United States
Environmental Protection
Agency
Office of Solid Waste
Washington, D.C. 20460
530R92011
Boilers and Industrial Furnaces
&EPA
Technical Implementation Document
for EPA's Boiler and Industrial
Funace Regulations
2 4 1992
OF
ui
Waste Management Division
U.S. EPA. REGION V
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TECHNICAL IMPLEMENTATION
DOCUMENT
FOR EPA's
BOILER AND INDUSTRIAL FURNACE
REGULATIONS
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 20460
March 1992
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ACKNOWLEDGEMENTS
This document was developed by the Office of Solid Waste, U.S. Environmental Protection Agency,
under the overall direction of Mr. Roben Holloway and Mr. Shiva Garg of the Waste Management Division.
Radian Corporation provided contractual support aad prepared the document with contributions from Energy
and Environmental Research Corporation (EER), Midwest Research Institute (MRI), and LVW Associates.
Major contributors were Lori Stoll, Carla Schultz, Mindy Wood, Susan Olinger, Susan Templeman, Hans
Tandon, Kim Cook, Nancy Grotenhuis, and Barbara Gillen (Radian), Wyman Clark (EER), Beth Rice (MRI),
and Leo Weitzman (LVW). Special thanks are extended to Beth Antley, Cathy Massimino, Gary Gross, Y J.
Kim, Ruben Casso, Joe Galbraith, Sonya Sasseville, and Jawad Touma for their valuable comments and
contributions.
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TABLE OF CONTENTS
Pagt
1.0 INTRODUCTION 1-1
1.1 Purpose and Objectives 1-1
12 Overview of the BIF Rule 1-1
1.2.1 Applicability 1-1
122 Interim Status Compliance Schedule 1-2
123 Exemptions 1-2
123.1 Small-Quantity Burners (SQBs) 1-2
1232 Smelters 1-3
1233 Coke Ovens 1-3
123.4 Precious Metals Recovery Furnaces 1-3
12.4 Summary of the Regulations 1-3
1.2.4.1 Emissions Standards 1-4
1.2.4.2 Operating Requirements 1-5
12J Sham Recycling Policy 1-6
l.i.6 Direct Trec:sfer Operatic^1 16"
12.7 Management of Residue 1-6*
2.0 DETERMINATION OF ALLOWABLE EMISSION RATES 2-1
2.1 Organic Emissions Controls 2-1
2.1.1 PIC Controls 2-1
112 Alternative HC Limit 2-1
2.13 Diorin and Furan Controls 2-2
2.1.4 DRE for Organics 2-2
22 Metals and CL./HC1 Emission Controls 2-2
23 Risk Assessment Procedures ._ 2-3
23.1 Maximum Exposed Individual (MEI) 2-3
232 Risk-Specific Doses (RSDs) for Carcinogens 2-3
233 Reference Air Concentrations (RACs) for Noncarcinogens 2-5
2.4 Tier I and Tier D Emission Limits for Metals, HO, and dj 2-6
2,4.1 Facilities Ineligible to Use Tier I and Tier D Screening
Limits 2-7
2.42 Bubble Approach for Multiple Stacks 2-7
2,43 Calculation of Terrain-Adjusted Effective Stack Height 2-7
2J Tier ID Emissions Limits 2-8
25.1 Hazardous Waste Combustion Air Quality Screening
Procedure (HWCAQSP) 2-9
252 Site-Specific Air Dispersion Modeling 2-9
152.1 Screening-Level Modeling 2-10
1522 Refined Modeling 2-11
153 Compliance Demonstration Based on Dispersion Modeling 2-14
16 Adjusted Tier I Feed Rate Limits 2-16
3.0 PRECOMPLIANCE CERTIFICATION ACnVTTIES 3-1
3.1 Identification of Key Operating Parameters 3-1
32 Determination of Operating Conditions 3-3
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TABLE OF CONTENTS (Continued)
Page
32.1 Precompliance Operating Limits 3-3
32.1.1 Maximum Feed Rate of Each Hazardous Metal 3-3
32.12 Maximum Combined Feed Rate of Chlorine in
All Feed Streams 3-3
3.2.13 Maximum Combined Feed Rate of Ash in All
Feed Streams 3-3
3.2.1.4 Maximum Hazardous Waste Feed Rate 3-3
32.1.5 Maximum Production Rate 3-4
322 Other Parameters to be Considered During Precompliance 3-4
322.1 Maximum Combustion Chamber Temperature 3-4
3.22.2 Maximum Flue Gas Temperature Entering the
PM Control Device 3-4
33 Estimation of Allowable Emissions 3-4
3.4 Estimation of Actual Emissions 3-5
3/ Use of Engineering Judgment to Estimate Partitioning and
APCS RE Values 3-5
3.- Options When Estimated Emission Rates Exceed
Allowable Levels 3-6-.
3.5 Certification of Precompliance 3-6l
3.6 Precompliance Procedures for Furnaces that Recycle Collected PM 3-6
3.7 Precompliance Procedures for Furnaces that Feed Waste at
Locations Other Than the Hot End 3-7
3.8 Public Notice and Maintenance of Correspondence File 3-7
3.9 Post-Precompliance Certification Activities 3-7
3.9.1 Continuous Monitoring 3-7
3.92 Waste Analysis 3-7
3.93 Maintenance of Operating Records 3-8
3.93.1 Engineering Records 3-8
3.932 Operating Records 3-8
3.10 Revision of Precompliance Certification 3-8
4.0 COMPLIANCE INSTRUMENTS AND MONITORING REQUIREMENTS 4-1
4.1 Continuous Emissions Monitoring 4-1
4.1.1 Performance Specifications 4-1
4.1.1.1 CO and Oj Monitors 4-1
4.1.1.2 HC Monitors 4-1
4.12 Data Corrections and Reporting 4-3
4.13 Monitoring of CO and O, in the Bypass Duct 4-3
42 Process Monitoring 4-4
42.1 Waste Feed Rate 4-4
42.1.1 Solid-Sludge Feeds 4-4
42.12 Liquid Feeds 4-5
42.13 Gaseous Feeds 4-5
422 Combustion Temperature 4-5
422.1 Thermocouples 4-5
4222 Optical Pyrometers 4-7
423 Production Rate 4-7
42.4 Flue Gas Temperature Entering the PM Control Device 4-7
42.5 APCS Operating Parameters 4-7
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TABLE OF CONTENTS (Continued)
