sufficient removal efficiency of acid gas
The subcoolmg of the off-gas was in a
closed loop through a heat exchanger to
reduce heavy metal emissions Slowdown
from the second stage was treated and then
used as makeup water for the first stage [3]
The third step consisted of a two-stage
ionized wet scrubber to remove particulates
The scrubber used high voltage lonization to
electrostatically charge particulates in the
gas stream before they entered the scrubber
section Particles greater than 3 microns
were collected by mertial impaction
Smaller particles were attracted to the
neutral surfaces of the scrubber due to the
electrostatic charge which had been
imparted on them Slowdown from the
scrubber was treated and then used as
makeup water for the first stage [3]
Operating Parameters Affectina Treatment Cost or Performance
Table 2 Summary of Operating Parameters
The blowdown from the second and
third stages was treated in a system
which consisted of a 1,000 gallon surge
tank, a three-stage particulate filter, an
activated carbon filter, and a particulate
post filter The surge tank acted as a
primary settling tank for particulate
removal and provided capacity to
handle excess flow conditions The
three-stage particulate filter was
designed to remove particulates larger
than 1 micron The carbon filter was
designed to remove organic compounds
that were present The post filter
removed any particulate larger than 0 5
microns The solids collected by the
filters were collected and sampled prior
to disposal [3]
Combustion gases were drawn through
the kiln system and ARCS by an
induced draft fan and were exhausted
through a 30-foot fiberglass reinforced
plastic stack Typical flue gas velocity
was 85 m3/mm
Parameter
Residence Time
System Throughput
Kiln Temperature
•v^jsT', S ';P 9 'ff t
NA
60 6 kg/mm
650°C
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
-------
1FMC Corporation - Yakima PA Superfund Sits
TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards
• The cleanup goals and standards were
specified in the ROD The ORE standards
were set based on RCRA incinerator
regulations in 40 CFR part 264, subpart O
• A ORE of 99 99% was required for each
constituent of concern
• Ash residuals were tested using the Toxicity
Characteristic Leaching Procedure (TCLP)
prior to on-site disposal
• Cleanup standards in mg/kg were set for the
following constituents in soil ODD (5 1),
DDE (3 6), DDT (3 6), Dieldnn (0 076),
cadmium (8 0), hexavalent chromium (1 0),
endosulfan (4 2), ethion (42 4), malathion
(1,695), parathion (11 0), zinc (500)
Cleanup standards in mg/100 cm2 were
set for the following constituents in
concrete and other surfaces ODD
(0 0065), DDE (0 0046), DDT (0 0046),
dieldrm (0 0001), endosulfan (0 010),
ethion (0 270), malathion (8 2), and
parathion (2 4)
The soil cleanup criteria were
established according to a risk
assessment which allowed a 5 x 106
excess lifetime cancer occurrence
A cumulative hazard index was set at
less than or equal to 1 for all
noncarcmogenic substances
Treatment Performance and Compliance
• A trial burn conducted at Yakima was
designed to operate the incineration system
at conditions that would reflect worst-case
destruction and removal of all constituents
of concern Hexachlorobenzene was
selected as the POHC The reported ORE
for this POHC is included in Table 3
• The incinerator at Yakima operated within
the operating limits established during the
trial burn, signifying that all cleanup
requirements established in the ROD were
met The AWFCOs limits used during the
operation of the
incinerator are shown in Table 4
Information about the frequency of
AWFCOs was not available Available
trial burn and typical operating
parameters are shown in Table 5
The residual ash was sampled and
analyzed using the Toxicity
Characteristic Leaching Procedure
(TCLP) to determine if it was in
compliance with on-site disposal
requirements These data are
presented in Table 6
Table 3 Average Destruction and Removal Efficiencies from Trial Bum [4]
Contaminant
, Average Contaminant
*r ** 'Vff t * * ,^,
Average Contaminant Rate in
Stack Gas emissions (Itj/nr)
Hexachlorobenzene
30
246x107
0130
99 999992
Table 4 Automatic Waste Feed Cutoffs
#'-??'&&'jp:£&&#ii*i* d*w" :.,,.>;••"
Maximum contaminated soil feed rate1
Maximum kiln temperature
Minimum kiln temperature
Minimum SCO outlet temperature
':- *•" ^-^' T C&ofrtLtaii,?'7 / -IV ' -' ••"'
67 kg/mm
1,000°C
600°C
1,093°C
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
89
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• FMC Corporation - Yakima Pit Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 4 Automatic Waste Feed Cutoffs
I""1'1 ' , Parameter **" /
Maximum quench outlet temperature
Minimum recycle to venturl
Minimum venturi differential pressure
Minimum absorber recycle flow
Minimum absorber flow water pH
Maximum cooling tower Inlet temperature
Minimum Ionized wet scrubber #1 recycle water flow
Minimum Ionized wet scrubber #2 recycle water flow
Minimum Ionized wet scrubber #1 voltage
Minimum Ionized wet scrubber #2 voltage
Maximum exhaust stack CO concentration
Maximum exhaust stack average CO concentration1
Maximum exhaust stack O2
Maximum exhaust stack flow
Minimum kiln Oz level
Minimum SCC outlet O2 level
Maximum kiln pressure
Bypass stack not closed
'i '\%S-tS»;i«c«io®«!it £•- :'," "~ "-
100°C
150 Lpm
750 mm w c
1,000 Lpm
6
80°C
1 ,000 Lpm
1 ,000 Lpm
12 kV
12 kV
500 ppm
100ppm
4%
175 rrrYmm
6%
3%
-1 3 mm w c
Open
'One hour rolling average
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
90
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1FMC Corporation • Yakima Pit Superfuncf Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table5 Operating Parameters [4, 7]
• ;: • " - - ~"~ 'i
Contaminated Soil Feed Rate
Fuel Fired Feed Rate
Emission Rate
Particulate
HCI
CI2
S02
NOX(@7%O2)
Operating Conditions
CO concentration in gas
Exhaust stack O2 concentration
Kiln temperature
SCC outlet temperature
Stack gas flow rate
Quench outlet temperature
r^'^'J; ^^^*J' ,".< -* C^', y^
1,,. J^AelttalValue1 i,V
60 6 kg/min
10 5 million BTU/hr
NA
NA
NA
NA
NA
10ppm
10%
650°C
1,107°C
85 m3/mm
85°C
,-w. ,->** oi_ ^ ^ .» ^A -j
;,,, TftalBOtttValae - A
81 8 kg/min
10 5 million BTU/hr
00014gr/dscf
0 004 kg/hr
<0 001 kg/hr
6 18 ppm
1,123 83 ppm
18 44 ppm
1297%
NA
NA
NA
NA
'Anticipated values as reported in the Incineration Work Plan
Table 6 TCLP Comparison for Residual
<.J -^ Jf?J ,*. -'- - * ;^ / M>VJ, ? ,
..? '-,» ^ <*=* ^-Cooltituent , _, C^r*
Metals
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Organochlorine Pesticides
Chlordane
Endnn
Heptachlor (and epoxide)
Lmdane
Methoxychlor
Toxaphene
" ' ' JiMlrii^^y Threshold ' " "
-• x<5s>ndhlrattwting/iir)* *r^
5
100
1
5
5
02
1
5
003
002
0008
04
10
05
" ^rerageTCLP-CorKsentratlon -
" =•!* ~***tfRS$3> M *•- «v ^
0016
019
00028
0011
0020
000012
00099
00046
0 00037
0 000082
000018
0 000037
000011
00012
Note Only pollutants that were detected are included in this table
aExcerpted from 40 CFR § 261 24 Table 1
bGeometnc mean value of reported ash samples
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
91
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1FMC Corporation - Yakima Pit Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Completeness
• Data are available for concentrations of
contaminants in the soil before treatment
Performance Data Quality
• According to site personnel, the QA/QC
program used throughout the remedial
action met the EPA and the State of
Washington requirements All monitoring
was performed using EPA-approved
methods, and the vendor did not note any
exceptions to the QA/QC protocols
Data are also available for
concentrations of contaminants in the
incinerator residue These data were
periodically collected prior to on-site
land disposal
TREATMENT SYSTEM COST
Procurement Process
The RP contracted with VESTA Technology
Ltd to provide and operate the incinerator
at the site
Cost Data
• The estimated treatment cost of
$6,000,000 was reported by Bechtel
Environmental, Inc A total of 7,840 tons
of soil were incinerated This corresponds
to a total unit cost of $770 per ton A
detailed breakdown of these costs was not
available
Cost Data Quality
• Actual capital and operations and
maintenance cost data are available from
the treatment vendor for this application
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
92
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1FMC Corporation • Yakima Pit Superfuncf Site
OBSERVATIONS AND LESSONS LEARNED
Observations and Lessons Learned
• It was estimated in the ROD that between
900 and 4,000 cubic yards of material were
contaminated However, contamination
extended deeper than previously anticipated
and, as a result, over 5,600 cubic yards of
material was excavated for incineration
• Samples from 7 feet below ground surface
taken during excavation contained
contaminant concentrations above the
cleanup goals EPA determined that
excavation below 7 feet was technically
impracticable, and that the material did not
pose an exposure risk because soil at this
depth was constantly submerged below
water Additionally, EPA felt that the
groundwater was not at risk due to the
excavation of material which had already
taken place Groundwater monitoring was
scheduled to take place for five years
following the completion of the incineration
project [5]
Many problems occurred while trying to
get the incinerator operational
Shakedown activities were scheduled
for the winter months with average
temperatures around 25° F The cold
weather caused many delays in setting
up the incinerator Additionally, the
incinerator contractor did not anticipate
the amount of monitoring that would
occur on-site, which caused further
delays [6]
Excavation of contaminated soil at the
site was complicated by environmental
factors The water table at the site is at
its seasonal low of 7 feet below ground
surface during the winter months
Excavation of soil with the water table at
this level is preferred but harsh winter
conditions in Washington introduced
other problems During the warmer
summer months, the water table at the
site is at its seasonal high of 6 inches to
1 foot below ground surface While the
warmer temperatures make outdoor
operations easier, the high water table
hampers soil excavation
REFERENCES
1 Superfund Record of Decision. FMC
Corporation Yakima Pit, Yakima,
Washington, September 14,1990
2 Remedial Action Completion Report.
Bechtel Environmental, Inc , May 16,1994
3 Performance Demonstration Test Plan
Section 2. VESTA Model 200 Incinerator
Engineering and Design Specifications.
VESTA Technology, November 1992
4 Final Results of the Trial Burn
Demonstration Test of the VESTA
technology. Ltd Model 200 Incinerator at
the Former FMC Pesticide Formulating
Facility in Yakima. Washington.
Environmental and Risk Management, Inc ,
April 1993
Explanation of Significant Differences -
FMC Corporation Yakima. Washington.
U S EPA Region X, April 1993
Personal Communication, Mr Kevin
Rocklm, May 19,1997
Incineration Work Plan - Revision 3.
Addendum 2. VESTA Technology, Ltd ,
January 1993
Cleanup Summary for Incinerator Ash
and Waste. Beehtel Environmental,
Inc, June 1993
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
93
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This Page Intentionally Left Blank
94
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Incineration at the Former Nebraska
Ordnance Plant Site
Mead, Nebraska
95
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Incineration at the Former Nebraska Ordnance Plant Site
Mead, Nebraska
Site Name:
Former Nebraska Ordnance
Plant - Operable Unit 1
Location:
Mead, Nebraska
Contaminants
Explosives and Propeliants
• TNT, RDX, TNB, DNT,
DNB, HMX, Tetryl, o-NT
and m-NT
• Maximum concentrations
in mg/kg - TNT
(133,000), RDX (23,270),
TNB (430) and DNT
(1193)
Period of Operation:
• Mini and Trial Burn
Operation - September
1997
• Full-Scale Operation -
October to December 1997
Project Management
U S Army Corps of
Engineers Formerly Used
Defense Sites Program
Edwin Louis
Kansas City District
700 Federal Building
Kansas City, Missouri 68144-
3869
(816) 983-3563
Technology:
On-Site Incineration
• Soil stream was fed
through a grizzly screen
to remove large debris
• Incineration system
consisting of a co-current,
rotary kiln and one
secondary combustion
chamber (SCC)
• Kiln operated at an exit
gas temperature of 1150
to 1800 °F, SCC operated
1800°F
• Hot flue gases exiting the
kiln were quenched using
water spay nozzles
• Solids exiting the kiln
were stockpiled for
compliance sampling
Cleanup Type:
Remedial Action
Cleanup Authority
CERCLA and State
ROD date - August 29, 1995
SIC Code:
9711B (Ordnance Production
and Storage) and 9711C
(Ordnance Testing and
Maintenance)
Waste Sources:
Discharge of contaminated
rinse water and burning of
explosives
Purpose/Significance of
Application:
Project completed in
extremely short time period,
including all permitting
requirements
Type/Quantity of Media
Treated:
Soil and Debris
• 16,449 tons (13,009 cubic
yards) of soil and debris
• Average Moisture
Content 1682%
• Average BTU value per
pound 1220
• Average Soil Density -
93 7 pounds per cubic
foot
Regulatory Points of
Contact
Craig Bernstein
USEPA Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
(913)551-7688
Troy Bendenkamp
NDEQ
Suite 400, The Atrium
1200N Lincoln Street
Lincoln, Nebraska 68509-8922
(402)471-2214
96
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Incineration at the Former Nebraska Ordnance Plant Site
Mead, Nebraska
(Continued)
Regulatory Requirements/Cleanup Goals.
Destruction and Removal Efficiency (ORE) of 99 99% for POHC
The following limits were set for treated soil after incineration in mg/kg
- TNT-17 2
- RDX-58
- TNB - 1 7
- DNT-09
- TNB - 1 7
- HMX-1,7152
- Tetryl - 343
- NT-343
Results:
• Emission and trial burn data indicated that all ORE and emissions standards were met
• Treated soil sampling indicated that all soil cleanup goals were met
Costs
The total cost for this project was $10,700,001 The technology cost was $6,479,245 ($394 per
ton of contaminated material)
Description:
During several intervals between 1942 and 1959, the Nebraska Ordnance Plant (NOP) site was
used for loading, assembly and testing of bombs, boosters and shells During site cleaning
activities, explosives-containing wash water was discharged into surface water drainage ditches
at the site In addition, contamination was observed in soil at the Burning/Proving Grounds at
the site A Record of Decision (ROD) was signed in August 1995, specifying on-site
incineration as the remedial technology for addressing shallow contaminated soil at the site
Shallow contaminated soil at the former NOP (soil between 0 and 4 feet below the ground
surface) was identified as Operable Unit (OU) 1 Site soil cleanup goals were specified in the
ROD
Because the former NOP site was designated as part of the Formerly Used Defense Site
(FUDS) program, the USAGE was responsible for managing remedial actions at this site
Site work for construction of the incinerator was commenced in February 1997 Incinerator
start up and shake down were performed in August and September 1997 Mini burn and trial
burn tests were conducted in September 1997 After receiving approval from EPA and NDEQ
of the proposed operating limits, the incinerator was put into full production in October 1997
Treatment was completed in December 1997 The incineration system consisted of a co-
current, rotary kiln followed by a secondary combustion chamber (SCC) After confirming that
treated soil met the cleanup criteria, the soil was returned to an excavation at the site
Demobilization of the incinerator from the site was completed in May 1998
97
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Former NOP OU-1
SITE INFORMATION
IDENTIFYING INFORMATION Ml
Site Name:
Location:
Operable Unit:
CERCLIS #:
ROD Date:
Technology:
Type of Action:
Former Nebraska Ordnance Plant (NOP)
Mead, Nebraska
OU1
NE6211890011
August 1995 (Signed by EPA on August 29, 1995)
On-Site Rotary Kiln Incineration
Remedial
Figure 1 shows the location of the former NOP in Nebraska
TECHNOLOGY APPLICATION (2)
Period of Operation:
Mini and trial burn operation - September 1997
Full-scale operation - October through December 1997
Quantity of Material Treated During Application:
16,449 tons of explosives-contaminated soil
BACKGROUND
Site Background (1,3):
• The former NOP facility is located on 17,000 acres of land approximately 2 miles south of
the town of Mead in eastern Nebraska The site was used to load, assemble and pack
bombs, boosters and shells in the 1940s during World War II and in the 1950s during the
Korean conflict The NOP included the following facilities
Four bomb Load Lines,
A Bomb Booster Assembly plant,
An ammonium nitrate plant,
Two explosives burning areas,
A proving range,
A landfill,
A wastewater treatment plant,
Analytical laboratories, and,
Administration facilities
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
98
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Figure 1 Location of the Former NOP Facility m Nebraska
Former NOP OU-1
NOP1 DWG DC-RTG 4/9/98
U S ENVIRONMENTAL PROTECTION AGENCY
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Former NOP OU-1
• In 1959 the facility was declared excess to Army needs, and was transferred to the General
Services Administration for disposition
• Since 1959, various portions of the 17,000 acres have been transferred to government
agencies (Army, Air Force and The Department of Commerce), local public officials (The
University of Nebraska) and various private individuals and corporations Since its closure,
the majority of the former NOP facility has been used for agricultural production However,
several private businesses have been operated at the facility since 1959
Figure 2 shows the layout of the former NOP facility
SIC Code:
9711B (Ordnance Production and Storage) and 9711C (Ordnance Testing and Maintenance)
Waste Management Practices that Contributed to Contamination (1)
Explosives production equipment and buildings were regularly cleaned and decontaminated with
water Wash water containing explosives flowed into drainage ditches and sumps outside the
buildings Explosives were regularly tested in the Burning/Proving Grounds at the site
Site Operation History (1):
• The Nebraska Defense Corporation operated the NOP facility from 1942 to 1945, producing
boosters in the booster assembly area and bombs at the four load lines The facility was
placed on inactive status in 1945 Routine operations at the NOP included discharge of
explosives-containing wash water into site sumps and open ditches
• The facility was decontaminated in 1945 Decontamination procedures included the
following
Building floors were cleaned by sweeping and flushing,
Explosives-production surfaces were scraped and brushed by hand,
Internal roofs and trusses were steam-cleaned,
External roofs were cleaned by flushing with water, and,
Cleaning residues, contaminated soil and sludges and selected wooden structures
and tile drainage pipe were all taken to the Burning/Proving Grounds for disposal by
burning
In 1950, the facility was reactivated to produce weapons for the Korean Conflict The NOP
was placed on standby in 1956, and declared excess to Army needs in 1959
• Decontamination records following 1950 could not be located for the NOP It is assumed
that portions of the facility were decontaminated with hot water and steam It is likely that
several areas of the facility were not decontaminated
U S ENVIRONMENTAL PROTECTION AGENCY
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Technology Innovation Office
100
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Figure 2. Layout of the Former NOP Facility
Former NOP OU-1
NOP3 DWG DC-RTG 4/9/98
E CROP I
enoN j
PROPERTY OF
FEDERAL
GOVERNMENT
n
FORMER RAILROAD
ROAD
NOP BOUNDARY
LAND USE BOUNDARY
2000 4000
APPROXIMATE SCALE IN FEET
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Former NOP OU-1
• In 1959, the facility was transferred to the General Services Administration Over the next
several years, parcels of the property (totaling approximately 3,000 acres) were retained by
the Army, Air Force and the Department of Commerce
• In 1962 and 1964,10,200 acres were transferred to the University of Nebraska for
agricultural research The remaining land was sold to various private individuals and
corporations
• A fireworks company operated in the Bomb Booster Assembly Area from 1969 to 1989
• Since closure of the NOP, the property has been used primarily for agricultural production
and research
Site Investigations (1):
• An archives search was performed in 1983 by the U S Army Toxic and Hazardous Materials
Agency (USATHAMA) The documents located during this search indicated that the most
likely areas of explosives contamination at the NOP facility were the four Load Lines, the
Booster Assembly Area and the Burning/Proving Grounds
• PCB investigations were performed by the following groups in the years listed
University of Nebraska -1984 and 1985
USEPA-1988
USAGE-1993
• In 1989, the USAGE investigated soil, sediment surface water and groundwater at the site
• In 1990, a shallow soil gas survey was performed at the site
• In 1991, the USAGE conducted soil and unexploded ordnance (UXO) investigations
• In 1991, a preliminary health assessment for the site was conducted by the Agency of Toxic
Substances and Disease.Registry (ATSDR)
• In 1991 and 1992, a Remedial Investigation was performed for operable unit (OU) 1 by the
USAGE Results of this investigation indicated that explosives contamination was present in
the shallow soil in several areas at the former NOP facility
• In 1991, the USAGE performed a Supplemental Soil Remedial Investigation for OU 1
• In 1995, a Record of Decision (ROD) was signed for OU 1
• In 1996, a soil investigation for polychlormated biphenyls (PCBs) was performed at the NOP
facility
The investigation and remediation at the former NOP facility has been divided into three OUs by the
USAGE in consultation with the USEPA and the Nebraska Department of Environmental Quality
(NDEQ) The OUs are described as follows
• OU 1 includes remediation of shallow (less than 4 feet below ground surface (bgs))
explosives- contaminated soil
• OU 2 includes remediation of contaminated groundwater, volatile organic compound (VOC)-
contammated soil and explosives-contaminated soil deeper than 4 feet bgs
• OU 3 includes remediation of the on-site landfill and other disposal areas not identified in the
Inter-Agency agreement (IAG) among the USAGE, USEPA and NDEQ
In addition, it was determined by the USAGE, in consultation with USEPA and NDEQ, that PCB-
contaminated soil would be addressed separately from OU 1 soils
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SITE LOGISTICS/CONTACTS
William J Crawford, P E
USAGE
HTRW Center of Expertise
12565 West Center Road
Omaha, Nebraska 68144-3869
(402) 697-2579
Edwin Louis, PM
USACE
Kansas City District
700 Federal Building
Kansas City, Missouri 64106-2896
(816)983-3563
Kevin Birkett
USACE
CENWO-CD-QA-KBIRKETT
215 North 17th Street
Omaha, Nebraska 68102
(402)221-4271
Jennifer Young
USACE
Ft Crook Area Off ice
PO Box13287
Offutt AFB, Nebraska 68113
(402) 293-2566
Troy Bendenkamp
NDEQ
Suite 400, The Atrium
1200 N Lincoln Street
Lincoln, Nebraska 68509-8922
(402)471-2214
Craig Bernstein
USEPA Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
(913)551-7688
Gregory McCartney
OHM Remedial Services Corporation
16406 US 224 E
Fmdlay, Ohio
(419)425-6003
MATRIX AND CONTAMINANT DESCRIPTION
MATRIX IDENTIFICATION
Soil (ex situ)
SITE GEOLOGY/STRATIGRAPHY
The NOP subsurface consists of four discreet Pleistocene-age unconsolidated layers consisting of
alluvial and eolian (wind-deposited) material overlying sedimentary bedrock The surficial deposits
consist of a gray to brown sand and gravel alluvium that is up to four feet thick Beneath the surficial
alluvium is the clayey silt, silt, and silty clay Peoria Loess unit that ranges in thickness from 2 to 27
feet Beneath the loess deposits is the Todd Valley Sand Unit, which is a 35 to 90 feet thick unit
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Former NOP OU-1
consisting of gray to yellow-brown, very fine to coarse sand The deepest unconsolidated layer
consists of the Grand Island-Crete Sand and Gravel Unit, which is a predominantly gray to yellow-
brown, fine to coarse sandy gravel unit, that is 0 to 55 feet thick
Sedimentary bedrock that underlies the unconsolidated material consists of Cretaceous-age shales
and sandstones of the Omadi Formation Depth to bedrock beneath the NOP site ranges from 48 to
150 feet below grade The shallower shale is brown-yellow to green-gray, non-calcareous,
micaceous, and moderately hard The shale overlies a yellow to orange, poorly to moderately
cemented, fine to medium grained, quartzitic sandstone The Cretaceous-age bedrock overlies older
Pennsylvanian-age shale and limestone bedrock
Groundwater beneath the NOP site is first encountered in the unconsolidated Pleistocene sands and
gravels Groundwater is also present in the deeper sandstone bedrock Where present, the shale
bedrock will act as an aquitard that separates the sand and gravel aquifer from the deeper sandstone
aquifer. Average transmissivities for the sand and gravel and sandstone aquifers are 69,000 gallons
per day per foot (gpd/ft) and 196,000 gpd/ft, respectively Groundwater beneath the NOP site flows
in a south-southeasterly direction under a hydraulic gradient of approximately 115 feet per mile
CONTAMINANT CHARACTERIZATION m
Primary Contaminant Group. Explosives/Propellants
Key Specific Contaminants:
2,4,6-Tnnitrotoluene (TNT)
Hexahydro-1,3,5-tnnitro-1,3,5-tnazme, or cyclonite, or research department explosive (RDX)
1,3,5-trmitrobenzene (TNB)
2,4 and 2,6-dmitrotoluene (DNT)
1,3-dmitrobenzene (DNB)
Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazme (high melt explosive or HMX)
2,4,6-tetranitro-n-methylanilme (tetryl)
o-nitrotoluene (o-NT)
m-nitrotoluene (m-NT)
CONTAMINANT PROPERTIES (5. 6. 7.10.131
Table 1 lists selected properties for several of the contaminants present at the NOP site
Table 1. Contaminant Properties
Property
Chemical
Formula
Molecular Weight
Specific Gravity
Vapor Pressure
Octanol-Water
Partition
Coefficient
Soil-Water
Partition
Coefficient (K,)
Units
-
g/mole
-
mm Hg
logK™
L/kg
TNT
C7H5N306
22713
1 654
(20°C)
1x10^
(20°C)
1 65-2 83
38
(soil)
RDX«*
C3H6N606
22226
1 82
(20°C)
1x10^
(25 °C)
081-1 41
616
(bentonite)
«
C6H3(N02)3
21311
1 76
(20°C)
22x10"
(25°C)
1 18
NA
? W OUT*
C6H3CH3(N02)2
18213
1 521
(15°C)
217x10"
(25°C)
1 88-2 77
2512
NA - Not available
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NATURE AND EXTENT OF THE CONTAMINANTS (10. I'M
Former NOP OU-1
The results of the Rl indicated that explosives-contaminated soil was present in the following areas
• All four Load Line Areas,
• The Burning/Proving Grounds,
• The Bomb Booster Assembly Area, and,
• The Administration Area
Contamination was predominantly located in areas in and around sumps and drainage ditches at
each area Because the contaminated areas at OU 1 were numerous and spread across large areas
of the NOP facility, it is not practical to show the areal extent of contamination in this report Based
on data collected for the Rl, it was estimated that approximately 9,200 cubic yards of soil was
contaminated in OU 1
During remediation activities, it was determined that contaminated soil volumes were greater than
originally estimated In addition, some of the soil excavated was contaminated with PCBs, and was
therefore sent off site for disposal Actual contaminated soil volumes from each area at the facility
are listed below It should be noted that all volumes listed are based on surveys of the excavations
and do not account for expansion of the soil during excavation
Table 2. Actual Contaminated Soil Volumes Excavated at the NOP Facility
sir &
,
(cubifc yar
Load Line 1
39237
1223
38014
Load Line 2
42876
82
42794
Load Line 3
15703
1799
13904
Load Line 4
191 3
374
1539
Burning/Proving Grounds
3431 2
250
3181 2
Administration Area
1924
1924
Bomb Booster Assembly
Area
106
106
TOTALS
136071
5978
130093
The total volume of soil processed through the incinerator was 13009 3 cubic yards This volume,
when converted to mass was equal to 16,449 tons Based on this conversion, the average soil
density was equal to 93 7 pounds per cubic foot
CHARACTERISTICS OF UNTREATED SOIL M. 3^
Soil samples were collected from vanous depths and at several locations during the 1991 Rl and the
1992 Supplemental RI/FS Selected results from these samples are shown in Table 3
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Former NOP OU-1
Table 3. Characteristics of Untreated Soil (1)
IP I- I ""
I 1 ' , 1 ' II , -
1 ,
i T ,
1 Sample Location
Load Line 1
Load Line 2
Load Line 3
Load Line 4
Booster Assembly Area
Burning/Proving Grounds
Administration Area
Pnmary Area
T"' MWfti
: "iif|
.«*$
(mg/
num '
f'l'"']' ;
UM
&
133,000
176,000
29,700
131
70
313
0314
045
y W^J7m f ~
t J. Tf> V <*P|!f ^ t
396
23,270
404
227
ND
1,700
ND
ND
, 't^ffiufex «.
<^%*$M 's
Cortoempaiion^
ffcund ,-..,*.
l^tW9^s)^^.
338
430
953
60
36
353
ND
ND
Maximum DNT
Jtohceirtration
Pound (mg/kg)
289
1193
148
176
ND
125
ND
ND
ND - not detected
MATRIX CHARACTERISTICS AFFECTING TREATMENT COST OR PERFORMANCE (Si
Table 4 lists selected characteristics of untreated soil from the former NOP facility
Table 4 Matrix Characteristics
Soil Classification
Clay Content and/or Particle Site Distribution
Soil Plasticity
Moisture Content (%)
Porosity
Total Organic Carbon
BTU value (BTU/lb)
Halogen Content
Metal Content or the Presence of Metals
Presence of Alkali Metal Salts
USCS Soil Type CLandCH
88 to 100 percent silty and clay
0 to 12 percent sand
Information not available
1682*
Information not available
Information not available
1220*
Information not available
Information not available
Information not available
*Average value from the tnal bum test
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Former HOP OU-1
TREATMENT SYSTEM DESCRIPTION
PRIMARY TREATMENT TECHNOLOGY (4)
Incineration
A mobile rotary kiln incineration system was used for this project, including the following
• Solid waste screening to remove debns larger than 2 inches,
• Solid waste feed system (dual-screw feeder), and
• A refractory bnck-lined, propane-fired (oxygen-ennched), co-current rotary kiln
SUPPLEMENTARY TREATMENT TECHNOLOGIES (41
Post-Treatment (hot flue gas) - Incineration (secondary combustion chamber)
Post-Treatment (hot flue gas) - Baghouse
Post-Treatment (hot flue gas) - Quench (scrubber)
TIMELINE 12. 3)
Community Relations Plan prepared and issued
Proposed Plan for the site released by USAGE and USEPA
June 1995
Gn-site incineration accepted as the recommended alternative by
NDEQ
August 1995
ROD signature by USEPA Region VII Administrator Project
Plans, Tn?l Bum Plan and Site Design accepted by USAGE,
USEPA and NDEQ
January 1997
Notice to Proceed issued to OHM for OU 1 Delivery Order
February 1997
Begin site work atOU1
March 1997
Preconstruction Meeting
May 1997
Begin incinerator set up
July 1997
Incinerator set up completed
August - September 1997
Incinerator start up and shake down
September 1997
Incinerator Mini Bum and Trial Bum tests performed
October 14.1997
Begin full-scale operation of the Incinerator
December 21,1997
Remediation completed, incinerator shut down
January 5 -May 22.1998
Demobilization of the Incinerator and site restoration
TREATMENT SYSTEM SCHEMATIC AND TECHNOLOGY DESCRIPTION AND OPERATION
Figure 3 shows a process flow diagram for the mobile incineration system used to treat ex-situ soil at
the former NOP facility
Mobilization (2)
The contractor began mobilizing to the site on February 24, 1997 A proconstruction meeting was
held on March 29, 1997
Construction (2)
Incinerator construction was started on May 27, 1997 and completed on August 29, 1997
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_______._-____—-——————.^—^————— Former NOPOU-1
Operation (2.3.9)
The treatment system was operated using the following steps
• Contaminated so. was excavated from previously designated areas, transported to the feed
preparation area and screened to remove oversized particles Excavation sampling was
performed to confirm that dean up criteria were met for soil remaining in-place
Contaminated soil was blended pnor to treatment to equalize contaminant levels in the feed
stream
• Contaminated soil was fed through a grizzly screen onto a variable speed feed belt, weigh
belt conveyor, and into the kiln feed hopper The waste stream was delivered from the
hopper to the kiln via dual water-cooled feed screws
• The pnmary kiln was 45 feet long and had an inside diameter of 6 5 feet The kiln was
operated co-currently with the waste feed located at the same end as the oxygen-propane
burner Contaminated soil traveled through the kiln via gravity The kiln was designed to
operate at exit gas temperatures of 1150 to 1800°F
• Solids exiting the kiln were conveyed to a wet ash storage area for stockpiling and
compliance sampling Hot flue gases were quenched using water nozzles in the kiln breech
and in the duct cooler after exiting the kiln
• Kiln gases then passed through a baghouse for removal of paniculate matter and submicron
heavy metals The baghouse was designed to operate at a maximum temperature of 500°F
• Exhaust gases from the baghouse were fed to a secondary combustion chamber (SCC)
The SCC was designed to be operated at 1800°F with a gas retention time of 2 seconds
• Exhaust gases from the SCC were cooled from 1800°F to 180°F with water in a quench
tank. The tank was level controlled The pH was maintained between 6 5 and 8 0 by addition
of hydrochloric acid to the spray water circulation line The quench tank was followed by a
mist eliminator
• An induced draft (ID) fan drew gases througi. the entire system and discharged to the stack
at the end of the treatment system The fan produced negative pressure throughout the
treatment unit, including within the kiln
A mini bum test (three runs) was conducted on September 17 and 18,1997 A trial bum test (four
runs) was conducted from September 22 to September 29,1997 A total of 1376 tons of
contaminated soil was treated during the mini bum and trial bum tests
In addition to the incineration system, a wastewater treatment system was installed and operated at
the site The following sources of wastewater were encountered during this project-
• Wash water from equipment and personnel decontamination activities,
Rain water collected from the soil excavation cavities,
• Quench tank blowdown, and,
• Rain water collected in the incineration processing area
US ENVIRONMENTAL PROTECTION AGENCY
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Figured. Process Flow Diagram
FomwNOPOU-1
NOP2.MC DC-KIE »/'/»•
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——^———_———^_— Former NOP OtM
The wastewater treatment system consisted of the following units and treatment steps-
wastewater storage tanks;
chemical precipitation,
flocculation,
sand filtration,
carbon absorption,
bag filtration.
pH adjustment, and,
a sludge filter press
Post-Operation (3)
When soil treatment operations were completed, the treatment system was shut down and
dismantled for demobilization from the site Areas where contaminated soil had been excavated
were filled with dean soil taken from other areas at the NOP facility Treated soil was returned to a
large on-site excavation. The reason for placing all of the treated soil into one excavation was to
provide a source of sterile soil for planned agricultural experiments to be performed by the University
of Nebraska As part of demobilization, OHM graded disturbed areas, repaired damage to facility
roads, and placed topsoil where necessary to support planting of grass in the future Based on an
agreement between the USAGE and the current owner of the site, The University of Nebraska, the
disturbed areas will be seeded by The University of Nebraska. The costs for seeding will be paid by
the USAGE
Treatment system demobilization and site restoration activities (other than University of Nebraska
seeding) are scheduled to be completed on May 22,1988
OPERATING PARAMETERS AFFECTING TREATMENT COST OR PERFORMANCE (31
The following table lists operating limits for the Incineration system that were approved by the
USEPA and NDEQ prior to full-scale operation of the system
Waste
6 6 hourly raffing average
19 6 Instantaneous
Nln Draft, Maximum, inches we
-0 50 audible alarm
•01 (10 sec delay)
00 Instantaneous
KHn Temperature. Minimum. *F
1416. Instantaneous
SCO Temperature. Minimum. «F
1825. Instantaneous
Stack Gas Velocity. Maximum, ft/sec
2133
Home Pressure Drop. Mta. Inches we
1 0
Quench Water Fkw, Minimum, gpm
397 4 alarm
350 Instantaneous
65-80
i, Maximum, ppmv
100 ppmv (10 sec delay)
200 ppmv Instantaneous
(may resume feed after i5 minutes operating s100
ppmv)
KHn Rotation. Maximum, rpm
I average
we-water column
gpm - gallons per minute
CO • carbon monoxide
ppmv - parts per million (by volume)
rpm - revolutions per minute
The following table lists values for parameters associated with operation of the incinerator at the
former NOP site The parameters were selected for this report based on USAGE guidance
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ForrmrNOPOU-1
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Former NOPOU-1
Oxygen Flow Rate
2.5 tph
Gas Residence Time in Rotary
Film
System Throughput (tph)
Kiln Minimum Temperature (°F)
SCO Combustion Temperature
(°R
5 3 seconds
(at 18 tph and
1200°F)
18
1150-1800
1800
NA
166 (average)
196
(instantaneous)
1416
1825
8 5 seconds*
(average)
13.44 (average)
1416-1616
1825-1950
NA-Not Applicable
tph-tons per hour
* Calculated based on 13 44 tph and 1516°C in the kiln
TREATMENT SYSTEM PERFORMANCE
PERFORMANCE OBJECTIVES
The following table lists the treatment compliance objectives for the MOP Incinerator These
objectives were established during the mini and trial bum tests and were approved by USEPA and
the USAGE
Table?. Treatment
POHC Destruction and Removal Efficiency (DRE)
Hydrochloric Add Stack Emissions
£40 Ib/hr or 2 99 % removal
Carbon Monoxide Stack Emissions
The following table lists the concentration objectives for soil treated in the incinerator operated at the
NOP facility These objectives were established In the ROD for OU1
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Former HOP OU-1
Table a Treated Soil
HMX
RDX
TNB
DNB
TNT
DNT
NT
Tatryl
1,7152
5.8
1.7
34
172
09
3430
343.0
In addition to treatment objectives for explosive compounds, Created soil (ash) also had to be below
the following TCLP (or corresponding total) concentrations before it could be returned to the site as
fill material. These requirements are outlined in the ROD for OU1.
