vvEPA
                      United States
                      Environmental Protection
                      Agency
                            Office of Water &
                            Waste Management
                            Washington, D.C. 20460
SW - 908
January 1981
 Hazardous  Waste  Facilities
 Standards  for  Incinerators
                       A  Summary of the  Regulations
       Standards and
  Permit Requirements
          for Owners
        and Operators
  of Hazardous Waste
            Facilities
  The Resource Conservation and Recovery Act of 1976 (RCRA) calls
  for a national program to control hazardous waste.  All wastes identified
  as hazardous m the regulations issued under Subtitle C of RCRA Ire
  tracked by manifests from where they originate to their final disposition

  Al±vC1/i^^
  Agency (EPA) or an authorized State to treat, store, or dispose of
  waste  Regulations for carrying out Subtitle b of RCR^i

  to 124) TL°i H  1*; Re^lations (4° CFR Parts 260 to 266 and 122
  19, 1980.           hazardous waste program became effective November


    One portion of the EPA regulations covering owners and operators
 of hazardous waste facilities sets standards for incinerators. These
 facilities are covered by two types of standards:

    •   general requirements for all hazardous  waste management facilities

    •   specific requirements for the various types of facilities

    The regulations covering hazardous waste management facilities

  h?^rn|AmCmerat0r/' apply t0 two types of facilities operating under
 the RCRA program for controlling hazardous waste:

    *  ^°f with Interim, gatua. These facilities were in existence
      «£ iNovember i», iy80 (the effective date of the regulations).
      They have notified EPA of their hazardous waste  activities and
      have applied for a permit, though processing of their applications
      has not been completed.  During the processing period  they
      T™ 0T£lyeWith mterim stat"s Standards set forth in Part 265
      of Title 40 of the Code of Federal Regulations. These selected
      minimum requirements will move their operations toward RCRA's
     .goal of protecting human health and the environment.

   *  those with a permit, either from EPA or a State authorized to
      permit hazardous waste management facilities under RCRlT"
      7De?9^1UtLe.SZnUSt conW Wltn «ie General (Permit) Standards
        ,  A £''• -whlfh are intended to ensure accomplishment of RCRA's
      goal. All new facilities are covered by the General Standards.

   In January 1981, EPA is establishing regulations covering several
aspects of incinerator operations:

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     Applicability
INTERIM STATUS
     STANDARDS
            Waste
          Analysis
          Operating
      Requirements

     Monitoring and
          Inspection
  •  Interim Status Standards in final form. To allow the public to
     comment, they were promulgated on an interim final basis on
     May 19 1980. They became effective on November 19, iy»u.
     Minor technical and reorganizational changes were made, and
     the applicability provision was clarified to include exemptions
     for ignitable wastes (Part 265).
  •   General Standards on an interim final basis. They will be effective
      in July 1981 (Part 264).
  •   information required for Part B of a permit application for an
      incinerator and criteria for trial burn permits, on an interim
      final basis (Part 122)
   •  a regulatory proposal, on which public comment is sought, to
      modify the General Standards to allow a variance in acceptable
      incinerator emissions (Section 264.343)

   This document summarizes the major features of the incinerator
regulations established in January 1981.

   The Interim Status and General Standards apply to incinerators treating
hazardous waste, except those that are hazardous solely because of
SSy   Also, combustion of wastes primarily for recovery of  their
SStenrtconsidired incineration and so is exempt from these standards.

   The Interim Status Standards require the owner or operator of an
incinerator to analyze a new waste to establish normal Steady state)
operating conditions (including waste feed, aux liary waste , feed .and
air flow) and to determine the type of pollutants that might be emitted.
At a minimum, the analysis must determine:

    •  heating value
    •  content of  halogens (chlorine, fluorine,  bromine, iodine) and sulfur

    •  lead and mercury concentration (unless written, documented
       data show that the element is not present)

    Results of the analysis must be placed in the operating record.

          the incinerator is being started up or shut down, hazardous
                              incinerator is at normal operating  conditions.
     The following monitoring and inspections are required:
     •  instruments that relate combustion and emission control (for
        example, those measuring waste feed, air flow, and temperature)
        must be monitored at least every 15  minutes.
     •  Color and opacity of the stream (smokestack) plume must be
        observed visually at least every hour.
     .  The complete incinerator and associated equipment (for example,
        niimos valves  conveyors, and pipes  must be inspected at least
        ^££StiS$a*«***#&*e fissions -J^^g-ey
        shutdown controls and system alarms must be checked to assure
        proper operation.

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GENERAL (PERMIT)
       STANDARDS

               Waste
             Analysis
     Principal Organic
           Hazardous
         Constituents
         Performance
           Standards
    Corrections must be made immediately when problems are detected.

    When an incinerator is closing, all hazardous waste (including ignitable
 waste) and hazardous waste residues (for example, ash and scrubber
 sludges) must be removed from the incinerator site.  At closure, as through-
 out the operating period, any residues that are hazardous must be managed
 within the RCRA system.

    Under the General Standards, required analysis takes two forms.

    •   Each waste feed must be analyzed as part of each permit application
       and whenever a permit is modified or a trial burn permit is sought.
       (Waste feed,  rather than waste as received, must be analyzed,
       since wastes  are often mixed before combustion.)  Certain physical
       properties of the waste feed must be described, and the analysis
       must identify the presence of any hazardous organic constituents
       listed in Appendix VIII of Part 261 of the RCRA regulations.

   •   Throughout normal operation, the owner or operator must ensure
       that the waste feed does not deviate from that defined in his
       permit.

   For each waste feed, the permit will specify Principal Organic Hazardous
Constituents (POHCs) that must be destroyed or removed as required
by the performance  standards.  POHCs are selected primarily on the
basis of how hard they, are to incinerate, but their concentration in the
waste feed is also considered.