Page
42.6 Flue Gas Flow Rate 4-7
4.2.6.1 Pressure Drop Across Flow Restriction 4-9
42.6.2 Combustion Air Velocity 4-9
42.63 Combustion dumber Pressure 4-9
42.6.4 Fan Conditions 4-9
43 Automatic Waste Feed Cutoffs and Pre-AJarms 4-9
43.1 Requirements for Automatic Hazardous Waste Feed
Cutoff 4-9
432 Recommendations for Pre-Alarm Systems 4-10
432.1 Objectives of a Pre-Alarm System 4-10
4322 Candidates for Pre-Alarm Parameters 4-10
4.4 Data Logging/Recording 4-12
5.0 COMPLIANCE CERTIFICATION ACTIVmES 5-1
5.1 Compliance Schedule 5-1
5.2 Preparation of the Compliance Test Plan 5-1
52.1 Objective of the Test 5-:
522 Notification of Planned Compliance Test 5-1.
523 Test Design 5-3-
523.1 Number and Duration of Tests 5-3
5232 Operating Conditions 5-3
5233 Feed Rates 5-9
523.4 Metals Spiking 5-9
5233 Preconditioning and Steady State Operation 5-12
523.6 Burning Low-Heating Value Hazardous Waste 5-12
523.7 Operating Modes 5-12
523.8 Conflicting Parameters 5-13
523.9 Soot Blowing 5-14
52.4 Testing Under the Alternative Metals Approach 5-14
523 Data in Lieu of Testing 5-15
52.6 Sampling and Analysis Procedures 5-16
52.6.1 Wastes, Fuels, and Raw Materials 5-16
52.62 Stack Samples 5-20
52.7 Quality Assurance/Quality Control 5-23
52.7.1 QA and QC Objectives 5-23
52.72 Sampling and Monitoring Procedures 5-23
52.73 Sample Handling, Custody, and Holding Times 5-23
52.7.4 Specific Calibration Procedures and Frequency 5-23
52.73 Analytical Procedures 5-23
52.7.6 Specific Internal QC Checks 5-25
52.7.7 Data Reduction, Validation, and Reporting 5-25
52.7.8 Routine Maintenance Procedures and Schedules 5-25
52.7.9 Assessment Procedures for Accuracy and
Precision 5-25
52.7.10 Audit Procedures, Corrective Action, and QA
Reporting 5-26
52.8 Personnel 5-26
52.9 Scheduling 5-26
52.10 Compliance Test 5-26
iii
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TABLE OF CONTENTS (Continued)
Page
53 Determination and Certification of Interim Status Operating Limits 5-26
53.1 Sample Calculations 5-29
532 Compliance Certification 5-29
5.4 Options in the Event of Noncompliance 5-29
5.4.1 Automatic 12-Month Extensions 5-29
5.42 Case-by-Case Extensions 5-30
5.43 Closure 5-30
6.0 POST-COMPLIANCE CERTIFICATION ACTIVITIES 6-1
6.1 Waste Analysis 6-1
62 Inspections, Calibrations, and Equipment Maintenance
Requirements 6-1
62.1 Continuous Emission Monitoring Systems 6-1
622 Automatic Waste Feed Cutoff Systems 6-2
623 Fugitive Emissions Systems 6-2
63 Recordkeeping '. 6-3
6.4 Periodic Recertification and Revised uertitication of Compliance
Requirements 6-4
7.0 SPECIAL REQUIREMENTS FOR BOILERS AND INDUSTRIAL FURNACES
FEEDING HAZARDOUS WASTE AT LOCATIONS OTHER THAN THE HOT END7-1
7.1 Special Requirements 7-1
7.1.1 HC Monitoring 7-1
7.12 Temperature Control at Feed Location 7-1
7.13 Determination of Adequate Oxygen for Combustion 7-2
7.13.1 DRE Trial Burns to Demonstrate Adequate
Oxygen 7-2
7.132 Measurements and/or Calculations to
Demonstrate Adequate Oxygen 7-3
7.1.4 Feeding of Hazardous Waste Directly into Cement Kilns 7-3
7.2 Criteria for Burning Hazardous Waste Solely as an Ingredient 7-3
72.1 Concentration of Nonmetal Constituents in the Waste 7-3
722 Heating Value of The Waste 7-4
723 Use of the Waste as a Raw Material Substitute 7-4
73 Precompliance Certification 7-4
8.0 METALS COMPLIANCE ALTERNATIVES FOR FAOLmES THAT RECYCLE
COLLECTED PARTICULATE MATTER 8-1
8.1 Kiln Dust Monitoring 8-1
8.1.1 Determination of Precompliance Limits 8-2
8.12 Determination of Compliance Limits 8-2
8.13 Calculation of Kiln Dust Metals Concentrations Limits 8-3
8.1.4 Continued Compliance During Interim Status 8-3
8.1.5 Using the PM Emissions Limit in Lieu of Dust
Concentration Limits 8-4
82 Semicontinuous Stack Sampling Emissions Testing 8-6
83 Preconditioning Before Emissions Testing 8-7
8.4 Using Different Metals Compliance Alternatives 8-7
8.5 Special Concerns 8-8
iv
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TABLE OF CONTENTS (Continued)
Page
8.5.1 Metals Emissions from Bypass Sucks 8-8
8.5.2 APCS Main and Bypass Considerations for Sharing the
Same Suck 8-8
9.0 ALTERNATIVE HYDROCARBON LIMIT FOR CEMENT KILNS 9-1
9.1 Requirements for the Part B Permit Application 9-1
92 Determination of Baseline HC Emissions 9-2
9.2.1 Definition of Normal Operations 9-2
92.1.1 Normal Raw Materials 9-2
9.2,1.2 Normal Fuck 9-2
9.2,13 Normal Products 9-3
9.2.1.4 Normal Operating Conditions 9-3
922 Test Protocol 9-3
923 Determination of Baseline Levels from Test Dau 9-4
93 Demonstration of Design and Operation to Minimize HC
Erai- 9-4
9.4 Mouito.,.. 2 '• --'L •£*- i- Baseline HC Levels 9-5
9.5 Emissions Testing During the Trial Burn 9-5
9.5.1 Determination of Baseline HC Levels 9-5 •
9.5.2 Demonstration that Emissions Do Not Exceed Baseline
Levels When Burning Waste 9-5
9.53 Determination of Toxic Organic Emissions and Risk
Assessment 9-5
9.6 Requirements for Interim Status 9-6
10.0 PERMITTING 10-1
10.1 Introduction 10-1
10.1.1 Existing Facilities 10-1
10.12 New Facilities 10-6
102 Overview of Permitting Procedures 10-6
102.1 Existing Facilities 10-6
102.1.1 Submission of the Permit Application 10-6
102.12 Review of the Permit Application 10-6
102.13 Performance of the Trial Burn 10-7
102.1.4 Tentative Permit Determination 10-7
102.1.5 Public Comment on Tentative Permit
Determination 10-7
102.1.6 Final Permit Determination 10-7
1022 New Facilities 10-8
1022.1 Submission of the Permit Application 10-8
10222 Review of the Permit Application 10-8
10223 Tentative Permit Determination 10-8
1022.4 Public Comment on Tentative Permit
Determination 10-8
1022.5 Permit Determination 10-8
1022.6 Performance of the Trial Burn and Final
Operating Conditions Determination 10-9
103 Preparation of a RCRA Permit Application 10-9
10.4 Preparation of the Trial Burn Plan 10-10
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TABLE OF CONTENTS (Continued)
Page
11.0
12.0
10.4.1 Restrictions on Operating Conditions During
Precompliance, Compliance, and Permit Periods 10-10
10.42 Conflicting Parameters and Test Design 10-10
10.43 POHC Selection 10-13
10.5 Extrapolation/Interpolation of Metals Emissions Data 10-14
10.5.1 Theoretical Background 10-14
10.5.2 Extrapolation to Different Feed Rates 10-17
10.5.3 Interpolation to Different Feed Rates 10-17
10.6.1 Low Risk Waste Exemption 10-20
10.62 Waiver of DRE Trial Burn for Boilers Operating Under
Special Requirements 10-21
10.63 Data Submitted in Lieu of Trial Burn 10-22
MANAGEMENT OF RESIDUE 11-1
11.1 Residue Excluded Under the Bevill Amendment '' '
11.1.1 Part One of the Bevill Test
11.12 Part Two of the Bevill Test • *_
11.2 Sampling of Residue 11-2;
113 Analysis of Residue 11-2
REFERENCES 12-1
Appendix A: DESCRIPTION OF DEVICES SUBJECT TO BIF REGULATIONS
Appendix B: SAMPLE PRECOMPLIANCE CERTIFICATION FORMS
Appendix C: SAMPLE COMPLIANCE TEST NOTIFICATION FORMS
Appendix D: SAMPLE CERTIFICATION OF COMPLIANCE FORMS