Barium
1000
2,000
Cadmium
10
20
Chromium
50
100
Lead
5.0
100
Mercury
0.2
4
Silver
5.0
100
Selenium
JLSL
20
* Total concentrations are based on 20 times TCLP values
TREATMENT PLAN f31
Following construction of the incinerator in August 1997, a mini bum test was performed This test
consisted of three runs conducted on September 17 and 18 Contaminated site soils spiked with
naphthalene were used for the test The three runs confirmed that the incinerator could meet several
significant performance criteria, Including destruction and removal efficiency (DRE), paniculate
emissions, HCI emissions and backfill requirements (allowable ash concentrations). The following
table summarizes the results of the mini bum test
gr/dscf - grains per dry standard cubic foot
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. .-' • i • i .ii.ii Former HOP OU-1
Based on the results of the mini bum test, a tnal bum test of the incinerator was performed The test
consisted of four runs (run three was repeated) conducted from September 23 to 29 Table 11 lists
the operating parameters dunng the various tnal bum runs
Table 11. Trial Bum Process
Waste Feed Rate
Win Discharge
Temp
SCO Temperature
Secondary
Oxygen
Kiln Draft
Baghouse
Pressure Drop
Stack Carbon
Monoxide
SCC Quench
Recycle
Kiln Oxygen
Scrubber pH
Stack
Temperature
Stack Row Rate
SCC Draft
Kiln Rotation
Stack Oxygen
tons/hr
°F
°F
%
inches we
inches we
ppmv
gpm
%
PH
°F
fps
inches we
rpm
%
1734
1,417
1,813
601
-1 72
161
00
399
693
706
184
2136
-2.20
207
998
1551
1,412
1,823
592
-1.98
151
00
398
636
736
185
2067
-242
198
978
1688
1,427
1,806
592
-191
154
00
398
645
745
185
2136
-239
197
978
1688
1,408
1,849
565
-1.93
191
01
397
740
756
185
2178
-252
222
903
Test 4 was a re-run of Test 3
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Forn*r HOP OU-1
Table 12 lists analytical results for the contaminated soil fed to the incinerator (pnor to treatment)
during the trial bum test.
Table 12. Trial Bum Contaminated Soil Feed
Moisture. %
Heat Value,
BTU/lb
TNB, jug/kg
DNB.^q/kg
TNT.wg/kg
DNT.jua/kg
HMX.tfO/kg
NT, MO/kfl
RDX^o/ka
Tetryl, jwg/kg
Arsenic, mg/kg
Banum. mg/kg
Cadmium, mg/kg
Chromium,
Lead, mg/kg
Mercury, mg/kg
Selenium, mg/kg
f:j i TO J i iCT ITTaaa'
1 Naphthalene,
1 «o/ka
25
1,200
4.500
<510S
240.000
<510
<510
<510
<510
<510
<13
160
0.7
6
15
003
<13
6
190
158
2,100
5.800
<540
310.000
<540
<540
<540
<540
<540
5
160
0.8
6
14
003
<12
2
110
15.8
1,300
1,200
<490
150.000
<490
<490
<490
<490
13,000
5
170
1
8
15
0.04
<12
2
470
15.5
1,600
2,700
<510
160,000
<510
<510
<510
<510
1,500
5
150
08
7
14
003
<11
2
82
15.6
330
7,800
<440
76.000
<440
<440
<440
<440
3.000
NA
NA
NA
NA
NA
NA
NA
NA
<390
16.82
1,220
4.213
<491
165.000
<491
<491
<491
<491
4,506
7.6
160
085
7
145
0033
<11.8
27
273
•Metals and PHCs reported on a dry basis
"Represents duplicate sample.
'Estimated concentration below the reporting limit
Tables 13,14, and 15 list additional results from the Trial Bum including,
treatment soil concentrations, and baghouse ash concentrations
TREATMENT PERFORMANCE DATA
Treated soil (ash) was analyzed prior to disposal for parameters listed previously in this section
Explosives concentrations were compared to maximum allowable concentrations. Total metals
concentrations were compared to 20 times the allowable TCLP concentrations All results met the
explosives and metals treatment objectives with the exception of three samples, which did not meet
the total lead concentration requirement One of these samples was reanalyzed for total lead and
passed. The remaining two samples were reanalyzed for TCLP lead and also passed Starting on
December 12, all samples were analyzed for TCLP metals concentrations without first analyzing for
total metals concentrations Bypassing the total metals analysis step increased the analytical cost,
but allowed for more rapid determination of compliance with treatment criteria
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FormorNOPOU-1
Table 13. Trial Bum Stack Gas
2.4.6-Trl
<37E-6
<34E-6
NA
<35E-6
<3.5E-6
108E-2
RDX.
<3.7E-6
<34E-6
NA
<35E-6
<3.5E-6
106E-1
1,3.5-Trinttrobenzane. gfa
<3.7E-6
<34E-6
NA
<175E-S
8.2E-6
282E-3
LS-Dhiltrobenzene. gte
<37E-6
<34E-6
NA
<35E-6
<3.5E-6
811E-3
a4-DWtrotoluena. (
<37E-6
<34E-6
NA
<3.5E-6
<3.5E-€
4.39E-1
<37E-6
<34E-6
NA
<35E-6
<3.5E-6
318E-1
2,6-OWJrotoluene.afe
<37E-6
<3.4E-6
NA
<3.5E-6
05E-6
1.35E-1
NHrotohiane. pto
<37E-6
<3.4E-6
NA
<3.5E-6
<3.5E-6
2.5E+0
Nitrobenzene, gfls
1.2E-5
<55E-6
NA
<55E-6
<77E-6
6.38E-2
<59E-6
<5.5E-6
NA
<5.5E-6
<5.5E-6
180E-2
<59E-6
<55E-6
NA
<5.5E-6
enzo(k)f»uoranthene. ate
<81E-6
<7.5E-6
NA
<76E-6
<77E-6
567E-2
Chrysane, gfc
PfcenzofarQanthracene. i
<37E-6
<34E-6
NA
<35E-6
<3.5E-6
1.90E+0
<74E-6
<69E-6
NA
<69E-6
<71E-6
<44E-6
<41E-6
NA
<4.2E-6
10E-4
9.8E-5
NA
1 1E-4
34E-5
35E-5
41E-5
NA
37E-5
Barium, gfs
19E-4
19E-4
18E-4
NA
19E-4
790E-5
2.08E-3
371E-2
1J27E+0
BenBum.gts
<86E-7
<83E-7
<8.3E-7
NA
<84E-7
410E+0
Cadtntum, g^8
29E-6
58E-6
44E-6
NA
44E-6
194E-1
Chromium, g/s
24E-4
56E-5
NA
11E-4
1.55E-2
17E-5
<16E-5
<17E-5
NA
i<17E-S
Meroufy, gi's
27E-4
2.6E-4
21E-4
NA
24E-4
422E-4
21E-4
44E-4
10E-4
NA
2.5E-4
1.90E+0
<49E-5
5.9E-5
NA
<53E-5
190E-2
Silver,
<86E-6
1.5E-5
NA
1E-5
137E-2
Thaaum. ate
<49E-5
<50E-5
NA
<50E-5
i corrected to 7% Oxygen
<063
2.3
4.5
NA
<2.5
100
tTEQ
<0011
<00087
NA
<00090
<00096
NA
PCDD/PCDFsTEQ
<77E-11
<54E-11
NA
<56E-11
779E-9
NA-Results not available
g/s - grams per second
ng/dscm - nanograms per dry standard cubic meter
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
115
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Former NOP OU-1
Table 14. Contaminant C
Hone In Treated Soil Du
4500
3000
2700
2400
NA
1.3.5-Ttlnltobenzane. ua/kg
1500
<490
-------
Former NOPOU-1
Table 15. Contaminant Concentrations
During the Trial Bum
1,3-Onltrobenene.^gAg
<490
<450
<440
<470
3400
2,4.6-Trinltrotoleune. Mg/Kg
<490
<450
<440
<470
17200
2.4-Dlnltroto>uene.ti8/kg
<490
<450
<440
<470
900
2,6-DWtrottuene,ug/kg
<490
<450
<440
<470
900
HMX.«g/fcB
<490
<450
<440
<470
1.715.200
343.000
m-Nttrotoluene, ^g/kg
<490
<450
<440
<470
o*Nftotolu9ne, nfitoQ
<490
<450
<440
<470
343.000
p-Nitrotaluene, usfno
<490
<450
<440
<470
343,000
<490
<450
<440
<490
<450
<440
54
64
65
03
04
-------
FormwNOPOU-f
Table 16 summanzes selected results from explosives analyses performed on treated soil piles
None of the treatment objectives for explosives compounds were exceeded in any of the treated soil
samples
Results from Treated
HMX
RDX
TNB
DNB
TNT
2.4-DNT
2,6-DNT
60
60
60
60
60
60
60
0
2
0
0
25
0
0
MA
026-0.44
NA
MA
023-60
NA
NA
1,7152
58
17
34
17.2
09
0.9
NA-Not Applicable
Wastewater sample results were also compared to allowable concentrations for selected parameters
as specified in the NPDES permit application Most of the samples met all of the requirements,
however, three samples exceeded the maximum daily allowable concentration for iron The overall
average iron concentration for the project duration was below the allowable average concentration
In addition, the wastewater treatment system had difficulty meeting the proposed aluminum
concentration requirement throughout the project On December 4,1997, OHM requested that the
discharge limit for aluminum be waived based on the fact that aluminum is a common background
element in the site soil, and because it was estimated that treated water did not leave the former
NOP facility before infiltrating in the ground Because this project was conducted under CERCLA
regulations, it was not necessary to obtain this permit, or a waiver for aluminum
PERFORMANCE DATA QUALITY
A sampling and analysis plan (SAP), included as part of the construction quality control (CQC) plan,
was used for excavation sampling and for treated soil sampling performed on this project A total of
549 soil samples were collected from excavation bottoms and sidewalls. Results from the soil
samples were used to determine if additional excavation was necessary in each area. Each of the
60 treated soil piles was sampled individually Treated soil samples were collected as composites to
accurately represent each pile Results from the treated soil samples were used to determine if
treated soil could be returned to the site as fill material.
TREATMENT SYSTEM COST
PROCUREMENT PROCESS f!2l
OHM Remediation Services Corp. was selected to design, construct, test and operate the
incineration treatment system for this site. The contract bid quantity for this project was 9600 tons of
contaminated soil The bid price for this quantity was $6,748,302. This price translates to $703 per
ton of contaminated soil.
Because OHM had performed the initial design that was approved by the regulators, they were
•elected to perform construction and operation of the thermal treatment unit OHM subcontracted
with the following companies to perform the listed project tasks
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Offlct
118
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———————————————^———_ Former MOP O(M
Subcontractor
Judds Brothers Construction Grading, forming and placement of concrete foundations for the
thermal treatment unit, the feed preparation building, the oxygen
vaporizer, the propane tank saddles and the ash storage pad
Construction of the feed storage building
Davis Crane and Rigging Crane services for set up and teardowi
Miller Electric Electrical wiring for the treatment plant
Butler County Landfill Disposal of non-TSCA regulated PCB-contaminated soil
Kobus Construction Transportation of non-TSCA regulated PCB-contaminated soil to
the Butler County Landf i!'
TREATMENT SYSTEM COST tS\
The total project cost for remediation of OU 1 soils at the former NOP facility was $10,700,001. The
total mass of soil treated was 16,449 tons Therefore, the cost for treatment was $650 per ton of
contaminated soil Table 17 summarizes the costs for construction and operation of the incineration
system
COST SENSITIVITIES
According to the Feasibility Study, changes in the volume of soil to be treated would cause the
project cost to change significantly This was the only parameter that was identified in the Feasibility
Study as a significant source of cost sensitivity
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
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Former MOP CXM
m i aote i i. summary OT i reanmm vonm m HUK. warogonzeo Accorqing ro nw WBS IBJ
BBHH
33101
33101 01
33101.01 01
33101 01.02
33101 01 03
33101 01 04
33101 01 04.24
33101 01 06
33101.02
33101 02 09
331010211
33101.03
33101.0302
331010304
33101.0306
3310105
33101 05.07
3310106
331010801
33101 14
33101 1401
33101 14.01 05
33101 140106
33101.14.01 07
33101 14 01.09
33101 14 50
tm&ems&s&mam^fori^^Mud* • jjaam
H I'RW Remedial Action (Construction)
tori zation and Preparatory Work
toW rat on o Construction Equipment and Facilities
Mobilization o Personnel
Submitted/Implementation Plans
Setup/Construct Temporary Facilities
Security Fencing
Construct Temporary Fencing
Temporary RefocattonaVRoads/Structures/Utilities
Laboratory Chemical Analysis
Geotechnksal Testing
Includes testing for the concrete slab
Siteworfc
Clearing and Grubbing
Roads/Parking/Curbs/Walks
Electrical Distribution
Indudes transformer and connection fees
Surface Water Collection and Control
Sediment Barriers
Solids Collection and Containment
Contaminated Soil Collection
Digging, dean pit, includes hauling, includes dean cover
Thermal Treatment
Indneration
Mobilization/Setup of Portable Treatment Plan
Mob of all equipment to set up the temporary incinerator
Startup
Trial Bum
Demobilization of Portable Treatment Plant
40 trucks were used in demoting the equipment from the
incinerator
O&M of Permanent Treatment Plant During Construction
Plant was not constructed to operate in winter conditions, yet
the plant was winterized since the operations were extended
due to finding more contaminated soil
Construction of Permanent Plant Facility
Construction of a Metal building that will be left on site for the
owner to OCCUDV Size of metal buildina 8ffx\2ff
BB^
100
100
100
2,40000
100
100
100
700
1,00000
1,10000
20000
13,60700
100
100
100
400
100
EA
EA
EA
LF
EA
EA
EA
ACR
SY
LF
LF
CY
EA
EA
EA
EA
?•:$ '^l-i^i •» • i&'T.''' •'.;
113,59400
68,110.00
571.219.00
740
1.37900
173.51200
18,11700
4,59500
620
4183
1530
5548
2,133,01500
708,12000
601,23000
759,22000
730,80000
772.06200
113.59400
68.11000
571.21900
17.760.00
17,76000
1.37900
191.62900
173.51200
18,11700
84.37800
32.16500
6.20000
46,01300
3.06000
3.06000
754,916 38
754,916 38
7.210.045.00
6.479.245 00
2,133,015 00
708,120 00
601,23000
3,036,880 00
730,800 00
US ENVIRONMENTAL PROTECTION AGENCY
Office of SoW Waste and Emergency Response
Technology Innovation Office
120
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••••
33101.19
33101 1921
33101.1922
3310120
331012001
3310120.03
33101200301
3310120.04
3310121
3310121 01
3310121.01 24
3310121 04
3310121.05
HBHHHBHB99HBEQH
Disposal (Commercial)
Transportation to Storage/Disposal Facility
Di
Si
Isposal Fees and Taxes
te Restoration
Earthwork
hauling and backfill
Permanent Features
Roads
Repair of existing roads on site
Revegetation and Planting
University of Nebraska is doing all the revegetation
Demobilization
Removal of Temporary Facilities
Security Fencing
Removal of temporary fencing
Demobilization of Construction Equipment and Facilities
Demobilization of Personnel
E3B9I
125000
1.25000
13,60700
15,00000
1100
2,40000
100
100
TON
TON
CY
SY
ACR
LF
EA
EA
1470
7980
8320
1000
15300
250
207.000.00
69,000.00
onnwnur uu-7
PBBI
118,12500
18.375.00
99.75000
1.283.78538
1,132,10238
150.00000
150,00000
1,68300
282.00000
6.00000
6,00000
207.00000
69.000.00
•IK r, P. i»ra m p [<^/:
-------
__^__-_—^_-—-——^—-—-——————————————— Form* HOP OU-1
It is possible that overall project costs could have bean reduced by using a unit price payment
schedule instead of alime and materials schedule If unit pricing (payment per mass of soil treated)
had been used, the USAGE would not have incurred labor and equipment costs during down time
associated with equipment failure or material handling problems The element of nsk assumed by
the contractor on this project created an inherent difficulty in negotiating the cost of remediation
under a unit price payment schedule Because this contract was negotiated under a pre-placed
remedial action contract, and with a short procurement schedule, it was difficult to determine a
"reasonable cost" for the risks assumed by the contractor It is recommended that project managers
use competitive procurements for future unit price incineration projects.
REGULATORY/INSTITUTIONAL ISSUES
Because this project was performed under CERCLA regulations, it was not necessary to obtain
permits from local regulatory authorities for on-site activities It was necessary, however, to meet the
substantive requirements of potentially applicable regulations The following permitting and public
relations issues were addressed on this project
• A NPDES permit application was submitted for wastewater discharges associated with the
thermal treatment system For reasons discussed above, a permit was never issued Dunng
treatment operations, a problem arose with treatment of aluminum It was subsequently
speculated that the elevated aluminum concentrations in the wastewater were a result of
high aluminum background concentrations in the site soil
• A public meeting was held on October 13,1997 to discuss the operating limits of the
incineration system The operating limits that were approved at this meeting are presented
at the beginning of this section Treatment of contaminated soil began the next day (October
14)
• A permit for disposal of soil and debns from the NOP site at the Butler County Landfill was
issued on October 21,1997 This permit was necessary to handle any material that was too
large to be processed through the kiln
OBSERVATIONS AND LESSONS LEARNED
COST OBSERVATIONS AND LESSONS LEARMED
Project costs were higher than expected due to the increased volume of contaminated soil that was
encountered during excavation These additional costs could have been accounted for during the
procurement process if site investigations had more accurately delineated the extent of
contamination
Additional costs were also incurred due to shut down of the system during a penod of inclement
winter weather These costs could have been avoided if the system had been operated during a
warmer portion of the year. Because the project was performed under a tight time table, it is unlikely
that these additional costs could have been avoided
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
122
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——^——.^—_—.^_____ Former HOP OU-1
It is recommended that better planning and scheduling be performed during the procurement phase
on future similar projects Because the project schedule was so tight, the USAGE lost some
leverage dunng contracting negotiations
PERFORMANCE OBSERVATIONS AMD LESSONS LEARNED
Dunng operation, the most sensitive aspect of the treatment system was the soil feed system On
several occasions the incinerator had to be shut down to address issues with the feed system. It is
recommended that future projects of this nature place increased emphasis on selecting and
designing the most appropriate feed system
Unexpected problems associated with handling of high and low moisture-content soil were observed
on several occasions dunng treatment These problems were chiefly observed in the feed system. In
addition, a recurring problem was observed relating to separation of extremely fine soil particles
dunng treatment This fine material became suspended at the top of the wet ash conveyor, and
when the suspension became thick enough it would inhibit discharge of solids from the bottom of the
tank This problem was ultimately solved by periodically pumping the suspended soil to the ash
handling area where it was gravity dewatered and filtered through hay bales It is recommended that
future projects of this nature include preliminary study of the handling charactenstics of the soil to be
treated In addition, it may be beneficial to include pilot-scale testing as part of the system design.
This would allow the design team to identify problems similar to those described above pnor to full-
scale operation
OTHER OBSERVATIONS AND LESSONS LEARNED f14l
It is recommended that future projects Include a preliminary meeting with field office personnel and
CX personnel The purpose of this meeting would be to provide insight regarding past projects of a
similar nature
The primary remedial action objective was to eliminate the potential for dermal exposure to
contaminants in the soil at the site To achieve this objective, the top four feet of soil was excavated
and incinerated in areas identified as being contaminated. Additional areas were excavated to
remove potential sources of groundwater contamination Contaminated areas were identified in the
vicinity of the former load lines based on historical records that descnbed discharge of contaminated
wash water dunng facility cleaning activities
Site conceptual model assumptions from the remedial investigation did not correlate in all cases to
observations made in the field dunng soil excavation activities For example, a substantial volume
of additional contaminated material was found at the Burning/Proving Grounds The contaminants
were placed in this area by burning and burial of explosive materials, not by discharge of
contaminated surface water Therefore, the site conceptual model did not predict the presence of
large pieces of unbumed explosives in the subsurface at this site Unbumed explosives were
observed at depths between 4 and 12 feet bgs dunng excavation at the Burning/Proving Grounds
Discrete soil sampling may not have been appropriate for characterizing this explosives-
contaminated site Explosives are solid at ambient temperature, dissolve slowly and sparingly in
aqueous solution and have low vapor pressures These properties can restrict the transport rates of
these contaminants in soil, especially when compared to rates for other contaminants, such as fuels
or solvents Typically, areas of high explosives contamination will remain at or near the ground
surface at the point of deposition, unless the soil containing the contamination Is physically moved.
Too often, local spatial heterogeneity Is ignored In favor of sampling, based on the theory that
heterogeneity will be accounted for if the number of samples is sufficiently large. At this site,
heterogeneity of contamination was not properly accounted for by characterization soil sampling
Although it Is possible to over-characterize a site, project planners may increase the efficiency of
remedial actions by performing a combination of composite sampling, field homogenlzation of
samples and on-slte colorimetric analyses. This type of characterization will produce data that are
U 8 ENVIRONMENTAL PROTECTION AGENCY ' ——
Office of Solid Waste and Emergency Response
Technology Innovation Office
-------
Former NOP OU-1
accurate and precise, but that also may be more representative of site conditions It is also
recommended that the type of characterization sampling be selected based on the nature of
contaminant deposition This may necessitate varying sampling methods in different areas at a
single facility
To ensure proper blending of contaminated soil prior to incineration, it is recommended that any
identified "hot spots" be remediated prior to incineration. This will help ensure that the feed material
to the incinerator remains uniform during treatment operations
A problem with freezing of a water line was encountered on one occasion dunng operation of the
treatment unit it was subsequently determined that the buned water line had frozen due to its
proximity to a liquid oxygen line During a period of low air temperature, the sheath of ice that
typically surrounds a liquid oxygen line expanded and encompassed the water line It is
recommended that future projects take into account this possibility when locating utilities
It is recommended that future projects include regular project team meetings or conference calls
The NOP project included a weekly conference call attended by representatives from the USAGE,
USEPA, NDEQ, and OHM Allowing a weekly forum for project communication helped facilitate
timely, efficient completion of the project
This project used an innovative procedure for obtaining timely approval of allowable airborne
contaminant emission rates from the treatment unit Prior to performance of the mini brm or trial
bum tests, a list was developed of emission rates that met typical air permitting requirements These
hypothetical rates were submitted to NDEQ and USEPA, and were ultimately approved after review
and comments by the regulatory agencies When the mini bum and tnal bum tests were completed
and it was determined that the system could keep emission rates below the hypothetical rates, rapid
approval was obtained for full-scale operation of the system Full-scale production began
approximately two weeks followinr completion of the tnal bum test It is recommended that other
projects of this nature use this procedure if rapid approval of emission rates is desired
REFERENCES
1) Final Record of Decision. Operable Unit 1, Former Nebraska Ordnance Plant, Mead
Nebraska, USEPA Region VII and USAGE Kansas City District, August 1995
2) Draft Remedial Action Report. Former Nebraska Ordnance Plant, OU-1, Mead Nebraska,
OHM Remediation Services Corporation, January 1998
3) Incineration of Explosives Contaminated Soil at the Former Nebraska Ordnance Plant.
William J Crawford, P E (USAGE) and Kevin W Birkett (USAGE), January 8,1998
4) Operation and Maintenance Manual. Mead Thermal Treatment Unit, Asset No 61027, OHM
Remediation Services Corporation, August 1997
5) The Merck Index. Eleventh Edition, Merck and Co, 1989
6) Hawlev's Condensed Chemical Dictionary. Eleventh Edition. N Irving Sax and Richard J
Lewis, Sr, 1987
7) Handbook of Environmental Data on Organic Chemicals. Second Edition, Karel
Verschueren, 1983
8) Former NE Ordnance Plant Operation Unit #1. Single Project WBS Report - With Notes, no
date provided.
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Reeponee
Technology Innovation Office
ImrT
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Former HOP OU-1
9)
10)
11)
12)
13)
14)
Memorandum - From John OToole, to File, dated September 23,1997, Re NPDES
PERMIT, Discharge Standards
Remedial Alternative Feasibility Study. Operable Unit 1. Former Nebraska Ordnance Plant.
RUST Environmental, September 22,1993
Supplemental RI/FS. Former Nebraska Avenue Plant. Operable Unit 1. Mead. Nebraska.
SEC Donohue, September 23,1992
Draft Remedial Action Report for the Fonner Nebraska Ordnance Plant. OU-1 ,?. Mead.
Nebraska. OHM Remediation Services Corporation, March 13,1998
Encyclopedia of Explosives and Related Items. PATR 2700, Volume 9, US Army Armament
Research and Development Command, 1980
Sampling Error Associated with Collection and Analysis of Soil Samples at TNT-
Contaminated Sites. T F Jenkins, et al, published in Field Analytical Chemistry and
Technology 1 (3) 151-163,1997
ACKNOWLEDGMENTS
This report was prepared for the U S Army Corps of Engineers under USACE Contract No
DACA45-96-D-0016, Delivery Order No 12
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
125
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This Page Intentionally Left Blank
126
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On-Site Incineration at the
MOTCO Superfund Site
Texas City, Texas
127
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Incineration at the MOTCO Superfund Site
Texas City, Texas
Site Name:
MOTCO Superfund Site
Location:
Texas City, Texas
Contaminants:
Styrene tars, VOCs, PCBs, and
metals
benzene, vinyl chloride, 1,1,2-
trichloroethane, lead, cadmium,
mercury, and chromium
Period of Operation:
May 1990 to December
-991
« '^•^^•^••••••^^^•i^^HMMMMMMB
Cleanup Type:
Remedial action
Vendor:
IT Corporation
312 Directors Drive
Knoxville, TN 37923
(423)690-3211
SIC Code:
2865 (Industrial organic
chemicals)
Technology:
• Two incineration systems
the Hybrid Thermal Treatment
System* HTTS-2 and
HTTS-3, HTTS-2 designed to
process solids, sludges, tars,
aqueous wastes, and organic
liquids, and HTTS-3
designed to process aqueous
wastes and organic liquids
• Solids transferred to feed
preparation building where
materials were mixed and
screened
• The HTTS-2 consisted of two
chambers (the kiln and SCC)
and a gas cleaning system
consisting of a quench
system, gas conditioner, wet
scrubber system, and a vane
separator; the HTTS-3
consisted of a combustion
chamber and a gas cleaning
system
• Solids, sludges, and aqueous
wastes fed to the HTTS-2 kiln
by a screw conveyor; organic
liquid wastes used as primary
fuels in the kiln
• Residual ash from kiln
collected, landfilled, and
capped on site
Cleanup Authority:
CERCLA and State
Texas
• ROD signed 3/15/85
• RP-lead, EPA oversight
Point of Contact:
Ashby McMullan
Texas Natural Resources
Conservation Commission
(512) 239-1000
Wast* Source:
On site pits - styrene tars and
chemical wastes - wood
preserving wastes
Type/Quantity of Media Treated:
Soil, sludge, organic liquids, and aqueous wastes
• 10,471 tons aqueous wastes
• 7,568 tons organic liquids
• 283 tons sludges and tars
• 4,699 tons soH
128
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Incineration at the MOTCO Superf und Site
Texas City, Texas
(Continued)
Purpose/Significance of Application:
Mechanical problems were encountered, caused in part by lack of accurate waste
characterization, onslte incineration halted in December 1991 because of dispute between the
contractor and RP; remedy changed to off-site incineration in part because of dispute and
mechanical problems
Regulatory Requirements/Cleanup Goals:
Destruction and Removal Efficiency (ORE) of 99 99% for each principal organic hazardous
constituent as required by Resource Conservation and Recovery Act (RCRA) incinerator
regulations In 40 CFR part 264, subpart 0,99.9999% ORE for PCBs as required by Toxic
Substances Control Act (TSCA) regulations in 40 CFR part 761
Results:
Emissions and performance data indicate that all ORE and emissions standards have been met
Description:
The MOTCO site was established in 1959 for the recycling of styrene tars From 1961 to 1968,
on-sfte pits that held styrene tars were used for the disposal of chemical wastes from local
industries In March 1985, a Record of Decision (ROD) that required source control was signed,
and in September 1989, a ROD that addressed off-site migration of contaminants was signed
The remedy selected for the first Operable Unit (OU-1) was off-site treatment and disposal of
contaminated material, however, the ROD specified that on-site incineration was a viable
alternative to be evaluated dui ing the design phase A later Consent Decree required on-ate
incineration and established incinerator requirements
The site operated two incineration systems The first system was called the Hybnd Thermal
Treatment System* 2 (HTTS*-2), and the second system was referred to as HTTS-3. The HTTS-
2 consisted of a rotary kiln, a secondary combustion chamber (SCC), and a gas cleaning system.
This incineration system processed solids, sludges, tars, aqueous wastes, and organic liquids
The HTTS-3 consisted of a combustion chamber and gas cleaning system identical to the SCC
and gas cleaning system of the HTTS-2 The HTTS-3 processed only aqueous wastes and
organic liquids
In December 1991, the HTTS-3 had passed the tnal bum and was performing under intenm
operating conditions, and the HTTS-2 was in the process of conducting a tnal bum when the
contractors stopped incineration and filed a lawsuit against the responsible party (RP) for breach
of contract. Due to the dispute and several technical problems (Including slagging), on-site
incineration did not resume
In January 1993, an Explanation of Significant Differences (ESD) specified off-site incineration of
the remaining sludges, tars and organic liquid The remaining soil was to be capped on site
The cost incurred during the on-site incineration was approximately $76 million consisting of $20
million in capital costs and $56 million in operating costs.
129
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MOTCO Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-srte incineration at the
MOTCO Super! und site in Texas City, Texas
Incineration began in May 1990 but was halted
in December 1991 by a contractor dispute
Contaminants of concern at the site were PCBs,
styrene tars, volatile organic compounds
(VOCs), and metals
The MOTCO site was established in 1959 for
the recycling of styrene tars. The recycling was
discontinued in 1961 due to damage by
Hurricane Carta From 1961 to 1968, on-site
pits that held styrene tars were used for the
disposal of chemical wastes from local
industries In March 1985, a Record of Decision
(ROD) that required source control was signed,
and in September 1989, a ROD that addressed
off-site migration of contaminants was signed
This report addresses the incineration specified
in the first ROD, unless otherwise stated
The remedy selected for the first Operable Unit
(OU-1) was off-site treatment and disposal of
contaminated material; however, the ROD
specified that on-srte incineration was a viable
alternative to be evaluated during the design
phase A later Consent Decree required on-site
incineration and set incinerator requirements
including a destruction and removal efficiency
(DRE) of 99 99% for each principal organic
hazardous constituent (POHC) and 99 9999%
for polychlorinated Wphenyls (PCBs)
The site operated two incineration systems The
first system was called the Hybrid Thermal
Treatment System* 2 (HTTS*-2), and the
second system was referred to as HTTS-3 The
HTTS-2 consisted of a rotary kiln, a secondary
combustion chamber (SCC), and a gas cleaning
system. This incineration system processed
solids, sludges, tars, aqueous wastes, and
organic liquids. The HTTS-3 consisted of a
combustion chamber and gas cleaning system
identical to the SCC and gas cleaning system of
the HTTS-2. The HTTS-3 processed only
aqueous wastes and organic liquids
In the rotary kiln, organic compounds from
the contaminated matenal were volatilized
and destroyed The exhaust gases were
channeled to the SCC The SCC provided
further combustion of organics in the off-
gases, which were then water quenched
Waste oils were used as fuel in the kiln and
SCC of the HTTS-2 and in the combustion
chamber of the HTTS-3
The gas cleaning systems for both
incineration systems consisted of a quench
system, a gas conditioner, a wet scrubber,
and a vane separator The quench system
and gas conditioner removed paniculate
and acid gas Caustic solution was sprayed
into the gas stream in the wet scrubber for
particulate matter and acid gas removal,
and the solution was then removed from the
gas stream by the vane separator
In December 1991, the HTTS-3 had passed
the trial bum and was performing under
interim operating conditions, and the HTTS-
2 was in the process of conducting a trial
bum when the contractors stopped
incineration and filed a lawsuit against the
responsible party (RP) for breach of
contract Due to the dispute and several
technical problems (including slagging), on-
site incineration did not resume
In January 1993, an Explanation of
Significant Differences (ESD) specified off-
site incineration of the remaining sludges,
tars and organic liquid The remaining soil
was to be capped on site
The cost incurred during the on-slte
incineration was approximately $76 million
consisting of $20 million in capital costs and
$56 million in operating costs
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
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MOTCO Superfund Site
SITE INFORMATION
Identifying Information
MOTCO Superfund Site
Texas City, Texas
CERCLIS # TXD980629851
ROD Date: March 15,1985 (OU-1)
Rnclcaraund
Traatmant Annllcailon
Type of action: Remedial (on-site
incineration)
Period of incinerator operation: May
1990-December 1991
Quantity of material treated during
application: 10,471 tons of aqueous
wastes, 7,568 tons of organic liquids, 283
tons of sludges and tars, and 4,699 tons of
soil
Historical Activity that Generated
Contamination at the Site: Recycling styrene
tars and disposal of petrochemical wastes
Corresponding SIC Code: 2865 Industrial
organic chemicals
Waste Management Practice That
Contributed to Contamination: Disposal of
wastes is unlined surface impoundments
Site History:
• The MOTCO site is located on the Gulf
Coastal Plain at the edge of a coastal marsh
system
• The site is within 1/4 mile of the habitats of
four endangered species in Texas (the
Brown Pelican, the Arctic Peregrine Falcon,
the Attwater's Frame Chicken, and the
American Alligator) as listed in Endangered
Species of Texas and Oklahoma 1980 [2]
• The site recycled styrene tars from 1959
until 1961 when flood waters from Hurricane
Carla inundated pits containing the styrene
tars The pits on the site were then used
until 1968 for disposal of chemical wastes
from local petrochemical industries [12]
• During this period, various solvent wastes
were disposed of in seven unlined waste
disposal pits. An estimated 500,000 gallons
of material was disposal of; some of this
Baekctmund /Cont.l
matenal was removed dunng attempts
at waste recycling in the 1970s [13]
• The pit contained four layers of source
matenal surface pit water (aqueous
waste), organic liquids, sludges and
tars, and soil The aqueous waste was
acidic and contained metals and
organics The organic liquid was
igmtable and the primary contaminants
werePCBs The sludge/tar layer and
the soil contained styrene tars, VOCs,
and metals [1]
• In 1980, the US Coast Guard removed
drums, extended a dike around the
perimeter of the pits, and erected a
fence around the pits cPA conducted
three emergency response actions
(September 1981, March 1983, and
September 1983) to treat and discharge
excess aqueous liquid caused by heavy
rainfall [3]
• Two site investigations were conducted
in 1981-82 and a Feasibility Study (FS)
was completed in September 1984
• The contaminated materials to be
Incinerated were located in seven
unlined pits covering a surface area of
approximately 4 6 acres The OU-1
ROD estimated that 62,200 tons of
aqueous wastes, 13,920 tons of
sludges/tars, and 31,950 tons of soil
would require Incineration.
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
131
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MOTCO Suparfund Sit*
SITE INFORMATION (CONT.)
• Incineration began in May 1990, but ended
in December 1991 when the remedial
contractors filed suit against the RP for
breach of contract. The dispute involved
several operational problems discussed
later in this report under Lessons Learned
• In the time that the on-site incinerators
operated, 10,471 tons of aqueous wastes,
7,568 tons of oil, 283 tons of sludges/tars,
and 4,699 tons of soil were incinerated
When on-site incineration ceased, it *as
estimated that approximately 8,100 tons of
organic liquid, 10,100 tons of sludges/tars,
and 61,600 tons of soil remained at the site
[12] All PCB-contaminated organics had
been incinerated by this time
Regulatory Context:
• In Jury 1982, the MOTCO site was placed
on the National Priorities List (NPL)
• An OU-1 ROD was signed in March 1985,
specifying source control by incineration of
organic liquids on site or off site, biological
treatment of pit surface water and/or on-site
incineration, and off-site landfillmg of
sludges, tars, and soils or on-site
incineration [3]
• In 1987, EPA and the RP entered into a
Consent Decree At that time, the
alternative of on-site incineration was
selected
• The OU-2 ROD was signed in September
1989, specifying management of migration
by incineration of dense, nonaqueous phase
liquids (DNAPLs), treatment of
contaminated ground water, and
consolidation and capping of slightly
contaminated surface soils [41
• During the design phase for the OU-2
remedy, EPA determined that long-term
management of the site was necessary
The complete removal of all
contaminated matenal associated with
OU-1 was deemed no longer essential,
therefore contaminated soils were left
on site to be incinerated by the OU-2
remedy [12]
• EPA prepared an Explanation of
Significant Differences (ESD) in
January 1993, specifying off-site
incineration of liquids and sludges/tars
and capping of contaminated soils [12]
• The remedial standards applied at
MOTCO were based on the following
laws, regulations, and policies the
Toxic Substances Control Act (TSCA)
and associated regulations in 40 CFR
part 761, Executive Order 11990
(Protection of Wetlands), Executive
Order 11988, (Floodplam Management),
and the Resource Conservation and
Recovery Act (RCRA) and associated
regulations in 40 CFR part 264, subpart
0[3]
• Site activities were conducted under
provisions of the Comprehensive
Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), as amended by the
Superfund Amendments and
Reauthorization Act (SARA) of 1986,
and the National Contingency Plan
(NCP) 40 CFR part 300 [12]
Remedy Selection: On-site rotary kiln
incineration was selected as the remedy for
the contamination at the MOTCO site based
on the results of the RI/FS, two site
investigations, a responsiveness summary,
and long-term economic considerations [3]
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wsjte and Emergency Retpome
Technology Innovation Office
132
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Timeline
MOTCO Superfund Site
Table 1 Timeline f 21
yp^j^K^^^i^
1959-1968
1981
1962
July 1982
September 1984
March 1985
October 1987
October 1990
May 1990- December 1991
December 1991
January 1993
Operations ware performed at the MOTCO site
Initial site Investigation performed
Second site rnvasUgaUan conducted
Site placed on the NPL
Feastoffity Study completed
Record of Decision f or OU-1 signed
EPA entered into a Consent Decree with a number of Potentially Responsible Parties
Trial Bum for second incineration system (HTTS-3)
Incineration occurred on site
Contractor stopped Incineration and fled suit against RP
ESD specified off-site incineration as new remetfal action for liquids and sludges/tars with
capping 01 coniarTiin&ou SON..