   Three performance standards are at the heart of this regulation.
The most important  is:

   •  An incinerator must achieve a destruction and removal efficiency
      (ORE) of 99.99 percent for each POHC designated for each waste
      feed.

         This standard allows an incinerator facility credit for removal
      of pollutants in air pollution control equipment as well as for
      destruction in a combustion zone, and it avoids the technical
      difficulties of precise measurements within the extreme conditions
      of the combustion zone.  The standard still protects the environment
      because it covers all emissions before their release and because
      the residues trapped by emission control equipment must still
      be treated as  hazardous wastes and managed properly within
      the RCRA system.

         There are  limits to the DRE approach:

         — It is difficult to apply to metals because they are not destroyed
            by combustion.

         — It fails to describe the actual amount of POHCs emitted.

         — It does not account for products of incomplete combustion,
            which may be equally or more hazardous than the POHCs
            themselves.

        To deal with these problems, EPA is proposing a set of procedures
      (discussed later, in this summary) for varying this performance
      standard.

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 New Wastes
    Operating
Requirements
Monitoring and
     Inspection
   The two secondary performance standards are:
   •  An incinerator burning hazardous waste containing more than
      0.5 percent chlorine must remove 99 percent of the hydrogen
      chloride from the exhaust gas.
   •  An incinerator burning hazardous waste must not emit particulate
      matter exceeding 180 milligrams per dry standard cubic meter.

   The three performance standards would be difficult to monitor on
a continuous basis. For this reason, the regulation will be enforced
on the basis of compliance with operating conditions (specified in a
permit) that have been shown to achieve the performance standards.
EPA can modify, revoke, or reissue a permit if tests indicate that the
operating conditions fail to achieve the performance standards.

   Each permit specifies the waste feeds it allows and the operating
conditions required for each. For all other waste feeds, the owner or
operator must:
   •  obtain a new permit or permit modification by demonstrating
       the operating conditions needed to achieve the performance standards

   •  obtain a temporary trial burn permit

   Each permit sets limits, on a case-by-case basis, for certain operating
conditions and may set any additional conditions needed to meet the
performance standards.  The required conditions are:
   •  carbon monoxide (CO) level in the stack exhaust gas

   •  waste feed rate
   •  combustion temperature
    •  air feed rate to the combustion system
    •  allowable variations in incinerator system design or operating
       procedures

    Three other operating requirements will be applied uniformly:
    •  During start-up and shut-down of an incinerator, hazardous waste
       (except ignitable waste) can be fed only if the incinerator is at
       normal operating conditions.
    •  Fugitive emissions from the combustion zone must be controlled
       by:
       —  totally sealing the combustion zone, or
       —  maintaining a combustion zone pressure lower than atmospheric
           pressure.
     «  A system  must be available for automatically shutting off waste
       feed when operating requirements are violated.

     The following variables  must be monitored continuously when hazardous
 waste is being incinerated:
     •  combustion temperature,  waste feed rate, and air feed rate.
        These variables most significantly affect the destruction and
        removal efficiency and are readily controllable.

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  INCINERATOR
      FACILITY
      PERMITS
     PROPOSAL
OF ADDITIONAL
      GENERAL
   STANDARDS
   •  carbon monoxide downstream of the combustion zone and prior
      to release to the atmosphere.  This is the simplest procedure
      for determining that combustion is adequate.

   Daily inspection is required of the incinerator and associated equipment
(for example, pumps, valves, conveyors, and pipes).

   At closure, the owner or operator must remove all hazardous waste
(including ignitable waste) and hazardous waste residues (for example,
ash and scrubber sludges) from the incinerator site. At closure, as
throughout the operating period, any residues that are hazardous must
be managed within the RCRA system.

   The regulations covering the permitting process are being expanded:

   •  The contents of Part B of the permit application have been expanded
      to specify the particular information needed for incinerator facilities.

   •  The title of the section on Emergency  Permits has been changed
      to Short-Term Permits, and a new subsection has been added.
      The subsection describes procedures and standards for obtaining
      a permit for a trial burn to gather data needed to apply for a
      permit. Because trial burns are generally of limited duration,
      the permitting process has been simplified, where the standards
      ensure that the trial burn will be carried out in a manner that
      protects human health and the environment.

   EPA is proposing the following modifications to the performance
standards for permitted incinerators:

   •  Combustion by-products formed from POHCs must be destroyed
      so that their total mass emission rate from the stack is no more
      than 0.01 percent of the total mass feed rate of  POHCs.
   •  The EPA Regional Administrator may, on a case-by-case basis,
      set an emission rate of POHCs or  hazardous combustion by-products.
      This may be more or less restrictive than the normal performance
      standard. The variance is  to be based  on an assessment of the
      risk to human health or the environment.
   •  The Regional Administrator may,  on a case-by-case basis, set
      limits on mass emission rates of metals, hydrogen halides, and
      elemental halogens, if needed to protect human health or the
      environment.

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      Major Features   40 CPE Parts 264/265, Subpart O
Where to Find Them
   in the Regulations
Applicability (Sections 264.340, 265.340)
Waste Analysis (Sections 264.341, 265.341)
Principal Organic Hazardous
      Constituents (POHCs) (Section 264.342)
Performance Standards (Section 264.343)
New Wastes: Trial Burns or
      Permit Modifications (Section 264.344)
Operating Requirements (Section 264.345)
General Operating Requirements (Section 265.345)
Monitoring and Inspections (Sections 264.347, 265.347)
Closure (Section 264.351)
Closure (Interim Final) (Section 265.351)
                        40 CFR Part 122
                        Contents of Part B (Section 122.25(b))
                        Short-Term Permits (Section 122.27)

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