Appendix E: ALTERNATIVE METALS IMPLEMENTATION FOR FURNACES
THAT RECYCLE COLLECTED PARTICULATE MATTER
Appendix F: SAMPLE FORM TO REQUEST A TIME EXTENSION TO COMPLY
WITH THE HC STANDARD
Appendix G: WORKSHEETS
Appendix H: THERMAL STABILITY rNONERABUJTY RANKING
VI
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LIST OF FIGURES
Page
5-1 Options in the Event of Noncompliance 5-2
10-1 Typical Relationship Between Metals Feed Rate and Emissions Rate 10-15
10-2 Potential Results of Extrapolation of Test Burn Data 10-18
10-3 Potential Effects of Interpolating Between Test Results 10-19
vu
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LIST OF TABLES
2-1 Risk- Specific Doses (RSDs) for Carcinogenic Metals and Reference Air Concentrations
(RACs) for Noncardnogenic Metals, HO, and Clj ............................ 2-4
3-1 Key Precompliance Operating Parameters .................................. 3-2
4-1 Performance Specification Requirements for Continuous Emissions
Monitors [[[ 4-2
4-2 Types of Thermocouples ............................................... 4-6
4-3 APCS-Specific Operating Parameters Which Must be Monitored .................. 4-8
5-1 Contents of the Compliance Test Protocol and QA/QC Plan .................... 5-4
5-2 Key Compliance Operating Parameters ............................ ........ 5-5
5-3 Sample Test Matrix of Sampling and Analysis Parameters
and Methods [[[ 5-17*
* i
5-4 Analytical Methods for Metals in Feed Streams ............................. 5-21
5-5 Analytical Methods for Metals in Stack Samples ............................. 5-24
5-6 Sample Compliance Certification Schedule ................................. 5-27
10-1 Documentation Requirements for Existing and New Facilities with
Newly Regulated BIFs ................................................ 10-2
10-2 Contents of a Trial Burn Plan ......................................... 10-11
10-3 Operating Parameters for Which Limits Are Established During Precompliance,
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LIST OF TERMS
AAS Atomic absorption spectroscopy NSPS
APCD Air pollution control device NTIS
APCS Air pollution control system
ASTM American Society for Testing and NWS
Materials OAQPS
BIF Boiler and bdustrial furnace
Btu British thermal unit PC
CD Calibration drift PCB
CDD Chlorinated dibenzo-p-dioxins PIC
CDF Chlorinated dibenzofurans PM
CE Calibration error POHC
CEM Continuous emissions monitor
CFR Code of Federal Regulations ppmv
Clj Chlorine gas PSD
CO Carbon monoxide
CO2 Carbon dioxide QA
DMCL Dust metals concentration limit QC
DRE Destruction and removal efficiency QA/QC
EF Enrichment factor RA
EPA Environmental Protection Agency RAC
ESP Electrostatic precipitator RCRA
FAA Flame atomic absorption
spectroscopy RE
FID Flame ionization detector RfD
FR Federal Register RSD
GAQM Guideline on Air Quality Models SCRAM BBS
(Revised) (Appendix X to 40 CFR
Part 266)
GEP Good engineering practice SEF
GFAA Graphite furnace atomic absorption SIP
spectroscopy SQB
gr/dscf Grains per dry standard cubic foot SOR
HAF Halogen acid furnace SRE
HC Hydrocarbon SSU
HC1 Hydrogen chloride STAR
HRA Hourly rolling average SW-846
HWCAQSP Hazardous Waste Combustion Air
Quality Screening Procedure
ICP Inductively coupled argon plasma TCDD
emission spectroscopy TCLP
ISC Industrial Source Complex
ISCLT Industrial Source Complex Long TEF
Term Model TESH
IWS Ionizing wet scrubbers
kVA Kilovolt-amperes TOC
KW Kilowatts TSDF
MDL Method detection limit
MEI Maximum exposed individual TSLoO2
NAAQS National Ambient Air Quality
Standard TWA
NFPA National Fire Protection Association UDRI
NOD Notice of Deficiency
New Source Performance Standard
National Technical Information
Service
National Weather Service
Office of Air Quality Planning and
Standards
Pulverized coal
Polychlorinated biphenyl
Product of incomplete combustion
Paniculate matter
Principal organic hazardous
constituent
Parts per million by volume
Prevention of significant
deterioration
Quality Assurance
Quality Control
Quality Assurance/Quality Control
Relative accuracy
Reference air concentration
Resource Conservation and Recovery
Act
Removal efficiency
Reference dose
Risk-specific dose
Support Center for Regulatory Air
Model's Electronic Bulletin Board
System
Safe enrichment factor
State implementation plan
Small-quantity burner
Special operating requirements
System removal efficiency
Saybolt seconds
Stability Array
Test Methods for Evaluating Solid
Wastes: Physical/Chemical Methods.
SW-846. Third Edition (EPA, 1986)
Tetrachlorodibenzo-p-dioxin
Toxicity Characteristic Leaching
Procedure
Toxic equivalence factor
Terrain-adjusted effective stack
height
Total organic carbon
Treatment, storage, and disposal
facility
Thermal stability at low or deficient
oxygen level
Time-weighted average
University of Dayton Research
Institute
IX
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LO INTRODUCTION
1.1 Purpose and Objectives
On February 21, 1991, the Environmental
Protection Agency (EPA) published a final rule
which expands controls on hazardous waste
combustion by regulating the burning of hazardous
waste in boilers and industrial furnaces (the BIF
Rule).1
The BIF Rule controls emissions of toxic
organic compounds, toxic metals, hydrogen chloride,
chlorine gas, and paniculate matter from boilers
and industrial furnaces (BIFs) burning hazardous
waste. In addition, the rule subjects owners and
operators of these devices to permitting and other
standards applicable to hazardous waste treatment,
storage, and disposal facilities. The requirements of
the BIF Rule are described briefly below.
The purpose of this document is to provide
permit writers and owners/operators of BIFs with
technical guidance in implementing the BIF Rule
requirements. The document specifically addresses
certain precompliance and compliance certification
activities, permitting, continued compliance with
operating requirements, and associated planning and
testing required for compliance with the rule. This
document does not address every requirement or
aspect of the BIF Rule, nor does it discuss the
rationale for the requirements. It does not
supersede any of the BIF regulations promulgated
under the Resource Conservation and Recovery Act
(RCRA). Finally, it is not intended to address
facility-specific and process-specific questions as
they relate to the new rules. Owners and operators
of boilers and industrial furnaces that burn
hazardous waste are advised to consult the Federal
Register notices addressing BIF requirements and
the appropriate EPA Regional Office and state, if
additional clarification is
L2 Overview of the BIF Rule
The BIF Rule became effective on
August 21, 1991. Before the rule was issued, BIFs
were exempt from regulation when hazardous waste
was burned for energy or material recovery,
activities occurring before or after burning, such as
storage or transportation of hazardous waste fuels
or residues, however, were regulated.