SJteLontetlM/Contacte
Site Management: HP-Lead
Oversight: EPA
Remedial Project Manager:
Cartrs Sanchez
U.S EPA Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 665-8507
State Contact:
Ashby McMullan
Texas Natural Resources Conservation
Commission
(512) 239-1000
Treatment System Vendor:
IT Corporation
312 Directors Onve
Knoxville, TN 37923
(423) 690-3211
MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed
Through the Treatment System: Soils,
sludges, tars, organic liquids, and aqueous
wastes were removed from unlined pits
Contaminant
Characterization
Primary Contaminant Groups: Styrene tars,
VOCs, PCBs and metals
• The contaminants of greatest concern were
styrene tars, benzene, vinyl chloride, 1,1,2-
trichloroethane, lead, cadmium, mercury,
and chromium
• The maximum concentrations of
selected organic constituents and
metals in the pit wastes were 22,000
mg/kg of styrene, 61,000 mg/kg of
1,1,2-trichloroethane, 41,500 mg/kg of
1,2-dlchloroethane, 7,600 mg/kg of vinyl
chloride, 5,440 mg/kg of benzene,
12,000 mg/kg of aluminum, 920 mg/kg
of cadmium, 550 mg/kg of chromium,
and 46,000 mg/kg of lead.
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
133
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MOTCOSMMTftmrfSfte
MATRIX DESCRIPTION (CONT.)
The major matrix characteristics that most significantly affected cost or performance at the site and
their measured values are presented in Table 2
Table 2 Matrix Characteristics of
Density
Ash Content
OfgmfcCMorine
1003 gAnl
0.59%
0048%
The matrices most affecting cost were the
viscosity and heat content of the oils and
sludcds. For example, the heat content of the
as-encountered waste exceeded the as-
characterized waste by 40 percent, and the
as-encountered waste viscosity substantially
exceeded the as-characterized viscosity This
required the majority o* the waste feed to be
treated in the smaller HTTS-2 kiln instead of
in the two SCO chambers as onginally
planned The net result was that the
equipment on site had excess capacity for
treating pumpable sludges and insufficient
capacity to treat solid sludges and soils
Hence, the project was not as economical as
had onginally been planned
TREATMENT SYSTEM DESCRIPTION
HTTS-2-
• Rotary kiln; and
• Secondary combustion chamber (SCO).
HTTS-3
• Combustion chamber
SiiDDtemantal Traatmant Technology
Pretreatment (solids) Shredded and Mixed
Post-Treatment (air) for both HTTS-2 and
HTTS-3, including-
• Quench system,
• Gas conditioner;
• Wet scrubber hydro-sonic tandem
nozzle scrubber system; and
• Vane separator.
Post-Treatment (water) Filtration in a
closed-loop system
rtotk
Two incineration systems were designed for
useattheMOTCOsHe: HTTS-2 and
HTTS-3. The HTTS-2 was designed to
process solids, sludges, tars, aqueous
wastes, and organic liquids. The HTTS-3
was designed to process only aqueous
wastes and organic liquids
Organic liquids, aqueous waste, and
pumpable sludge were transferred to
dedicated tanks before being fed to the
incineration systems Any solids were
prepared in the feed preparation
building where materials were mixed to
provide a homogeneous matrix, then
screened. Oversized material was
shredded and remixed.
U 3. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wast* and Emwgancy Response
Technology Innovation Offlca
134
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MOTCO Supfrfund SHe
TREATMENT SYSTEM DESCRIPTION (CONT.)
Sv«fam Pagcriptlon and Operation fConU
• The HTTS-2 employed at the MOTCO site
consisted of two chambers (the kiln Itself
and the SCC) and a gas cleaning system
consisting of a quench system, gas
conditioner, wet scrubber system, and a
vane separator The HTTS-3 consisted of a
combustion chamber and a gas cleaning
system that were identical to the SCC and
gas cleaning system of the HTTS-2
• Solids, sludges, and aqueous wastes were
fed to the HTTS-2 kiln by a screw conveyor
designed to minimize air infiltration, and the
sludges and aqueous waste were pumped
from separate tanks through separate
lances into the kiln Organic liquid wastes
were used as primary fuels in the kiln
• The HTTS-2 kiln was a carbon steel
chamber that measured 45 feet long, with
an outer diameter of 7 feet, 7 inches, an
inner diameter of 6 feet, 6 inches, and a
volume of 1,540 cubic feet The kiln was
lined with a 6-inch-thick layer of super-duty
refractory brick. The kiln was rated at 40
million BTU/hr The kiln was of
countercurrent design and was capable of
operating in either an oxidative mode or a
combined oxidative and reductive mode,
depending on the waste feed
• The aqueous wastes and organic liquid
wastes were injected into the HTTS-3
combustion chamber burners through air-
atomized burner guns Organic liquid
wastes were also used as primary fuels for
the SCC and the HTTS-3 incineration
chamber main burners
• The SCC for the HTTS-2 and the
combustion chamber for the HTTS-3 were
down-fired steel chambers The chambers
were lined with 7 to 9 inches of refractory
insulating material and were approximately
52 feet tall with an outer diameter of 12 feet.
The units operated at a minimum of 3
percent excess oxygen with a 2-second off-
gas retention time.
• Residual ash from the kiln was collected
and was to be Sandffiled and capped on site,
but disposal of the ash did not occur before
the contractors stopped Incineration and
filed the lawsuit Disposal of ash was
addressed by the subsequent BSD.
The exhaust gases from the HTTS-2
SCC and the HTTS-3 combustion
chamber were directed through
separate but identical gas cleaning
systems First, the gases were routed
to the quench system for cooling and
removal of particulate matter and acid
gas Flue gas from the quench system
then flowed into the gas conditioner,
where additional particulate matter and
acid gas were removed.
Gas leaving the gas conditioner ente'e4
the first of two Hydro-Sonic* subsonic
nozzles where caustic solution was
sprayed into the gas stream The gas
stream then passed through a mixing
tube to the second Hydro-Sonic*
subsonic nozzle for additional
treatment.
The gas stream passed through a
second mixing tube before entering the
vane separator, where the spray
solution from the scrubber was
removed
Combustion gases were drawn through
the incineration system by an induced
draft fan (resulting in a constant
negative pressure throughout the
system) and were exhausted through an
80-foot fiberglass reinforced plastic
Both systems had an emergency relief
vent system to treat off-gases from the
kiln during emergency shutdowns. The
Environmentally Safe Temporary
Emergency Relief System* (ESTER*)
received electricity from a battery-
powered unlnterruptable power source,
so the off-gases were treated even
during power outages. The ESTER
system consisted of a natural gas ring
burner, two continuous gas pilots, and
two natural draft air dampers. The
system was designed to be a complete
stand-alone combustion system In
emergency shutdown situations [5]
U.S. ENVIRONMENTAL PROTECTION AQENCV
Office of Solid Watte and Emergency Response
Technology Innovation Office
135
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UOTCOSuperfundSOe
TREATMENT SYSTEM PERFORMANCE (CONT.)
Tabled Summary of
Residence Time (Solids)
15 to 90 minutes
System Throughput
NA
Kiln Exit Temperature
800°-1800°F
TREATMENT SYSTEM PERFORMANCE
The cleanup goals and standards were
specified by the Consent Decree The ORE
and ash residual standards were set based
on regulations under TSCA in 40 CFR part
761,subpartD
The pits were to be excavated to the sludge/
soil interface and to a depth of one foot
below the sludge/soil interface. The
sludge/soil interface was identified visually
by the personnel performing the excavation
[3]
Cleanup levels had to conform to a level
that presented a lifetime increased cancer
nsk of 1x10* or less
Applicable or relevant and appropriate
requirements (ARARs) required a ORE
of 99 99 percent for POHCs and
99 9999 percent for PCBs
The management of residual ash from
on-site incineration was addressed by
the second consent decree that
specified off-site incineration
The trial bums conducted at the MOTCO
site were designed to operate the
incineration system at conditions that would
reflect worst-case destruction and removal
of all constituents of concern
Naphthalene, 1,1,2-tnchloroethane, and
carbon tetrachlonde were selected as the
POHCs for the MOTCO site
The MOTCO site was required to
demonstrate a 99 9999 percent ORE for
PCBs However, the concentration of PCBs
was not sufficient to demonstrate this ORE.
Therefore, the DREs for 1,1,2-
trichloroethane and carbon tetrachloride
were demonstrated to be greater than
99 9999 percent rather than the 99 99
percent specified [5]
Before the trial bum for HTTS-3, the
wastes were analyzed and a 10 percent
spike of 1,1,2-trichloroethane and a 10
percent spike of carbon tetrachloride
were added to the organic liquids.
Concentrations of naphthalene were
measured and were deemed high
enough so that spiking was not
necessary
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
136
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MOTCOSuptrfundSite
•MENT SYSTEM PERFORMANCE
• The AWFCO limits for the incinerator are
shewn in Table 4 Information about the
frequency of AWFCOs was not available
• The HTTS-3 had completed a trial bum and
was running under interim standards and the
HTTS-2 was in the process of conducting a
trial bum when on-srte incineration ceased
as the result of a dispute between the RP
and the contractor The chemical makeup,
quantities, and mixture of the waste were
found to be different than initially estimated
As a result, the incineration systems were
not properly designed for the actual waste
A number of technical difficulties were
expenenced with the systems, including
slagging, paniculate carryover, dust
blocking the flame detector in the kiln, and
low utility fuel gas pressure
• Several problems that caused the
dispute are presented in the Lessons
Learned section of this report
Table 4 Proposed Automatic Waste Feed Cutoffs for HTTS-2 and HTTS-3
MMmum rotary Mb) temperature
-a I. •! t. fe * A.
Minimum secondary combustion chamber temperature
Maximum Mn soMfeludge/aqueous flow (HTT5-2only)
Maximum Win organic liquid flow (HTTS - 2 only)
Maximum SCC organic liquid flow
Maximum SCC aqueous waste flow
Maxknum Mn pressure (15 second delay) (HTTS • 2 only)
Maximum quench chamber temperature
Maximum sncK gas caroon monoxKie cuncenvanon ( i-nour
Minimum stack gas oxygen concentration
Maximum stack gas ftow(1 hour roWng average)
SOOT
2,020
20tons/hr
2,500 to/hr
7,300 IbAir
9,700 tolhr
0 Inches we
220 F
35 Inches we
lOOppm
3vol%dry
55,000 acfm
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
137
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MOTCO Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
A list of contaminants detected in the
various matrices at the site is available in
the Initial Investigation [1]
According to site personnel, the Quality
Assurance/Quality Control (QA/QC)
program, used throughout the remedial
action met the EPA and the State of Texas
requirements
TREATMENT SYSTEM COST
• The RP contracted with IT Corporation to
conduct the remedial work
Cost Data
The total capital cost exceeded $20 million
In the time that the incineration systems
were operated, the contractor spent
approximately $56 million in operating and
maintenance costs The initial bid for on-
slte incineration was $30 million, and at the
time
Data Oiialltw
the contractors stopped incineration and
filed the lawsuit, the RP had paid the
contractor $20 million The total cost to
complete the on-site incineration was
estimated to be $110 million A total of
23,021 tons of material - including soil
sludge, organic liquid, and aqueous
waste ~ were incinerated This
corresponds to a total unit cost for
incineration of $3,300 per ton
Cost data was acquired through personal
communications between IT and EPA and
between the RP and EPA
OBSERVATIONS AND LESSONS LEARNED
The Initial profile of the contamination on
site was inaccurate. Therefore, the
incineration systems that were designed
were not optimal for the wastes. This
resulted in a large Increase in clean-up time
and cost. The contractor Interpreted the
waste characterization data to show
principally pumpable organic waste suitable
for direct firing in an SCC, and
subsequently mobilized two SCCs with
one small kiln. In actuality, most of the
waste was solid In nature and needed to
be fed to the kiln Hence, the two
incinerators did not provide feed
systems suitable to the actual on-site
waste.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
138
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OBSERVATIONS AND LESSONS
MOTCO SupvfundSH*
• The MOTCO site had several technical
problems with the incineration systems, one
of which was slag buildup and plugging in
the bottom of the HTTS-2 SCO According
to site personnel, a possible solution would
have been to discharge the ash while it was
still hot and quench and cool the ash and
slag outside of the SCC A Key cause of the
slag build-up was the high gas velocity in
the HTTS-2 kiln due to increased feed rates
for soils and sludges The resulting high
gas velocities carried particulates into the
HTTS-2 SCC
• Another problem was excessive participate
carryover from the air pollution control
system Fine paniculate was produced in
the quench due to the high chlorine content
of the waste and the use of a saturated
bnne crystallizer system to remove salt from
recirculatmg quench wastes A water/steam
"supersub" was placed in the first hydro
scrubber to address this problem
• Slide valves in the incineration systems
were used to isolate certain areas during
incineration A workman at the MOTCO site
was killed when removing timbers that had
been used to block open a slide valve
dunng internal maintenance. Any designs
utilizing slide valves should incorporate
devices that will safely keep valves open
Public Involvement
• A community Involvement plan was
developed in 1987 and revised in 1989
Two open houses and workshops were held
in November 1990 and October 1993 EPA
held public meetings for the source control
ROD and the management of migration
ROD in January 1986 and July 1989,
respectively. Starting In 1987, several fact
sheets were sent to 270 citizens on the site
mailing list
Almost a third of the shutdowns at the
MOTCO site were, due to incinerator
dust blocking the flame detector The
detector would signal that the kiln
burners were extinguished and then
shut down the system
Another problem was caused by an
electrical switchgear in the Induced draft
fan overheating by operating at peak
capacity in the Texas heat. Site
personnel stated that sensitive electncal
equipment should be protected from
such weather by air-conditioned and
heated buildings or other means [14]
Low utility fuel gas pressure caused
several problems Site personnel felt
that an oversized gas line would have
improve the utility fuel gas pressure
A high level of organized interest
existed in the community regarding the
cleanup of the site. Many concerns
voiced were regarding air emissions
during the trial bums and the litigation
between the RP and their contractor
U.S ENVIRONMENTAL PROTECTION AGENCY
Off let of Solid Waste and Emergency Response
Ttohnology Innovation Office
139
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REFERENCE
MOTCO Supwfund Sfl»
1 Initial Investigation of MOTCO Hazardous
Waste Disposal Site. Final Report. Black &
Veatch Consulting Engineers, December 23,
1981.
2 Source-Control Feasibility Study MOTCO
Site. LaMaroue. Texas. CH2M Hill,
September, 1984
3 Suoerfund Record of Decision Operable
Unit 1. MOTCO, Texas City, Texas, March
15,1985
4 Superfund Record of Decision Operable
Unit 2. MOTCO, Texas City, Texas,
September 27,1989
5. MOTCO Site Remediation and Incineration
Proiect Trial Bum Report for HTTS-3. IT
Corporation, February, 1991
6. Personal Communication between E F
Steelier of the MOTCO Trust Group and
U.S. EPA Region 6, Novembers, 1991
7. Complaint. IT Corporation v MOTCO Site
Trust Fund and Monsanto Company. The
United States District Court for the Southern
District of Texas, Houston Division,
Decembers, 1991
8 IT Corporation News Release. Houston,
December4,1991
9 Personal Communication between
Frances E Phillips of Gardere & Wynne
and U S EPA Region 6, December 17,
1991
10 Personal Communication between R E
Guilliams of the MOTCO Trust Group
and U S EPA Region 6, December 5,
1991
11 Personal Communication between R E
Guilliams of the MOTCO Trust Group
and U S. EPA Region 6, December 19,
1991
12 Explanation of Significant Differences.
MOTCO Superfund Site, LaMarque,
Galveston County, Texas, January 13,
1993
13 EPA Region 6 Superfund Homepage,
lntemet,(http.//www epa gov/earth1r6/6s
f/motco pdf) March 28,1997
14 Personal communication with Carl
Edlund, U S EPA Region 6, May 15,
1997.
U.8 ENVIRONMENTAL PROTECTION AGENCY
Offiet of Solid Watte and Emergency Rttpoma
Technology Innovation Office
140
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On-Site Incineration at the
Old Midland Products Superfund Site
Ola, Arkansas
141
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Incineration at the Old Midland Products Superfund Site
Ola, Arkansas
Site Name:
Old Midland Products
Superfund Site
Location:
Ola, Arkansas
Contaminants:
Pentachlorophenol and
polynuclear aromatic
hydrocarbons, end VOCs
• Benzo(a)anthracene,
benzo(a)pyrene,
benzo(k)fluoranthene,
chrysene, fluoranthene, 2-
methyl naphthalene,
phenanthrene, benzene,
toluene, tnchloroethylene,
xylene, and chloroform
• POP concentrations up to
5.900 mg/kg and PAH
concentrations up to 38,000
mg/kg
Period of Operation:
June 1992-May 1993
Cleanup Type:
Remedial action
Vendor
Chemical Waste Management,
Inc
ENRAC South Division
P O. Box 579
Ola, AR 72853-0579
SIC Code:
2491 (Wood Preserving)
Technology:
On-Sfte Incineration
• Solids pretreated with
shredding, screening, and
mixing with cement kiln dust
• Incineration system
consisting of rotary kiln and
secondary combustion
chamber (SCC)
• Enclosed conveyor
transported contaminated soil
and debris to the unit
• Kiln temperature of 1,425°F,
SCC temperature of 2,091 °F
• Treated soil and debns
(incinerator ash) discharged
onto conveyors and taken to
an ash storage area
Cleanup Authority:
CERCLA and State.
Arkansas
• ROD Date* 3/24/88
Points of Contact:
Carlos Sanchez
US EPA Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202
(214) 665-8507
Clark McWilliams
State of Arkansas
Department of Pollution
Control and Ecology
PO Box 8913
Little Rock, AR 72219
(5011682-0850
142
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Incineration at the Old Midland Products Superfund Site
Ola, Arkansas
(Continued)
Waste Source:
Disposal lagoons - wood
preserving waste
Purpose/Significance of
Application:
Initially, dioxms and furans
were believed to be present in
the soil Later, concentrations
of dioxins and furans were
determined to be very low and
none were in the form of
2.3.7.8-TCDD.
Type/Quantity of Media Treated:
Sludge and Soil
• 102,000 tons of sludge and soil
• Moisture content- sludge - 43.6%
Regulatory Requirements/Cleanup Goals:
• Destruction and Removal Efficiency (DRE) of 99 9999% for all constituents of concern as
required by Resource Conservation and Recovery Act (RCRA) incinerator regulations in 40
CFR part 264. subpart O
Results:
• Monitoring and tnal bum data indicate that all DRE and emission standards have been met
• Analytical data of residuals indicate that cleanup goals have been met
Description:
Between 1969 and 1979, the site operated as a wood preserving plant Effluents from the
treatment process containing PCP and PAHs were discharged to seven on-site lagoons A series
of inspections at the site were performed by the Arkansas Department of Pollution Control and
Ecology and the U S EPA between 1981 and 1986 A Record of Decision (ROD) was signed
March 1988, specified on-site incineration as the remedial technology for the sludge, soil, and
sediments Site cleanup goals and DRE standards were specified for constituents of concern
On-site incineration began in June 1992 and was completed in May 1993. The treatment system
consisted of a rotary kiln and an SCC An enclosed conveyor moved the soil and debris to the kiln
for treatment Treated ash from the incinerator was discharged to a conveyor and conveyed to a
collection area During its period of operation, the incinerator processed 102,000 tons of sludge
and soil. Incineration achieved the soil cleanup goals specified in the ROD
The total cost of the remedial action was approximately $27,000,000
143
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Old Midland Products Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-srte incineration at the
Old Midland Products Superfund site in Ola,
Arkansas A rotary kiln incinerator was operated
from June 1992 through May 1993 as part of a
remedial action Contaminants of concern at
the site included pentachlorophenol (PCP) and
polynuclear aromatic hydrocarbons (PAHs)
The Old Midland Products site was a former
creosote and pentachlorophenol wood
preserving plant and sawmill that operated from
1969 to 1979 During this time, effluent from
wood preserving processes was discharged to
on-site lagoons. Soil and sediment in the area
of the lagoons were found to be contaminated
with PCP and PAHs in concentrations as high as
5,900 mg/kg and 38,000 mg/kg, respectively
In March 1988, a Record of Decision (ROD) was
signed for the site, specifying incineration of
surface soils, lagoon sludge, and sediments
The remedial action was conducted by the state
of Arkansas, but was financed under the
Comprehensive Environmental Response,
Compensation, and Lability Act (CERCLA)
The material specified for excavation and
incineration included approximately 2,770 cubic
yards of sludges, 850 cubic yards of sediment,
and up to 21,000 cubic yards of soil The ROD
specified incinerator requirements that included
a destruction and removal efficiencies (ORE) of
99 99% or 99 9999%, depending on the
constituent The ROD also specified that
approximately 450,000 gallons of contaminated
groundwater were to be pumped and treated on
site The remainder of this report will address
only the incineration as required by the ROD,
unless otherwise stated
The selected Incineration system consisted
of a feed system, a rotary kiln; a secondary
combustion chamber (SCC), and an air
pollution control system (APCS).
Excavated matenal was taken to a feed
preparation building where it was screened
and mixed with cement kiln dust prior to
being fed to the kiln
The resulting ash was discharged from the
kiln and conveyed to an ash storage area
while exhaust gases were channeled to the
SCC The SCC provided for further
combustion of organics in the off-gases,
which were then quenched with water
The APCS consisted of a baghouse, a
ventun quencher, and a scrubber
Particulate removal occurred in the
baghouse The ventun quencher cooled the
gas, then the scrubber removed acid gases
Dunng the 9 months of operation, the
incinerator processed approximately
102,000 tons of soil, sludge, and sediment
Treatment performance and air monitoring
data collected during this application
indicated that all performance standards
and monitoring requirements were met
The total cost for remediation using the
incineration system was approximately
$27,000,000
U 8. ENVIRONMENTAL PROTECTION AGENCY
Offlc* of Solid Waste and Emergency Response
Technology Innovation Office
144
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Old Midland Product* Supwfund Site
SITE INFORMATION
Old Midland Products Superfund Site
Ola, Arkansas
CERCLJS * ARD980745665
ROD Data March 24,1988
Rackaround
Treatment Application
Type of action Remedial (on-site rotary
kiln incineration)
Period of operation June 1992-May
1993
Quantity of material treated during
application 102,000 tons of creosote-
contaminated sludges, soils, and
dramageway sediments.
Historical Activity that Generated
Contamination at the Site Creosote and
pentachlorophenol wood preserving plant and
sawmill
Corresponding SIC Code 2491 (Wood
Preserving)
Waste Management Practice That
Contributed to Contamination Storage and
disposal of wastes in lagoons
Site History:
• The Old Midland Products site is flat with a
total area of approximately 37 acres It is
located in an agncultural area A wildlife
management area is located one mile north
of the site
• Between 1969 and 1979, the site operated
as a wood preserving plant Effluents from
the wood treatment process containing POP
and PAHs were discharged to seven on-site
lagoons
• A senes of inspections and investigations at
the site v/sre performed by the Arkansas
Department of Pollution Control and
Ecology (ADPC&E) and the U.S EPA
between 1981 and 1986.
• The remedial investigation and feasibility
study (RI/FS) were completed in October
1987. An estimated 9,000 to 21,000 cubic
yards of contaminated soil, 850 cubic yards
of contaminated dralnageway sediments,
and 2,770 cubic yards of lagoon sludges
were identified (a total of approximately
45,000 tons)
• The pnncipal pollutants of concern were
POP and PAHs DunngtheRI,
chlorinated dibenzodioxins and
dibenzof urans were believed to be
present, but later studies found only
very low concentrations of these
pollutants, no 2,3,7,8-TCDD was found
• A tnai bum was conducted in Apnl 1992
Incineration began In June 1992 and
was completed in May 1993 In that
time, 102,000 tons of soil, sediment,
and sludge were incinerated
Regulatory Context:
• In June 1986, the Old Midland Products
site was placed on the National
Priorities List (NPL)
• The ROD was signed March 24,1988,
specifying source control by incineration
of surface soils, lagoon sludge, and
dralnageway sediments
• The Old Midland Products site was a
state-lead site that was financed under
CERCLA
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wart* and Emergency Response
Technology Innovation Office
145
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Old Midland Products Superfund Site
SITE INFORMATION (CONT.)
Background (ConLV
The selected remedy was conducted under
the provisions of CERCLA, the Superf und
Amendments and Reauthonzation Act of
1986 (SARA), and the National Contingency
Ran MCP) 40 CFR Part 300
Tha DREs were set in accordance with
RCRA incinerator regulations in 40 CFR
part 264, subpart O, §264.343.
Remedy Selection On-site incineration
was selected as the remedy for
contaminated soil at the Old Midland
Products Superf und site This remedial
action was deemed to be protective and
cost-effective, and attained applicable or
relevant and appropriate federal and state
standards It utilized permanent solutions
and treatment technologies that reduced
contaminant mobility, toxicity, and volume
to the maximum extent practicable
Tlme!ine
1969-1979
1981
June 1986
October 1967
March 1988
1991 - 1992
Aptl 1992
June 1992 -May 1993
October -November 1993
Dates of site operations
taWal site Investigation
Site placed on the NPL
Remedial IrwesfJgaBon/Feaslbfflty Study completed
Record of Decision signed
Contaminated sol Is excavated
Trial bum conducted
Rotary KHn Incinerator operational
Site cleanup Inducing seeding
Stta Loolftticft/Contact*
Sit* Management State-lead
Oversight State
Remedial Project Manager:
Carlos Sanchez
US EPA Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 665-8507
State Contact:
Clark McWilhams
State of Arkansas Department of Pollution
Control and Ecology
P O. Box 8913
Little Rock, AR 72219
(501) 682-0850
Treatment System Vendor:
Chemical Waste Management, Inc
OHM Remediation
John Patin
225 West Alrtex Boulevard
Houston, TX 77090
(281) 775-7071
U.S. ENVIRONMENTAL PROTECTION AQENCY
Office of Solid Watte and Emergency RaaponM
Technology Innovation Office
146
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Old Midland Products Supviund Site
MATRIX DESCRIPTION
Uatrf
Typeofl
d Through the
Treatment System: Surface soils, lagoon
sludges, and drainageway sediments
liumt fihi
aracterlzaflon
Primary Contaminant Groups-
Pentachlorophenol, polynuclear aromatic
hydrocarbons, and VOCs
• Specific contaminants of concern included
benzo(a)anthracene, benzo(a)pyrene,
benzo(k)fluoranthene, chrysene,
fluoranthene, 2-methyl naphthalene,
phenanthrene, benzene, toluene,
trichloroethylene, xylene, and chloroform.
The maximum detected concentrations
of POP was 790 mg/kg In the surface
soil and 5,900 mg/kg in the lagoon
sediments.' The maximum detected
concentrations of PAHs were 14,000
mg/kg in the surface soil and 38,000
mg/kg in the lagoon sediments.
The major matrix characteristics that most significantly affected cost or performance at the site and
their measured values are presented in Table 2
Table 2 Matrix Characteristics of
SoHCtessfficaBon
Moisture Content
Chloride
Organtes
Heat Content
436%
113%
1339%
6.165 Btu/fc
NA
NA
NA
NA
ATMENT SYSTEM DESCRIPTION
Primary Treatment Tt
Incineration system including
• Rotary kiln, and
• Secondary combustion chamber (SCC)
Pretreatment (solids) Screened and mixed
with cement kiln dust
Post-Treatment (air):
• Quench tower
• Baghouse
• Venturi quencher
• Scrubber
Post-Treatment (scrubber water) Off-Site
deep weli injection
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
147
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Old Midland Products SuporfundSte
TREATMENT SYSTEM DESCRIPTION (CONT.)
Svatom Description and QparaUon
• Excavated matenal was stockpiled and
during the wet winter months, mixed with
cement kiln dust to control its moisture
content. The stockpiles were then moved
into a feed preparation building where they
were screened before being fed to the
incinerator. An enclosed belt conveyor
system fed bulk solids to the kiln feed
hopper located above the screw feed
system From the kiln hopper, waste was
conveyed into the kiln with a dual-rotor
screw feeder
• The kiln was constructed of 0.5-inch-thick
steel plate and was lined with 5 5-inch-thick,
high-fired, super-duty firebrick backed with a
C 5-inch-thick insulating board The tain had
an inside diameter of 6 5 feet and a length
of 45 feet
• The oxygen-fuel burner was designed to
bum natural gas or propane The burner
was rated at 30 million BTU per hour
• The incineration system had a series of
conveyors designed to combine incinerator
ash collected at various points in the
incinerator into a single ash stream for
conveyance to the ash storage area Ail
conveyors used in the incineration system
were totally enclosed and vented to the
incinerator SCO or ARCS to control fugitive
emissions Ash that was generated was
sampled and analyzed to determine whether
ft met disposal requirements
• Hot flue gases from the (din were
discharged through a hot gas cyclone into
the SCC The hot gas cyclone was a
refractory-lined vessel that removed a
portion of the paniculate cany-over from the
flue gases before their introduction Into the
SCC. The SCC was a vertical cylindrical
chamber lined with six inches of high-
temperature refractory with a burner located
at the base of the unit The SCC was
operated at a minimum temperature of
2,050°F.
• The SCC gases entered the quench
tower where the temperature was
reduced to approximately 400°F with
air-atomized water spray nozzles The
quenched combustion gases passed
into two parallel baghouse assemblies
Each baghouse was designed with a
four-to-one air-to-cloth ratio
• From there, the internal draft fan drew
combustion gases through the wet
scrubbing system out to the stack. The
fan was of centrifugal design, sized to
develop a vacuum of approximately 25
inches water column (we) The fan was
powered by a 350-horsepower vanable-
speed motor The fan maintained a
negative pressure in the kiln
• The wet scrubbing system consisted of
a ventun quencher, a pre-packing spray,
a packed bed absorber, and a Chevron
mist eliminator
• The ventun quencher used water sprays
that cooled the off-gases from
approximately 350°F to 185°F A
mildly caustic scrubber-water solution
neutralized dissolved acid gases in the
system. From the venturi quencher, the
cooled flue gases entered the packed
bed absorber section of the scrubber
where they came in contact with the
scrubber solution The packed bed was
designed to provide sufficient contact
between the off-gases and the scrubber
solution to permit efficient absorption
and removal of the acid gas
contaminants Before the gas exited
the stack, it passed through a Chevron
mist eliminator for removal of entrained
water droplets
U S. ENVIRONMENTAL PROTECTION AGENCY
Offlct of Solid Watt* and Emergency Response
Technology Innovation Office
148
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Old Midland Products Superfund Site
TREATMENT SYSTEM DESCRIPTION (CONT.)
Sv«tem Description and Operation fCont.1
The stack was made of fiberglass-reinforced
plastic and was approximately 73 feet high
with a design flue gas exit velocity of 20 to
35 feet per second.
Water used for ash quenching system
was recirculated Scrubber blowdown
water was taken off site and disposed of
by deep well injection
SoDd Residence Time
NA
System Throughput
18tons/hr
Kin Extt Gas Temperature
TREATMENT SYSTEM PERFORMANCE
The cleanup goals and standards were specified
by the ROD The ORE was set based on RCRA
standards
• Soils, sludges, and sediments with
concentrations of greater than 1 mg/kg of
POP were excavated and incinerated
• The incinerator operating conditions set by
the State specified that the incinerator must
achieve a ORE of 99 99% for each organic
hazardous constituent with the exception of
POP, polychlorodibenzo-p-dioxins (PCDD),
and polychlorodibenzofurans (PCDF) which
were required to achieve a DRE of
99.9999%. Once excavation began, the
concentrations of dioxins and furans were
determined to be very low; no 2,3,7,8-TCDD
was found However, the RP decided to
meet the DRE of 99.9999% for these
contaminants although it was not necessary
Ash was placed on site and covered
with a vegetated soil layer The ash
disposal criteria were 1 ppm for PCP,
10 ppm for total PAHs, and 1 ppb for
total dioxm and furans as TCDD
The maximum allowable concentration
for total dioxins and furans was
eventually raised from 0.1 ppb to 1 0
ppb TCDD equivalents after review and
consideration of the thermal treatability
study, the capabilities of the incinerator,
and the long term risks to human health
and the environment [6]
The cleanup levels were deemed to be
sufficient to clean the site to a 1x10*
excess lifetime cancer nsk level
U 3. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
149
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Old Midland Products Superfund SHe
TREA
IT SYSTEM PERFonr
A trial bum conducted at the Old Midland
site was designed to operate the
Incineration system at conditions that would
reflect worst-case destruction and removal
of all constituents of concern
Naphthalene and 1,2,4-trichlorobenzene
were selected as the POHCs to demonstrate
the DREs lor PAHs and POP, respectively
The DREs for dioxins and f urans also were
demonstrated with 1,2,4-trichlorobenzene
The incinerator at Old Midland operated
within the operating limits established during
the trial bum, indicating that all
requirements established in the ROD were
met The AWFCOs and their frequency of
occurrence dunng the operation of the
incinerator are shown in Table 5
Values for operating parameters dunng
the trial bum are shown in Table 6;
actual values for these parameters
dunng operation were not available
Ash generated from the incinerator was
sampled and analyzed to determine if it
was in compliance with disposal
requirements The complete list of
maximum allowable concentrations for
hazardous constituents in the ash is
presented in Table 7
Table 4. A\
t Destruction and Removal Efficiencies from
Table 5. Automatic Waste Feed Cutoffs
fttadmum
MMtimu Un pressure, Instsntsnsous
•oilnchwe
20
MWmum Mn temperature, 1 hour roMng mirage
1396*F
1200*F
MMniUHi misty Mflvspufyt flow, InslsnUnsous
SOchn
33
MlnlnuM) ratify vriw PUTQA prMiure, InsbmlMwous
OSinchwe
MMTOOT 8CC Ismpsreture, Instantaneous
2,068°F
82
MWmum SCC oxyge
ntration, dry gas volume percent
3%
176
MHmum bugh
dHftrentW p
re, instantaneous
1 1nch we
10
451 gpm
10
MMmum scfublMr pH, If tMlow ft)r 60 mkuit*§ or mort
65
fctodmum stack gas CO <
!)
rrtraOon, uneorrectad 1 hour roUng
lOOppmv
MeMmurn stack gas THC (
icing average (dry g»)
ntratton, uncorrected 1 hour
20ppmv
MttdnHiin stack QM vsloclty, lostsntansous
20.7 Wssc
66
US ENVIRONMENTAL PROTECTION AGENCY
Offlo* of Solid Wattt md Emtrgmwy Response
Technology Innovation Offlc*
150
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Old Midland Product* Supertund SH»
TREATMENT SYSTEM PERFORMANCE (CONT.)
Waste feed rate
Kin pressure
Kin temperature
Rotary valve purge flow
SCC temperature
SCC oxygsn concentration
Baghouse oKterenttal pressure
Scrubber waste flow rate
Scrubber pH
Stack gas CO concentration
stack gas THC concentration
Stack gas vatocfty
Chlorine feed rate
Ash feed rate
Dissohwd soNds m the scrubber water
Differential pressure across scrubber packing
Quench exit temperature
18tph
-01 Inches we
1,4250F
379ctm
2.091 °F
3%
1 inch we
451 gpm
65
100 ppm
20 ppm
20.2 ft/sec
171tomr
29,900 ttVhr
lOBg/mL
1 1nch we
426-F
Table 7. Maximum Allowable Concentrations for Hazardous Constituents in the Ash
Pentachlorophenol, PCP
Dknvns and Furans as TCDD
Naphthatane
Phenanthrene
Acanaohthene
Acenaphthytene
Fhjorene
Chryaane
Pyrane
Benzene
Ethytoenzene
Toluene
Xvtane (total)
Total BNA
Total PNA
10
10ppb
10
0.3
03
03
0.3
03
03
01
01
01
01
100
10.0
* Reported m ppm In IMS otherwise stated.
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Witt* and Emtrgency Rasponte
Tachndogy Innovation Office
151
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Old Midland Pr
jt»Sup»rfundSitm
TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Complatanaaa
• Data are available for concentrations of
contaminants in the soil and sediment
before treatment.
Data are also available for concentrations
of contaminants in the incinerator residue
These data were collected periodically
throughout operation of the incinerator
prior to landf tiling
The Quality Assurance/Quality Control
program used throughout the remedial
action was deemed to have met EPA and
State of Arkansas requirements
TREATMENT SYSTEM COST
• Chemical Waste Management, Inc,
ENRAC South Division was the remedial
contractor for the incineration
Cost Data
• The cost data were provided by the
Arkansas Department of Pollution Control &
Ecology The estimated cost for operating
the incinerator at the site was about
$17,100,000. Additional contaminated soil
was encountered during the remedial action
A total of 102,000 tons of soil, sludge, and
sediment were incinerated. Total project
cost was approximately $27,000,000 This
corresponds to a total unit cost of $264 per
ton Table 8 shows information on costs for
the remedial action at the site
331
01
01
Mobilization of Construction Equipment and Facilities
$984,500
331
01
03
Submittals/lmplementation Plans
$1,031,304
331
01
04
Setup/Construct Temporary Facilities
$303,600
331
02
06
Sampling Soil and Sediment
$1,307,900
331
02
09
Laboratory Chemical Analysis
331
03
02
Clearing and Grubbing
$210,490
331
03
03
Earthwork (I e , excavating, backfill, grading, stockpiling)
$12,699,115
331
14
01
Incineration (Including feed preparation)
331
03
05
Fencing
$26,056
Miscellaneous
3551,000
Additional contaminated soil
$9,886,035
Total
$27,000,0001
1 This number Is an approximation, as a result, the total of the number's In the table do not exactly match
this number.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Witt* and Emergency Response
Technology Innovation Office
152
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OM Midland Products Superfund Sit*
OBSERVATIONS AND LESSONS LEARNED
The cost was higher than initially estimated
because the amount of material to be
incinerated was underestimated According
to site personnel, the very demanding
cleanup goals required additional
excavation not originally planned based on
the results of the RI/FS. In addition, the
geology of the area was folded and faulted,
as a result, analysis of soil borings did not
yield representative results of subsurface
contamination
• Site personnel reported few problems during
incineration Reasons cited for success
include thorough characterization of the
waste before it was fed to the incinerator
and the development of detailed plans at
the beginning of the project
Public Involvement
According to site personnel, local politicians
and residents did not raise significant
opposition to the selected remedial action
A community involvement plan was
developed in August 1985 and revised
in December 1988. An open house was
held May 1986, and periodically, fact
sheets were sent to the 10 citizens on
the site mailing list.
