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: ------- 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. ------- Closure 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. ------- 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. ------- Closure 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. ------- 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) ------- |