BIFs are now subject to essentially the
same general facility standards as are other RCRA
treatment, storage, and disposal facilities: the
nontechnical standards of Subparts A-H in Parts
264 and 265, and the air emissions standards under
Subparts AA, BB and CC in Parts 264 and 265.
The emissions standards for BIFs are similar to
those the Agency is applying to hazardous waste
incinerators (when using the omnibus permit
authority to control emissions of metals and
products of incomplete combustion (PICs)). The
BIF Rule requires precompliance and compliance
certifications by existing facilities to document
conformance with all emissions standards (except
the Destruction and Removal Efficiency, or DRE,
standard) during interim status before a RCRA
operating permit is issued. Several types of BIFs
may be exempt from regulation under specific
conditions, and residue from certain facilities may
be excluded from regulation under specific
conditions. Each of these provisions of the rule is
discussed below.
1.2.1 Applicability
Except as
in Section 123 below
and in 1266.100, owners/operators of boilers and
industrial furnaces (as these devices are defined in
40 CFR 1260.10) that burn or process hazardous
waste must comply with the requirements of the
BIF Rule.
'56 FR 7134 (February 21,1991). EPA published uneadments at 56 FR 32688 (July 17,1991), 56 FR 42504 (August 27,1991), and 56 FR
43874 (September 5,1991).
Bff\SECT01.BIF
1-1
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EPA has designated the following devices
as industrial furnaces under 40 CFR $260.10:
cement kilns2; lime kilns; aggregate kilns (e^, light-
weight aggregate kilns, asphalt loins); phosphate
kilns; coke ovens; blast furnaces; smelting, melting,
and refining furnaces; titanium dioxide chloride
process oxidation reactors; methane reforming
furnaces; pulping liquor recovery furnaces;
combustion devices used in the recovery of sulfur
values from spent sulfuric acid; and halogen acid
furnaces. Appendix A of this document provides a
brief characterization and schematic diagram of
industrial furnaces that commonly burn hazardous
waste as fuel or for material recovery. The process,
operation, and H^cign details that characterize a
boiler or industrial furnace are given in (260.10 and
in the preambles to the rules supporting the
ions.
122 Interim Status Compliance Schedule
The BIF Rule requires BIFs operating
under interim status to comply with all emission
standards except the DRE standard. BIFs operating
under interim status must submit a Part B permit
application and will be subject to permitting
requirements under a schedule developed by the
EPA regional office or authorized state. To
implement the emission controls as quickly as is
reasonably possible, the rule establishes a
certification schedule to be followed by
owners/operators of interim status units:
(1) By August 21, 1991, a certification of
precompliance must have been submitted
providing information that emissions of
individual metals, hydrogen chloride (HC1),
chlorine gas (dj), and paniculate matter
(PM) are not likely to exceed allowable
levels; and
(2) By August 21, 1992, or by the applicable
date allowed by an extension under
{266.1Q3(c)C7), a certification of compliance
must have been submitted certifying that,
based on compliance 1***™%, emissions of
individual metals HO, CL, PM, carbon
monoxide (CO), and where applicable,
hydrocarbons and dioxins and furans, do
not exceed allowable levels.
Limits on operating parameters during
interim status are established at certification of
precompliance and at certification of compliance.
If a facility misses any interim status deadline,
hazardous waste-burning operations must cease and
the owner/operator must apply for a Part B permit
in order to resume burning hazardous waste.
Sections 3.0 and 4.0 of this document discuss in
detail precompliance and compliance certification
procedures, respectively.
123 Exemptions
L2J.1 Small-Quantity Burners (SQBs)
The BIF Rule exempts, under specific
conditions, burners of small quantities of hazardous
waste. BIFs burning hazardous waste in quantities
that do not exceed limits specified in the nu>
qualify for the exemption. The quantity limits in
this risk-based exemption are established as a
function of the facility's stack height (see 40 CFR
266.108). The exemption applies only to BIFs
burning hazardous waste fuel at the same facility at
which it is generated, and at no time can the
hazardous waste firing rate exceed 1% of the total
fuel requirements of the device. As amended in the
August 27,1991 Federal Register (56 FR 42510 and
42515), this firing rate limit is based on either a
total heat input or mass input basis, whichever
results in the lower mass feed rate of hazardous
waste.
In addition, a SQB must notify EPA that he
or she claims the exemption and must keep records
to document compliance with the conditions of the
exemption. Sample form SQB-1 in Appendix B of
this document can be used by the owner/operator
(but is not required) to notify EPA of eligibility for
the exemption. If the facility was burning hazardous
waste on or before August 21, 1991, a notification
'Emissions from clinker cooler stacks are not subject to regulation under the BIF Rule because the dinker cooler is a (dinker) product processing
step at a cement production facility. Emission* from the clinker coder would instead be subject to applicable regulations under the Qean Air Act.
1-2
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must have been submitted by August 21,1991. For
facilities not burning hazardous waste before August
21, 1991, the facility must notify EPA before
burning hazardous waste. If the facility had
previously notified EPA of other hazardous waste
management activities, it must re-notify EPA of its
intent to daim the SQB exemption.
The SQB exemption is not related to the
RCRA definition of a small-quantity generator in 40
CFR Parts 261 and 262. A generator of any
quantity of hazardous waste (e^, a large-quantity
generator) may qualify for the SQB exemption as
long as the requirements in §266.108 are met
Part Three, Section X of the preamble to
the February 21, 1991 final rule (56 FR 7189)
provides a detailed discussion of the small-quantity
burner exemption.
L23.2 Smelters
The BIF Rule defers regulation of smelting,
melting, and refining furnaces that burn hazardous
waste solely for legitimate metals recovery. To be
eligible for this exemption, the operator must notify
EPA that he or she claims the exemption and must
document that hazardous waste is burned solely for
legitimate metals recovery. In general, the criteria
for legitimate metals recovery include: (1) the
waste may not contain more than a total of 500 ppm
by weight of Part 261, Appendix vm organic
compounds, as-fired. If so, EPA considers the
waste to be burned at least partially for destruction
(facilities should contact their EPA Regional office
for guidance if there are not SW-846 methods for
any Appendix Vm organic compounds which could
reasonably be expected to be in the waste, or if
there are problems with availability of standards for
any of these compounds); (2) the waste may not
have a heating value excefding 5,000 Btu/Ib, as-
fired (if so, EPA considers the waste to be burned
at least partially for energy recovery); and (3) the
waste must contain recoverable levels of metals (for
further details, see §266.100(c)(l), and Part Two,
Section ED. of the February 21,1991 preamble (56
FR 7142)). (It should be noted that the criteria for
burning wastes in secondary lead smelters and in
nickel chromium recovery furnaces are somewhat
different and are found at 40 CFR 266.100 and in
Appendices XI and XII of Part 266.)
Sludges or by-products exhibiting a
characteristic of hazardous waste are not considered
a solid waste (and by definition are therefore not
considered a hazardous waste) when they are
reclaimed (see 40 CFR 261.1(c)(4) and 26L2(c)(3)).
Furnaces burning or processing these materials are
not regulated under the BIF Rule.