Suoerfund Record of Decision. Old Midland,
Ola, Arkansas, March 1988
2 Old Midland I
i Suoerfund Site
Incinerator Facility Trial Bum Plan 2. Radian
Corporation, Match 1992
3 Old Midland Products Superfund Site
Incinerator Operating Conditions. State of
Arkansas, June 1992
4 EPA Region VI Superfund Homepage,
Internet, (rrttp //www epa gov/earth1r6/6sf/
midland pdf) March 26,1997
5. Personal communication with Carlos
Sanchez, U.S. EPA Region VI, June 9,
1997.
Remedial Action Report Construction
Phase Old Midland Products Site. IT
Corporation, May 1996
Contractor's Site Specific Worker
Health and Safety Plan. Old Midland
Products Site, Chemical Waste
Management, May 1991.
Old Midland Products Superfund Site
Incineration Facility Trial Bum Test
Report. Radian Corporation, May 1992
9 Inolner
Chemical'
January 1992.
10 Remedial li
Remedial Investigation Draf
Midland, IT/MTR, July 1987
^Description Report.
Inc.
Draft. Old
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Offkj*
153
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This Pags IntMitkMMHy Loft Btank
154
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On-Site Incineration at the
Petro Processors Superfund Site
Baton Rouge, Louisiana
155
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Incineration at the Petro Processors Superfund Site
Baton Rouge, Louisiana
Site Name:
Petro Processors Superfund
Site
Location:
Baton Rouge, Louisiana
Contaminants:
Chlorinated Hydrocarbons,
Polynudear Aromatic
Hydrocarbons (PAHs), Heavy
Metals, and Oils
• Hexachlorobutadiene and
hexachlorobenzene
Period of Operation:
(Report ongoing covers
11/94-5/97)
Cleanup Type:
Remedial action
Site General Contractor:
NPC Services, Inc.
500 Brooklawn Drive
Baton Rouge, Louisiana 70816
(504)778-6200
SIC Code:
4953 (Refuse Systems)
Technology:
On-Site Incineration
• Combustion of fumes and
liquids from groundwater
treatment system
• Incineration system consisting
of a horizontal, direct-fired
kiln
• Air fan delivers fumes and
centrifugal pump delivers
liquids to the unit
• Kiln temperature of 2,000° F
to2,400°F
• Slowdown from the system is
pH adjusted with lime and
discharged
Cleanup Authority:
CERCLA and State
Louisiana
• ROD Date No ROD,
Consent Decree took the
place of the ROD
• RP-lead
Point of Contact:
Cynthia Kalen
Remedial Project Manager
US EPA Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-6772
Waste Source:
Disposal of petrochemical
wastes in on-site lagoons
Type/Quantity of Media Treated:
Liquids and Fumes
• 213,376 gallons of DNAPLs to date
Purpose/Significance of
Application:
Incinerator treats liquid
organics and air shipper fumes
from a groundwater treatment
system
Regulatory Requirements/Cleanup Goals:
• Destruction and Removal Efficiency (ORE) of 99.99% for organic constituents of concern as
required by Resource Conservation and Recovery Act (RCRA) incinerator regulations in 40
CFR part 264. subpart O
Result*:
• Emissions and tnal bum data indicate that all DRE and emission standards have been met to
Cost Factors:
• Total cost of the Incinerator is approximately $32,827,799 to date
• Approximate Total Capital Costs- $18,159,087 (Including equipment, site preparation,
construction/engineering, startup), Projected Future Capital Costs: $500,000
• Approximate Total Operating Costs- $14,668,912 (Including maintenance, project
management, sampling and analysis, supplies), Projected Future Monthly Operating Costs
$300.000 oer month
156
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Incineration at the Petro Processors Superfund Site
Baton Rouge, Louisiana
(Continued)
Description:
Between 1961 and 1980, the Petro Processors Superfund Site operated as a petrochemical waste
disposal area A remedial investigation determined that soil and groundwater at the site were
contaminated A Consent Decree entered into Federal Court on February 16,1984 specified that
a plan of action be developed for the site The plan included a groundwater treatment system
which utilized an incinerator to treat liquid organics and air shipper fumes Site cleanup goals
and ORE standards were specified for the organic constituents of concern.
The treatment system began operation in November 1994 and is ongoing at the time of this
report. The Incineration system consists of a horizontal, direct-fired incinerator A centrifugal
pump and an combustion air fan deliver the liquid and fume waste, respectively, to the
incinerator. The incinerator is equipped with an air pollution control system consisting of a
quench tank; an HCI absorber/caustic scrubber tower; a paniculate scrubber, and a entrapment
separator
The total cost of the remedial action is approximately $32,827,799 to date. Capital costs
accounted for approximately $18,159,087 with a projected future cost of $500,000 Operation
and maintenance costs accounted for approximately $14,668,912 with a projected future monthly
cost of $300,000
157
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PftroPnc9»9onSup9rfundSit»
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site Incineration at the
Petro Processors (Petro) Superfund site in
Baton Rouge, Louisiana. Since November
1994, an incinerator designed to dispose of
fumes and liquids from the groundwater
treatment system has been operating as part of
a remedial action Contaminants of concern at
the site include chlorinated hydrocarbons,
polynudear aromatic hydrocarbons (PAHs),
heavy metals, and oils
The Petro site operated as a petrochemical
waste disposal site from 1961 to 1980 During
this period, various chemical wastes were
disposed of in lagoons. It was estimated based
on the results of an investigation conducted at
the site that 330,000 m3 of soil was
contaminated. Groundwater and soil at Petro is
contaminated with hexachlorobutadiene and
hexachlorobenzene
In 1984, a Consent Decree was signed by
Federal and State government agencies and the
Responsible Parties (RPs) for the Petro site A
Destruction and Removal Efficiency (ORE) of at
least 99 99% for organic constituents of concern
was called for by the approved operating
specifications.
Remedial activities at the site include the
design, construction and operation of a
groundwater treatment system which uses the
incinerator for the destruction of the residuals
generated This report focuses on the cost and
performance of the incinerator and does not
present any detailed information on the
groundwater treatment system
Groundwater is currently being extracted with a
system of 165 recovery wells Recovered
groundwater is treated by phase separators to
remove non-aqueous phase liquids (NAPLs)
from the water; the separated water is treated
with air strippers to remove additional
contaminants.
The NAPLs removed by the groundwater
treatment system are stored in a waste feed
tank prior to being fed to the incinerator
through a liquid waste feed nozzle The
vent gas from the air stoppers also is fed to
the incinerator as part of the combustion air
The incineration system consists of a vent
gas feed system; a liquid waste feed
system, a horizontal, direct-fired incinerator;
a quench tank, a HCI absorber/caustic
scrubber; a particulate scrubber; and an
entrapment separator
The incinerator volatilizes and destroys
organic compounds from the liquid and
fumes Treated gas is then drawn into the
quench tower for cooling The HCI
absorber/caustic scrubber then removes
HCI, CI2, SO2, and some particulate matter
The particulate scrubber and errtrainment
separator remove additional particulate
matter before off-gas is released through
the stack
Dunng the 30 months of operation, the
incinerator has processed approximately
213,376 gallons of dense non-aqueous
phase liquids (DNAPLs) Treatment
performance and emissions data collected
during this application indicate that all
performance standards and monitoring
requirements are being achieved.
The cost for treatment of the residuals using
the incineration system is approximately
$32,827,799 to date This amount consists
of $18,159,087 in capital costs and
$14,668,900 in operating costs.
U.S. ENVIRONMENTAL PROTECTION AQENCY
Offlct of Solid WMte and Emergency Response
Technology Innovation Office
158
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ffefro Processors Suporfund Site
ITE INFORMATION
idanttfvlno information
Petro Processors Superf und Site
Baton Rouge, Louisiana
CERCUSt: LAD057482713
ROD Data: Not Applicable A Consent Decree
was issued in lieu of a ROD
und
Type of action: Remedial (groundwater
treatment with on-srte incineration of
residuals)
Period of operation: 1994-present
Quantity of material treated during
application: 213,376 gallons of LNAPLs to
date
Historical Activity that Generated
Contamination at the Site: Waste collection
and disposal
Corresponding SIC Code: 4953 (Refuse
Systems)
Wast* Management Practice That
Contributed to Contamination: Disposal of
waste in on-stte lagoons
Site History:
• The Petro site operated from 1961 until its
closure in 1980 The site is comprised of
two former petrochemical waste disposal
areas, the Scenic Highway and Brooklawn
areas, which are located approximately 1 5
miles apart
• The Scenic Highway area operated from
1961 until 1974 and covers approximately
17 acres The area was filled and closed in
1974, but there was still concern over the
potential for leachate migration and erosion
• The Brooklawn site operated from 1969 until
1980 and covers approximately 60 acres
No known actions were taken to mitigate
potential risks to human health and the
environment at the time operations ceased
• During the site's penod of operation, various
petrochemical wastes were disposed of in
unlined lagoons. It was estimated based on
investigation at the site that 330,000 m* of
soil was contaminated
Soil and groundwater at Petro were
contaminated with chlorinated
hydrocarbons, PAHs, heavy metals, and
oils
A spill from the waste lagoons in 1969
contaminated a local ranch, killing 30
cattle Additionally, on several
occasions, waste in the lagoons
spontaneously ignited
The Petro site is located over a drinking
water aquifer for the area referred to as
the 400-foot sands
In July 1980, the U S Department of
Justice, the State of Louisiana, the City
of Baton Rouge, and the Parish of East
Baton Rouge filed suit against the site
owner and several waste generators
who had transported material to the site
for disposal [1 j.
A Consent Decree was entered into the
Federal Court's record on February 16,
1984. Under the terms of the decree
the site was closed and the RPs were
required to investigate and develop a
detailed plan of action for the Petro Site
[1].
The proposed remedy included the
excavation and incineration of visibly
contaminated soil; the solidification,
incineration, or off-site disposal of all
non-aqueous phase wastes in the
lagoons, and the Installation of recovery
wells to recover NAPLs [1].
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offlct of Solid Watte and Emergency Response
Technology Innovation Office
159
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PWroPr
Supertax/S/te
1AT10N (CONT.)
fCnrtt.l
In 1987, during the early phases of the
excavation at Brooklawn, on-ate air
monrtonng equipment detected volatile
organic compounds Operations at the site
ceased in order to protect the safety of on-
site workers and the safety of workers at
industrial plants adjacent to the site
In December 1988, the RPs reported in a
Supplemental Remedial Action Plan
(SRAP) that the remediation could not
continue under the proposed plan without
future unacceptable releases of volatile
organic compounds. As required by the
Consent Decree, the RPs also proposed
methods for remediation in the SRAP EPA
Region VI, however, found the RPs' findings
insufficient and began an internal 18-month
review of potential remedial solutions
In 1989, the SRAP was approved amending
tha Consent Decree and the remedy
changed to capping the lagoons and
hydraulic containment of the groundwater
plume Based on the findings of the
amended Consent Decree, the RPs began
design and construction activities
The majority of the Brooklawn area was
covered by a soil cap, seeded, and
contoured to control erosion This action
was completed July 1990, at which time the
RPs also submitted a workplan for the
earthwork which was needed at the Scenic
Highway site One lagoon in the area was
and currently is left open in order to deposit
drill cuttings from the wells installed on site
A groundwater treatment system was
installed in 1994, which currently includes
98 sumps and 190 operating recovery wells
of a planned number of 213.
As in the Brooklawn area, the Scenic
Highway area was covered with a soil cap,
seeded, and contoured to control erosion
This action was completed September
1992. In October 1996, eleven
recovery wells were installed to recover
NAPLs from the area and thirty-four
monitoring wells were installed to gauge
the natural attenuation of the plume
The contingent remedy had not been
implemented at the time this report was
prepared
• The treatment system that was
constructed at the Brooklawn area
included an incinerator which was
capable of disposing of both organic
liquids and fumes A trial bum was
conducted the week of November 7,
1994, after which the incinerator began
operating under intenm conditions The
final operating specifications were
approved by EPA on December 28,
1995
• Bayou Baton Rouge was re-routed
during remedial activities so that it did
no flow through the site. Portions of the
site are located within the Bayou Baton
Rouge flood plain
• A section of the Brooklawn area is in the
Mississippi River flood plain
Additionally, the Mississippi flood plain
located to the south of the Brooklawn
area, known as Devil's Swamp, is
classified as a wetland A state health
advisory currently covers parts of
Devil's Swamp
Regulatory Context:
• In 1984, the Petro Site was placed on
the National Priorities List (NPL)
U 8 ENVIRONMENTAL PROTECTION AQENCY
Office of Solid Wttte and Emergency Response
Technology Innovation Office
160
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Potro Pmc»*9or» Superfund Site
SITE INFORMATION (Cor\rr.)
Bflcknround fCont.)
in 1984, a Consent Decree was filed into
Federal Court, which required remedial
activities at the site in Baton Rouge,
Louisiana
Treated groundwater is discharged under a
National Pollutant Discharge Elimination
System (NPDES) permit
The DREs were set in accordance with
Resource Conservation and Recovery Act
(RCRA) incinerator regulations in 40 CFR,
part 264 subpart O
Remedy S0K>ctlon: Hydraulic containment
and recovery followed by on-site
incineration of free-product and nonaqueous
organic residuals from the groundwater
treatment system was selected as the
remedy for the Petro Processors Superf und
site On-site incineration was selected
based on the cost associated with using an
incinerator and the reduction in long-term
threats to human health and the
environment which occurred as a result of
destroying the contaminants
Timeline
1961 - 1980
Table 1. Timeline
The Petro Site was used for Disposal of petrochemical waste
February 1984
Consent Decree established for site cleanup
1984
Petro Stte was placed on the NPL
1987
Remedial construction begins
1989
Consent Decree amended
November 7 -11, 1994
Trial Bum
November 1994 - December 1995
Incinerator operated under Interim standards
December 28. 1995
Final ooeraBno standards approved for Incinerator
Site Loalatlca/Contacte
Site Management: RP-lead
Oversight. EPA
Remedial Project M anager:
Cynthia Kalen
US EPA Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-6772
State Contact:
Glenn Miller
Louisiana Department of Environmental
Quality
Inactive and Abandoned Sites Division
PO Box 82282
Baton Rouge, Louisiana 70884-2282
Site General Contractor:
Bill Dawson
NPC Services, Inc
3867 Plaza Tower Drive
Baton Rouge, Louisiana 70816
(504) 778-6206
U S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watta and Emergency Response
Technology Innovation Office
161
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Pfoctitoft Suptffund Sft»
Type of Matrix Processed
Through the Treatment System: Organic
liquid and gas residuals generated during the
treatment of groundwater contaminated by
infiltration from unlined waste lagoons used for
waste disposal
Primary Contaminant Groups: Chlonnated
hydrocarbons, PAHs, heavy metals, and oils
The contaminants of greatest concern
were hexachlorobutadiene and
hexachlorobenzene
Information on matrix characteristics was not available
Incineration system including.
• Fume waste feed system
• Organic liquid waste feed system
• Horizontal, direct-fired incinerator
Pretreatment (liquids)
• Agitation
Post-Treatment (air)-
• Quench tank
• HCI absorber/caustic scrubber tower
• Particulate scrubber
• Entrainment separator
Post-Treatment (water)
• pH adjustment
• Carbon adsorption
Groundwater is recovered from the
BrooMawn site using an existing system of
165 extraction wells. The groundwater Is
pumped through phase separators to
remove NAPLs and air strippers to remove
dissolved organtes. The treatment system
Is designed to treat groundwater with 1,000
to 2,000 mg/L of chlorinated organics
The MAPI liquid waste is stored in a
waste feed tank, which contains an
agitator to maintain a homogenous
mixture, prior to being fed into the
Incinerator. The tank is a pressure
vessel rated at 15 pslg with a storage
capacity of 4,760 gallons, which
provides storage capacity of
approximately one day. [2].
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Oific*
162
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TREATMENT SV<
DESCRIPTION (CONT.)
The tank is padded with nitrogen to
maintain an inert, non-flammable mixture
above the liquid and it is kept at an
operating pressure between 2 and 10
psig To maintain the correct pressure,
the tank is vented as needed to the
incinerator through a flame arrester The
waste tank is equipped with an electric
heating panel to control the viscosity of
the waste at a temperature between 70°F
and95°F
The liquid waste is pumped by a
centrifugal pump through a strainer to
remove any solids and into the incinerator
liquid waste feed nozzle. The liquid waste
feed is monitored by a Conolis meter and
controlled by a flow control valve and a
safety shutoff valve If an automatic
waste feed cutoff (AWFCO) is initiated,
the pump is shut down, and the feed
control valve and safety shutoff valve are
closed. The liquid waste feed nozzle is
atomized with air supplied by an on-site
air compressor; the atomization air
pressure is maintained above the liquid
waste feed pressure at the nozzle [2]
The vent gas stream produced by the air
strippers is fed to the incinerator through a
combustion air fan and is discharged into
the incinerator as part of the total
combustion air The flow of the
combustion air fan is controlled such that
the minimum air flow to the incinerator
exceeds the vent gas flow; this is
designed to provide the incinerator with
sufficient air for proper combustion A
gravity damper allows fresh air to be
pulled into the blower with the vent gas
stream if the burner demands more air
than that supplied by the vent gas stream
12]
The design maximum vent gas flow rate
is 2,800 standard cubic feet per minute
(scfm); the combustion air fan has a
design capacity of 3,260 scfm The
combustion air flow is monitored by a flow
meter and controlled by a flow control
valve on the suction line [2].
The incinerator is 30 feet in length, has an
outar diameter of 8.5 feet, and is lined
with 8 inches of firebrick and castable
lining. The incinerator has a firing
capacity of 14 million BTU/hr A negative
pressure is maintained within the
incinerator in order to prevent fugitive
emissions
The incinerator is designed to dispose of
vent gases and liquids simultaneously, but
can process either wastestream
separately should an AWFCO occur.
The incinerator operates in both a fume
and liquid-injection mode While
operating in the fume mode natural gas is
used as a fuel. The liquid-injection mode
includes operation while using liquid
organics recovered from the site to
supplement or replace the natural gas [2]
The incinerator is equipped with two
burners A low-No, main burner is used
for firing liquids The waste and
atomization air are discharged from the
nozzle through small orifices in the nozzle
tip directly into the main bum flame [2]
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emcrgtncy ReiponM
Technology Innovation Offlcn
163
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P»tro PracMKN* Supwftmd Site
n**erintton MM! Ouaratlon /Cont.1
Natural gas is used as auxiliary fuel for the
incineration system and is fed to the
incinerator through a burner located at the
inlet end of the incinerator chamber, which
is fired tangentially into the mam burner
flame [2]. The design liquid waste feed rate
is 1,600 Ib/hr and the design temperature for
liquid-injection operation is 2,000°F to
2,400°F
The exhaust gas from the incinerator is
channeled to the quench tower, where it is
cooled with water to approximately 175°F
The quench tank is a vertical, wet-walled,
rubber-lined steel vessel. An emergency
water tank is installed above the quench
tank in the event of a toss of process water
The RP estimate is estimated that 50% of
the HCI in the exhaust gas is absorbed in
the quench tank
Following the quench tank, the exhaust gas
enters the HCI absorber/caustic scrubber
tower The tower is a vertical fiberglass
vessel containing packed sections Water
recirculated through the HCI absorber
removes approximately 40% of the HCI in
the gas.
The caustic scrubber is designed to remove
approximately 99 9% of the remaining HCI,
97% of the CI2,90% of the SO2, and some
participate matter A btowdown stream from
the caustic scrubber is fed to the HCI
absorber to remove salt and ash from the
caustic scrubber system [2J
• Residuals collected in the blowdown
from the APCS Is treated by a carbon
adsorption unit which is part of the
groundwater treatment system
• The off-gas leaves the scrubber system
and enters a high-energy paniculate
scrubber, where it is split into two
streams The two streams are then
recombined and are contacted with a
recirculating water stream where water
droplets entrap participate matter The
particles are then removed from the
water in the entrainment separator
• Blowdown from the APCS is pumped
into a neutralization system. The
blowdown is treated with lime to bnng
the pH into the 6 - 9 range before
discharge under the terms of a NPDES
permit to the Mississippi River
• Combustion gases were drawn through
the incineration system by a variable
speed, induced draft fan and were
exhausted through an 100-foot stack
The fan has a 75 tip motor and is
designed to handle 4,400 scfm Design
condition flue gas velocity is 3,800 -
4,000 actual cubic feet per minute
(acfm) at a temperature of 147°F
• The groundwater which was isolated
from the NAPLs in the phase separator
is treated with carbon adsorption before
being discharged under a NPDES
permit
Table 2.
Parameters
2Mconds
System Throughput
KHn Temperature
980 to/hr (liquid)
1,600' (fume mode)
2,000'F - 2,300'F (liquid mode)
U 8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wast* and Emergency RttporiM
Technology Innovation Offlct
164
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ProcMMW SifMf/uncf SAW
TREATMENT SYSTEM PERFORMANCE
The ORE requirements were set based on
RCRA incinerator regulations 40 CFR part
264, subpart O
A ORE of 99.99% was required for each
constituent of concern.
A 60-mmute rolling average stack gas CO
concentration less than or equal to 100 parts
per million by volume (ppmv), dry basis,
corrected to 7% O2 is required for the
incinerator
Stack gas parbculate concentrations of
less than or equal to 0 04 grains per dry
standard cubic foot (gr/dscf), dry basis,
corrected to 7% O2 are required for the
incinerator.
HCI emissions of less than or equal to 4
Ib/hr are required for the incinerator.
Two trial bums, one for liquid mode
incineration and one for fume mode
incineration, were conducted at Petro
These trial bums were designed to operate
the incineration system at conditions that
would reflect worst-case destruction and
removal of all constituents of concern
Tetrachloroethene and monochlorobenzene
were selected as the principal organic
hazardous constituents (POHCs) * or the
liquid mode tnal bum, 1,1,2 -
tnchloroethane and tnchloroethei were
selected as the POHCs for the fume mode
tnal bum The reported DREs for each
POHC are included in Table 3-A and 3-B
To date, the incinerator at Petro has
operated within the operating limits
established during the tnal bum,
signifying that all cleanup requirements
that have been established are being
met The AWFCOs and their frequency
of occurrence dunng the operation of
the incinerator are shown in Table 4-A
and4-B Trial bum and typical
operating parameters are shown in
Tables 5-A and 5-B
Table 3-A Av
i Destruction and Removal Efficiencies from
Mode Trial Bum [3]
Tabte 3-B. Average Destruction and Removal Efficiencies from Fume Mode Trial Bum [4,
U 8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
165
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i Sup»rhmd SHo
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 4-A. Automatic Waste Feed Cutoffs for
Msalmumorgsnlc squid fssd rate1
1.470«Vhr
Monthly
MMmumcombustkOTChsmbsfg^tsnysrature'
2.000"F
Monthly
Msxfcnun combustion crambsra^tsmpsrahire*
2.300'F
Monthly
MMmumcaurtte scrubber pH1
7.5
Monthly
MMmum HCI sbsoffasr yscyde flow rate
130 axn
Monthly
MstsnuHi caustic iciubbif recycle flow rate
300 gpm
Monthly
Msidmum stack gas flow rate1
15,200 Mir
Monthly
Mtaln^parfculste scrubber dOTsrsnM pressure1
35 Inches we
Monthly
Ma*num<
chamber pi
Monthly
IQOppmv
Monthly
MHmum stack(
mtraflon1
2% volume oYybaate
Monthly
Mtrtmumqmnch chamber •xttgai temperature'
w.c -Watercolumn
'Bated on 60-mlnute nMng wwage
Instantamous vriue
200-F
Mom>:
Table 4-B. Automatic Waste Feed Cutoffs for Fume Mode Incineration [4,(
••••••iHHHaBBBBIMHiHHBIl^B^^^^^^^^^^BBHI^BMl
Mndmum eJr tlilppei wtter flow rate1
Mnknum combunon cnimoer OBB umpennurar
MkUmum caustic acrubber pH1
MMmum HCI etworberrecyde flow rate*
MMmum caustic enubber recycle flow rate1
Mrtmum stack QM flow rate1
Mndmum combustion ulMmbw pnMsunr
MMmum •IKK BM co conowinnon (oomciM to n» ug)
MMmum stack get O. concentraflon1
^^^•^^IH^^^I^MBH^H
200 gpm
1.600'F
7^
130 gpm
300 gpm
16,200 Mir
-Ollncrw6HtO
lOOppmv
2% volume dry basts
Monthly
Monthly
Monthlv
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Mssd on eXHrnraite i
Instsntsneous vshie
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offlo* of Solid Wattt «nd Emwgtnoy RttponM
Technology Innovation OffkM
166
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Putro AOOMMM* Suptrfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.-)
14 million BTU/hr
14mmonBTU/hr
Emission Rate
Partlculate matter
HO
a,
HydKXiflroons
MA
NA
NA
NA
00264 gr/dscf
OIQOto/hr
0003 b/hr
07ppnw
Operating Conditions
ktadmumCOcani
ntratton In gas (corrected to 7% Oj)
Mnknum combustion chamber gas temperature
MWmum caustic scrubber pH
MWmum HCI absorber recycle flow rate
MMmum caustic scrubber recycle flow rate
MMmum partteutate scrubber deferential pressure
Marfmum combustion chamber pressure
Quench chamber exft gas temperature
16ppmv
2.042-F
8.2 s u
178 gpm
369 gpm
37 Inches we
-2 34 Inches we
169-F
17ppmv
2,000°?
131 gpm
305 gpm
35 inches we
-1.26 Inches we
178°F
we E Water column
Table 5-B Operating Parameters tor Fume Mode Incineration
£^3«i.r^^^^ii^ •*
Air Stripper Fkw Rate
Fuel-Fired Feed Rate
Emission Rate
Paniculate matter
HCI
q,
Hydrocarbons
Operating CondWons
Maximum CO concentration In gas (corrected to 7% OJ
Mnknum comDusoon cnarnoer gas tsmperature
Meodmurn combustion chamber pressure
Quench chamber exit gas temperature
93 gpm
14 mHon BTU/hr
NA
NA
NA
NA
1.2 ppmv
1,680»F
-2 443 inches we
156°F
fj§ ^ J
•(•WdHW
^^•{•^^^•^^•HaM
"" ™^»
200 gpm
14 mWon BTU/hr
00018gr/dscf
OOltVhr
007IVhr
NotAvaUMe
38 ppmv
1,6008F
-450lncheewc
158°F
we «Watercolumn
Data are available for concentrations of
contaminants In the groundwater before
treatment
• Data are also available for
concentration of contaminants in the
liquid and gaseous waste that were fed
to the Incinerator the two trial bums
Parfa
i Data Oualltw
The QA/QC program used throughout the
remedial action met EPA and the State of
Louisiana requirements All monitoring was
performed using EPA-approved
methods, and the vendor did not note
any exceptions to the QA/QC protocols.
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
167
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PftroPr
rfundSto
TREATMENT SYSTEM Cos
The RPs have installed and are operating the
treatment system, including the incinerator,
at the site
The estimated treatment cost of $59,221,500
and the projected costs were reported by the
RPs in terms of capital costs and operation
and maintenance costs To date, the
estimated capital costs for the incinerator are
$44,552,586 and the estimated operation and
maintenance costs are $14,668,908 The
projected cost for the remaining capital
expenditures is $6,971,000 The projected
monthly operation and maintenance costs for
the incinerator are $300,000. The estimated
costs for thermal treatment were about
$4,800,000. To date, a total of 213,000
gallons of organic liquids and fumes have
been incinerated This corresponds to a total
unit cost of $280 per gallon and a unit cost
for thermal treatment of $21 per gallon
Tables 6 and 7 show capital costs and
operation and maintenance costs for the
remedy
Mobilization and preparatory work
331
Monitoring, sampling testing, and analysis
$4,310.840
$520.000
331
03
$6,405,230
$150,000
331
05
Surfa
oHBcDon and control
$2,418,588
$100.000
331
08
Qroui
i and control
$9,285,089
$3,100.000
331
22
General requirements
$3,973,752
$3.101,000
Tote/Capfttf Costs
$44,552,586
S6.971.000
Table 7 Operation and Maintenance Costs 171
342
02
Monitoring, sampling, tasting, and analysis
$1.696,888
$35,000
342
03
SHswork
$232.520
$6000
342
14
Thermal trsatnwrt
$4.749.582
$115000
342
18
$92.429
$2.500
342
22
$7.987.489
141 50
TottlOptntton and Mibttrmnc* Coed
$14,668,908
$300000
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wait* and Emergency Response
Technology Innovation Office
168
-------
Petro Procrasof* Superfund Sfte
TREATMENT SYSTEM COST (CONTINUED)
Actual and projected capital and operations
and maintenance cost data are available
from the RP for this application
OBSERVATIONS AND LESSONS LEARNED
Site personnel feel that there have been
relatively few problems with the incinerator
thus far They have attributed this to the
fact that they used all of their allowable pre-
operation, or shakedown, hours to properly
adjust the system in order to successfully
complete the tnal bum [5]
REFERENCES
1 Suoerf und Site Status Summaries. US
EPA, "Petro Processors of Louisiana, Inc",
http //www.epa.gov/earth1r6/6sf/petropro,
May 9,1997
2 Remedial Design and Construction Plan.
Petro-Processors. Inc. "Design &
Construction Specifications. Operating
Specification for the Liquid Mode Operation
of the LTAD Incineration System,
Addendum A, Volume III, Part 5, Book 10 of
17, NPC Services Inc, November 15,1995
3 Remedial Design and Construction Plan.
Petro-Processors. Inc. "Design &
Construction Specifications Operating
Specification for the Liquid Mode Operation
of the LTAD Incineration System,
Addendum A, Volume III, Part 5, Book 1 of
17, NPC Services Inc, November 15,1995
4 Remedial Design and Construction
Plan. Petro-Processors. Inc. "Design &
Construction Specifications Operating
Specification for the Fume Mode
Operation of the LTAD Incineration
System, Addendum A, Volume III, Part
4, Book 1 of 11, NPC Services Inc,
November 15,1995
5 Personal Communication, Ms Cynthia
Kaleri, April 2,1997
6 Personal Communication, Mr. Bryan
McReynolds, July 24,1997
7 Personal Communication, Mr Marty
Munley, July 28,1997
U.3 ENVIRONMENTAL PROTECTION AGENCY
Offlet of Solid WMM and Emergency RMponi*
Technology Innovation Office
169
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This Page Intentionally Left Blank
170
-------
On-Site Incineration of Basin F Liquids at the
Rocky Mountain Arsenal Superfund Site
Commerce City, Colorado
171
-------
Incineration at the Rocky Mountain Arsenal Superfund Site
Commerce City, Colorado
Site Name:
Rocky Mountain Arsenal
Superfund Site
Location:
Commerce City, Colorado
Contaminants:
Organochloric and
organophosphoric pesticides
and metals
ardnn
dieldnn
vapona
copper
zinc
arsenic
Period of Operation:
July 1993-July 1995
Cleanup Type:
Intenm response
Vendor:
T-Thermal Sub-X® Liqui-
Datur® Incinerator
manufactured by T-Thermal
Incorporated and cross-
licensed by Nittetu Chemical
Engineering, Limited
SIC Code:
NA
Technology:
On-Site SQI Incineration
• High-temperature oxidation in
a down-fired, SQI
• High-energy ventun scrubber
for paniculate emission
control
• Packed tower caustic
scrubber for neutralization of
GXn&USt QdSGS
• Residuals transported to off-
site handling facility
Cleanup Authority:
CERCLA and State.
Colorado
• U.S. Army, PRP, and
EPA enter into Federal
Facilities Agreement 2/89
- includes 13 intenm
response actions
-ROD signed 12/9/96
• DoDLead
Point of Contact:
Colonel Eugene H Bishop
Program Manager
Rocky Mountain Arsenal
Commerce City, CO
80022-2180
(303) 289-0467-Public
Affairs Off ice
(303) 286-8032-SQI
Information Hotline
Waste Source:
Evaporation basin used to store
manufacturing wastewaters
Type/Quantity of Media Treated:
Uquids
• 10 9 million gallons
Purpose/Significance of
Application:
Innovative design used to
capture metal particulates;
250,000 pounds of copper
recovered and recycled
Regulatory Requlf
ite/Ctoanup Qoala:
•gulatory Reqi
Destruction and Removal Efficiency (ORE) of 99.99% for all constituents of concern as required
by Resource Conservation and Recovery Act (RCRA) Incinerator regulations in 40 CFR part
264. tuboartQ
172
-------
Incineration at the Rocky Mountain Arsenal Superfund Site
Commerce City, Colorado
(Continued)
Results:
Monitoring and tnal bum data Indicate that all ORE and emission standards have been met
Description:
RMA was established in 1942 and historically has been used for manufacturing and
demilltarizating chemical incendiary weapons Portions of RMA were leased for the private
production of agricultural chemicals including pesticides from 1947 to 1982. Between 1957 and
1982 an evaporation pond (Basin F) was used for disposal of various wastewaters from the site's
manufacturing process and wastes from demilitarization activities
The Army and the on-site chemical manufacturer were designated as responsible parties in a
Federal Facilities Agreement (FFA) entered into in 1989 The FFA specified 13 interim response
actions (IRAs), including the remediation of Basin F A Record of Decision (ROD) for all operable
unite at the site was signed June 11,1996
The Army selected SQI to dispose of Basin F liquids The SQI system included an atomizing
liquid injection system, an incinerator chamber; a quench chamber; a spray dryer; a venturi
scrubber for paniculate matter control, a packed-tower scrubber for neutralization of off-gases;
and a residuals handing facility
Full-scale operation of the SQI began in July 1993, and incineration of approximately 10 9 million
gallons of Basin F liquid was completed by July 1995 The SQI was decommissioned,
dismantled, and sold for parts, per the FFA, upon completion of the project. All applicable and
relevant or appropriate requirements were met throughout the project.
The actual cost for remediation of Basin F was approximately $93,000,000. including
$14,800,000 in capital costs and $78,500,000 in operation and maintenance costs.
173
-------
ftocfcy Mountain ArawMf Supwfund SH*
This report presents cost and performance data
for the application of on-sfte incineration at the
Rocky Mountain Arsenal (RMA) Superfund Site
near Commerce City, Colorado Anon-site
submerged quench incinerator (SQI) was used
from July 1993 through July 1995 to treat liquid
wastes generated at RMA
The primary contaminants of concern in the
liquid waste included organochloric pesticides
(including aldrin and dieldrin), organophosphoric
pesticides (including vapona), and metals
(including copper, lead, arsenic, and zinc)
RMA was established in 1942 and historically
has been used for manufacturing and
demilitanzating chemical incendiary weapons.
Portions of RMA were leased for the private
production of agricultural chemicals including
pesticides from 1947 to 1982 Between 1957
and 1982 an evaporation pond (Basin F) was
used for disposal of various wastewaters from
the site's manufacturing process and wastes
from demilitarizations
The Army and the on-site chemical
manufacturer were designated as responsible
parties in a Federal Facilities Agreement (FFA)
entered into in 1989. The FFA specified 13
interim response actions (IRAs), including the
remediation of Basin F Standards for Basin F
were established in a 1990 Final Decision
Document (DD) These standards included
treatment resulting in a 99 99% destruction and
removal efficiency (ORE) of organic
constituents A Record of Decision (ROD) for
all operable units at the site was signed
June 11,1996
Remediation of Basin F was conducted in
two parts The first part consisted of
removal and temporary storage of liquid,
and ^removal and stockpiling of solids and
sludges. Tte second part consisted of
disposal of the stored liquid The remainder
of this document addresses the disposal of
Basin F liquids, unless otherwise stated
The Army selected SQI to dispose of Basin
F liquids The SQi system included an
atomizing liquid injection system; an
incinerator enamben a quench chamber; a
spray dryer; a venturi scrubber for
paniculate matter control, a packed-tower
scrubber for add neutralization of the
exhaust gases; and a residuals handing
facility
Full-scale operation of the SQI began in
July 1993, and incineration of approximately
10.9 million gallons of Basin F liquid was
completed In July 1995 The SQI was
decommissioned, dismantled, and sold for
parts, per the FFA, upon completion of the
project Ail applicable and relevant or
appropriate requirements (ARARs) were
met throughout the project
The actual cost for remediation of Basin F
was approximately $93,000,000. This
consisted of approximately $14,800,000 in
capital costs and $78,500,000 in operating
and maintenance costs.
U.S. ENVIRONMENTAL PROTECTION AQENCY
OfflM of Solid Watt* And Emergency Ratpontt
Technology Innovation Office
174
-------
Rodty MounttAi Aram*/ Supvfund Sft»
Rocky Mountain Arsenal Superfund Site
Commerce City, Colorado
CERCLISf MA
ROD and DD Date: A Decision Document for
the Basin F IRA was issued May 1890 A single
ROD for all on-site OUs, including Basin F. was
signed June 11,1996
Type of action: Interim response (on-site
SQI incineration)
Period of tail-scale Incinerator operation:
July 1993 through July 1995
Quantity of material treated during
application: 10.9 million gallons of liquid
hazardous waste
Historical Activity that Generated
Contamination at the Site. Manufacture and
demilitarization of chemical munitions and
manufacture of pesticides
Waste Management Practice that
Contributed to Contamination- Disposal of
manufacturing wastewater into an evaporation
basin
Site History:
• RMA was established in 1942 for the
manufacture of chemical and incendiary
munitions as well as demilitarization of
chemical munitions Pesticides were
manufactured at the site from 1947 through
1982
• The RMA site is located on approximately
17,000 acres 10 miles northeast of
metropolitan Denver, Colorado and directly
east of Commerce City
• From 1943 through 1950, stocks of
Levinstein mustard gas were distilled,
several million rounds of mustard-filled
shells were demilitarized, and mortar rounds
filled with smoke and high explosives were
test-fired
In 1947, portions of RMA were leased
for production of chlorobenzene, DDT,
naphthalene, chlonne, and fuzed
caustic
In 1951, another manufacturer assumed
the lease and produced pesticides until
1982
Through 1956, waste streams from the
above manufacturing operations were
discharged to unlined evaporation
basins (Basins A through E)
In 1956, Basin F was designed and
constructed as an evaporation basin to
receive various manufactunng wastes.