L2J3 Coke Ovens
Coke ovens are exempt from the BIF Rule
if the only hazardous waste they process is K087,
decanter tank tar sludge from coking operations
(see 40 CFR 266.100(b)(4)). In addition, on
September 5, 1991, EPA amended §266.100(a) by^
adding a note to reflect an administrative stay of th<
applicability of the BIF Rule to coke ovens
processing coke by-products or wastes exhibiting the
Toxicity Characteristic of 126124 (see 56 FR
43874). EPA is currently evaluating comments on
a rulemalting proposed on July 26, 1991 that would
continue to exempt coke ovens from the BIF Rule
if other wastes generated by the coke by-products
industry are also burned in the coke ovens (56 FR
35787); once the mfcmalritig fc complete, the
administrative stay on die applicability of the BIF
Rule to coke ovens will no longer be in effect and
the note to f266.100(a) will be removed.
L2J.4 Precious Metals Recovery Furnaces
Precious metals recovery furnaces are
generally exempt from RCRA Subtitle C regulation,
including the requirements of the BIF Rule, with
the exception of certain tracking and recordkeeping
requirements (see 56 FR 42508 (August 27, 1991)
and 40 CFR 266.100(f)). This exemption is more
fully discussed in the August 27, 1991 Federal
Register notice (56 FR 42508).
Summary of the Regulations
Under the BIF Rule, BIFs burning or
processing hazardous waste and operating under
interim status must comply with the requirements of
{266.103. Once permitted, BIF facilities must
comply with the requirements of §266.102. Except
Bff\SECroi.BlF
1-3
-------
for the additional Destruction and Removal
Efficiency (DRE) requirements for permitted
facilities, the requirements for interim status and
permitted facilities are the same. These
requirements include:
• Emission «tanHarH< for particulate matter
(PM), toxic metals, hydrogen chloride
(HC1), chlorine gas (Qj), carbon monoxide
(CO), and in some situations, hydrocarbons
(HC) and dioxins/furans;
rftfl|"rements. including analysis
and feed rate monitoring of all feed
materials (Len hazardous waste, fuels, and
raw materials); feed rate limits on total and
pumpable hazardous wastes and on
hazardous metals, chlorine, and ash;
combustor and air pollution control system
(APCS) operating conditions; continuous
emissions monitors (CEMs); inspections;
operation of an automatic hazardous waste
feed cutoff system; and recordkeeping;
Nontechnical facility stapdar'jk under 40
CFR Parts 264 and 265, Subparts A
through H (e-g, personnel training,
contingency plan, emergency procedures,
closure, and financial requirements); and
gtanHaf js under 40 CFR Parts
264 and 265, Subpart AA (process vents),
Subpart BB (equipment leaks), and
Subpart CC (tanks, surface impoundments,
and containers)1, except for §§264.1050(a)
and 265.1050(a).
1.2.4J Emission Standards
The ^mfa
standards are summarized in
the following subsections. More detailed discussions
are provided ia subsequent sections of this
document.
Particulate Matter Emission Standard-PM
emissions are limited to 0.08 grains per dry standard
cubic foot (gr/dscf), corrected to 7% oxygen (Oz).
Compliance with the PM emission limit must be
demonstrated during both a facility's interim status
compliance test and trial burn for the Pan B RCRA
permit (except under permitting for a facility that
has been granted a low risk waiver under §266.109).
BTPs already subject to a new source performance
standard (NSPS) or other PM limit under the Clean
Air Act are required to meet the more stringent
standard.
Metal Emission Standards-Emissions are
limited for the 10 toxic metals listed in Appendix
vm of 40 CFR Part 261, based on projected
inhalation health risks to a hypothetical maximum
exposed individual (MEI). The standards for the
carcinogenic metals (arsenic, beryllium, cadmium,
and chromium) limit the combined increased
lifetime cancer risk to the MEI from the four
metals to a maximum of 1 in 100,000. The
standards for the noncarcinogenic metals, antimony,
barium, mercury, silver, and thallium, are based on
oral reference doses (RfDs) below which no adverse
health effects have been observed. The standard for.
the noncarcinogenic metal lead is based on the
National Ambient Air Quality Standard for lead. A
discussion of risk assessment procedures is
presented in Part Three, Section in of the preamble
to the February 21,1991 rule (56 FR 7164), and in
Section 23 of this document
The metal emission standards are
implemented through a three-tiered approach.
Compliance with any one of the three tiers is
acceptable. The tiers are structured to allow higher
feed rates or emission rates as an owner/operator
elects to conduct more site-specific testing and
analyses (e-g^ emission testing and dispersion
modeling). Thus, the feed rate or emission rate
limits under each of the tiers are based on different
levels of site-specific information related to facility
design and surrounding terrain. For a more
detailed discussion of the toxic metals emissions
standards and their implementation, refer to Part
Three, Section IV of the preamble to the February
21,1991 final rule (56 FR 7171), and to Section 2.0
of this document
'Although Subpart CC a currently in proposed form (56 FR 33491, July 22,1991), it it anticipated that it will be finalized prior to issuance of any
final BIP permit decisions.
1-4
-------
Industrial furnaces (e.g-, cement kilns) that
recycle collected paniculate matter back into the
furnace must comply with one of three procedures
for testing to determine compliance with the Tier n
or Tier m metals emissions standards under interim
status (see 40 CFR 266.103(c)(3)(u)). These three
alternatives are discussed in Part Three, Sections IV
and YD of the February 21,1991 preamble (56 FR
7176 and 7185), and in Section 8.0 of this document
HC1 and d, Emission Standards-
Emissions of HQ and Q, are controlled under the
same general approach as that used for metals; the
owner/operator must implement and comply with
HC1 and Qj controls in the same manner as that
used for metals (see Part Three, Section V of the
preamble to the February 21,1991 final rule (56 FR
7179), and Section 2.0 of this document).
Controls on Organic Emissions-Organic
emissions are controlled by limiting CO, and in
some instances, HC concentrations, in stack gas
under a two-tiered approach. This approach is fully
explained in Part Three, Section n of the preamble
to the February 21, 1991 final rule (56 FR 7146),
and in Section 2.0 of this document.
For industrial furnaces (e^, cement kilns)
that feed hazardous waste at locations other than
where fuels are normally fired, restrictions are
placed on the feed locations. These restrictions are
fully explained in Part Three, Section lUM.b. of the
preamble to the February 21,1991 final rule, in the
August 27, 1991 amendment (56 FR 42511), and in
Section 7.0 of this document
The BIF Rule requires facilities operating
under interim status to comply with these organic
emission controls by August 21,1992. If a furnace
is unable to achieve the 20 ppmv HC limit by that
date because of organics present at baseline
conditions (i.e., when the facility is designed and
operated to mi™™** HC emissions from raw
materials and fuels while producing normal products
under normal operating conditions, and when no
hazardous waste is burned), the furnace may be
eligible for the case-by-case time extension provided
by §266.103(c)(7)(ii) if certain conditions are
satisfied (see Part Three, Section n of the preamble
to the February 21, 1991 final role (56 FR 7155),
and Section 9.0 of this document).
The BIF Rule also requires facilities that
have dry PM control devices operating at
temperatures between 450*F and 750*F, and
industrial furnaces that have HC emissions greater
than 20 ppmv, to demonstrate that emissions of
chlorinated dioxins and furans will not result in a
increased cancer risk to the MEI.
During the interim status compliance test, emission
rates for all tetra- through octa-congeners must be
determined. Dispersion modeling must be
conducted to predict the exposure to the MEI, and
the resulting increased cancer risk must be less than
1 in 100,000 (see Part Three, Section 0£. of the
February 21, 1991 preamble, and Section 23 of this
document).
As an additional control on organic
emissions, the BIF Rule requires boilers and*
industrial furnaces to comply with the same
Destruction and Removal Efficiency (DRE)
standard currently applicable to hazardous waste
incinerators: 99.9999% DRE for designated organic
hazardous constituents in dicotin-listed wastes, and
9959% DRE for all organic hazardous constituents
in other hazardous wastes. Testing for 99.99%
DRE of organics is not required under interim
status (see Part Three, Section DA. of the February
21, 1991 preamble, and Section 2.1.4 of this
document).
L2A2 Operating Requirements
As discussed in the preamble to the
February 21, 1991 final rule (56 FR 7180), BIF
owners/operators must conduct, during interim
status, certain activities to ensure conformance with
precompliance and compliance certification
requirements. Ret«MU^ing operating parameters
and limits before certifying precompliance is
discussed in Section 3.0 of this document Similarly,
Sections 4.0 and 5.0 of this document address
compliance certification activities, including:
continuous emissions monitoring of CO, oxygen
(Oj), and if required, HC; process monitoring;
operation of automatic waste feed cutoff systems
and pre-alarms; and preparation of compliance test
plans. Discussions on post-compliance requirements
BIF\SECn)l.BIF
1-5
-------
for equipment maintenance and calibration,
inspections of the combustion device and associated
equipment, and recordkeeping activities are
presented in Section 6.0 of this document.
Procedures for BIFs subject to permitting
requirements are discussed in Section 10.0 of this
document
L2.S Sham Recycling Policy
The BIF Rule supersedes EPA's sham
recycling policy (48 FR 11157 (March 16, 1983))
once an owner /operator certifies compliance under
interim status (or receives a RCRA permit) (see 56
FR 7183, February 21, 1991, and §266.103(a)(6)).
Therefore, after interim status compliance
certification, a BIF may burn hazardous waste with
a heating value lower than the 5,000 Btu/lb limit
that was generally considered to be the minimum
limit for a legitimate hazardous waste fuel.
A BIF facility that achieved interim status
as an incinerator or thermal treatment unit and was
operating under interim status standards for
incinerators or thermal treatment units on the
effective date of the rule (August 21, 1991) may
continue burning low-Btu hazardous wastes before
compliance certification (see FR 42504, August 27,
1991). The BIF Rule also allows halogen acid
furnaces (HAFs) that were burning low-Btu
hazardous wastes as an ingredient before February
21, 1991 to continue such burning before
certification of compliance. For clarification on this
HAF provision, see §266.103(a)(6) and 56 FR 42504
(August 27, 1991). Other BIFs cannot burn
hazardous waste with a heating value of lower than
5,000 Btu/lb before compliance certification
except: (1) for up to 720 hours for testing purposes;
and (2) if the waste is burned solely as an
ingredient.
Direct Ifcusbr Operations
Under (266.111, the BIF Rule addresses
the direct transfer of hazardous waste from a
transport vehicle to a BIF without the use of a
storage unit
The direct transfer standards reference
extensively the Subpart I container standards and
the Subpart J tank standards of Parts 264 and 265
and apply equally to facilities operating under a
permit as well as to those operating under interim
status. The regulations address transport vehicle
areas, piping, and other ancillary equipment (termed
"direct transfer equipment" in the BIF Rule) used to
transfer waste from the vehicle to the burner. The
standards include general operating requirements
and controls on equipment integrity, containment
and detection of releases, responses to leaks or
spills, ttetign and installation of new direct transfer
equipment, and closure requirements. General
operating requirements apply to both containerized
and bulk hazardous waste. Direct transfer vehicles
need not comply with the 50-foot setback
requirement, but instead may comply with the
National Fire Protection Association (NFPA) code
regarding setback from the property boundary (see
the February 21, 1991 preamble discussion (56 FR
7195), and the August 27, 1991 amendment (56 FR
42510)).
The Agency encourages facilities to uSe
storage units (e.g-, tanks) rather than direct transfer
operations and considers the addition of such
storage to be an allowable change in interim status
under (270.72 (see preamble discussion at 56 FR
7188, February 21, 1991); however,
owners/operators of facilities located in states that
are authorized to implement RCRA storage
standards should consult with the appropriate state
regulatory authorities.
EPA considers direct transfer operations to
be a part of the hazardous waste firing system, and
not a storage activity. Hence, facilities that are not
subject to the burner standards of §§266.102 (permit
standards) or 266.103 (interim status standards) are
not subject to the direct transfer standards.
L2.7 Management of Residue
The Bevill exclusion (see RCRA section
3001(b)(3)(A)(i-iii)) refers to residues resulting
from burning or processing certain materials
whereby the residues are not considered to be
hazardous waste at t-Hk time because RCRA
requires that EPA conduct a special study to
determine whether they should be regulated as
hazardous waste. The BIF Rule establishes:
Bff\SECTDl.BIF
1-6
-------
(1) criteria to determine whether residues generated
at a BIF are eligible for the Bevill exclusion; and (2)
a case-by-case determination involving a two-part
test to determine whether the exclusion continues to
apply when an eligible device burns or processes
hazardous waste. The applicability of the Bevill
exclusion to combustion residues when BIFs burn or
process hazardous waste and how the case-by-case
determination works is fully «KymfH in Part Three,
Section Xm of the preamble to the
February 21,1991 rule (56 FR 7196), the August 27,
1991 amendment (56 FR 42509), and Section 11.0 of
this document.
BIF\SECn>l.BIF 1-7
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2.0 DETERMINATION OF ALLOWABLE
EMISSION RATES
This section defines the procedures for
determining allowable emission rates for PICs, other
organics, metals, hydrogen chloride, and chlorine. Risk
assessment procedures for organic and metal emissions
are also discussed to orient the permit writer to the
appropriate procedures defined by the BEF Rule.
Finally, an overview of air dispersion modeling
procedures is provided to assist the permit writer in
evaluating applications. The limits established for
compliance with the BIF Rule may not be exceeded. A
source may not operate at rates above the established
limits part of the time in exchange for not operating or
operating at a lower level for the remainder of the year.
This document does not provide guidance in the
application of specific air dispersion models; for more
detailed information, readers should consult the user's
guides for the specific models.
2.1
Ornnic Emissions Controls
The BIF Rule controls organic emissions by
limiting the emissions of products of incomplete
combustion (PICs), principal organic hazardous
constituents (POHCs), and dioxins/furans, where
necessary. These controls are discussed below.
2.1.1 PIC Controls
PIC controls include limits on CO, and, if
necessary, HC emissions. Under the Tier I controls, CO
emissions may not exceed 100 ppmv, and HC emissions
are not limited. Under Tier n, HC emissions are
limited to 20 ppmv, and CO emissions are limited based
on levels demonstrated dnriaf the compliance test
Following i
of continuous emissions
monitoring equipment for CO, all BIFs must
continuously monitor CO emissions from the stack.
Compliance with CO limits is based on an hourly rolling
average (HRA) format, which determines CO emissions
as the arithmetic mean of the 60 most recent 1 -minute
average values recorded by the monitoring system. To
comply with the Tier I CO limit, the BEF cannot exceed
an HRA CO level of 100 ppmv, on a dry gas basis
corrected to 7% O2. CO monitoring equipment and
procedures are discussed in Section 4.0.