The basin had a surface area of 93
acres and a capacity of approximately
243 million gallons. The basin was
constructed using an asphalt liner
covered by a 1-foot layer of sand
Between August 1957 and December
1981, Basin F was the only evaporative
wastewater disposal location in service
at RMA.
Basin F was located in the northeast
section of RMA and was used to
dispose of wastes containing
organochloric and organophosphoric
pesticides and various metals
U.S. ENVIRONMENTAL PROTECTION AQENCY
Office of Solid Watt* and Emergency ResportM
Technology Innovation Offlc*
175
-------
Rocky Mountain Amnal SupMfunrf Site
fCant.1
In 1986, the Department of Interior, the
Department of Health and Human Services,
the Department of Justice, and the U.S.
EPA (EPA et a/,), and the potentially
responsible parties (PRP) at the site agreed
(via the Basin F Memorandum of
Understanding) to undertake a removal
action to address threats to human health
and the environment posed by liquids and
contaminated soils and sludges in Basin F
Part One of the removal action (completed
in December 1968) included the removal of
liquids from Basin F to storage tanks and a
surface impoundment, and the removal of
soil and sludge to a double-lined waste pile.
Part Two included incineration of the Basin
F liquid that was stored in the holding tanks
and surface impoundment
In February 1989, EPA et al., and the PRPs
entered into a FFA for all of RMA, including
remediation of Basin F.
In May 1990. the Army issued a Final
Decision Document for Basin F Liquids
which specified remediation via SQI with a
venturi/packed-tower scrubber.
• Between July 1993 and July 1995, the
SQI processed 10.9 million gallons of
Basin F liquids, meeting the standards
established in the FFA.
Regulatory Context: In February 1989,
EPA et al., the Army and the second PRP
entered into a FFA that stated RMA Is
subject to the cleanup standards in Section
121 of the Comprehensive Environments
Response, Compensation, and Uabilrt / Act
(CERCLA) and provisions of the National
Contingency Plan for Oil and Hazardous
Substances (NCR).
Remedy Selection. On-stte submerged
quench incineration (SQI) was selected as
the remedy for Basin F liquids at RMA
based on the results of feasibility studies, a
preliminary risk assessment, and treatability
studies (laboratory and pilot-scale testing),
economic considerations; and input from the
public
TtttMlhM
Table 1. Timeline
1942
1M3-19SO
1947
1961-1962
1957-1982
1986
JUV1987
May 1988 -Daoamtoar
1986
8aplambaM9SB
February 1969
Dacambar1989
RMA aatottahad tor manufacture and damMMzaton of chamtealaridlmMmtaymunNtona.
ChamlcalimailfcnamanulaclufadanddamB*^^
Portion* of RMA teased; manufacture oC cMorabanzana, DDT, naphAalana. chtorina, and fuzad
PRP ataumaalaaiiind manufacture paattcMee
BarinFtouaadaaanwaporaltonpondtorMn^RIM
U S, Aimy. another PRP, and EPA al al . agraa to Bartn F Mamorandum of Undaratandbig,
outttfng
BaatoFIRA
RMAptoadcnttjaNPL
ran una 01 oaam r IHA eonaucno (ramoMi am Mmporavy aniapa OF MMMM;
PartTtoof Bailn F IRA InlMad (oharaeMriaatoor
^B^M«k^Jk^ ^^••kaj* drf ta^^HbMMBit t^rfi hr> nJ-mm j ft a^biM f& 4*^^rfaM^ant n*ix»»»»t
•NrTpfipvt. wwKi oi oMnNvn wcnnowyy, o won or vMnrnvn PTOOMII
U.8. Army, andhar PRP, and EPA at al , antar Into a FFA that Ineludat 13 IRAa at RMA (Including
atwo*artlRAforrarmK*atlonforBaiinF
Final Tcaafenam Aaaasamant Raport daaorttng Vw prafarradallarnallvafortraalmantofBatlnF
Intffk
US ENVIRONMENTAL PROTECTION AGENCY
Offkw of Solid Waat* and Emergency Racpona*
Technology Innovation Offlc*
176
-------
Rocky Mountain Annul Suf*rfund Slto
Table 1. Timeline
MsylMO
Ssctsmbsr 1902
Msy 20-25. 1903
Jim 10-12. 1903
July 1993 -July 1995
DKntfNM993
Msy 1996
FhisJ Dwtoton DocunMnl tor Bask) F taiidlnKiiMntlsauML
Trial Bum Ptan submitted
TWO MN DUIIB COnOUCMQ HO SSISDISn KlMlm MINIS)
TrW Bum conducted
Futacato opsnflon of SOI conducted
TiW Bum SumnMiy Rsport compMsd.
SQI dscofnmte»lon«d,oTsnwiisdtrt sold for parts
Site Management DOO-Lead
Oversight: EPA with input from Colorado
Department of Health, U.S Fish and Wildlife
Service, and Tri-County Health Department
Remedial Project Manager:
Laura Williams
U.S. EPA Region 8
99918th Street, Suite 500
Denver, Colorado 80202
(303)312-6660
Type of Matrix Proceseed Through the
Treatment System- Liquid waste from
pesticide manufacturing processes
U.S. Army Contact:
Colonel Eugene H Bisnop
Program Manager
Rocky Mountain Arsenal
Commerce City, CO 80022-2180
(303) 289-0467 - Public Affairs Office
(303) 286-8032 - SQI information Hotline
Treatment System Vendor and Operator:
T-Thermal Sub-X® Uqui-Datur® Incinerator
manufactured by T-Thermal Incorporated
and cross-licensed by Nittetu Chemical
Engineering, Limited
SQI system operated by Western Inc.
Contaminants: Organochloric and
organophosphoric pesticides and metals in
solution
• The contaminants of greatest concern
include pestiddss (aldrin, dtoldrin, and
vapona) and metals (copper, zinc, and
arsenic)
• Several organochlorte pestiddes were
detected, including vapona at a maximum
concentration of 2.40 mg/L
Several organophosphoric pesticides
were found at concentrations ranging
from 011 to 0.89 mg/L
Several metals were detected, including
copper, zinc, and arsenic at maximum
concentrations of 210 mg/L 0.95 mg/L
and 3.0 mg/L respectively.
US ENVIRONMENTAL PROTECTION AGENCY
OfHoe of Solid Waste and Emergency Response
Technology Innovation Offlcs
177
-------
/tacfcy Mountain 4fumf Supwfluntf Site
The Basin F liquid was sampled and
analyzed and determined to be corrosive,
according to RCRA regulations in 40 CFR
261.22. The higher heating value of Basin
F liquid was measured to be 37 BTU/Ib
Specific gravity and pH of the liquid
were measured to be 1.2 and 6.02,
respectively.
SYSTLFJ DFSC
Submerged quench incineration system
including:
• Atomizing liquid injection system
• Submerged quench incinerator
• Quench chamber
• Spray dryer
Post treatment (air):
• High-energy venturi scrubber for
partlculate matter control
• Packed tower caustic scrubber for add
neutralization of the exhaust gases
The incineration system at RMA consisted
of high-temperature oxidation in a down-
fired. SQI followed by a high-energy venturi
scrubber for paniculate emission control and
a packed tower caustic scrubber for acid
neutralization of the exhaust gases A
schematic of the incineration system is
presented in Figure 1
During operations, liquid waste was fed to
the flame zone of the down-fired incinerator
through an atomizing spray nozzle. Molten
salts (residuals from combustion) flowed
down the sides of the Incineration vessel
and fell into a quench tank with water
circulation. Combustion gases were
bubbled through the quench tank and routed
to the ARCS. The quench tank liquid
(brine), which contained dissolved salts and
residual heavy metals, was transported first
to the residuals storage facility and
ultimately off-site where the metals were
removed and recycled to a smelter.
The ARCS included of a mechanical venturi
scrubber for removal of paniculate* In the
off-gases from the quench tank. TheAPCS
also Included a caustic (packed) tower
scrubber used as secondary treatment
for the quench tank gases and primary
treatment for the discharge air from the
residuals handling facility The packed-
tower scrubber system consisted of an
absorber section, a mist eliminator, and
an exhaust stack
Combustion gases were drawn through
the SQI and ARCS by an induced-draft
fan and were exhausted through a 30-
meter reinforced, concrete stack.
Typical exit gas velocity was 14.7
meters per second.
The SQI was developed by T-Thermal,
Inc The SQI design operating
parameters are presented in Table 2
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergsncy ReiponM
Technology Innovation Offlo*
178
-------
Rocky Mountain Anuial Suporfund SHo
TREATMENT SYSTEM DESCRIPTION (CONT.)
Cm tmountun after quench
Figure 1 Conceptual Schematic of the Submerged Quench Incineration System
(prepared by Woodward-Clyde Consultants)
TRF. ATMFNT Svsn.r.i PERFOHMANCF
The cleanup goals and standards specified
in the FFA were consistent with the
requirements In Section 121 of CERCLA
and the provisions of the NCP.
The maximum acceptable concentrations of
contaminants corresponded to a 1x10*
excess lifetime cancer risk and a hazard
Index of 1 00.
The required DRE for POHCs was
9999%
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offlo* of Solid Waste and Emergency RMponM
Technology Innovation Office
179
-------
Rocky Mountain Aram/ Suf*rfund Sit*
Two mini-burns were conducted at RMA
May 20 through May 25,1993, and a full
trial bum was conducted from June 10
through June 12,1993 The bums ware
designed to operate the incineration system
at condWons that would reflect worst- case
destruction and removal of all constituents
of concern Monochtorobenzene and
carbon tetrachloride were selected as
POHCs for the trial bum at RMA. The
POHC feed rate, stack gas emissions rate,
and calculated DREs are shown in Table 3
Interim operating limits were then
established based on results of the mini-
bums These interim limits were used until
approval of final limits.
The SQI operated within the operating
limits established during the mini bums
and trial bum, signifying that all
emissions requirements were met or
surpassed Tnal bum and interim
operating parameters are shown in
Table 4
Table 3. A
Destruction and Removal Efficiencies from Trial Bum
•Ndttwr POHC %MS detected In toe waste feed.
Table 4 Operating Parameters [4]
WsBtaFMdRste
Emission Ratr
Parfcutoto -O7%Ot
• O12K CO,
HO
CO(HRA)
THC
NO,
S0t
HO
Openflng CondWons
MMmum SQI Chsmbsr Tsmpsmtur*
MNWVNIff) ^NkMnOA TNVI9
minimum Beets Oxygsn
Minimum Quench pH
Minimum Scrubber pH
Mtadmum Vwturt Rsoyoto Flow Rita
178feAi*i
OQ214grakisftkcf
00320gra*w/*cf
0^291 toUr
51^ppm
8.2Sppm
131 ppm
55 6 ppm
zsoppm
183B*F
272 see
8.50%
012
5.78
l267qaVmki
<166bAnln
<006gralnsAiscf
<010g«*isAJ8cf
<4h/hr
< 100 ppm
MA
NA
NA
NA
1825'F
2.7 S«C
9%
4
6.25
lOOgsVmln
U.8. ENVIRONMENTAL PROTECTION AGENCY
Of/let) of 8oHd Wsjstc and Emergency RMporwc
Ttchnology Innovation OffkM
180
-------
Rocky Mountain A/MM/ Sqpevfund Site
MBdmum Venturi DffleranM Praseum
Ma*num UquU/Ga* Raflo
Mttdmum Scrubber ftocycto Rate
Natural Gas Row Rate
Total Combustion Air
SOI Chamber Prasaura
90 fetches W.C.
mgaMccf
2857gaHi*i
438scfm
7,107 scfm
3.87 prig
80 Inches W.G.
9.3gaMccf
ZTOgaMnln
MA
MA
NA
• A «•»•«•••*!••* *«»l»a» ***- •• — ' • -»•-»—-•—• MM nuia ^ J - '
*ont half th* daMcflon Imtt for kKMckMlnon-delactraMlte ww
lm In* »rtbfchrt during hw-mlnH)unw"cono^ TtimvriuaewmusadatllmrlsumilapprovaJof
th* ImHs pnposad during thv trial burn
dtcf - Dry standard cubic tot
HRA-HounyroingavBraoe
tef-Thousand cubic feet
paig • Pounds per square Inch, gauge
scfm - Standard cubic feet per minute
NA-NotaMtabto
w.c -Watercolumn
Complete results of Basin F liquid testing
can be found in the Summary Report for
Incineration of Basin F Wastes [1] and the
Trial Bum Summary Report [4].
Complete risk assessment results can
be found in the Final Human Health
Risk Assessment [S\.
According to site personnel, Quality
Assurance and Quality Control (QA/QC) for
all testing and associated analyses,
evaluation of all data, and the complete
decision making process was followed in
accordance with the FFA.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offlo* of Solid Wast* end Emergency Reeponae
Technology Innovation Office
181
-------
Rocky Mountain Antnal Suptrfund Sfa
TREATr:
IT SYS'
• IT and Weston, Inc were contracted to
commission, test, and operate the SQI at
the site.
Coat Data
• The total project cost of $93,337,779 was
reported by Rocky Mountain Arsenal in
terms of capital costs and operation and
maintenance costs The capital costs for
the incineration system were $14,829,318
and operation and maintenance totaled
$78,508,461 The total costs for thermal
treatment were reported as $58,145,681 A
total of 10.9 million gallons of liquid waste
were incinerated. This corresponds to a
total unit cost of $9 per gallon, and a unit
cost for thermal treatment of $5 per gallon
Tables 5 and 6 show the operation and
maintenance costs for incineration
331
331
331
01
02
03
MobMzaKon and preparatory wok
Monitoring. samping, tasting, and analysis
SMewoifc
Total Cartta! Costs
$6,923,728
$3.505.590
$2.400,000
$14.829.318
and Maintenance Costs
342
342
342
14
18
22
1 iWTTtW 1 IMUIMII (inCtflMaWOilJ WTHCfl nCMOM
• EqulpnMnt
• Labor
• Dlrsct operating costs
• Overhead
DteoossJ
QsnarsJ Rsoulremsnta
TotfJOottqpon v$ MalntoWKi Costa
$58,145,681
$18.936.616
$1.428.164
S78.S06.4ei
Actual capital and operations and
maintenance coat data are available from
Rocky Mountain Arsenal.
U.S. ENVIRONMENTAL PROTECTION AOENCY
Offlos of Solid Watt* and Emwgtnoy RsjponM
Technology Innovation Offlc*
182
-------
OBSERVATIONS AND LESSONS LEARNED
• Unexpected weather conditions caused
delays in the start-up of the incinerator A
heavy rainfall classified as a 25-year/24-hour
event significantly increased the volume of
liquid in the open holding pond just before
the start of the project This necessitated
construction of a special double-lined holding
pond for additional storage capacity
Additionally, a tornado touched down near
the tanks and holding pond, requiring
inspection and subsequent repair of
equipment.
Public Involvement
• An extensive Community Relations program
was developed in 1988 at RMA that
addresses public concern relating to the
entire site This program included the
establishment of an on-site information
center, providing speakers for local clubs and
organizations, attending conventions, public
meetings, and open houses.
A 24-hour telephone hotline was established
and a monthly publication (the Rocky
Mountain Arsenal SQI Update) was
developed
In addition, a Restoration Advisory Board,
including members of local governments and
the public, was established to obtain input on
the remedial approach from various parties
According to site personnel, these actions
helped to alleviate public concern related to
the on-slte remediation action
The draining of liquid from Basin F and
the subsequent drying of soils,
sediments, and the Basin F liner was
identified as a significant odor concern
by nearby residents. Air purifiers were
distributed to affected homes to help
alleviate the odors. lexicologists from
various agencies identified the
compounds causing the odors and
determined that they did not present
acute health effects.
REFERENCES
Summary Report for Incineration of Basin F
Wastes at Rockv Mountain Arsenal. Volume
1; September 1988
Final Decision Document for the Interim
Response Action, Basin F Liquid Treatment,
Rocky Mountain Arsenal, Volume I - Text,
May 1990.
3 Interim I
> Action. Basin F Liquid
Incineration Project, Implementation
Document, Volume I; January 1992.
Trial Bum Summary Report for the Interim
Response Action, Basin F Submerged
Quench Incineration Project, Volume I,
December 1993
Interim Response Action, Basin F Liquid
Incineration Project, Final Human
Health Risk Assessment, Volume I;
March 1994
U 8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wute and Emergency Response
Technology Innovation Office
183
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This Page Intentionally Left Blank
184
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On-Site incineration at the
Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
185
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Incineration at the Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
Site Name:
Rose Disposal Pit Superfund
Site
Location:
Lanesborough, Massachusetts
Contaminant*:
Primary Contaminant
Groups: PCBs, volatile
organic compounds (VOCs)
including TCE, benzene, and
vinyl chloride
• PCBs at were detected at
concentrations up to
440,000 mg/kg The
average PCB concentration
was 500 mg/kg
Period of Operation:
February 1994-July 1994
Cleanup Type:
Remedial action
Vendor:
Mark Phillips
Maximillian Technology
Pittsf ield, MA
(413) 494-3027
SIC Code:
NA
Technology:
On-sfte incineration
• Soil was pretreated with
crushing and shredding to
achieve a homogenized
incinerator feed
• Incineration system
consisting of rotary kiln and
secondary combustion
chamber (SCC)
• SCC temperatures
averaged 2000 T
• Ash was discharged, and
returned to the excavated
areas on site
Cleanup Authority:
CERCLA
• ROD Date. 9/30/96,
11/21/89
• EPA-lead
Point of Contact:
Pam Shields
U S EPA Region 1
Waste Source:
Disposal of manufacturing
wastes in an open trench
Type/Quantity of Media Treated:
Soil (51,000 tons)
Purpose/Significance of
Application:
Incineration of PCB-
contaminated soil
Regulatory Requirements/Cleanup Goals:
Destruction and Removal Efficiency (ORE) of 99 9999% for DCBs as required by Toxic
Substances Control Act regulations in 40 CFR part 761 subpart D
Results:
Treatment performance and air monitoring data collected during this application indicated that all
required performance and standards emissions were achieved
186
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Incineration at the Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
(Continued)
Description:
Between 1951 and 1959, the 14-acre residential tot received wastes from a nearby manufacturer
Soil at the site was contaminated with PCBs as well as volatile organic compounds (VOCs) A
Record of Decision signed September 23,1988 and November 21,1989 specif iedon-site
incineration as the remedial technology for the soil and sediments Site cleanup goals and DRE
standards were specified for constituents of concern
On-sfte incineration began in February 1994 and was completed in July 1994 The treatment
system consisted of a rotary kiln and an SCC Kiln ash was treated and stored and treated gas
was exhausted to a stack. Incineration has achieved the soil cleanup goals specified in the ROD
No information was available on costs for the remedial action.
187
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Alow Disposal Pit Superfund Site
EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site incineration at the
Rose Disposal Pit Superfund Site (Rose Site) in
Lanesborough, Massachusetts. A rotary kiln
incinerator was operated from February 1994 to
July 1994 as part of a remedial action
The Rose site is a 1 5-acre section of a 14-acre
residential lot located in Lanesborough,
Massachusetts. From 1951 through 1959 and
possibly later, wastes from a nearby
manufacturer were disposed of in an open
trench at the site. Soil at the Rose Site is
contaminated with PCBs, as well as volatile
organic compounds (VOCs) including
trichloroethylene, benzene, and vinyl chloride
Measured concentrations of PCBs at the site
VHP re as high as 440,000 mg/kg
In 1988, EPA signed a Record of Decision
(ROD) specifying on-site incineration as the
selected remedy for the contaminated soil at the
Rose Site In 1989, EPA released an
Explanation of Significant Differences (ESD)
which outlined EPA's agreement with the
responsible party to conduct complete source
remediation. To achieve complete source
remediation, the responsible party excavated
and incinerated a greater volume of
contaminated soil than that specified in the
ROD The ROD set a Destruction and Removal
Efficiency (ORE) standard for PCBs of
The remediation activities performed at the
Rose Site also included the construction and
operation of a groundwater treatment system,
However, unless otherwise indicated, only
Issues relating to on-site incineration are
discussed in this report
The excavated soil at the Rose Site was
crushed and blended before incineration
The blended soil entered the rotary kiln at
through the kiln co-current with the exhaust
gas. Kiln ash was quenched in a water
bath, while the exhaust gases were directed
to a secondary combustion chamber (SCC)
for further destruction of contaminants in the
waste feed
The air pollution control train consisted of a
cyclone separator for removal of larger
paniculate matter, a quench tower, a
baghouse for removal of finer paniculate
matter, a second quench tower, and a wet
scrubbing system designed to remove
residual contaminants. Dust removed by
the cyclone separate^ and the baghouse
was discharged to the ash quench bath
Wastewater from the quench towers and the
scrubbing system was also discharged to
the ash quench bath All of the solid waste
generated by the system was removed with
the incinerator ash and landfilted on site
Dunng its five months of operation, the
incinerator processed approximately 51,000
tons o* contaminated soil Treatment
performance and air monitoring data
collected during this application indicated
that all required performance and standards
emissions were achieved
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
188
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Ro»* Dfepom/ Pit Sup»ffund SH»
SITE INFORMATION
Identifying Informatlcfl
Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
CERCLIS f MAD980524169
ROD Date: September 23,1988 (ROD)
November 21,1989 (ESD)
Treatment Application
Type of action: Remedial (on-site rotary
kiln incineration)
Period of operation: February 1994 - July
1994
Quantity of material treated: 51,000 tons
of contaminated soil
Historical Activity that Generated
Contamination at the Site: The site was used
for disposal of waste generated from many
different manufacturing processes
Corresponding SIC Codes: NA
Waste Management Practice That
Contributed to Contamination: Disposal of
manufacturing waste in an open trench
Site History:
• The Rose Site is located on Balance Rock
Road in Lanesborough, Massachusetts
approximately 4 miles north of Pittsfield
The site is bounded on the north and
northeast by the deciduous forest of
Balance Rock State Park, on the east and
southeast by cropland and pasture, on the
west by mixed forest, and on the southwest
by a residential area
• The Rose Site is the location of a trench
used for disposal of manufacturing wastes
generated by the responsible party between
1951 and 1959 The wastes contained
PCBsandVOCs
• Between 1980 and 1982, EPA conducted
the preliminary assessment, site inspection,
and field investigation All subsequent
activities at the site have been performed
by the responsible party
• A remedial investigation (Rl) was conducted
in 1983 and supplemented in 1986, and the
feasibility study (FS; was conducted In
1988.
• Based on the results of the Rl and the
FS, a ROD was signed on September
23,1986 specifying excavation and on-
srte incineration of contaminated soils.
The ROD specified excavation of the
contaminated soil to the top of the
saturated zone
• In 1989, EPA released an ESD which
outlined EPA's agreement with the
responsible party to conduct complete
source removal Under this agreement,
the responsible party excavated
additional soil below the saturated zone
Complete source removal allowed the
responsible party to avoid installing a
cover and establishing other long-term
institutional controls
• Approximately 51,000 tons of soil were
processed between February 1994 -
July 1994 By July 1994 all of the
cleanup goals had been met for the
contaminated soil, and incineration had
Regulatory Context:
• In 1984, the Rose Site was added to the
National Priorities List (NPL)
• A ROD was signed in 1988 requiring the
responsible party to conduct remedial
activities at the Rose Site
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
189
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AM* Otpotul Mr Supfrfund SU»
In 1989, EPA released an ESD which
outlined EPA's agreement with the
responsible party to conduct complete
removal; this action was more aggressive
then that associated with the goals set
forth in the ROD
The ORE and ash residual standards were
established the provisions of the Toxic
Substance(s) Control Act (TSCA) and
associated regulations in 40 CFR part 761
subpartD.
The selected remedy is consistent wfth
the Comprehensive Emergency
Response, Compensation and Liability
Act of 1980 (CERCLA). as amendeo by the
Guperf und Amendments and Reauthorization
Act of 1986 (SARA), and to the extent
practicable, the National Contingency Plan
(NCR) in 40 CFR part 300.
Remedy Selection: EPA determined that on-
site incineration was the only available
alternative that satisfied all of the criteria
established in the ROD. particularly
permanence, and that on-site incineration was
more cost effective than off-site incineration
for the Rose Site [1].
1851-1959
1960-1982
1983
1984
May 1984
1966
1988
September 23. 1988
Nwwnber21,1989
Octobar1993
February 1994
April 1994 -July 1994
Wattes am dhpoead of by ttw HP at ffw Ron Disposal Pit site.
M_kl L^. — „ « _l>^ * MS • «_•_•• ••_.» tm ii it i
U by EPA.
Araro»dMlnviatlg
-------
ROM Otcpoe*/ Ptt Supfftund SK»
MATRIX DESCRIPTIOT
Type of Matrix Proces»ed Through the
Treatment System: Contaminated soil
excavated from the disposal pit both above
and below the saturated zone
Primary Contaminant Groups: PCBs, volatile
organic compounds (VOCs) including TCE,
benzene, and vinyl chloride
PCBs at were detected at
concentrations up to 440,000 mg/kg
The average PCB concentration was
500 mg/kg.
The matrix characteristics that most significantly affected cost or performance at this site and their
measured values are presented in Table 2
Sol Density
Heat content
Ash
Chlorine Content by Wright
IBgfcc
290Btu/t>
86%
038%
TREATMENT SYSTEM DESCRIPTION •
Rotary kiln incineration system, including
• Waste feed handling system
• Rotary kiln incinerator
• Secondary combustion chamber
Air Pollution Control System, including
• Cyclone separator
• Baghouse
• Quench towers
• Wet scrubbing system
The soil at the Rose Site was excavated
and transported to the crusher/shredder.
The crusher/shredder was used to reduce
the particle size of the soil feed to less than
075 Inches. The crushed soil was
transported to the soil blending building
where it was blended before Incineration to
achieve a homogenized incinerator feed
The soil blending building was equipped
with a vapor-phase carbon filtration system
designed to reduce possible PCB or VOC
emissions.
• The soil feed entered the kiln at the
flame end and traveled through the kiln
co-current with the combustion gases
Ash and exhaust gases were discharged
from the kiln.
• Kiln ash was quenched in a water bath
and discharged to a storage area. The
solids in the ash quench bath were
allowed to settle and were continuously
removed
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wast* and Emergency Response
Technology Innovation Office
191
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TREATT
(CONT
The co-current rotary kiln was 110 feet long
with an internal diameter of approximately 8
feet. The kiln consisted of three refractory-
lined cylindrical sections bolted together at
flanged connections to function as one unit
The kiln was designed for an optimal
throughput of approximately 50 tons of
contaminated soil per hour
The kiln was fired with oxygen, fuel oil, and
excess air The kiln-drive system employed
a 200-hp moto'.
The kiln exhaust gases were directed to a
cyclone separator for j.noval of larger
particulates Exhaust gases entered the
cyclone sep- T" rtangentially allowing
larger parho.es to fall out Particles
separated from the exhaust gas fell to the
bottom of the cyclone and were transported
to the ash quench bath.
The exhaust gas then entered the SCO
which provided further destruction of
remaining contaminants. The SCO was 52
feet long and had an internal diameter of 11
feet It was lined with refractory brick and is
fired with oxygen, fuel oil, and excess air
Exhaust gas from the SCO was cooled in a
quench tower from approximately 2,000 °F
to approximately 425 °F Quench nozzles
in the tower spray atomized recycled water
into the gas stream
The quenched exhaust gas was then
drawn into a baghouse The baghouse
consisted of 1,020 woven fiberglass
bags. Each bag had a 6-inch diameter
and length of 10 feet for a surface area
of 16 square feet per bag. The total
filter area of the baghouse was
approximately 16,300 square feet The
dust removed in the baghouse was
discharged to the ash quench bath
were then quenched in a second quench
tower similar to the one previously
described
The filtered and quenched exhaust
gases were drawn through a packed-
tower-design wet scrubber Scrubbing
was achieved by spraying caustic
solution over the packed bed as the
exhaust gas flowed up through the bed
Scrubber wastewater was continuously
recycled, with a bleed stream
discharged to the ash quench bath
Gases were forced out of the scrubber
and into the exhaust stack which was
mounted on top of the scrubber The
stack released gas to the atmosphere at
approximately 200 °F The internal
diameter of the stack was 4.5 feet and
the height above the ground was 66
feet
The solids in the quench bath included
all of the residuals from the air pollution
control units as well as the ash from the
incinerated soil These solids were
sampled and analyzed using the TCLP
and eventually returned to the
excavated areas on site
U S. ENVIRONMENTAL PROTECTION AGENCY
Offlcn of Solid Watt* and Emargancy Rwponw
Technology Innovation Offlc*
192
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TREATMENT SYSTEM PERFORMANCE
i Goate/Standardi
The cleanup goals and standards were
specif led in the ROD The ORE was set
based on TSCA regulations 40 CFR part
761 subpart D [1]
The soil cleanup level was 13 mg/kg for
PCBs. This corresponds to a 1 x 10 *
excess lifetime cancer risk level for the
average case
The required ORE was 99.9999% for
PCBs
The maximum concentration of PCBs in
the residual ash was set at 2 mg/kg
A tnal bum conducted at the Rose site was
designed to operate the incineration system
at conditions that would reflect worst-case
destruction and removal of all constituents
of concern
PCBs were determined to be present in the
soil at sufficient concentrations such that
spiking with PCBs or principle organic
hazardous constituents (POHCs) was not
necessary
The AWFCOs limits dunng the
operation of the incinerator are shown in
Table 4 Information about the
frequency of AWFCOs was not
available The values of various
operating parameters as measured
during the tnal bum are shown in Table
5, information on actual values of these
parameters dunng operation was not
available
The average concentration of PCBs in
the residual ash was 0.0618 mg/kg.
9999987
Maxknum pressure Win at entry
Mbiimum afterburner gas am temperature, Instantaneous
1,915'F
Minimum afterburner residence time, Instantaneous
Minimum pH at scrubber sump
Minimum flow scrubber redrculation flne
Maximum CO (7% O,)
Minimum O, (dry volume)
Minimum combustion efficiency
Maximum temperature quench f 1 gas ndt
Maximum temperature scrubber entry
2 seconds
5
450 gpm
lOOppmv
3%
999%
500'F
300-F
•Recommended limits from Trial Bum Report
U S ENVIRONMENTAL PROTECTION AQENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
193
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Tables
SCO Exit OM Temperature
Sol FMd Rate
PCS Feed Rate
Nkt Fuel O* Feed Rate
Ken Pressure
Quench ffl E* Temperature
SCC Residence Tbno
Scrubber Entry Temperature
Scrubber RedrcufaHon Flow
ScrabberpH
Slack Gas Carbon MonoxfcJe (60-Mnuto RoHng
Average)
Sleek Gw Oxygen (Diy Baste)
Secondary Draft
Combustion Efficiency
2,100 «F
51.8 tow/hour
740 Mir
1,734 fc/hr
-OSIncheewc
394 »F
4J seconds
206»F
575.8 gpm
7.5 8 U
9.9ppmv
90vd%
•OTIkicheewc
99.991
we -Watercolumn
«.u > Standard pH units
Tables TCLP Comparison for Residual
1,4-Dichlorabarasm
24Mhylphenol (o-cnwoO
nvcrasol^i-cnaol
NHrooenzene
• j^^jAlfimfA*. rt^relar*^
HWKnniDOUtBnMIW
2,4.6-Trtchtoropnenol
2,4,5-Titehlorophenol
2,4-DWtrotoluene
hlnmtun
i lawcnUHwenune
enUKnioropnanoi
Pyridrw
7JS
2000
2000
30
20
0.5
20
4000
013
013
1000
60
0010
0010
0021
0010
0010
0010
0010
0010
0.010
0010
0.021
0010
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offlc* of Solid Wtet» and Emwgwtoy RNponaa
Technology Innovation Offlct
194
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AM0 JXqtmM/ Pit Superfund SH»
TREATMENT SYSTEM PERFORMANCE (CONT.)
Cadmium
Table 6 TCLP Comparison for Residual
<00066
Chromium
SO
00137
50
0124
Mereuiy
<00070
Selenium
10
<00219
Slyer
50
<00133
Vinyl Chloride
0.2
<0011
1.1-Dfchtoroelnane
07
<0011
Chloroform
60
<0011
1,2'Dichloroethan0
05
<0011
2-Butamne (MEK)
2000
<0011
CarfxmTeCracMoride
05
<0011
TricNoroethene
OS
<0011
Benzene
05
<0011
Tabachtoroemene
07
<0011
Chtorabanzene
1000
<0011
gamma-BHC (Undana)
04
Endrfn
002
<0005
100
Toxaphene
05
Heptachtor
0008
<0003
1 Jnr»*f>nhlr>r
riopfBcmor
0008
<0003
Chtordane
003
<001
U 3. ENVIRONMENTAL PROTECTION AGENCY
Offlca of Solid Waste and Emargency Response
Technology Innovation Office
195
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AM* fftpoM/ PH Supvfund SH»
TREATMENT SYSTE
According to site personnel the QA/QC
program used throughout the remedial
action met all EPA requirements All
monitoring was performed using EPA-
approved methods, and the vendor did not
note any exceptions to the QA/QC
protocols [3]
TREATMENT SYSTEM Co<
According to site personnel the
responsible party contracted with Clean
Berkshire, Inc (CBI) To provide
design/remedial services at the site CBI
used several subcontractors to implement
specific aspects of the operation. [3]
• Information on the costs of on-site
incineration was not available
OBSERVATIONS AND LESSONS LEARNED
The incinerator was constructed during the
winter of 1992 Heavy snowfalls and low
temperatures hampered the progress of
workers
Cold weather also affected incinerator
startup, which occurred in January
1994 The extreme temperatures
caused various problems with water
used for cooling In addition, valves
cracked, solenoids remained closed or
open, and air lines froze
US ENVIRONMENTAL PROTECTION AGENCY
Offtet of Solid Wwte and Emergency Rtcponse
Technology Innovation Office
196
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Rote Disport Wf Suptrfumt Sft»
OBSERVATIONS AND LESSONS LEARNED (CoNT.)
Public Involvement
• Citizens expressed concern that the
incineration and excavation process would
create excessive noise EPA worked with
local officials to minimize the adverse
impacts of the site remediation activities [1]
• Many public meetings were held, and EPA
and state personnel met individually with
local officials and residents to discuss
specif ic concerns Neighborhood residents
formed a group that worked with EPA to
address public concerns
The RP setup a neighborhood network
that used volunteer neighbors to
periodically distribute fact sheets
regarding the site incineration project
REFERENCES
1. Superfund Record of Decision. Rose
Disposal Pit Site, Lanesborough,
Massachusetts, September 23,1988
2 Memorandum - Explanation of Significant
Differences. Rose Disposal Pit Site,
Lanesborough, Massachusetts, November
21,1989.
3 Trial Bum Report for the Clean
Berkshires. Inc. High Temperature
Incinerator (HTI) System. Rose Disposal
Pit Superf und Site, Lanesborough,
Massachusetts, December, 1993
4 Remedial Action Completion Report
F T. Rose Suoerfund Site, September
1994
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wast* and Emergency Response
Technology Innovation Office
197
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I
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On-Site Incineration at the
Rose Township Dump Superfund Site
Holly, Michigan
199
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Incineration at the Rose Township Dump Superfund Site
Holly, Michigan
Site Name:
Rose Township Dump
Superfund Site
Location:
Holly. Michigan
Contaminants:
PCBs, metals, and volatile end
semivolatfle organic
compounds
• Most common contaminants
(and maximum
concentrations) were toluene
(4,700 mg/kg), ethylbenzene
(430 mg/kg), chlorobenzene
(570 mg/kg), xylene (1,400
mg/kg), naphthalene (31
mg/kg), pentachlorophenol
(32 mg/kg), acetone (76
mg/kg), and total phthalates
(91 mg/kg)
Period off Operation:
September 1992 - October
1993
Cleanup Type:
Remedial Action
Vendor:
OHM Remediation Services
Corp.
16406 U.S Route 224 East
Findlay, OH 45840
SIC Code:
N/A
Technology:
On-Srte Infrared Incineration
• Excavated material screened
and blended with fuel oil pnor
to incineration
• PCBs and VOCs volatilized
and partially destroyed in
primary combustion chamber
• Kiln ash quenched by water-
cooled screw
• Exhaust gas from kiln
directed to air pollution
control system, consisting of
secondary combustion
chamber (SCC)
• Wastewater treated on-site
and discharged under
NPDES permit
Cleanup Authority:
CERCLA and State:
Michigan
• ROD signed 9/30787
• EPA-lead
Point off Contact:
Kevin Adler
US EPA Region V
77 West Jackson
Boulevard
Chicago, IL
Phone 312-886-7078
State Contact:
Brady Boyce
Michigan Department of
Environmental Quality
301 S Capitol Street
Lansing, Ml 48933
Phone 517-373-4824
200
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Incineration at the Rose Township Dump Superfund Site
Holly, Michigan
(Continued)
Waste Source:
Waste disposal areas in
landfills and surface
impoundments — wastes
included spent solvents, paint
sludges, lead battery sludges,
waste oils
Purpose/Significance of Application:
Operating in writer led to weather-related difficulties resulting
in suspension of the operation until spring
Type/Quantity of Media
Treated:
Soil
• 34,000 tons of surface and
subsurface soil
Regulatory Requirements/Cleanup Goals:
• Destruction and Removal Efficiency (DRE) of 99 9999% for principal organic hazardous
materials as required by Resource Conservation and Recovery Act (RCRA) regulations in 40
CFR part 264, subpart O, DRE of 99 9999% for PCBs as required by Toxic Substances Control
Act (TSCA) regulations in 40 CFR part 761
Results:
• EPA determined that demonstration of a 99.9999% DRE for PCBs was not necessary during the
tnal bum because (1) substantial hazards were associated with transporting and stonng
concentrated PCB oils, and (2) the unit had demonstrated the ability to adequately destroy
PCBs in order to obtain its TSCA permit
Description:
From 1966 to 1968 approximately 5,000 drums containing spent solvents, paint sludges, lead
battery sludges, and waste oils were buned in a 12-acre area at the Rose Township Dump site
Bulk wastes were also discharged to the surface or into shallow lagoons or pits in the area. On
September 30,1987, EPA signed a Record of Decision (ROD) specifying on-site incineration as
the selected remedy for contaminated soil at the site A consent decree was signed by 12
potentially responsible parties (PRPs) and EPA in 1988 to remediate the site
The incinerator used to process soils at the site was the OHM Mobile Infrared Thermal
Destruction Unit (TDU) The PCBs and VOCs were volatilized and partially destroyed in the
primary combustion chamber Off-gases from the preliminary combustion chamber were routed
to a secondary combustion chamber (SCC) for further destruction of any remaining VOCs and
PCBs Kiln ash was quenched by a water-cooled screw During the on-srte incineration remedial
action, 34,000 tons of contaminated soil were incinerated Treatment performance and emissions
data collected during this application indicated that all performance standards and emissions
requirements were achieved
The total cost for remediation using the incineration system was approximately $12 million.