If the BIF cannot meet the 100 ppmv Tier I CO
limit, it must continuously monitor both CO and HC
emissions and must demonstrate (except as indicated
below) that the HRA HC level does not exceed the Tier
n HC limit (i.e., is no greater than 20 ppmv measured
as propane, on a dry gas basis corrected to 7% O2). If
the HRA HC level measured during the compliance test
does not exceed the Tier n HC limit of 20 ppmv, HC
emissions during interim status are limited to 20 ppmv.
Emissions of CO under Tier n are limited to the
average of the highest HRA CO values measured during
each valid run conducted during the compliance test.
If the BIF is an industrial furnace which feeds
raw materials containing organic matter and cannot
meet the Tier n HC limit of 20 ppmv, it may be eligible
for the alternative HC limit under §266.104(f) as
discussed below and in Section 9.0. BIF units that
cannot meet the 20 ppmv HC limit and that are not
eligible for the alternative industrial furnace HC limit
must modify their operating procedures or equipment to
reduce HC emissions to the allowable level, or must1"
cease burning hazardous waste under interim status.
2.12 Alternative HC Limit
The BIF Rule requires facilities operating under
interim status to comply with the CO and, if applicable,
HC limits, by August 21, 1992, unless an extension is
granted. Some industrial furnaces, such as cement,
light-weight aggregate, and lime kilns, emit CO levels
greater than 100 ppmv and may not be able to meet the
20 ppmv HC limit allowed under Tier n because of
organics in normal raw materials.
To request an alternative HC limit, a facility
must submit a complete Part B permit application that
contains technical support as required in §266.104(f) for
an alternative site-specific HC limit The application
must include documentation of the baseline HC
concentrations (established by testing) when the facility
is feeding normal fuels and raw materials, not hazardous
waste. The procedures and documentation required for
the alternative HC limit request are discussed in Section
9.0 of this document
If needed, the facility can request a time
extension for compliance certification as described in
§266.103(c)(7)(Li) and §266.104
-------
a decision by August 21, 1992 as to whether to grant the
time extension.
2.1.3 Dioxin and Foran Controls
To control emissions of chlorinated dibenzo-p-
dioxins and dibenzofurans (CDD/CDF) in cases where
the potential for pgniffcant emissions of these
compounds is high, the BIF Rule requires emission
testing and air dispersion modeling to demonstrate that
predicted ground-level concentrations do not result in
exceedances of prescribed levels. The potential for
significant emissions of CDD/CDF exists for boilers or
industrial furnaces operating dry PM control devices at
temperatures of 45CTF to 750*F, and industrial furnaces
operating under the alternative HC limit.
Such facilities must determine the emissions of
all tetra- through octa-congeners of chlorinated dibenzo-
p-dioxins and dibenzofurans during the compliance test.
These test results must then be converted to 23,7,8-
tetrachlorodibenzo-p-dioxin (TCDD) toxic equivalence
factor (TEF) values. Methods for measuring CDD/
CDF concentrations in flue gas and converting measured
values to 23,7,8-TCDD TEF values are presented in
EPA Method 23, 40 CFR Part 60, Appendix A. Using
the 23,7,8-TCDD TEF stack emission rate, air
dispersion modeling must be conducted using any of the
methods described in Section 2J2 to estimate the
maximum annual average off-site ground-level exposure.
The predicted exposure may not exceed an increased
lifetime cancer risk of 1 in 100,000.
2.1.4 DUE for Organics
As an additional control on organic emissions
under the RCRA permit, the BIF Rule requires boilers
and industrial furnaces to comply with the same
destruction and removal efficiency (DRE) standard
currently applicable to hazardous waste incinerators:
99.9999% DRE for
-------
and chlorine emissions achieved either by partitioning of
pollutants to bottom ash or products, or by removal of
pollutants through the facility's APCS. Guidance on
using the Tier n emission limits is provided in
Section 2.4.
Site-specific emissions limits can be determined
under Tier HI by performing site-specific air dispersion
modeling. As with Tier n, compliance is confirmed by
stack sampling. Guidance on using Tier TTT emission
limits is provided in Section 25.
A combination of Tiers I and IE, referred to as
adjusted Tier I, is used to back-calculate maximum
emission rates for the individual metals and HC1/CL
from acceptable ambient levels using site-specific air
dispersion modeling results. These emission rates then
become the adjusted feed rate limits assuming all metals
and chlorine fed to the combustion device partition to
the exhaust gases. Guidance on Adjusted Tier I
emissions limits is provided in Section 2.6.
23 Risk Assessment Procedures
Risk assessment procedures are designed to
limit potential exposure of the hypothetical maximum
exposed individual (MEI) to emissions of carcinogenic
and noncarcinogenic metals, HC1, and Cl, from all
boilers and industrial furnaces burning hazardous waste,
such that:
• Summed risks attributable to ambient exposure
from all carcinogenic metals do not exceed an
additional lifetime risk of 1CT3 to the MEI;
• Exposure of the MEI to noncarcinogenic
metals, HO, and Clj does not exceed reference
air concentrations (RACs) established by the
BIF Rule; and
• Risks attributable to ambient exposure from
toxic organics do not exceed levels established
by the BIF Rule (e-g, risk analyses required by
the low risk waste exemption under permitting
and dioxins/rurans risk assessments).
Facilities that burn or process hazardous waste
intermittently should conduct risk assessment procedures
as if they burn or process hazardous waste seven days a
week. Inherent within these procedures is the
determination of acceptable ambient air quality levels.
The following subsections define three key elements
used in this determination: MEI, risk-specific doses
(RSDs) for carcinogens, and reference air
concentrations (RACs) for noncarcinogens.
2J.1 Maximum Exposed Individual (MEI)
The concept of MEI is used to estimate the
potential cancer risk from direct inhalation of pollutants
emitted from a facility. The MEI is a hypothetical
person assumed to reside at the point of maximum, off-
she, ground-level impact (unless people routinely reside
inside the facility boundary). The MEI is assumed to
weigh 70 kilograms (154 pounds) and to be continuously
exposed (24 hours per day) to contaminants over a
70-year lifetime.
The point of maximum ground-level impact is
determined by air dispersion modeling and is defined as
the point of the maximum off-site annual average*"
ground-level concentration. For facilities with more*
than one hazardous waste combustion stack, the point of
maximum impact, and thus the location of the MEI, may
vary for individual pollutants.
232 Risk-Specific Doses (RSDs) for Carcinogens
Human exposure to a carcinogenic substance,
even at very low concentrations, presents a quantifiable
risk. The risk associated with a particular substance
depends on the carcinogenic potency of the substance
and the duration of exposure. The incremental risk to
an individual exposed to ambient air containing one
microgram of the substance per cubic meter of air over
a 70-year lifetime is defined as the 'unit risk." Under
the BIF Rule, the unit risk is limited to direct exposure
through inhalation.
Dividing the acceptable level of additional risk
to the MEI, (which under the BIF Rule is one cancer
incident per 100,000 people (1 x 10*5)), by the unit risk
of a substance, defines the substance's risk-specific dose
(RSD) in micrograms per cubic meter (Mg/m3).2 Table
2-1 presents RSD values for carcinogenic metals covered
by the BIF Rule. The risk to the MEI from exposure to
a particular carcinogen is calculated by multiplying the
predicted maximum annual average ground-level
concentration of the substance by its unit risk.