201
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Ro*» Township Dump Supvfund Stt»
This report presents cost and performance data
for the application of on-srte incineration at the
Rose Township Dump Superf und Site (Rose
Township Site) in Holly, Michigan An infrared
incinerator was operated from September 1992
through October 1993 as part of a remedial
action. The contaminants of concern at the
Rose Township site were PCBs. metals, and
volatile and semivolatile organic compounds
From 1966 to 1968 approximately 5,000 drums
containing spent solvents, paint sludges, lead
battery sludges, and waste oils were buried in a
12-acre area at the Rose Township Dump site
Bulk wastes were also discharged to the surface
or into shallow lagoons or pits in the area
Dunngthe Remedial Investigation (Rl), PCBs
were detected in the soil at concentrations up to
980 mg/kg The majority of PCB contamination
was contained in an area approximately 200
feet by 750 feet Excavation of material to
depths of 22 feet was required to meet the
cleanup goals Lead was detected at
concentrations up to 3,200 mg/kg A variety of
volatile and semivolatile organic compounds
also were detected in soils during the Rl The
most common contaminants (and maximum
concentrations) were toluene (4,700 mg/kg),
ethyibenzene (430 mg/kg), chlorobenzene (570
mg/kg), xyiene (1,400 mg/kg), naphthalene (31
mg/kg), pentachlorophenol (32 mg/kg), acetone
(76 mg/kg), and total phthalates (91 mg/kg)
On September 30,1987, EPA signed a Record
of Decision (ROD) specifying on-srte
incineration as the selected remedy for
contaminated soil at the Rose Township Site
Performance standards for the incineration
process included a destruction and removal
efficiency (ORE) of 99 9999% for PCBs A
consent decree was signed by 12 potentially
responsible parties (PRPs) and EPA in 1988 to
remediate the site
Remedial actions were managed by Perini
Environmental, a remedial contractor hired by
the PRPs, and were performed under the
oversight of EPA Region 5.
Contaminated soil was excavated using
backhoes and longarms. Prior to
incineration, excavated material was
screened to less than one inch in diameter,
and blended with fuel oil to achieve the
desired BTU value. Wet soil was dried in a
drying building by heaters and blowers prior
to screening Oversize rocks, tree stumps,
and personal protective equipment were
shredded and incinerated Intact drums
unearthed dunng the excavation of soil were
disposed of off the site.
The incinerator used to process soils at the
Rose Township site was the OHM Mobile
Infrared Thermal Destruction Unit (TDU)
Off-gases *rom the preliminary combustion
chamber were routed to a secondary
combustion chamber (SCC) for further
destruction of any remaining VOCs and
PCBs. Kiln ash was quenched by a
water-cooled screw
Exhaust gas from the kiln was directed to an
air pollution control system (APCS) The
APCS consisted of a water spray to reduce
the temperature of the SCC exit gas, a low-
energy verrtun scrubber and a packed bed
adsorber to control particulates and acid
gas, and a high-energy ventun scrubber and
mist eliminator to control mete's emissions
and remove additional particulates All of
the wastewater generated by the system
was treated on site and discharged under a
fvpDES permit
During the on-site incineration remedial
action, 34,000 tons of contaminated soil
were incinerated. Treatment performance
and emissions data collected during this
application indicated that all performance
standards and emissions requirements were
achieved
The total cost for remediation using the
incineration system was approximately $12
million.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offfe* of Solid Wait* and Emwgmcy Rwponie
Technology Innovation Offte*
202
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Townthlp Dump Supfrtuntl Site
SITE INFORMATION
Identifying Information
Rose Township Dump Superfund Site
Holly, Michigan
CERCLISf: MID980499842
ROD Date: September 30,1987
Background
Historical Activity that Generated
Contamination at the Site: Dumping of spent
solvents, paint sludges, lead battery sludges,
and waste oils. No manufacturing or other
industrial activity was conducted at this site
Corresponding SIC Code: Not applicable
Waste Management Practice That
Contributed to Contamination: Waste
disposal in landfills and surface impoundments
Site History:
• The Rose Township site occupies a 110-
acre parcel of land A portion of the site
was used for farming from the 1950s to the
1960s From 1966 to 1968 approximately
5,000 drums containing spent solvents,
paint sludges, lead battery sludges, and
waste oils were buried in a 12-acre portion
of the site An undetermined amount of
bulk wastes were also discharged to the
surface or into shallow lagoons or pits in the
area
• The results of investigations at the site
indicate that surface and subsurface soils
and groundwater at the site were
contaminated with PCBs, metals, and
volatile and semivolatile organic
compounds
• In April 1979, the Michigan Department of
Natural Resources (MDNR) surveyed the
site and identified approximately 1,500
drums of unknown contaminants
Treatment Application
Type of action: Remedial (on-site infrared
incineration)
Period of operation: September 1992 -
October 1993
Quantity of material treated during
application: 34,000 tons of contaminated
soil
• A search warrant obtained in June of
1979 allowed the drums to be sampled
by the MDNR to identify their contents
• Based on the results of 1979 drum
sampling, a toxic substances
emergency was declared by the
Michigan Toxic Substances Control
Commission A removal action,
completed in July 1980 resulted in the
removal of over 5,000 drums from the
site for off-site disposal
• A Remedial Investigation [Rl] and a
Feasibility Study [FS] were initiated at
the Rose Township Site in February of
1984 and were completed in June of
1987
• On September 30,1987, EPA signed a
Record of Decision (ROD) specifying
on-site incineration as the selected
remedy for the contaminated soil at the
Rose Township Site An amendment to
the ROD was issued in 1989
• From September 1992 until October
1993, an infrared incinerator operated at
the Rose Township Site as part of a
remedial action During the remedial
action, 34,000 tons of contaminated soil
were incinerated
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
203
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flow Township Dump Supfrfund SA»
SITE INFORMATION (CONT.)
Regulatory Context:
The Rose Township Site was placed on
the National Priorities List (NPL) in 1982
On September 30,1987, EPA signed a
Record of Decision (ROD) specifying the
site cleanup requirements
A consent decree was signed by 12
Potentially responsible parties (PRPs) and
EPA in 1988 to remediate the site.
The DREs were set in accordance with
Resource Conservation and Recovery Act
(RCRA) incinerator regulations in 40 CFR
part 264, subpart O and Toxic Substances
Control Act (TSCA) regulations in 40 CFR
part 761
• The selected remedy was conducted
under the provisions of the
Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), the Superfund
Amendments and Reauthorization Act
of 1986 (SARA) and the National
Contingency Plan (NCP) in 40 CFR
part 300
Remedy Selection: EPA determined that
on-srte incineration would be protective of
human health and the environment, and cost
effective. EPA further determined that on-site
incineration satisfied the CERCLA
requirement that the remedy reduce toxicity,
mobility, or volume of the waste
Table 1. Timeline
••^•••^•••••^••••••^•iBaamH^^BB^
1966-1968
Apnl 1979
June 1979
July 1980
1982
February 1984-September 1987
CnntamKAr 1 QfiT
oepieniDer isw/
September 1992
September 1992
October 1993
Wastes are disposed of at Rose Township site
Michinan Danartmant of Natural RaftntiiKas fMDNRl
surveys site
Drums sampled by MDNR
5,000 drums removed from site by MDNR
Site placed on NPL
MDNR perfonns Remedial Investigation and Feasibility
Study
Record of Decision signed
Trial bum conducted
Excavation and Incineration operations begin
Incineration operations completed
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
204
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/to** Township Dump Superfund SA»
Site information
• The Rose Township site occupies 110-acres
on Demode Road in rural Rose Township,
Michigan Located approximately 1 mile
west of the town of Rose Center, the site
comprises an upland area almost
completely surrounded by wetlands with an
abundance of wildlife on the site The
southern portion of the site is heavily
wooded with hardwoods The middle
portion, a rolling meadow, is bordered by a
marsh to the west and northeast and
Demode road to the north
There are two groundwater contaminant
plumes on-srte In the northern part of
the site is a plume containing vinyl
chloride, and in the southwest is a
plume containing vinyl chloride, xylene,
toluene, and benzene. The northern
plume threatens to contaminate nearby
domestic drinking-water wells, one of
which is located within 1,600 feet of the
site
Site Lodistics/Contacts
Site Management: EPA Region 5-lead
Oversight: Michigan Department of Natural
Resources
Remedial Project Manager:
Kevin Adler
US EPA Region 5
77 West Jackson Boulevard
Chicago, IL
Phone 312-886-7078
State Contact:
Brady Boyce
Michigan Department of Environmental
Quality
301 S Capitol Street
Lansing, Ml 48933
Phone 517-373-4824
Treatment System Vendor
Greg McCartney
OHM Remediation Services Corp
16406U.S Route 224 East
Findlay, OH 45840
MATRIX DESCRIPTION
Matrix notification
Type of Matrix Processed Through the
Treatment System: Soil, rocks, and tree
stumps
Contaminant Characterization
Primary Contaminant Groups: RGBs, metals,
and volatile and semivolatile organic
compounds.
• Dunng the Rl, contaminants detected in the
soil included PCBs at concentrations up to
980mg/kg. Lead was detected at
concentrations up to 3,200 mg/kg. A variety
of other volatile and semivolatile organic
compounds also were detected In soils
during the Rl The most common
contaminants and their respective
maximum concentrations were toluene
(4,700 mg/kg), ethylbenzene (430
mg/kg), chlorobenzene (570 mg/kg),
xylene (1,400 mg/kg), naphthalene (31
mg/kg), pentachlorophenol (32 mg/kg),
acetone (76 mg/kg), and total phthalates
(91 mg/kg)
U 8 ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
205
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Ro*»Town»hlpDumpSiip»rfundSH»
MATRIX'DESCRIPTION (CONT.)
The major matrix characteristics that most significantly affected cost or performance for this
technology and their measured values are presented in Table 2
Table 2 Matrix Characteristics
1 Th» value given Is the range of values found m sols incinerated during the trial bum Information on matrix characteristics for
the fuR-scde hdnowton is not currently available
1 SMEW W-Standard Methods for the Examination of Water and Waste, ITtfi EelBon. 1989
3 ASTM-Amertcan Society for Testing and Materials, 1985 edHton
TREATMENT SYSTEM DESCRIPTION
Prinvv Tntntrnent Tectinotociv
Incineration system including OHM Mobile
Infrared Thermal Destruction Unit, including
• Waste feed handling system
• Infrared incinerator
• Secondary combustion chamber
Pretreatment (solids).
• Screening
• Drying
• Blending
• Crushing/shredding (rocks/debns)
Post Treatment (air)
• Quench
• Low-energy venturi scrubber
• Packed-column chemical scrubber
• High-energy ventun scrubber
Post Treatment (water).
Clarification
Sand filtration
Bag filtration
Activated carbon adsorption
Ion exchange
U.C ENVIRONMENTAL PROTECTION AGENCY
Offlc* of Solid WMte and Emergency RMDOHM
Technology Innovation Office
206
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J?OM Township Dump Suptrfund SHe
TREATMENT SYSTEM DESCRIPTION (CONT.)
Sv«ti
i DMcrlotion and
Soil was excavated from the Rose Township
Site using backhoes and longarms.
Excavated materials were screened to
remove debris greater than 1 inch in
diameter using a portable three-tiered
screen Wet soils were dned before
screening in a drying building to prevent
clogging of the screen
Drying was conducted on the site in a
building equipped with heaters and blowers
Excavated material that required drying was
placed in the building and periodically mixed
with a f rontend loader or tractor equipped
with a rototiller Soil was also screened in
the building following drying
Screened soils were blended with fuel oil or
diesel fuel to raise its heat content to
approximately 500 BTU/lb
Debns such as rocks and tree stumps
screened out of the soil were stored
separately for further processing Rocks
were crushed using a mobile crusher and
tree stumps were shredded in a tub gnnder
Both the rocks and tree stumps were
reduced to less than one inch diameter and
incinerated along with shredded personal
protective equipment
Intact drums unearthed dunng the
excavation were sampled and analyzed to
determine their contents and disposed of off
the site at approved facilities
Material to be incinerated was loaded into a
feed hopper, from which it was discharged
onto a weigh belt feeder The material then
dropped from the weigh belt feeder to an
enclosed conveyor belt, where it was
leveled as it passed under a screw The
material then dropped from the conveyor
belt to a high temperature metal alloy belt
that conveyed it through the primary
combustion chamber
in the primary combustion chamber material
was heated with Infrared radiant heat
generated by silicon carbide heating
elements Ash and off-gases were then
discharged from the primary combustion
chamber
Ash from the primary chamber dropped
on to an enclosed, water-cooled screw
conveyor. Ash discharged from the
screw was sprayed with water to
suppress dust and for additional cooling
Ash that contained greater than 1 mg/kg
RGBs was incinerated again,
aporoximately 600 tons of material was
incinerated again Ash that exceeded
the extraction procedure (EP) toxicity
test threshold of 5 mg/L for lead or
arsenic was stabilized. All ash that met
the treatment criteria, including ash that
was incinerated or stabilized, was
disposed of on site
The primary combustion chamber
residence time was required to be
greater than 15 minutes for incineration
at the Rose Township Site The
incinerator feed rate was limited to less
than 13,800 Ib/hr
The maximum heat input to the primary
combustion chamber from the
silicon-carbide heating elements was
3,412,000 BTU/hr. The primary
combustion chamber was capable of
operating at temperatures up to
1,800°F, and was required to be
operated at the site at temperatures
greater than 1,400° F Within the
primary combustion chamber the
material was stirred by cake-breakers
powered by 1/2 horsepower (hp) motors
Pnmary combustion chamber gas
flowed counter-current to the material
being incinerated Combustion air was
provided by an forced draft blower
manufactured by Buffalo Forge
Company, Model No. 270, type BL
U.8 ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
207
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ROM Township Dump Suptrfund Sit*
TREATMENT SYSTEM DESCRIPTION (CONT.)
Off-gas from the primary combustion
chamber entered the SCO for further
destruction. The SCO was 88 feet, 10
inches long and had an internal height of 8
feet, internal width of 7 feet, and internal
volume of 3,770 cubic feet. The SCO was
fired by 4 Multifile® natural gas burners,
Model No 31534. manufactured by Maxon
Corporation, Munde, Indiana. Integral to
the burner system was a 20 hp forced air
blower capable of providing 32 inches of
water column pressure. The burner system
had a maximum firing capacity of
12,020,000 BTU.
The SCO was designed to operate at
temperatures up to 2,400°F, and was
required to operate at greater than 1,950°F
at the Rose Township Site
Excess combustion air was provided in the
SCO by a blower manufactured by the
Chicago Blower Corporation, Model 24-1/2
SQAD, with a maximum capacity of 14,000
acfm.
Gas exiting the SCC was quenched with a
water spray that reduced its temperature to
less than 250°F
The off-gas from the quench was then
routed to a low-energy venturi scrubber to
remove particulates Water was injected
into the ventun scrubber at a rate of 140
gallons per minute (gpm), and the pH In the
venturi scrubber was controlled by the
addition of a 10% caustic solution The off-
gas was then sent to a packed column
chemical scrubber
The packed column chemical scrubber
removed acid gas by passing the gas
through 260 cubic feet of 3.5-inch Jeager
Tripack polyethylene packing. Water at a
flow rate of greater than 150 gpm was
passed through an overhead distribution
plate onto the packing to scrub the gas.
The pH of the packed column was
controlled by the addition of a 10%
caustic solution
The off-gas then was sent to a
high-energy venturi scrubber to remove
particulates and heavy metals. Water
was injected into the scrubber at a rate
of 140 gpm, a pressure drop of 55 to 65
inches of water column was maintained
across the scrubber
After passing through the high-energy
venturi scrubber, the gas was passed
through 4 banks of high efficiency
Munter Chevron mist eliminators, and
then to an exhaust stack with an inside
diameter of 32 inches and a height of 37
feet. Two induced draft fans maintained
a negative pressure in the system One
fan was a Robinson Industries Model
No. 70x3.5 RBD-SWSI, which could
draw 30,000 acfm at 190°F, induced a
pressure of 45 inches water column,
rotated at a speed of 1,780 rpm, and
was powered by a 200 hp motor. The
second fan was a Robinson Industries
Model No 57x3.5 RBD-SWSI, which
could draw 30,000 acfm at 190°F,
induced a pressure of 35 inches water
column, rotated at a speed of 1,780
rpm, and was powered by a 200 hp
motor
Wastewater generated by the scrubbers
and mist eliminators was treated on the
site with a system consisting of
clarification, sand filtration, bag
filtration, activated carbon adsorption,
and ion exchange After treatment the
water was discharged under a NPDES
permit
The health and safety plan developed
for the Rose Township Site required
level C personal protective equipment
in the soil crying building
Figure 1 shows a simple block diagram
of the incineration system.
U.8. ENVfRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Retporme
Technology Innovation Office
208
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Rou»Ta*mmhipDumpSuj»rfuntlSlt»
TREATMENT SYSTEM DESCRIPTION (CONT.)
SECONDARY
COMBUSTION
CHAMBER
PRIMAHY
COMBUSTION
AIR BLOWER
oA«h Storage*
Water
I
Figure 1. Block Diagram of Incineration System used at the Rose Township Dump Superfund Site
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wctta and Emergency Response
Technology Innovation Office
209
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AOM TowraNp Dump Suptrfund Sft»
TREATMENT SYSTEM PERFORMANCE
The cleanup goals and standards were
specif led in the ROD The ORE and ash
management standards for metals were
based on the regulations under Resource
Conservation and Recovery Act (RCRA) (40
CFR 264.343 for the OREs and 40 CFR
261 24 for ash residuals) The ORE
standards for PCBs were based on the
Toxic Substances Control Act (TSCA)(40
CFR part 761)
The ROD established target cleanup levels
of 10,70,14. and 0.08 mg/kg for PCBs,
lead, arsenic, and total VOCs, respectively
The ROD specified on-site incineration of all
soil contaminated with either organics or
PCBs However, a consent decree signed
in 1988 by 12 PRPs required incineration of
PCB-contaminated soil and an alternate
remediation for soil contaminated with
organics only. Therefore, a soil target
cleanup level was not established for
semivolatile organic compounds in
incinerated soil
The DRE requirements for the
incinerator were set at 99 9999% for
PCBs. The metals emissions
requirements were based on EPA
guidance and Michigan Act 348
The incinerator ash was required to
contain less than 1 mg/kg PCBs prior to
disposal on-site
A trial bum, conducted on September 11
and 12,1992, was designed to operate the
incineration system at conditions that would
reflect worst-case destruction and removal
of all constituents of concern. Samples of
all influent and effluent streams during
operation at these conditions were collected
during the trial bum These samples were
then analyzed to determine whether all of
the incinerator operating standards were
met Operating limits were then set based
on the worst-case values that were
established during the trial bum
Because of the detection limit used for
PCBs, and the low concentrations of PCBs
in soils at the Pose Township Site, it was
not possible to demonstrate a 99 9999%
DRE However, the Incineration unit
employed at the Rose Township site had
been issued a TSCA permit for the
incineration of contaminated soils, based on
a trial bum conducted In June of 1988 at
another site. EPA determined that
demonstration of a 99 9999% DRE for
PCBs was not necessary during the tnal
bum because (1) substantial hazards
were associated with transporting and
storing concentrated PCB oils, and (2)
the unit had demonstrated the ability to
adequately destroy PCBs in order to
obtain its TSCA permit
f
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid W«itt and Emergency Response
Technology Innovation Office
210
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Township Dump Suporfund SK»
TREATMENT SYSTEM PERFORMANCE (CONT.)
• Dunng the tnal bum, the incinerator
demonstrated its ability to meet the
emission standards specified in its TSCA
permit for the incineration of
PCB-contaminated soils, and the Michigan
Act 348 metals and PCB emissions
standards
• Soil excavated from areas on site that was
known to be contaminated with RGBs, lead,
and arsenic was incinerated dunng the tnal
bum Before incineration the soil was
blended with fuel oil or diesel fuel to
achieve a minimum heat content of 500
BTU/lb
• Dunng the tnal bum conducted in June 1988
as part of the procurement of a TSCA PCB
incineration permit for the incinerator, a
99 9999 % ORE was demonstrated on
waste feed containing 5,600 mg/kg of PCBs
This information was deemed sufficient by
EPA to demonstrate compliance at the site.
The ORE for PCBs was calculated by the
PRP, and this information is shown in Table
3
• The incineration system included continuous
emissions monitors (CEMs) for carbon
monoxide, carbon dioxide, oxygen, and total
hydrocarbons The stack operating data for
the CEMs dunng the tnal bum were used to
set ranges for normal operating conditions
The CEMs were employed during the
normal operations of the incinerator to
ensure that operating conditions remained
within the bounds established dunng the tnal
bum.
• The incineration system also included an
automatic waste feed cutoff (AWFCO)
system to suspend operations if the
operating conditions were not within the
proper ranges set by the tnal bum The
AWFCO limits used dunng the remedial
action are shown in Table 4
Information about the frequency of
AWFCOs was not available
• Tnal bum and typical operating
parameters are shown in Table 5.
• The incinerator operated at the Rose
Township Site operated predominantly
within the operating limits established
dunng the trial bum
• The residual ash was sampled and
analyzed using the EP toxicity test for
lead and arsenic to determine whether
these parameters met the requirements
specified in the ROD for on-srte disposal
as backfill The ROD required ash that
failed to meet the requirements for
teachable metals to be stabilized before
land disposal No ash required
stabilization before land disposal
• Initially some of the incinerated soil at
the site did not meet the cleanup goal of
less than 1 mg/kg PCBs This was
attributed to the fact that the size of the
material being fed to the incinerator
was too large. As a result,
approximately 600 tons of material
required reincmeration All subsequent
feed to the incinerator was screened to
less than 2 inches In diameter No
material r< ,uired reincineratton after the
institution of such screening. The DRE
was met for PCBs and metals
Tables Average Destruction and Removal Efficiencies from
Trial Bum Compliance Testing I
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
211
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TREATMENT SYSTEF.
3MANCE (CONT.)
Tabfe* Automatic Waste Feed Cutoffs
Secondary Chamber Temperature
Secondary Chamber Excess Oxygen Level
Stack Cannn MowxHe Concentration
PifenaiyBenFalure
Primaiy Chamber Pressure
Ash Cooing Conveyor Failure
Induced Draft Blower Fahire
Stack Temperahire
Scrubber Quench Temperature
Primary Chamber Zone A2 Temperature
Primary Chamber Zone B2 Temperature
High-Energy Venturi Pressure Drop
Scrubber pH
<1950°F,>2,500eF
<3%
> 90 ppmwHh 2 rnlnute delay, >1 50 ppm Instantaneous
NA
<0 00 Inches we
Not Applicable
NotAppHeable
>250°F
>2SO"F
NotAppHeable
<1.400eF
<1,530'F
<20 Inches we
<4su
NotAvaiabte
su.» Standard units
w.c = Water column
Primary Combusflon Chamber Zone A2
Temperature
Primary Combustion Chamber Zone 82
Temperature
Primary Combustion Chamber Pressure
Secondary Combustion Chamber
Temperature
Secondary Combustion Chamber Excess
Oxygen
Stack Carbon Monoxide
Stack Gas Flow Rate
Scrubber pH
Low-Energy Venturi Pressure Drop
Wast* Feed Rate
Primary Combustion Chamber Retention
?"• - .
>1.400°F
>1.530"F
<00 inches we
>1,950'F
>3%
<90ppm
<6,l80dscm
>60
>6tncheewc
>45 Inches we
<13,800trVhr
>15 minutes
1,523-1.543°F
1.624- 1,651 »F
NA
2,025 -2,048°F
6125-651%
279-334 ppm
4,958- 5.411 dsom
641-687
11 42 -11 96 Inches we
52.98 -56 4 Inches we
13,092- 13.937 RVhr
NA
we •wanreolumn
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid WMta and Em«rgancy Response
Technology Innovation Office
212
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ROM Township Dump Superfund Sftf
TREATMENT SYSTEM PERFORMANCE (CONT.)
Data are available for concentrations of
contaminants in the soil before incineration
Confirmatory soil samples were collected by
the vendor after the remediation was
completed
Data are also available for
concentrations of contaminants in the
incinerator residue These data were
collected penodically prior to landfillmg.
In addition, emissions data are available
from the incinerator compliance test
TREATMENT SYSTEM COST
Procurement Process
• The PRP contracted with Penni
Environmental to acquire and operate the
incinerator at the Site Perini
Environmental used several
subcontractors to implement specific
aspects of the operation
The total cost for operation of the
incineration system was approximately
$12,000,000 A total of 34,000 tons of
soil, rocks, and tree stumps were
incinerated This corresponds to a total
unit cost for incineration of $350 per ton
A detailed breakdown of these costs was
not available.
OBSERVATIONS AND LESSONS LEARNED
Substantially more soil required incineration
than anticipated, which resulted in increased
costs Based on the results of the RI/FS,
9,000 to 13,000 cubic yards of soil were
estimated to require incineration However,
verification sampling
during excavation indicated additional
soil required incineration in order to
meet cleanup goals, and 18,000 cubic
yards of soil were ultimately incinerated
at the Rose Township Site
Soil screening was hindered in wet weather
because soil formed clumps that would not
pass through the screening equipment A
drying building equipped with heaters and
blowers was constructed to dry the soil
before screening
The incinerator was shut down periodically
to replace broken or damaged heating
elements and for repairs to the conveyor
belt Replacement of the main conveyor
belt required a 3-day shut down at one point
during the project No cause of these
failures was Identified by site personnel
Several times during the project the
incinerator had to be shut down to
remove fry ash that had slagged in the
duct between the primary and
secondary combustion chambers and in
the secondary combustion chamber
Other operational problems included
ash discharge system malfunction, loss
of flame in the secondary combustion
chamber, temporary loss of power, and
weigh belt feeder malfunction
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
213
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OBSERVATIONS AND LESSONS
Row Township Dump Supttfund SH»
Public involvement
• The public comment period for the RI/FS
commenced on June 29.1987 and ended
on August 12,1987 A public meeting
was held on July 1,1987 to discuss the
RI/FS and to present the proposed
remediation plan. During the public
meeting, no significant opposition was
raised against the proposed plan The
public was generally supportive of the
proposed plan as they wished the source
of the contamination to be removed
1 Emissions Verification Test Plan. OHM
Remediation Services Corp., Findlay, Ohio,
June 12,1992
2 EPA National Pnonties List. Rose Township
Dump Fact Sheet. USEPA Region V,
February. 1996
Final Closure Report. Excavation and
Rose Township Site. Oakland
6.
7.
Dountv.
Perini Environmental
Services, Inc, Framingham,
Massachusetts, March, 1996
4. Final Design Report. Thermal Treatment of
PCB Laden Soils. Pertand Environmental
Technologies, Inc April 1,1992.
5. Final Soil Investigation Report. Rose
Township Site in Oakland County. Michigan
Pertand Environmental Technologies, Inc,
Burlington, Massachusetts, August 28,
1992
Incineration of PCB Contaminated Soils at
the Rose Township Suoerf und!
Superfund XV Conference and I
Proceedings. Ungs, R.T, et al., PRC
Environmental Management Inc, Denver
Colorado, 1994.
on Volatile Oroanlcs in Soils. Rose
Site. Oakjand County. Michigan.
Perini Environmental Services, Inc.,
Framingham, Massachusetts, March, 1996
8.
Suoerfund Record of Decision. Rose
Township Dump Demode Road
Suoerfund Site. U.S. Environmental
Protection Agency, September 30,
1987.
9. Trial Bum Report. Mobile Destruction
Unit. Rose Townsh p Superfund Site.
Hotlv. Michigan OHM Remediation
Services Corp., Findlay, Ohio,
November 6,1992
10 U S. EPA Fact Sheet. Update on
Remedial Actior
Demode Road Superfund Site. Rose
11
Township. Michigan USEPA Region V.
October 1989.
Personal communication between Peter
Shields, Eastern Research Group and
Kevin Addler, U.S. EPA Region V. April
22,1997
12. Shirco Infrared Incineration System
Applications Analysis Report. US
Environmental Protection Agency, June,
1989
13. Personal communication between
James Styers, Tetra Tech EM Inc. and
Ed Hammond, Massachusetts Port
Authority (formerly of Perini
Environmental) December 1,1997
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
214
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On-Site Incineration at the
Sikes Disposal Pits Superfund Site
Crosby, Texas
215
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Incineration at the Sikes Disposal Pits Superfund Site
Crosby, Texas
SHeName:
Sikes Disposal Pits Superfund
Site
Location:
Crosby, Texas
Contaminants:
Organic and Phenolic
Compounds
• Naphthalene, chlorobenzene,
creosote, toluene, xylene,
dichloroethane, and vinyl
chloride
• Maximum concentrations in
mg/kg - naphthalene (58),
chlorobenzene (2 3), toluene
(5), dichloroethane (20), and
vinyl chloride (1)
Period of Operation:
February 1992 to June
1994
Cleanup Type:
Remedial action
Vendor:
Mike Gust
International Technology
Corporation
2790 Mosside Boulevard
Monroeville, PA 15146-2792
(800) 444-9586
SIC Code:
Not Applicable
Technology:
On-Site Incineration
• Soil and debris pretreated
with shredding and mixing
with lime
• Incineration system consisting
of rotary kiln and two
secondary combustion
chambers (SCCs)
• Enclosed conveyor
transported contaminated soil
and debns to the unit
• Soil residence time of 45
minutes, kiln temperature of
1,300°F, SCC temperature of
1,800°F
• Treated soil and debns
(incinerator ash) discharged
into rotary mixer, where it is
sprayed with water
Cleanup Authority:
CERCLA and State Texas
• ROD Date 9/18/86
• State-lead
Point of Contact:
Earf Hendnck
Remedial Project Manager
US EPA Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-8519
Waste Source:
Disposal Pits - drummed and
bulk wastes
Purpose/Significance of
Application:
Third largest Remedial Action
Contract ever awarded to
incinerate nearly 1/2 million
tons of contaminated soil and
debris
Type/Quantity of Media Treated:
Soil and Debns
• 496,000 tons of soil and debns
• Moisture Content soil -10 -12%
• Soil Density (in situ) 1 58 -1 72 g/cm3
Regulatory Requirements/Cleanup Goals:
• Destruction and Removal Efficiency (DRE) of 99 99% for principal organic constituents of
concern as required by Resource Conservation and Recovery Act (RCRA) incinerator
regulations. 40 CFR part 264. subpart O
Results:
• Emissions and trial bum data indicated that all DRE and emissions standards were met
• Analytical data of residuals Indicated that cleanup goals were met
216
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Incineration at the Sikes Disposal Pits Superfund Site
Crosby, Texas
(Continued)
Description:
Between 1961 and 1967, the Sikes Disposal Pits Superfund Site was the location of the
unpermrtted disposal of drummed and bulk wastes into unhned sand pits A remedial investigation
determined that soil at the site was contaminated with VOCs and PAHs A Record of Decision
(ROD), signed in September 1986, specified on-site incineration as the remedial technology for
the soil and debris Site cleanup goals and DRE standards were specified for the organic
constituents of concern
Remedial Activities began in October 1990 when IT/Davy began clearing the site On-site
incineration using the IT Corporation Hybrid Thermal Treatment System* began in February 1992
and concluded in June 1994 Following demobilization and site cleanup, remedial activities
ceased in December 1994 The treatment system consisted of a rotary lain and two SCCs An
enclosed conveyor moved the soil and debns to the kiln for treatment Ash from the incinerator
was discharged to a rotary mixer where it was quenched with water Incineration achieved the soil
cleanup goals specified in the ROD
The total cost of the Remedial Action was approximately $115,000,000 Capital costs accounted
for approximately $20,000,000 Operation and maintenance costs accounted for approximately
$95,000,000
217
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^EXECUTIVE SUMMARY
This report presents cost and performance data
for the application of on-site incineration at the
Sikes Disposal Pits Superfund site in Crosby,
Texas. A rotary kiln incinerator was operated
from February 1992 through June 1994 as part
of a remedial action Contaminants of concern
at the site were organic and phenolic
compounds including naphthalene,
chiorobenzene, creosote, toluene, xylene,
hahdes, dichloroethane, and vinyl chloride
The Sikes Disposal Pits site was used for the
disposal of drums and bulk wastes from 1961
through 1967 Dunng this period, an estimated
1,500 fifty-five gallon drums and an
undetermined amount of bulk waste was
disposed of at the site Dunng the remedial
investigation, soil concentrations were
measured as high as 58 mg/kg for naphthalene,
2 3 mg/kg for chlonnsnzene, 5 mg/kg for
toluene, 20 mg/kg fc. dichloroethane, and 1
mg/kg for vinyl chlonde
In June 1982, EPA signed a cooperative
agreement with the Texas Water Commission
(TWC), currently the Texas Natural Resource
Conservation Commission (TNRCC), to oversee
response actions at the site A Record of
Decision (ROD) signed in 1986 established a
destruction and removal efficiency (DRE) of
99 99% for organic contaminants
EPA and TWC conducted remedial activities
including the operation of a rotary kiln
incinerator to dispose of the contaminated soil.
The incineration system used at Sikes Disposal
Pits was comprised of a solid waste feed
system, a countercurrent, controlled-air, rotary
kiln, two secondary combustion chambers
(SCCs), two wet gas cleaning systems (GCSs);
and a treated materials handling system
In order to prepare the feedstock, soil excavated
at the site was mixed with lime if its moisture
content was above a prescribed level, and
drums were shredded to reduce their size to an
acceptable size for the incinerator Prepared
material was fed to the incinerator by an
enclosed conveyor
Resulting ash from the incinerator was
removed and quenched with water while off-
gas was drawn into one of the two parallel
SCCs The SCCs were down-fired steel
shells that provided further combustion of
contaminants in the off-gases The
incinerator and both SCC's were fueled by
natural gas
Treated gas was then drawn into the GCS,
which consisted of a quench section for
cooling, and a venturl scrubber and a two-
stage Hydro-Sonic® scrubber for removal of
parhculate matter The GCS cooled the gas
from the SCC and controlled particulate and
acid gas emissions Ash and dust collected
from the incinerator and GCS were sampled
and analyzed to determine whether they
were in compliance with on-site land
disposal requirements, at which time they
were landfilled on site
During the 28 months of operation, the
incinerator processed approximately
496,000 tons of contaminated soil and
debris and the on-site water treatment
system treated 350 million gallons of
contaminated groundwater and stormwater
Treatment performance and emissions data
collected during incinerator operation
indicated that all performance standards
and emissions requirements were achieved.
The actual total cost for remediation using
the incineration system was approximately
$115,000,000 This amount consisted of
approximately $20,000,000 in capital costs
and $95,000,000 in operating costs
U.3. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wattt and Emergency Response
Technology Innovation Office
218
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Sttus DttpOM/ Pitt Supnrtund Site
SITE ^FORMATION
Sikes Disposal Pits Superfund Site
Crosby, Texas
CERCLISf TXD980513956
ROD Date: September 18,1986
Type of action: Remedial (on-site rotary
kiln incineration)
Period of operation: February 1992 - June
1994
Quantity of
reated during
application: 496,000 tons of soil and
debns
Historical Activity that Generated
Contamination at the Site: Waste disposal
Corresponding SIC Code: Not applicable
Waste Management Practice That
Contributed to Contamination: Disposal of
drummed and bulk waste in unlmed sand pits
Site History:
• The site was used in the 1950s as a source
of sand for local construction projects The
site subsequently was used for disposal of
drums and bulk wastes from 1961 until
1967
• The Slkes Disposal Pits is an 185-acre site
bordered on the west by the San Jacinto
River and on the north by the Jackson
Bayou The majority of the site is within the
10-year flood plain and the entire site is
within the 100-year flood plain
• During this penod, an estimated 1,500 fifty-
five-gallon drums were disposed of in
unlined sand pits An undetermined amount
of bulk waste was dumped or pumped into
low-lying areas and sand pits
The contents of the drums were not
analyzed By the time remedial
activities began, the contents of the
drums had solidified into a substance
with a consistency similar to tar. The
contents had been exposed to the air for
many years, allowing the volatile
compounds to evaporate, leaving a very
low concentration of volatile organic
compounds within the drums
Soil at the site was contaminated with
organic and phenolic compounds,
including naphthalene, chlorobenzene,
creosote, toluene, xylene, halfdes,
dichloroethane, and vinyl chloride
A site investigation was conducted by
Region VI of EPA and TWC in 1981 in
June 1982, EPA and TWC signed a
cooperative agreement to oversee
response actions at the site A
Remedial Investigation and Feasibility
Study (RI/FS) was conducted from May
1983 until June 1986
Based on the RI/FS, a ROD was signed
in September 1986, specifying a
remedy which included on-site
incineration to reduce the concentration
of contaminants in soil and debris at the
site
U 8 ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
219
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SITE INFORMATION (CONT.)
Construction management and oversight
services for the remedial action activities
began in September 1989. In April 1990
TWO awarded the remedial action contract
to the joint venture of International
Technology Corporation and Davy McKee
Corporation (IT/Davy).
Remedial activities began in October 1990
when IT/Davy began clearing the site.
Rood protection at the site was required due
to Hs location m the flood plain IT/Davy
constructed an earthen embankment
structure to elevate the incineration facility
above the 100-year flood plain and
constructed a dike around the Main Waste
Pit area As required in the Remedial
Action Contract, the structures were a
minimum of two feet above the 100-year
floodplam
A shallow aquifer is located two to ten feet
below the pre-excavatlon ground surface.
Sampling and subsequent analysis showed
that the aquifer was contaminated by
leaching of contaminants from organic
sludge in waste pits.
A second aquifer located 65 feet below the
shallow aquifer and separated from the
shallow aquifer by plastic day showed
concentrations of contaminants just above
detection limits.
A third aquifer, the Chicot aquifer, Is located
140 feet below the second aquifer and
serves as a primary drinking water source
for the city of Houston The second aquifer
and the Chicot aquifer are separated by
clay. As a result, it was assumed that the
Chicot aquifer was not affected by the
contamination at the site [2]
Pre-trial bums were conducted at the site in
February and March 1992, followed by a
trial bum in April 1992 While awaiting
approval of trial bum results the incinerator
operated under interim conditions (at
reduced throughput) from April through
August 1992. Upon approval of the trial
bum conditions in August 1992, the
Incinerator began operating at full
production rate.
• IT/Davy processed approximately 496,000
tons of soil and debris between
February 1992 and June 1994
Following the completion of the
incineration of contaminated soil and
debris, IT/Davy began demobilization
and the last stage of the cleanup, the
planting of native grasses By
December 1994, all of the soil cleanup
goals specified in the ROD had been
met and all soil-related remedial
activities ceased In April 1995 the final
inspection of the worksite took place
Regulatory Context:
• In 1982, EPA and TWC entered into a
cooperative agreement, which included
remediation activities at the site in
Crosby, Texas
• In 1983, the Sikes Disposal Pits site was
placed on the National Priorities List
(NPL)
• As a result of the cooperative
agreement, EPA and TWC identified
site cleanup requirements described in
a ROD signed on September 18,1986
[1]
• The selected remedy was consistent
with the Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), the Superfund
Amendments and Reauthorizatfon Act
of 1986 (SARA), and the National
Contingency Plan (NCP) 40 CFR part
300 [1]
• The DREs were set according to
Resource Conservation and Recovery
Act (RCRA) Incinerator regulations In 40
CFR part 264, subpart O
Remedy Selection: On-site incineration
was selected as the remedy for
contaminated soil and debris at the Sikes
Disposal Pits Superfund site based on
treatabllity study results and long-term
economic, public health and welfare, and
environmental considerations.
U.S ENVIRONMENTAL PROTECTION AGENCY
Offlct of Solid Watt* and Emcrgtncy RetponM
Technology Innovation Offlc*
220
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SItos Disposal Pits Supsrfund Site
Timeline
SITE INFORMATION (CONT.)
1981
1982
1983
May 1983 -June 1986
September 1986
September 1987 - December 1988
October 1990
February -March 1992
April 1992
April -August 1992
August 1992 -June 1994
June 1994
December 1994
April 1995
EPA and TWO conducted site Investigations
EPA and TWO signed cooperative agreement to oversee Sites Disposal Pits
remeojanon
Sfcee Disposal Pits site placed on NPL
RemedW InvesttgaHon/FeasbMty Study
Record of Decision signed specifying on-slte incineration
niii»iiiiBol #|A«|JWI
nemooKH design
IT/Davy began clearing site
Pre-trial Bums conducted
Trial Bum conducted
Interim operation of Incinerator
Full opwftUon of incinerator
Ash backM completed
Completion of eol-related remeolal activities
Final bispection of worksite
SHe Management: State-lead
Oversight: EPA
Remedial Project Manager:
Earl Hendnck
U.S EPA Region 6
Allied Bank Tower at Fountain Place
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-8519
State Contact:
Jim Sher
Texas Natural Resources Conservation
Commission
MC144
12100 Park 35 Circle
Austin, TX 78753
(512) 239-2444
Treatment System Vendor:
Mike Gust
IT Corporation
2790 Mosside Boulevard
Monroeville, PA 15146-2796
(800) 444-9586
U.8 ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
221
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SflkM mpontf PH» Sujwrftjntf Site
MATRIX DESCRIPTION
Type of Matrix Processed Through the
Treatment System:
• Soil from the unlined sand pits
Contaminant Characterization
Primary Contaminant Groups: Organic and
phenolic compounds
• The contaminants of greatest concern were
naphthalene, chlorobenzene, creosote,
toluene, xylene, dichloroethane, and vinyl
chloride.
Drums which were disposed of on site
The maximum concentrations detected
in mg/kg were naphthalene (58),
chlorobenzene (2.3), toluene (5),
dichloroethane (20), and vinyl chloride
The matrix charactenstics that most significantly affected cost or performance at the site and their
measured values are presented in Table 2.
Table 2. Matrix Character
TREATMENT SYSTEM DES
IT Corporation's Hybrid Thermal Treatment
System* (Incineration system) including
• Solid waste feed system
• Countercurrent, controlled air rotary kiln
manufactured by Kennedy Van Saun
• Two parallel secondary combustion
chambers.
Sv«tem DMcrlotlon and
The contaminated soil and drums were
excavated using track excavators and
loaded onto 25-ton haul trucks for transport
Drums were taken to the solid waste feed
Supplemental Treatment Technoioov
Pretreatment (solids)-
• Lime addition
• Shredder.
Post-Treatment (air)
• Gas cleaning system manufactured by
the John Zirik Company including.
— Water quench tower
— Two-stage scrubber
— Vane separator
• Environmentally Safe Temporary
Emergency Relief System* (ESTER*)
Post-Treatment (water)'
• On-srte wastewater treatment system
system in the Feed Preparation Building
and soil was taken to a staging pad for
blending with other materials.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watts and Emergency Reaporwe
Technology Innovation Offlc*
222
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Sftw Disposal Ptot Supfrfund SH»
TREATMENT SYSTEM DESCRI
Blending at the staging pad was
accomplished through the use of bulldozers
and discs [2]. The Feed Preparation
pressure to control volatile organic
compound (VOC) emissions This building
housed a shredder to prepare material for
treatment, and had the capacity to store up
to a five-day supply of matenal for the
incinerator. The prepared matenal was fed
to the incinerator by an enclosed conveyer
Some of the excavated soil had a high clay
content, resulting in difficulties
homogenizing the incinerator feed stock
To better prepare the feed stock, lime was
added to the soil if it was wet. Drums were
prepared by placing them in the shredder to
reduce their size to acceptable standards for
the incinerator
The kiln was 75 feet in length, had an
outside diameter of 14 feet, and was lined
with high-temperature refractory. The
approximately 29 tons per hour (tph) with a
corresponding solids residence time of 45
minutes. The kiln was rated at 120 million
BTU/hr and operated at approximately
1,300°F A negative pressure was
maintained within the tain in order to prevent
fugitive emissions
Residual ash from the kiln was transferred
to the treated matenal quench facility where
it was water cooled in a rotary mixer to a
temperature of 180°F. The ash was then
placed in storage bins to await testing to
ens- -e that it met Toxicity Characteristic
Leaching Procedure (TCLP) criteria
Following sampling, analysis, and necessary
approval, the quenched ash was
landf illed on site. All of the ash met
site-specific land disposal requirements.
Flue gases from *he kiln were routed to
one of to..* two vertically downfired
SCCs for further combustion of
volatilized contaminants. The
incineration system was configured with
an SCO and its respective GCS in
parallel with another SCO and GCS
The SCCs operated at approximately
1,800°F The flue gas residence time in
the SCCs was a minimum of 2 seconds.
The exhaust gas from the SCCs was
channeled to the GCS, where it was first
cooled to a temperature of 220°F in the
GCS's water quench section Aventuri
scrubber and a two-stage Hydro-Sonic®
scrubber were then used to control
paniculate and acid gas emissions
Water used in the GCS was collected in
sumps below the unit This water, along
with water from the ash quench, was
treated in an on-site waste water
treatment system
Two systems that treated the water from
the GCSs and the ash quench
contained hydroclones and clanflers to
remove suspended solids from the
process water and a belt filter press to
dry the solid materials for handling [2].
The treatment processes were closed
systems with the water being discharged
into on-site holding ponds A third water
treatment system was used to treat
contaminated groundwater and
stormwater collected from the site.
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wast* end Emergency Response
Technology Innovation Office
223
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TREATMENT SYSTEM DESCRIPTION (CoNT.)
arfption and Operation fConLl
Combustion gases were drawn through the
kiln system and GCS by induced draft fans
and were exhausted through two 85-foot
fiberglass stacks Typical flue gas velocity
was 26,500 actual cubic feet per minute and
the typical stack exit temperature was
220°F.
The incinerator also was equipped with
an emergency backup system The
Environmentally Safe Temporary
Emergency Relief System* (ESTER")
provided for combustion of
contaminants in the kiln in the event of
a forced shutdown of the incinerator
Dunng such an event, the rotary kiln
gases were diverted to the ESTER9,
which was equipped with a 60 million
BTU Burner to thermally treat the gases
before release to the atmosphere
Tables. Summary of Opera
Win Exit Gas Temperature
TREATMENT SYSTEM PERFORMANCE
The cleanup goals and standards were
specified in the ROD. The ORE was set
based on RCRA Incinerator regulations in
40 CFR part 264, subpart O
A ORE of 99.99% was required for each
contaminant of concern
Cleanup standards required the
excavation and treatment of soil and
debris with volatile organic aromatic
concentration greater than 10 mg/kg
Ash residuals had to pass the Toxicity
Characteristic Leaching Procedure
(TCLP) before on-site disposal
A trial bum conducted at Sikes Disposal Pits
was designed to operate the incineration
system at conditions that would reflect worst
case destruction and removal of all
constituents of concern
Naphthalene was selected as a principal
organic hazardous constituent (POHC)
because It was a semivolatite c-ganic
compound present at hgh concentrations at
the site and because it ?*as a high Thermal
Destructibility Ranking Chlorobenzene
also was selected because it is a
volatile organic compound, was present
in abundance at the site, has a high
Thermal Destructibility Ranking, and is
a source of chlorine residuals [2]
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Retponse
Technology Innovation Office
224
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SOa* Disposal Pit* SupulundStto
TREATMENT SYSTEM PERFORMANCE (CON~
The incinerator at Sikes Disposal Pits
operated wrthm the operating limits
established during the trial bum The
AWFCOs limits used during the
incineration action and their frequency of
occurrence are shown in Table 4 Trial
bum and actual operating parameters are
shown in Table 5
The residual ash was sampled and
analyzed to see if it was in compliance
with the Remedial Action Contract's on-
site land disposal requirements The
residuals were tested had to pass the
TCLP before land disposal. These data
are presented in Table 6
Table 4 Automatic Waste Feed Cutoffs
4576tph
Maximum k8n pressure^
Mnbnum Un ndt gas temperature9
Maximum total SCO water gun flow rale*
MWmum SCC extt gas temperature*
Maximum quench outlet gas temperature3
Mtalmun oaa condHkvw redrculattan flow rate*
Mkiimum GCS-1 TedrcutaHon flow rate4
Mbitmum GCS-2 redrcutetton flew rate4
Minimum 6CS-2 sump pH4
Minimum pressure deferential across QCS-1 and 2s
MTMniuin oloCK ySS Uj COncenVBUOn
Maximum CO concentration In stack gas (O 7% oxygen)'
Maximum stack gas corrected THC concentration (O 7%
own)8
Maximum stack gas flow rate*
00 Inches wo
1.058-F
17.5 gpm
1,688-F
191 °F
28 gpm
251 6 gpm
183 gpm
69
32.2 inches we
3%
500 ppm
20ppm
47.550 acfm
975
36 |
0
40
120
8
12
9
148
114
148
1
5
5
'15-mlnute rolling average
230-second delay
Instantaneous
4Smlnutedetey
Bl-hour rolling average
tph = tons per hour
gpm = gallons per minute
ppm * parts per mlfflon
acfm • actual cubic feet per minute
we = water column
U.8 ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
225
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TREATMENT SYSTEM PERFORMANCE (CONT.)
Tables.
Contaminated Soi Feed Rate
Fuel Fired Feed Rate
. .._.*
Emission Rater
PartfcuMe
HO
S04«
Lead'
NO,
Operating CondWons
Kan pressure
co concemranon in gas
Mh eodt pjes temperature
SCC exit temperature
SUck gas flow rate
MHmum OCS pressure drop
Quench exit gas temperature
astph
120mMonBTU/hr
llMfl/m8
NotAvalable
OBugAn*
OCBugAnP
15ugAn*
-OTSfncheewc
144ug/m*
1^00"F
1,800°F
42,000 acfm
34 Inches we
180"F
45 78 ton
120m»onBTU/hr
16.704 Mg/rn3
<0 027 to/fir
2688ug/m*
NA
MA
NA
10
1.058eF
i,688«F
47 550 acfm
32^ Inches we
NA
we = Water column
•ActualvoJue. average parameters for daily operations as reported in the Remedtel Action Report.
•Corrected to 7% Oj
'Annual value
^Quarterly value.
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
50
1000
10
50
50
OS
10
50
<0.5
<100
<01
<05
<05
<002
<01
<0.5
Note: Only contaminants that were analyzed for are Included m thtstabte
*c~~~~t~l «.m in r*co aa< ni T«MA «
• Data are available for concentrations of
contaminants in the soil before treatment
Data are also available for TCLP
analysis for contaminants In the
incinerator residue. These data were
collected periodically throughout
operation of the incinerator prior to
landfilling.
US ENVIRONMENTAL PROTECTION AQENCY
Offict of Solid Wast* and Emergency Rctporw*
Ttohnology Innovation Offlc*
226
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Stttes Disposal Pita SuporfundSHe
PERFORMANCE (CONT.)
According to site personnel, the QA/QC
program used throughout the remedial
action met EPA and TWO requirements
established in the ROD All monitoring was
performed using EPA-approved methods
TREATMENT SYSTEM COST
Procurement Pro
TWO contracted with Lockwood, Andrews, &
Newnam, Inc (LAN) to manage the Sikes
Disposal Pits site IT/Davy was contracted
to provide and operate the incinerator at the
site
331
• The estimated treatment cost of
$115,000,000 was reported by LAN and
IT/Davy in terms of capital costs and
operation and maintenance costs. The
estimated capital costs for the
incineration system were $20,051,000
and estimated operation and
maintenance costs totaled $95,027,000
[5] The estimated total cost for thermal
treatment was $81,000,000 A total of
496,000 tons of soil and debns were
incinerated This corresponds to a total
unit cost for incineration of $230 per
ton, and a unit cost of $160 per ton for
thermal treatment.
Mobilization and preparatory work
02
Monitoring, sampling, testing, and analysis
$139.000
331
03
Sitework
$3.986.000
331
05
Surface water collection and control
$4.020.000
331
22
General requirements
$95.000
Total Capital Costs
$20,051.000
Monitoring, sampling, testing, and analysis
342
14
Thermal Treatment (Incineration) which includes
• Equipment
• Labor
• Direct operating costs
• Overhead
$81,000,000
342
18
Disposal
$3,044,000
342
22
General requirements
$6,754,000
Total Operation and Maintenance Costs
$96,027,000
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
227
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Sites Disposal Pits Superfund SHo
TMENT SYSTEM COST (CONT.)
Co«t Data Quality
Actual capital and operations and
maintenance cost data are available from
the treatment vendor and EPA Region 6 for
this application.
OBSERVATIONS AND LESSONS LEARNED
Actual costs for the project were
approximately 26% more than the projected
costs because the volume of contaminated
soil that required treatment was 45% greater
than anticipated
Change orders amounted to 25% of the
original contract cost
The added cost of building and installing
an additional SCO train was offset by
the fact that the extra train increased
the throughput rate of incinerator, which
decreased the amount of time that the
unit would have had to operate
IT/Davy anticipated that it would cost
less money to build an extra train and
operate for a shorter amount of time
than to operate with only one train [6]
Operation at the site was completed
approximately 18 months before the
deadline specified in the remedial action
contract even though 496,000 tons of
material was incinerated instead of the
342,000 tons originally estimated [4]
Because the incinerator used by IT/DAVY
was over three times larger than required
and the average throughput rate of 29 tons
per hour was almost two and a half times
greater than the minimum throughput rate of
12 tons per hour required in the contract,
the remediation was completed ahead of
schedule
The incinerator provided by IT/Davy was
larger than required because it was
anticipated that the incinerator would be
used at two other sites following Sikes
Disposal Pits Building the incinerator
larger, therefore, cut down on overhead
costs when compared to building three
separate incinerators. The Incinerator used
at Sikes Disposal Pits, along with one SCO
train, was transported to the Times Beach
Superfund Site upon the completion of
the project [6]
The limiting factor for the throughput
rate of the incinerator was the size of
the SCC tram and its capacity to
channel kiln off-gas The SCC train
size was constrained by the fact that it
had to be transported to the site One
SCC train would not have allowed the
incinerator to operate at its intended
capacity Therefore, the decision was
made by IT/Davy to install a second
SCC train Fn parallel with the first, giving
a 30% increase in throughput rate The
two trains were designed to operate
simultaneously, however, one train
could be shutdown for routine
maintenance while the incinerator still
functioned with one operating train [6]
Drum handling was an important issue
on site. Separate protocols were
developed for handling both intact and
ruptured drums. When excavation was
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wast* and Emergency Response
Technology Innovation Office
228
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Sikes Disposal Pits SuporfundStte
OBSERVATIONS AND LESSONS LEARNED (CONT.)
completed, however, it was discovered that
only one intact drum existed Few volatile
organic compounds remained in the
ruptured drums because they had previously
leaked into the soil or into the air Site
management felt that resources had been
spent developing a protocol for conditions at
the site which did not exist, and a more
thorough investigation might have avoided
this situation.
Dunng operations, 86 ESTER* events
occurred at the site Each event was
typically 2 to 3 minutes in length, beginning
with a shutdown of the induced draft fans
and the opening of the vent from the
incinerator to the ESTER* stack A dark
paniculate plume was visible around the
ESTER* stack during the event, but no
significant changes were measured by
monitors in ambient air quality [2]
Public involvement
Following the events there was
approximately a 45 minute delay which
occurred to get the system back on-line
The cause of the events was usually a
problem with instrumentation and not a
problem with incinerator operation [3]
Overpressunzation of the kiln caused
frequent AWFCOs The primary cause
of the overpressure in the kiln was
related to slag build-up in the SCCs. As
the slag built up, it would eventually fall
to the bottom of the SCC chamber,
which contained a water well The slag
falling into the water generated steam,
which would then back-up into the kiln
creating overpressure A similar
situation also developed, although to a
much lesser extent, from the ash
cooling system, where steam generated
from the water used to cool the ash also
backed up into the kiln [3]
The largest concern of the public was that
the incineration system would become a
permanent facility and treat waste from
other sites The public was not convinced
that such a large amount of money would
be spent on a facility which was only
temporary EPA held a series of public
meetings with local citizens in an
attempt to alleviate their concerns
REFERENCES
1. Suoerfund Record of Decision. Sikes
Disposal Pits, Crosby, Texas, September
18,1986
2 Sikes Disposal Pits Suoerfund Proiect
Remedial Action Report. Lockwood.
Andrews & Newnam, Inc., December 28,
1995
3 Personal Communication, Mr Earl
Hendnck, USEPA Region VI, April 10,1997
4 Successful Completion of tha Sikes
Incineration Protect. James R. Donnelly
and Michael Gust, Superfund XV
Conference and Exhibition
5 Correspondence with Mr Kevin Smith,
IT Corporation, Apnl 4,1997
6 Personal Communication, Mr Mike
Gust, IT Corporation, May 6,1997
U 8 ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Wute and Emergency Response
Technology Innovation Office
229
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This Page Intentionally Left Blank
230
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On-Site Incineration at the
Times Beach Superfund Site
Times Beach, Missouri
231
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Incineration at the Times Beach Superfund Site
Times Beach, Missouri
Sif@N&
-------
Incineration at the Times Beach Superfund Site
Times Beach, Missouri
(Continued)
Description:
Between 1970 and 1972, a pharmaceutical and chemical company produced wastes that
contained TCOD from the production of hexachlorophene A waste oil company mixed this waste
with waste oil and used the mixture to spray roads in Times Beach and the surrounding areas to
control dust. A remedial investigation determined that soil was contaminated at 27 sites in the
State of Missouri; Times Beach served as a central treatment facility for these sites. A Record of
Decision (ROD), signed in September 1988, specified on-site incineration as the remediation
technology for the excavated soil and debris Site cleanup goals and ORE standards were
specified for TCDD
On-srte incineration using the IT Corporation Hybrid Thermal Tiaatment System* began in
1996 and was completed in June 1997 The treatment system consisted of a rotary tain and an
SCO An enclosed conveyor moved the soil and debris to the kiln for treatment Treated ash
from the incinerator was discharged to a cooler where it was quenched with water Dunng its
operation, the incinerator at Time Beach processed 265,000 tons of soil and debns. Incineration
achieved the soil cleanup goals specified in the ROD, including 1,900 tons of incinerator ash that
met soil cleanup goals only after re-incineration
The total cost of the Remedial Action was approximately $1 10,000,000.
233
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Time* 0Mcn Supfrfund Sto
EXECUTIVE Sur.
This report presents cost and performance data
for the application of on-slte incineration at the
Times Beach Superfund site in Times Beach,
Missouri. A rotary kiln incinerator was operated
from March 1996 through June 1997 as part of a
remedial action. The contaminant of concern at
the site was 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD)
The Times Beach site served as a central
incineration facility for 27 TCDD-contaminated
sites across the state of Missouri Soil and
debris at these sites were contaminated with
TCOD in the 1970s by waste generated in the
production of hexacnloropnene by a
pharmaceutical and chemical company This
waste was mixed with waste oil and sprayed on
roads as a dust suppressant by a private firm.
The contaminated debns from the 27 sites
included home insulation, furniture, flooring,
carpet, and mattresses; scrap metal, and tree
stumps and brush Contaminated soil contained
rocks, asphatt, gravel, and sawdust [4]. The
geometric mean of TCDD concentrations
measured during the remedial investigation was
79ug/kg
In 1990, EPA and the State of Missouri entered
into an agreement with the Responsible Party
(RP) A Record of Decision (ROD) signed in
September 1988 established a destruction and
removal efficiency (ORE) of 99 9999% for
TCDD.
The RP conducted remedial activities including
the operation of the rotary kiln incinerator. The
incineration system used at Times Beach was
comprised of a solid waste feed system, a
countercurrent, controlled-air, rotary kiln with an
oxygen-enhanced burner; a secondary
combustion chamber (SCC); a wet gas cleaning
system (GCS); and a treated material handling
system [4].
Soil and debris were collected in bags,
drums, and boxes, and transported to the
Times Beach incinerator To prepare the
feedstock, soil was mixed with lime to
reduce moisture content and debns was
shredded to an acceptable size for the
incinerator. Prepared matenal was fed to
the incinerator by an enclosed conveyor
Resulting ash from the incinerator was
removed and cooled with water, while off-
gas was drawn into the SCC. The SCC was
a down-fired steel shell that provided further
combustion of contaminants in the off-
gases Both the incinerator and SCC were
fueled by natural gas.
Treated gas was then drawn into the GCS,
which consisted of a quench contactor, a
gas conditioner, two Hydro-Sonic*
scrubbers, and a vane separator. The GCS
cooled the gas from the SCC and was
designed to remove particulate matter,
metals, and add gases before discharge to
the atmosphere. Ash collected from the
incinerator and GCS was sampled and
analyzed, if it met the treatment critena it
was landfilled on site Ash that failed to
meet criteria was re-incinerated.
During its 16 months of operation, the
incinerator processed approximately
265,000 tons of contaminated material.
Treatment performance and emissions
collected during this application indicate that
all performance standards and emissions
were achieved
The actual cost for remediation using the
incineration system was approximately
$110,000,000
US ENVIRONMENTAL PROTECTION AGENCY
Offlct of Solid Watt* and Emergency Response
Technology Innovation Offlc*
234
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ktontttwina
Information
nfltmen
Times Beach Superfund Site
Times Beach, Missouri
CERCUSf MOD980685226
ROD Date- September 29,1988
packoreund
Historical Activity that Generated
Contamination at the Site Production of
hexachlorophene
Corresponding SIC Code: 2834
(Pharmaceutical Preparations)
Waste Management Practice That
Contributed to Contamination: Oil used for
roadside dust suppression
Site History-
• The Times Beach site occupies a 0.8 square
mile area on the Meramec River The site
served as the central collection and
treatment center for the 27 TCDD-
contaminated sites in the state of Missouri
• From Apnl 1970 until January 1972, a
pharmaceutical and chemical company
generated TCDD-contaminated waste
during the production of hexachlorophene
• From February 1971 until October 1971, a
waste oil company removed TCDD-
contaminated still bottoms from the
chemical plant and mixed It with waste oil
The town of Times Beach contracted the oil
company to spray unpaved roads with waste
oil to control dust from the summer of 1972
through the summer of 1976 [ f CJ
• In July of 1971, drums of waste containing
TCDD were buried at the Denney Farm site
An additional 225,000 gallons of waste were
ilteatk
Type of action Remedial (on-site rotary
kiln incineration)
Period of operation: March 1996 - June
1997
Quantity of material treated during
application- 265,000 tons of soil and
debris
taken to the wastewater treatment
school at Neosho. In October 1979, an
anonymous caller tipped EPA that the
waste was applied at various locations
in Missoun including Minker, Stout, and
Romaine Creek Subsequent
investigations found TCDD
contamination at the Denney Farm site
and other farms, the wastewater at
Neosho, and in fish and sediment in the
Spring River [7C§.
A site investigation was conducted in
the town of Times Beach in 1982 In
February 1983, under the advice of the
Center for Disease Control (CDC), EPA
transferred funds to the Federal
Emergency Management Agency
(FEMA) to permanently relocate Times
Beach residents and businesses [21
A Remedial Investigation and Feasibility
Study (RI/FS) was conducted in 1984
for the Times Beach and Minker, Stout,
and Romaine Creek sites Based on the
RI/FS, a ROD was signed in September
1988, specifying on-site incineration to
reduce the concentration of TCDD in
soil and debris.
EPA determined that Times Beach was
the best location for a temporary
treatment facility for the TCDD-
contaminated soil and debris from the
various sites in the state of Missouri
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Rwponw
Technology Innovation Office
235
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SITE INFORMATION (CONT.)
• The RP began excavating the contaminated
soil at all of the sites in 1992 Between
1992 and March 1996, the contaminated
soil and debris were stored in temporary
containment facilities. In March 1996, a
mobile, rotary kiln incinerator began
operation to remediate the excavated soil
and debris
• The RP incinerated approximately 240,000
tons of soil and debris between March 1996
and June 1997 [72J.
Regulatory Context:
• The Missouri Department of Natural
Resources (MONR) and EPA identified site
cleanup requirements described in a ROD
signed on September 29,1988 [2] The
ROD called for placing a dean soil cover at
least 1 foot in depth over soil in the state
that contained TCDD concentrations ranging
from 1 to 20 ug/kg Excavation and
incineration was required for soil with
concentrations exceeding 20 ug/kg
• In 1990, the state of Missouri and EPA
entered into an agreement with the PRP,
which included remediation activities at the
site in Times Beach, Missouri
• The selected remedy was consistent
with the Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), the Superfund
Amendments and Reauthorization Act
of 1986 (SARA) and the National
Contingency Plan (NCP) in 40 CFR part
300 [1].
• Hazardous Waste Management Facility/
RCRA Permit No MO0000335919,
issued by EPA and MDNR, signed on
April 14,1995, required a trial bum and
a dioxm stack test and set requirements
for air emissions from on-site
incineration of contaminated soil and
debris
• Resource Conservation and Recovery
Act (RCRA) regulations require a DRE
of 99 9999% for TCDD. Stack gas
monitoring was conducted for oxygen
and carbon monoxide in accordance
with 40 CFR part 264, subpart O.
Remedy Selection- On-site incineration
was selected as the remedy for
contaminated soil at the Times Beach
Superfund site, wastes from 26 other sites
in the State of Missouri also were
incinerated at the site based on treatability
study results, long-term economic concerns,
and human health considerations.
U 8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emwgwcy Rttponte
Technology Innovation Office
236
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Tftn
torn* Site
SITE INFORMATION (CONT.)
Timeline
Table 1 Timeline [1
July 1971
Waste buried at Penney Farm site
Summer 1972-Summer
1976
An <* company applied waste oH to unpavad streets of Times Beach
October 1979
225.000 gallons of waste token to Neoshi
atmentschi
October 1982
Initial site kn
February 1983
EPA formers furris to FEMA to permanaTtryreta^
February 1966
Remedial IriVBstigatoVFeasfcityStuclyccjrnpleted
September 1988
Record of Decision signed
November 11,13.14,
1995
Trial Bum
1992
Contarnlnated soil excavation started at Times Beach and 26 other sites
March 1996 - Juw 1997
Site Information
• Soil samples were collected at more than
1,000 different locations at the Times Beach
site, at varying depths to characterize the
extent of the contamination
Soil samples were also collected and
analyzed at 26 other sites across the
state to characterize the extent of
contamination at these sites
Site Management RP-lead
Oversight EPA
Remedial Project Manager:
Robert W. Feild
U.S EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7697
State Contact:
James O. Silver, OSC
Missouri Department of Natural Resources
Times Beach Project Oversight Office
97 North Outer Road, Suite 4
Eureka, MO 63025
(314) 938-9150
Treatment System Vendor:
Con Murphy
International Technology Corporation
97 North Outer Road, Suite 8
Eureka, MO 63025
(314)938-9711
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
237
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TftiMS BMcft SupHfUnd Site
MATRIX DESCRIPTION
Itotriy Identification
Type of Matrix Processed Through the
Treatment System- Soil and debns
• Excavated soil contained rock, asphalt,
gravel, and sawdust
Debns included insulation, furniture,
flooring, clothing, drapes, carpet,
mattresses, plastic liners, rubble, trash.
vinyl flooring, charcoal, water, metal
scrap, brush, tree stumps, vacuum truck
hoses, personal protective clothing,
samples, and containers [4]
Primary Contaminant Group Dioxins
• The contaminant of greatest concern is
TCDD.
The minimum and maximum
concentrations detected in the state
were 1 ug/kg and 1,800 ug/kg
respectively, with a geometric mean
value of 79 ug/kg
The soil treated at Times Beach had a
moisture content that ranged from 0 53 to
32%, with a geometric mean value of 7.8%
\A
Soil and debris from each of the sites
was collected in bags, drums, and
boxes. Each of these containers also
was incinerated
TREATMENT SYSTEM DESCRIPTION
IT Corporation's Hybrid Thermal Treatment
System* (Incineration system) including-
• Solid waste feed system
• Countercurrent, controlled air rotary kiln with
oxygen-enhanced burner manufactured by
Kennedy Van Saun
• Secondary combustion chamber
Pretreatment (solids).
• Lime addition
• Screening and shredding
Post-Treatment (air)-
• Gas Clean System manufactured by the
John Zink Company including:
— Water quench tower
— Two-stage scrubber
— Vane separator
• Environmentally Safe Temporary
Emergency Relief System* (ESTER*)
Post-Treatment (water)
• On-site wastewater treatment system
U.S. ENVIRONMENTAL PROTECTION AQENCY
Office of Solid Wait* and Emergency Revporwe
Technology Innovation Office
238
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SMC/I SkfMfftmcr Sffl»
System Description and Operation
• The contaminated soil had a relatively high
moisture content. To prevent the buildup of
excessive pressure in the kiln, the soil was
pre-treated to remove moisture Lime was
added to the soil or, if time permitted, the
soil was sun-dned
• Other feed material was prepared for
incineration using several pieces of
equipment Matenal preparation took place
in the Feedstock Handling Building, which
was maintained at a slight negative
pressure to prevent fugitive emissions An
initial screening device allowed six inch or
smaller matenals to fall into a crushing
circuit Material greater than six inches was
broken up with mobile equipment The
matenal was then stacked radially within the
building and a magnetic separator removed
metal items which could damage processing
and conveying equipment The matenal
was then fed into a shredder, which crushed
the matenal to a two inch or smaller size
The matenal was then blended to achieve
the desired feed consistency [4] Once the
matenal was prepared, it was fed to the kiln
by an enclosed conveyor
• The kiln had a length of 75 feet, an outside
diameter of 13 feet, 7 5 inches, and an
installed slope of 0 25 inches per foot The
tain was lined with 9 inches of high-
temperature, add resistant, insulating
refractory and was designed such that the
optimal throughput of contaminated soil was
approximately 38 tons per hour The kiln
rotated at a maximum rate of 60 revolutions
per hour with a corresponding solids
residence time of 1 hour
• The kiln employed an oxygen-enhanced
burner which had a firing capacity of 40
million BTU/hr and operated at
approximately 1,250*F The oxygen-
enhanced burner increased incinerator
productivity by increasing heat transfer and
throughput rate
Residual ash from the kiln was
transferred to a treated matenals cooler
and was water quenched until it reached
200°F. The ash was then sampled and
analyzed to ensure that it met treatment
criteria If the ash met the critena, it
was landfilled on site, if not, it was re-
incinerated.
Flue gases from the kiln were routed to
the SCO to ensure complete
combustion of volatilized contaminants
The SCO was downfired, with an
outside diameter of 12 feet, and a
height of 38 feet. The SCC operated at
approximately 1,750°F The flue gas
residence tome in the SCC was
approximately 2 seconds for a gas flow
rate of 87,000 actual cubic feet per
minute (acfm)
The exhaust gas from the SCC was
then routed to the system's GCS. Off-
gas entenng the GCS first passed
through a quench contactor where gas
was cooled by the evaporation of water
From the quench contactor the off-gas
was channeled to the gas conditioner
The gas conditioner contained wetted
packing matenal, to provide a surface
area for the collection of paraculate
matter Following the gas conditioner,
the off-gas passed through two Hydro-
sonic* scrubbers where high-energy
water sprays created small droplets to
capture particulate matter The last
stage of the GCS was a vane separator,
which contained multiple flat surfaces
onto which collected particulate matter
that was entrained in water droplets [4]
Water used in the GCS was recycled in
a sump below the unit Theblowdown
from this sump was either reused to
quench the ash from the incinerator or
treated in an on-site waste water
treatment facility Particulate matter
removed in the treatment process was
dried, and subsequently sampled and
analyzed to determine whether it could
be disposed of on the site.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
239
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Times Seocn Suptrfund $&•
TREATMENT SYSTEM DESCRIPTION (CONT.)
The GCS was rated for a design paniculate
loading of 0.01 grains per dry standard
cubic foot, corresponding to a paniculate
emission rate of 1 pound per hour [5| The
design operating conditions for GCS flow
rate and exit temperature were 12,000 dry
cubic feet per minute (dcfm) and 200°F,
respectively.
Combustion gases were drawn through the
kiln system and GCS by an induced-draft
fan and were exhausted through a 100-foot
stack. Typical stack gas flow was 37,000
acfm
The incinerator was also equipped with
an emergency backup system The
Environmentally Safe Tempo'ary
Emergency Relief System* (ESTER*),
provided for combustion of
contaminants in the kiln in the event of
a forced shutdown of the incinerator.
Dunng such an event, the rotary kiln
gases were diverted to the ESTER*,
which contained a propane-fired
oxidation system to thermally treat the
off-gases before release to the
atmosphere The ESTER* stack was
designed to reach a temperature of
1800°F
The ROD site performance requirements
and the MDNR established a ORE of
99.9999% for TCDD.
Cleanup standards required incineration
of soil with a TCDD concentration
exceeding 20 pg/kg A clean soil cover
of at feast 1 foot was required for soil
with TCOD concentrations from 1-20
Mg/kg
• The ROD rated that soils with TCDD
concentration exceeding 1 ug/kg at the
surface or exceeding 10 \igfog at a depth of
1 foot are of concern for the protection of
human health in residential settings
However, the ROD also stated higher TCDD
concentrations would be acceptable in
commercial and industrial settings and
concluded that a 20 pg/kg TCDD
concentration cleanup level would provide
adequate protection of public health when
considering the future expected land use at
the site [2]
A nsk assessment concerning the
operation of the incinerator estimated
that the excess lifetime cancer risk level
was below 1x10* for all residents in the
immediate vicinity of the site.
US ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
240
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Ttmea Beach Sqpwfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
A trial bum conducted at Times Beach was
designed to operate the incineration system
at conditions that would reflect worst case
destruction and removal of all constituents
of concern Hexachloroethane and 1,2,4-
tnchlorobenzene were selected as the
principal organic hazardous constituents
(POHC) The reported DREs for each
POHC are inducted in Table 2
AWFCO limits and the frequency of
occurrence of AWFCOs dunng the
operation of the incinerator are shown in
Tabled
The incinerator at Times Beach operated
within the operating hmrts established dunng
the trial bum signifying that all cleanup
requirements esteul«&ned in the ROD were
met Values for trial bum and actual
operating parameters are shown in Table 4
The residual ash was sampled and
analyzed in accordance with standards
set in the CERCLA Exclusion for Times
Beach Thermal Treatment Residues
which required that the ash meet
Toxicity Characteristic Leaching
Procedure (TCLP) landfill standards for
metals. The results of this analysis are
presented in Table 5.
MDNR provided oversight at Times
Beach to ensure proper facility
operation Additionally, St Louis county
officials inspected operations and
tracked air-monitoring to ensure that the
emissions were in compliance with the
county's air pollution permit
Table 2 A
Destruction and Removal Efficiencies from Trial Bum i
Table 3. Automatic Waste Feed Cutoffs
Maximum contaminated sol feed rate*
417tph
Rarely
Maximum CO <
(0
miration In stack gas
lOOppmv
Never
Mnknum Mki odt gas temperature''
1,117-F
Rarely
Minimum SCC exit gas temperature
1,714°F
Rarer/
Maximum stack gas flow rate1
38,260 aetim
Once
Minimum GCS differential pressure*
24.2 Inches H,O
Never
Maximum quench exit yn temperature
250°F
Rarely
Mndmum Win pressure
-006 inches H.O
DaAV*
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
241
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TiRM
vperfundStte
TREATMENT SYSTEM PERFORMANCE (C
Tables Automatic
Maximum ojuench radrcutaflon rate
400 gpm
Rarely
MHmum quanch redrctdatton pump
power
OkW
Rarely
MMnun Hydro-1 recfecuMion rate
307 gpm
Rarely
MMmum Hydrc-2 reeirculatlon rate
215 gpm
Rarely
Minimum scrubbing liquid pH in Hydro-2
sump
Rarely
Maximum ID for vibration
04SkVBec
Rarely
Maximum ID for cur-ant
720 A
Rarely
MMmum WESP secondary voltage
174KV
Rarely
MNmumgasO.(
nitration
3 5% by volume
Never
'AWFC tags were not maintained These descriptions
represent operator estimates
'l-hourroHng average
"lO-mlnute raing average
'High moisture content In the soN has caused overpressuriza-
tkxiofthekfti This caused 2 to 12 automatic waste feed
cutoffs per day and was the primary cause of AWFCO
su s standard PH units
tph = tons per hour
acfm = actual cubic feet per minute
gpm = galons per minute
A=amps
kV = Wlovolts
Table 4. Operating Parameters [7,8]
ig-'imm- •-%:•«-'-•>• •:-T:^-.-' ' •' •.•^&t •••'-;• ^'*zr^9m
Contaminated Sol Feed Rate
Fuel Fired Feed Rate
emission rune
Paniculate
HO
0,
CO,
0,
Lead
No.
Operating Conditions
co concentration n stack Gas
KNn ExK Qas Temperature
SCC ExH Temperature
Stack Qas Flow Rate
GCS Differential Pressure
Quench Extt Gas Temperature
31 tph
40 mWon BTLMir
MA
Not Monitored
Not Monitored
9% by dry volume
7-8% by volume
Not Monitored
Not Monitored
Trace
1,250'F
1.750-F
37,000 acfm
25 Inches H..O
200'F
41 7 tph
40 miton BTU/hr
0.94ltVhr
OOUtVhr
00023 to/hr
11 7% by dry volume
6 7% by volume
00082 Whr
157BVhr
Trace
1,117-F
1,714-F
38,300 acfm
242 Inches HtO
250°F
"Actual Value anticipated parameters for daily operations as projected In the Trial Bum Report
toh-tons per hour
acfm - actual cubic feet per minute
U.S. ENVIRONMENTAL PROTECTION AGENCY
Ohio* of Solid Wutt and Emergency Response
Tschnoteoy Innovation Office
242
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Times Bmach Superfund Sto
TREATMENT SYSTEM PERFORMANCE (CONT.)
Tables TCLP Comparison for Residual Ash
Barium
1000
0278
Cadmium
10
0072
Chromium
50
0008
Lead
50
0.233
Mercury
02
< 00008
Selenium
10
0041
Silver
50
<0004
Mole. Only contaminants lhatwwe analyzed for are Included In this table
•Excerpted from 40 CFR §261.24 Table 1
Performance Data Comnleteness
Data are available for concentrations of
TCDD in the soil before treatment
Performance Data Quality
• The QA/QC program used dunng the
remedial action met EPA and MDNR
requirements. All monitonng and sampling
and analysis was performed using EPA-
approved methods
Data are also available for
concentration of TCDD in incinerator
residuals These data were collected
before residuals were disposed of on
the site
TREATMENT SYSTEM COST
Procurement Process
• The RP contracted with Foster Wheeler
Environmental Corporation to manage the
Times Beach site IT Corporation was
contacted by Foster Wheeler to operate the
incinerator at the site
Coat Data
• The cost for operation of the incinerator at
Times Beach was $110,000,000 A total of
265,000 tons of soil and debris were
incinerated This corresponds to a total unit
cost for incineration of $800 per ton A
detailed breakdown of these costs was not
available.
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Response
Technology Innovation Office
243
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Times Beach Superfund Site
OBSERVATIONS AND LESSONS LEARMED
Site personnel expenenced problems with
the power supply to the incinerator One
incident involved an unexpected storm
which interrupted power supply Strong
wind gusts from the storm blew out the pilot
bgn*s on the ESTER* system Therefore,
w&he i the power was interrupted and the kiln
shut down, kiln gases routed to trie ESTER*
were released directly to the ambient
atmosphere Emission levels used in this
analysis could only be estimated because
the aii-monitonng equipment was on the
sanr-9 electrical circuit as the incinerator and
did not operate To prevent future weather-
related occurrences, the operator decided to
work closely with the local weather service
to receive accurate weather forecast
updates. Subsequently, the waste feed was
ceased during severe weather
Public
Involvement
High moisture content in the waste feed
caused overpressunzation in the kiln
resulting in 2 to 12 automatic waste
feed cutoffs per day Site personnel
noted that excavating the soil when it
was dry would have been the best way
to avoid this problem. However, at the
time of remediation, soil was either
being (1) excavated immediately pnor
to incineration due to time constraints,
which did not always allow the soil to be
excavated when it was dry or (2) was
stored in large bags from other sites In
response to this problem, personnel at
the Times Beach site added lime to the
soil, or, if time permitted, let it sun dry to
reduce moisture content before feeding
the soil to the incineration [11].
An estimated 1,900 tons of incinerator
ash required re-incineration because it
did not meet requirements Following
re-incineration, it met the requirements
and was able to be backfilled on site
The concern most frequently expressed by
local residents was the possibility that the
Times Beach incinerator would eventually
be used to incinerate dioxin-contaminated
material from other states EPAandMDNR
assured the public that the Times Beach
incinerator would cease operation once the
cleanup from the 27 sites in Missoun was
completed [11]
Before remediation began at the site,
local residents expressed concern about
the potential for excessive noise from
the incinerator This never became a
problem because the operations took
place within enclosed buildings. This
also served to prevent fugitive
emissions dunng matenals Handling
US ENVIRONMENTAL PROTECTION AGENCY
Offlc* of Sottd Waste and Em«rgercy R«epon«e
Technology Innovation Office
244
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Times Beach Superfund Site
REFERENCE;
1 Superfund Record of Decision. Times
Beach, St Louis, Missouri, January 13,
1984
2. Superfund Record of Decision. Times
Beach, Times Beach, Missouri,
September 9,1988
3 Letter to Mr GaryJ Pendergrass, P E ,
Project Coordinator for the Settling
Defendants, from Mr David A Shorr,
Director of the Missouri Department of
Natural Resources, Information on Modified
Hazardous Waste Management Facility
Permit for Times Beach, March 15,1996
4 Engineering Description and Trial Bum
Plan. Times Beach Thermal Treatment Unit.
IT Pollution Control Engineenng, April 1994
5 Final Times Beach Site Multimedia Risk
Assessment Vol I. U S Environmental
Protection Agency, March 28,1995
6. Letter to Mr David Shorr, Director of the
Missouri Department of Natural Resources,
from Mr. Fred Striley. Dioxin Incineration
Response Group, Information on permit
application for the Times Beach incinerator,
June 18,1995
Trial Bum Report for the Times Beach
Remediation Project. IT Corporation,
January 1996
Dioxin Stack Test Report for the Times
Beach Remediation Project. IT
Corporation, January 1996
8
9. WeeMv Progress '^pfo*0,. Eastern
Missouri Dioxin Cleanup Proiect.
Missouri Department of Natural
Resources, March 17,1997.
10. A Chronology. Important dates in the
Times Beach Superfund site history, St
Louis Post-Dispatch
11 Personal Communication, Mr James
Silver, March 27,1997.
12. Engineenng News-Record. McGraw-Hill
Companies, July 14,1997
U.S. ENVIRONMENTAL PROTECTION AGENCY
OfflM of Solid Waste and Emergency Response
Technology Innovation Office
245
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This Page Intentionally Left Blank
246
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On-Site incineration at the
Vertac Chemical Corporation Superfund Site
Jacksonville, Arkansas
247
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Incineration at the Vertac Chemical Corporation Superf und Site
Jacksonville, Arkansas
Site Name:
Vertac Chemical Corporation
Superf und Site
Location:
Jacksonville, Arkansas
Contaminants:
Dioxins and Volatile Organic
Compounds
• TCDD, chlorinated benzene,
chlorinated phenols, 2,4-D,
and 2,4,5-T.
• TCDD concentrations up to
50mg/L
Period of Operation:
January 1992 - September
1994
Cleanup Type:
Remedial action
Vendor:
MRK Industries
SIC Code:
2879 (Pesticides and
Agricultural Chemicals)
Technology:
On-Site Incineration
• Solids preheated by triple
nnsing, shredding, and
drying
• Incineration system
consisting of rotary kiln and
secondary combustion
chamber (SCC)
• Enclosed conveyor
transported contaminated
matenal to the unit
• Residence time was
approximately 40 minutes,
kiln temperature of 2,000 °F
and SCC temperature of
2,200 °F
• Treated materials
(incineration ash and
residual) were collected and
disposed of off site in a
Subtitle C hazardous waste
disposal facility.
Cleanup Authority:
CERCLA, SARA, RCRA,
and State: Arkansas
• ROD Date MA
• State-lead
Point of Contact:
MlkeArjmandi
Arkansas Department of
Pollution Control & Ecology
P.O. Box 8913
8001 National Drive
Little Rock, AR
72219-8913
(501) 682-0852
248
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Incineration at the Vertac Chemical Corporation Superfund Site
Jacksonville, Arkansas
(Continued)
Waste Source:
Drummed still bottom waste -
herbicide manufacturing waste
Purpose/Significance of
Application:
Two temporary restraining
orders were filed to stop the
incineration project over public
concern about the incinerator
Type/Quantity of Media Treated:
Storage Drums, Drummed Waste, and Soil
• 9,804 tons of waste
• 1,027 tons of soil
Regulatory Requirements/Cleanup Goals:
• Destruction and Removal Efficiency (DRE) of 99 9999% for all constituents of concern as
required by Resource Conservation and Recovery Act (RCRA) incinerator regulations, 40 CFR
part 264, subpart O
Results:
• Emissions and trial bum data indicated that all DRE and emissions standards were met
Cost Factors:
The incineration system at the site consisted of a rotary kiln and a secondary combustion
chamber, followed by an air pollution control system
Description:
Between 1948 and 1987, the Vertac site operated as a herbicide manufacturer within the city
limits of Jacksonville, Arkansas The by-product TCDD was placed in drums and stored on-site
Investigations at the site conducted by the U S. EPA and the Arkansas Department of Pollution
Control and Ecology (ADPC&E) as part of Vertac's participation in the 1978 National Dioxin
Survey revealed TCDD concentrations as high as 40 mg/L in production wastes and eventually
resulted in the site being placed on the National Priorities List (NPL) in 1983.
A Consent Decree was entered into by EPA, ADPC&E, and two RPs in January 1982, which
required an independent consultant to assess the management of wastes being stored on the site
and to develop a proposed disposal method The proposed remedy was implemented In the
summer of 1984 by court order over the objection of EPA who deemed the proposal
unsatisfactory
On-site incineration began in January of 1992 and was completed in September 1994
249
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V*rt»c Chemical Corporation SupwfundSlto
This report presents cost and performance data
for the application of on-site incineration at the
Vertac Chemical Corporation (Vertac)
Superfund site in Jacksonville, Arkansas A
rotary kiln Incinerator was operated from
January 1992 through September 1994 as part
of a remedial action. Contaminants of concern
at the site included 2,3,7,8-tetrachlorodibenzo-p-
dioxin (TCDD); 2,4-dichlorophenoxyacetic acid
(2,4-D); 2,4,5-trichlorophenoxacetlc acid (2,4,5-
T); chlorinated benzene; and chlorinated
phenols
The Vertac site was a former pesticide
manufacturing plant which operated from 1948
until it was abandoned in 1987. During this
period, approximately 29,000 drums of still-
bottom waste from the production process were
generated and stored on site. The drummed
waste at Vertac contained solvents and TCDD
During the remedial investigation, TCDD
concentrations were measured as high as 50
mg/L in the still bottom wastes and 2,800 ug/kg
in the soil
In 1987, the Arkansas Department of Pollution
Control and Ecology (ADPC&E) determined that
it would contract for the incineration of the
drummed wastes, and would finance the action
using a trust fund and letter of credit provided
by one Potentially Responsible Party (PRP) at
the site. Applicable regulations under the
Resource Conservation and Recovery Act
(RCRA) required a 99.9999% destruction and
removal efficiency (ORE) for cHoxin listed
ADPC&E conducted remedial activities
including the operation of a rotary kiln
incinerator to disposed of the drummed wastes
until June 1993, when EPA assumed
management responsibilities at the site The
incineration system used at Vertac was
comprised of a direct-fired rotary kiln, two
cyclone separators, a secondary combustion
chamber (SCC), a baghouse, a wet scrubbing
system, and ash removal facilities
The waste drums were opened, emptied,
and raised in an enclosed building
maintained at a negative pressure Waste
from the drums was fed to the incinerator
Wastewater generated was treated and
recycled in a closed system Ash from the
while off-gas from the kiln was routed to the
cyclone separators
The cyclone separators removed
parttculates, which were routed to the waste
feed system and re-incinerated, and
discharged the gas to the SCC. The SCC
provided further oxidation of the remaining
organic contaminants in the gas.
Treated gas was drawn through an air
pollution control system (ARCS), which
consisted of a spray drier, to lower the
temperature of the gas, and a baghouse
assembly, venturi scrubber, and baffle
absorption scrubber to remove additional
particulates. The gas was then discharged
to the atmosphere. Ash collected from the
incinerator and scrubbers was disposed of
at a Subtitle C hazardous waste disposal
facility
Dunng the 32 months of operation, the
incinerator processed 9,804 tons of waste.
Additionally, approximately 1,200 tons of
2,4,5-T waste was incinerated at an off-site
facility Treatment performance and
emissions data collected during this
application indicated that all performance
standards and emissions requirements were
achieved
The actual cost for remediation using the
incineration system was approximately
$31,700,000 This amount consisted of
approximately $21,000,000 in capital costs
and approximately $10,700,000 in operating
U.8. ENVIRONMENTAL PROTECTION AGENCY
Offlct of Solid Watt* and Emergency Response
Technology Innovation Office
250
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Vwtte Gnomic*/ Corporation Superfund Sft»
UBDttfti
Vertac Chemical Corporation Superf und Site
Jacksonville, Arkansas
CERCUSt ARD000023440
ROD Date: Not applicable
Type of action: Removal (on-ate rotary
kiln incineration)
Period of operation: January 1992-
September 1994
Quantity off material treated during
application: 9.804 tons of still bottom
waste, soil, and debns
Historical Activity that Generated
Contamination at the Site: Manufacture of
herbicides
Corresponding SIC Code: 2879 (Pesticides
and Agricultural Chemicals)
Waste Management Practice That
Contributed to Contamination: Improper
waste storage and disposal practices
Site History:
• The site operated from 1948 until it was
abandoned in 1987. The Vertac site is
located within the city limits of Jacksonville,
Arkansas, which has 28,000 residents
Approximately 1,000 people live within one
mile of the site, which is bounded by
residential areas to the east and south, Little
Rock Air Force base to the north, and an
industrial area to the west
• During this period, herbicides, primarily
2,4-D and 2,4,5-T, were manufactured at
the site TCDD was a by-product of the
manufacturing process The drummed still
bottom wastes generated in the
manufacturing process were stored on site
• The Vertac site participated in the 1978
National Dioxin Survey TCDD
concentrations as high as 40 mg/L were
found In the 2,4-D and 2,4,5-T production
wastes EPA and ADPC&E began
Investigations at the site, resulting in the site
eventually being placed on the National
Priorities List (NPL) in 1983. ADPC&E
issued an order in 1979 which required
the operators of the site to improve
hazardous waste handling practices [1].
During site investigations, TCDD
concentrations in the 2,4,5-T drummed
waste were measured as high as 50
mg/L TCDD concentrations in the 2,4-
D waste were generally less than 1
ug/L All of the waste on site, however,
was classified acutely hazardous waste
(see the dioxm listing rule of January
14,1985 (50 FR 1978))
A Consent Decree was entered into by
EPA. ADPC&E, and two PRPs In
January 1982, which required an
independent consultant to assess the
management of wastes being stored on
the site and to develop a proposed
disposal method The proposed remedy
was implemented in the summer of
1984 by court order over the objection
of EPA who deemed the proposal
unsatisfactory [1]
The remedy specified by the Consent
Decree required that the site's cooling
water pond and equalization basin be
closed and the sediments from these
areas be placed in an unlined
excavated area where waste had
previously been buried. The remedy
specified that a French drain, leachate
collection system, and monitoring wells
be Installed around the area and
required the area to be capped.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Offle* of Solid Watt* and Emergency Response
Technology Innovation Office
251
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VfrttcChunWCorponOonSupnfunaSite
SITE INFORMATION (CONT.)
A series of treatabllity studies using Vertac
wastes were performed In 1985 at the EPA
Combustion Research Facility in Jefferson,
Arkansas to determine if a 99 9999% ORE
was achievable The tests showed that
incineration was viable based on this
criterion, and in 1985 the RP operating the
site contracted with Environmental Services
Company (ENSCO) to incinerate the
wastes
Later in 1985, EPA and ADPC&E entered
into an agreement with the RP operating the
site, under the terms of which the RP
established a trust fund and a letter of credit
for environmental remediation
In 1986, after several unsuccessful trial
bums, ENSCO left the site In January
1987, the RP declared bankruptcy and
abandoned the site. The trust fund that had
been established continued to fund remedial
action through 1993.
When the site was abandoned, nearly
29,000 55-gallon drums of still bottom
production wastes remained on site.
Approximately 25,600 of these drums
contained waste from 2,4-D production and
about 3,200 others contained waste from
2,4,5-T production. The drums contained
high concentrations of solvents (for
example, toluenes and phenols), had an
average chlorine content of 25%, and had a
pH In the 2 - 3 range In addition, 650 tons
of contaminated sludges, liquids, and solids
were abandoned In approximately 100 of
the 190 production tanks that had been used
in the manufacturing process
EPA and ADPC&E also discovered that
many of the drums and production tanks
were leaking presumably as a result of the
corrosivlty of the waste and ultraviolet
degradation. EPA issued a work order to
the site which Instructed them to fix the
leaking tanks and dean up the spills
The contaminated soil at the site was
addressed in a separate operable unit
It was excavated and landfilled in a
Subtitle C facility.
In February 1987, EPA and ADPC&E
initiated an immediate removal action to
mitigate the hazards posed by the
deterioration of the drums The drums
were placed in 85-, 110-, and 130-gallon
overpack drums, and placed in a
covered storage area.
In 1987, ADPC&E awarded a contract to
MRK Industries using funds from the
trust for the incineration of the waste at
the Vertac site A trial bum was
conducted from August 30,1990 until
December 10,1990 A second trial
bum was required due to several
problems with the first tnal bum
ADPC&E cited problems with surrogate
spike recoveries for semi-volatile
compounds, data gaps for recorded
parameters, and laboratory QA/QC
procedures as the reasons for a second
tnal bum [1]
In September 1990, Records of
Decision (RODs) were signed for the
Jacksonville Municipal Landfill and the
Rogers Road Municipal Landfill, which
called for the excavation and
incineration at the Vertac site of
contaminated soils. Both landfills were
located in Jacksonville, approximately
five miles from the site and had been
contaminated by waste from the Vertac
site A total of 1,027 tons of landfill soil
and debris was transported to Vertac
and Incinerated.
U.8. ENVIRONMENTAL PROTECTION AGENCY
Offlct of Solid Watt* and Emergency Raspont*
Technology Innovation Offtct
252
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V»rtK C/wmfc*/ Corporation Supwfuntf Site
On May 29,1991 a motion was filed by
several organizations for a preliminary
injunction to halt the incineration of the
drummed hazardous wastes at the site The
organizations claimed that the incineration
would cause irreparable damage to the
community of Jacksonville. After court
testimony, the injunction was dissolved and
incineration was allowed to continue
The second tnal bum was conducted
October 9 through 11,1991 and the results
were approved by ADPC&E Incineration of
the 2,4-D waste began in January 1992
On October 28,1992, the Government
Accountability Project (GAP) filed a petition
in Federal District Court requesting a
temporary restraining order and temporary
injunction against burning the 2,4,5-T waste
at the Vertac site. On October 29,1992, the
court granted the restraining order, but
allowed ADPC&E five days in which they
could bum 2,4,5-T waste to gather
emissions data.
On October 29 through 31,1992, ADPC&E
incinerated approximately 80 drums of
2,4,5-T waste Data gathered from the
three day test showed dioxm and furan
emissions to be approximately the same as
emissions from the earlier 2,4-D
incineration
On November 16 and 17,1992, ADPC&E
conducted three stack tests using Method
23 in 40 CFR part 60 to quantify emissions
of dioxins and furans emitted during 2,4,5-T
incineration. Results showed that mass
emissions of dioxins and furans as TCDD
equivalents were less than detected during
the second trial bum ADPC&E resumed
the incineration of the 2,4-D waste following
the completion of the stack tests.
ADPC&E managed the 2,4-D Incineration
until June 1993 when the remedial contract
was terminated because the funds from the
trust had been exhausted. EPA took over
responsibility for the site and resumed the
incineration
• Although the results of the incineration
test with the 2,4,5-T waste
demonstrated that the emissions were
similar to those from the incineration of
the 2,4-D waste. EPA decided in 1994
to transport the 2,4,5-T waste off site for
incineration. The decision to incinerate
the 2,4,5-T waste off site was based on
(1) the fact that on-srte incineration
would have been more expensive and
(2) ADPC&E's desire to finish the
remediation of the site more quickly.
• On-srte incineration of the 2,4-D waste
at Vertac concluded in September 1994
Subsequently, approximately 3,200
drums of 2,4,5-T waste were
transported to the Aptus incinerator in
Coffeyville, Kansas until March 1996.
The incineration of this waste was
completed in Apnl 1996.
• MRK processed 9,804 tons of waste
between January 1992 and September
1994
• Off-site disposal of 33,972 drums of
incinerator salt and ash residuals was
completed in December 1996 The
residual was disposed of at the Highway
36 Land Development Company,
Subtitle C facility, in Deer Trail,
Colorado [2]
Regulatory Context:
• In 1983, the Vertac site was placed on
theNPL.
• Remedial activities at the site were
conducted under the provisions of two
Remedial Actions.
• The selected remedy was consistent
with the Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980 (CERCLA), the Superfund
Amendments and Reauthorization Act
of 1986 (SARA), and the National
Contingency Plan (NCP) 40 CFR Part
300 [3].
U.8. ENVIRONMENTAL PROTECTION AQENCY
Offlo* of Solid Wwte and Emergency RMpons*
Technology Innovation Offlo*
253
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Vwttc Cftwnfear Corporation StfMfftntf SH»
The DREs were set in accordance with
RCRA standards, at 40 CFR part 264,
subpartO
Remedy Selection: On-stte incineration
was selected as the remedy for drummed
waste at the Vertae Superfund site based on
treatabihty study results and long-term
economic considerations
Table 1. Timeline [I
1948- January 19B7
1878
1963
1984- July 1986
1985
February 1987
August 1990 - Oeeambar 1990
October 9-11, 1991
leWUta»U -1OQ3
MMJmy I We
kanei 1QQA
*lar^imhaf "IflfM
March 1996
December 1996
Vwtac site manufactured hertDfcides
National Dtorin Survey
Site placed on the NPL
Proposed Interim remedy knplemerrted
Indneraeon plot studes warn conducted
Emergency drum ovwpecklng
First Trial Bum
Second TiW Bum
Transport to off-rtte tnuliMfllor WBB comptotod
Off-site dteposal of residual salt and ash vwscompteted
Site Management: EPA-lead
Oversight: ADPC&E
Remedial Project Manager
Philip Allen
U.8. EPA Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-8516
State Contact:
Mike Arjmandi
Arkansas Department of Pollution Control &
Ecology
P O. Box 8913
8001 National Drive
Little Rock, Arkansas 72219-8913
(501) 682-0852
Treatment System Vendor:
MRK Industries
Address NA
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waits and Emergency Reeporwe
Technology Innovation Office
254
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Vwttc Gftemfcaf Corporation Supertax* SA»
MATRIX DESCRIPTION
Type of Matrix Processed Through the
Treatment System: Still-bottom waste from
the production of 2,4-D and 2,4,5-T, soil and
debris
The composition of the drummed waste
varied, but most of the drums contained
a mixture of solids, liquids, and sludges
11]
Soil and debris from off-site landfills
Primary Contaminant Groups: Oioxinsand
Volatile Organic Compounds
• The contaminants of greatest concern were*
TCDD; chlorinated benzene, chlorinated
phenols; 2,4-D, and 2,4,5-T
The maximum concentrations detected
in the still bottom waste in mg/L were
TCDD (50); chlorinated benzene (MA),
2,4-D (NA), and 2,4,5-T (NA)
The matnx charactenstics of the drummed still bottom waste that most significantly affect cost or
performance at the site and their measured values are presented in Table 2
Table 2 Matrix Characteristics
PH
Average chlorine contort
Average heat content (solids)
Maximum hart content (organic Iqukte)
2-3
25%
7,500 BTU*
10.500 BTU/to
Incineration system including
• Waste feed system
• Rotary kiln
• Secondary combustion chamber
Pretreatment (solids)*
• Suction lance
• Two-stage shredder
• Mixing with corncobs
Post-Treatment (air)
• Cyclone separator
• Wet scrubbers
Post-Treatment (water),
• Carbon adsorption
• Evaporation
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watte and Emergency Response
Technology Innovation Office
255
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Vurtac Chemical Corporation Supmfund SK»
TREATMENT SYSTEM DESCRIPTION (CONT.)
rintion and ODMfttlon
Drums were delivered to the feed
preparation building on a flatbed truck,
which could carry approximately 12 drums
The drums were removed from the truck
and placed on a rolling conveyor, where the
drums were weighted and subsequently
transported into the feed preparation
building. The building was maintained at a
negative pressure to prevent fugitive
emissions, air from the building was
channeled to the SCC to destroy
contaminants released during waste
handling
In the building, two operators, in Level A
personal protective equipment, opened the
overpacks and the drums Theoverpacks
were triple-rinsed in accordance with 40
CFR § 261.7, they were later used for the
storage of salt generated by the incineration
system. The overpack rinsate was treated
by carbon adsorption before discharge to
the scrubber water evaporation unit The
operators used a suction lance to remove
liquid organtcs from the drums which were
then pumped to a storage tank Once the
liquids were removed, the drums were
placed on an elevator, which took them to
the top of a two-stage shredder
As the drums entered the shredder,
pulvenzed corncobs were added The
corncobs served as a drying agent, which
absorbed any liquids liberated from the
drums during shredding. The first stage of
the shredder broke the drums into large
pieces. The pieces then dropped to the
second stage of the shredder and were
further broken into 1-Inch pieces. A
collection pan below the shredder was
designed to capture liquids which leaked
from the process.
The shredded material was transported by
an enclosed drag chain conveyor to a
weight hopper. The conveyor was covered
with a nitrogen blanket to purge oxygen
from the area The conveyor assembly was
also perforated to allow for the drainage
of excess liquids. From the weight
hopper, the material was transported to
the incinerator by a screw auger
conveyer The liquid organics in the
storage tank were fed to the incinerator
through a liquids nozzle
• The incineration facilities were placed
on a 90-by 160-foot temporary
foundation that was sloped to the center
to collect releases of wastes and
stormwater. The kiln was 38 feet in
length, had an outer diameter of 7 feet,
and was lined with high-temperature
refractory brick. The optimal throughput
of contaminated feed was
approximately 5,000 pounds per hour
with a corresponding waste residence
time of 1 hour
• The kiln was rated at 50,000 BTU/hr,
and was fueled by natural gas The
average kiln operating temperature was
2,000°F, and it rotated at a rate of 30
revolutions per hour. The waste
residence time was approximately 40
minutes
• Residual ash from the kiln was collected
in an ash bin and later stored In drums.
Off-gas from the incinerator was routed
to two parallel 8-foot-diameter cyclone
separators to partially remove
particulates. Removed particulates
were recycled to the waste feed and re-
incinerated
• Gases from the cyclone separator were
routed to the SCC for further
combustion of volatilized contaminants
The operating temperature of the SCo
was approximately 2,200°F. The SCC
had a length of 38 feet, a diameter of 7
feet, and was lined with high
temperature refractory brick. The SCC
was fueled by natural gas
U.S. ENVIRONMENTAL PROTECTION AQENCY
Office of Solid Waste and Emergency Response
Technology Innovation Offict
256
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Vertac Chamlcal Corporation Suparfund SH*
TEATME
DESCRIPTION (CONT.)
Sv«tem Description and Oo6ratlon fCont.)
• The exhaust gas from the SCO was then
channeled to the system's spray drier to be
cooled After passing through the spray
drier, the exhaust gas was drawn through a
baghouse assembly; the baghouse
assembly contained four individual
baghouses in a two-by-two parallel
configuration The system allowed two
baghouses in series to be in operation while
the parallel system was cleaned Following
the baghouses, a ventun scrubber and a
fiberglass reinforced vinylester baffle
absorption scrubber removed additional
particulates and acid gases from the gas
The spray drier, baghouse assembly,
ventun scrubber, and absorption scrubber
were designed to achieve a 95% parbculate
removal efficiency and a 99% add gas
removal efficiency for hydrogen chlonde
prior to atmospheric discharge [5]
• The quench and ventun scrubber sections
required a water flow rate of approximately
300 gallons per minute (gpm) and the
absorption scrubber required 600 gpm. The
scrubbing system was fed with re-circulated
water which was previously fed through a
pH controller. The pH controller analyzed
the pH of the water in order to control the
feed rate of the sodium hydroxide used to
neutralize the acid gases
• The wastewater blowdown from the
system contained sodium chloride salts
and ash residue The blowdown stream
was controlled automatically by a liquid
level control in the recirculation tank,
which maintained the stream at
approximately 40 gpm Make-up water
was provided to the system at a rate of
120 gpm to replace water lost through
quenching and evaporation
• The wastewater blowdown was
discharged to a carbon adsorption
system to remove organics The
discharge from the carbon system was
passed to :-n evaporation system where
the water was evaporated, leaving
sodium chloride salts The salts were
collected in drums The water used in
the air pollution control system (ARCS)
was recycled within a closed system
• Combustion gases were drawn through
the incinerator and ARCS by an induced
draft fan and were exhausted through a
40-foot fiberglass reinforced vinylester
stack.
• Incinerator residual and ash were
disposed of off site in a Subtitle C
hazardous waste disposal facility A
Subtitle C facility was required because
the wastes fed to the incinerator were
listed hazardous wastes, and therefore
all residuals from the incineration
process were also classified as
hazardous wastes.
Table 3 Summary of
Residence Time
System Throughput
rain Temperature
40 minutes
NA
2,000°F
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office
257
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Vrnlac Chemlcfl Corporation Supfrfund Stte
TREATMENT SYSTEM PERFORMANCE
All of the material on site was considered
acutely hazardous waste and was treated as
listed hazardous waste under the "derived
from* provision of the dioxm listing rale of
January 14,1985,50 Federal Register, pp.
1978-2006 [3].
Although the contents of all of the drums
were incinerated on or off site, an action
limit was established which corresponded to
a 4.2 x 10* excess lifetime cancer nsk over
a 3 - year exposure, and a 9 9 x 10*9 excess
lifetime cancer risk over a 70-year lifetime
exposure
A ORE of 99.9999% was required for
the POHCs in each dioxin listed waste
that was fed to the incinerator
The delisting critena for incinerator ash
was set at 0 004 parts per tnllion for
dioxins
• The two trial bums conducted at Vertac
were designed to operate the incineration
system at conditions that would reflect worst
case destruction and removal of all
constituents of concern
Hexachlorobenzene was selected as the
POHC for both trial bums The reported
ORE for hexachorobenzene is included in
Table 4.
• The incinerator at Vertac operated within the
operating limits established during the tnal
bum, signifying that all cleanup
requirements established were met
The AWFCOs and each parameter's
respective percentage of the total
number of cutoffs during the operation
of the incinerator are shown in Table 5
Values for operating parameters during
the trial bum are shown in Table 6
Information on the values of these
parameters during post-tnal bum
operation was not available
Table 4. A
Destruction and Removal
from the Second Trial Bum 16
U 8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Watt* and Emergency Rttponse
Technology Innovation Offlct
258
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Vortac Chemical Corporation Superfund Site
TREATMENT SYSTEM PERFORMANCE (CONT.)
Table 5. Automatic Waste Feed Cutoffs [7,11]
Minimum stack gas O, concentration
Maximum stack gas CO concentration (O 7% oxygen)
MMmum kttn exit temperature
Minimum SCO extt temperature
MWmum Win draft
MHmum SCO draft
Minimum scrubber Iqrfd pH
Maximum stack gas flow rate
MWmum Venturi scrubber pressure differential
Minimum brine flow to spray dryer
87%
SOppm
1,604'F
2^04'F
0 015 Inches w.c
0015 Inches we
26
29,750 acfm
210 inches we
no flow
75
4
3
B
7
4
1
<1
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Vertoe Chemical Corpontion Sup. /unc/Sfte
TREATMENT SYSTEM COST
ADPC&E contracted with MRK Industries to
acquire and operate the Incinerator at the
site When EPA took responsibility for the
site in 1993, they contracted with URS
Consultants, Inc. (now URS Greiner) to
provide oversight at the Vertac site
ADPC&E initially managed the Vertac
site using the $10.7 million which was
provided by the established trust fund
and letter of credit When this money
was exhausted, EPA took over
management of the site [3].
The actual cost of on-ate incineration of
$31,700,000 was reported in terms of
capital costs and operation and
maintenance costs. The actual capital costs
for the incineration system were
approximately $21,000,000 and actual
operation and maintenance costs totaled
approximately $10,700,000 for 32 months of
operation. A total of 9,804 tons of still-
bottom waste and soil were incinerated
This corresponds to a total unit cost for
incineration of $3,200 per ton.
Coat Pate Quality
• Actual capital and operations and
maintenance cost data are available
from the treatment vendor and EPA for
this application
OBSERVATIONS AND LESSONS LEARNED
The high cost per ton of waste incinerated
was attributed to waste feed limitations
due to the nature of the waste,
specifically, high chlorine content and low
PH[8]
The contract cost of incinerating the 2,4,5-
T waste off-site was $2/lb of dioxm waste
The total cost amounted to approximately
$4,000,000 for 1,200 tons Of 2,4,5-T
waste [11]
• The variable nature of the waste feed
slowed the incineration project The
inconsistency of the waste and the
difference in heat content between the
solid and liquid phases of waste,
necessitated constant adjustment of the
feed rate
• Electrical surges caused unexplained
shutdowns of the Incinerator. Surge
Publle Invoh/MMnt
suppressors were installed to the
input/output racks of the incinerator
control system Following installation, the
number of shutdowns were reduced [12]
Originally, calcium hydroxide solution was
used as the neutralizing agent in the
APCS However, the subsequent calcium
chloride residual in the brine solution
which was recirculated through the APCS,
clogged the spray drier Therefore the
neutralizing agent was changed to sodium
hydroxide, which did not cause clogging
problems
A video camera was installed in the
shredder to allow operators to detect
potential problems before the shredder
jammed [5].
A second CEM system was installed to
allow daily calibration of the CEMs to
occur without an incinerator shutdown
The second system allowed incineration
to continue uninterrupted during
calibration [5]
U.8. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Weete and Emergency Reeponte
Technology Innovation Office
260
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Vertac Ctomkxl Corporation Superfund Site
The public expressed a great deal of
concern pertaining to the Vertac site Two
temporary restraining orders were filed to
stop the incineration project Theanti-
incineration campaign was led by
Greenpeace and the Government
Accountability Project These groups felt
that the citizens of Jacksonville would be
put at risk from the emissions of the
incinerator The first restraining order was
dissolved after court testimony
substantiating the low-risk involved with
operating the incinerator The second
restraining order temporary prevented
the incineration of the 2,4,5-T waste,
which was later incinerated off site [9].
Pro-incineration groups expressed
concern over the amount of time it was
taking to start the project. These groups
wanted the EPA to start and finish the
project as quickly as possible [9].
1. Vertac Incineration Project - Background
and Site History. Provided by U.S EPA,
Region VI.
2 Suoerfund Site Status Summaries.
U.S EPA, "Vertac, Inc.,"
http.//www epa gov/earth1 r6/6sf/vertac,
April 30,1997.
3 Superf und Record of Decision. Vertac,
Incorporated, Jacksonville, Arkansas, June
1993
4. Action Memorandum. Request for Approval
of Non-Time Critical Removal Action Ceiling
Increase for the Vertac Chemical Core Site.
Jacksonville. PulasM County. Arkansas.
April 7,1992
5. Petition for a Regulatory Amendment and
Exclusion for Four Waste Byproducts at the
Vertac Site in Jacksonville. Arkansas.
Arkansas Department of Pollution Control &
Ecology.
6. Report on Trial Bum Testing. Clean Air
Engineering, Decembers, 1991
7. Impact of Reducing the Vertac Site
Contractors fVSC} Incinerator Stack Oxygen
Interlock Level at the Vartac CERCLA
Incinerator Located in Jacksonville.
Arkansas. Draft. URS Consultants,
October 15,1994.
8 Personal Communication, Mr Rick
Ehrhart, March 18,1997.
9. Personal Communication, Mr Rick
Ehrhart, Apnl 1,1997
10. Risk assessment for Vertac Off Site
Residents as Impacted bv Burning
Hazardous Waste on Vertac Site.
Texas/Oklahoma Remedial Section,
Suoerfund Branch, Hazardous Waste
Division, U.S EPA, June 24,1993.
11 Personal Communication, Mr Rick
Ehrhart, June 30,1997
12 Vertac Project Operations Closure
Report. URS Consultants, Inc, June
1997.
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of SoHd Wait* and Emergency Response
Technology Innovation Office
261
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