BIF\SECT02.BIF
2-3
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Table 2-1
Risk-Specific Doses (RSDs) for Carcinogenic Metals
and Reference Air Concentrations (RACs) for Noncarcinogenic Metals, HC1, and C12
BIF-Regalated Cardnogenk Metal
Arsenic
Beryllium
Cjtitmium
Chromium (hexavalent)
RSDto/m3)
23x10-'
4.1 x Ifr1
5.5 x 10°
83x10-
BIF-Regulated Constituent
Antimony
Barium
Lead
Mercury
Nickel
Selenium
Silver
Thallium (oxide)
Hydrogen Chloride (HC1)
Chlorine Gas (Cl,)
RAC 0*/mJ)
03
50.0
0.09 '
0.08*
20*
4*
3.0
03
7.0
0.4
The Agency's Reference Dose Workgroup revised the inhalation RfD for mercury late in the rulemaking
process. The RAC for mercury was therefore lowered from 03 /Jg/m3 to 0.08 jig/m3. RfDs for nickel and
selenium were finalized after promulgation of the BIF Rule. These RfDs were convened to RACs by
applying the equation in the proposed BIF Rule (54 FR 43756, October 26, 1989). The RACs for these
metals may be implemented under omnibus authority for permitted facilities.
2-4
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The RSDs are used to assess whether cancer
risks from exposure to stack emissions are excessive.
Risks are considered acceptable if the estimated risk to
the MEI is less than or equal to the RSD (i.e., the ratio
is less than or equal to 1.0). These ratios are summed
for all carcinogens, and the summed ratio must be less
than or equal to 1.0, since the effects of more than one
carcinogen are considered to be additive. For
carcinogenic metals that are not detected in the feeds
(and are therefore not targeted for analysis in
emissions), and for carcinogenic metals that are not
detected in stack emissions, the emissions method
detection limit must be used in calculating the summed
risk, and subsequently, in establishing feed rate limits for
the remaining carcinogenic metals.
For the BIF Rule, all chromium emissions are
considered to be in the hexavalent form unless the
owner/operator conducts site-specific emission testing
using the hexavalent chromium test method (described
in 40 CFR Part 266, Appendix DC).
2J3 Reference Air Concentrations (RACs) for
Noncardnogens
For toxic substances not known to display
carcinogenic properties, there is assumed to be an
exposure threshold (the reference dose (RfD)) below
which adverse health effects do not occur. Protection
against adverse health effects from a noncarcinogenic
substance is achieved by preventing exposure to levels
exceeding the RfD for that substance.
Because sources other than the controlled
source (for example, diet) may contribute to exposure,
RACs have been established for noncarcinogenic
substances as a fixed fraction of the RfD (with the
exception of HC1 and G^ for which background levels
are considered insignificant). RACs are reference air
concentrations converted from reference doses (mg/kg-
day) using the conversion equation presented in the
October 26, 1989 proposed ruk (54 FR 43756). The
RACs are used to assess whether adverse health effects
are likely to result from exposure to stack emissions by
comparing the maximum annual average ground-level
concentrations of a pollutant to the pollutant's RAC. If
the RAC is not exceeded, adverse health effects are not
anticipated. Table 2-1 summarizes the RACs for the
compounds covered by the BIF Rule.
The RAC for HC1 and CL is based on 100% of
the inhalation RfD. The RAC for lead is 0.09 pg/m3,
which is 10% of the National Ambient Air Quality
Standard (NAAQS) for lead (Le., 10% of the 1.5 Mg/m3
quarterly standard, converted to an annual basis using a
multiplier of 0.6).
Given the absence of inhalation doses, RACs
for metals other than lead are based on an oral (i.e.,
ingested) RfD that is unlikely to cause adverse health
effects even if exposure occurs daily throughout a
person's lifetime. The Agency converted oral RfDs to
RACs as discussed in the preamble (56 FR 7166,
February 21, 1991).
In addition to the RSD for hexavalent
chromium (CO, Appendix IV of the BIF Rule contains
a RAC for trivalent chromium (Cr*3) of 1,000 pg/m1.
This RAC is very high compared to the other regulated-.
metals shown on Table 2-1, and it is highly unlikely that-.
emissions from a facility would exceed this RAC.
The RACs promulgated as Appendix IV to the
rule were based on both Agency-verified and unverified
RfDs. Unverified RfDs are subject to revision as the
Agency's Reference Dose Workgroup verifies inhalation
RfDs. The Agency may also revise verified RfDs based
on «ig«ifif.»«t new information. In late 1990, subsequent
to the proposal of the BIF Rule, the Workgroup
established inhalation RfDs for eight compounds,
including mercury.4 For mercury, the promulgated RAC
in Appendix IV to the BIF Rule is 03 Mg/m', but the
Reference Dose Workgroup recently verified a lower
inhalation RfD for mercury resulting in a reduced RAC
of 0.08
RfDs for nickel and selenium were established
in 1991. RACs promulgated in Appendix IV to the BIF
Rule were not based on these newly-established RfDs.
Based upon an RfD of 0.02 mg/kg-day,1 the RAC for
nickel is 20 /»g/mj. The RAC for selenium is 4 /jg/m3
and is based upon an RfD of 0.005 mg/kg-day.' Permit
writers should consider using the omnibus permit
authority of $27032(b)(2) to control emissions of
•See Health Effects Assessment Summary Tables, Fourth Quarter - FY90. United State* Eaviroeaental Protection Ajency, OERR 9200.6-303
(90-4), September 1990.
"See Health Effects Assessment Summary Tables, Fun Quarter - FY91. United States Environmental Protection A|ency, OERR 9200.6-303
(91-1), January 1991.
*IRIS, verified by the Afenc/s Reference Dose Workgroup, March 1991.
2-5
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mercury, nickel, selenium, and other metals for which
RfDs have been newly established or revised, to ensure
protection of human health and the environment.
2.4 Tier I and Tier II Emission Limits for Metals.
HCL and CL
The Tier I and Tier II feed rate and emission
screening limits are presented as a function of terrain
characteristics, local land use, and effective stack height.
The Tier I feed rate limits and the Tier n emission rate
limits for noncarcinogenic metals are provided in 40
CFR Part 266, Appendix I-A for urban facilities, and in
40 CFR Part 266, Appendix I-B for rural facilities
located in noncomplex terrain. Appendix I-C to §266
presents screening limits for facilities in complex terrain.
Corresponding limits for carcinogenic metals are
provided in Appendices I-D and I-E to §266 for facilities
in noncomplex and complex terrain, respectively.
Screening limits for Clj and HC1 are presented in 40
CFR Part 266, Appendices n and m, for facilities in
noncomplex and complex terrain, respectively. The land
use characteristics (urban or rural classification) are
determined by the Auer method or by the simplified
land use classification procedures (see Section 6 of
40 CFR Part 266, Appendix DC).
Appendix G to this document includes a
worksheet (Worksheet #1) that can be used to
determine the appropriate Tier I/Tier n screening limits
for a facility. The worksheet includes a step-by-step
approach for determining the terrain-adjusted effective
stack height, terrain type, and land use classification. It
is also useful in determining whether a facility is
ineligible to use the screening procedures because of
non-conservative dispersion characteristics, as discussed
in Section 2.4.1. In addition, the worksheet contains
provisions for facilities that have more than one stack
subject to RCRA controls oa metals/d, emissions (see
Section 142 below and 40 CFR 266.106 the
Tier n allowable emission rate must be calculated* and
the ratios summed to evaluate the combined risk.
Under Tier n, carcinogenic metals which are not
detected in the hazardous waste should be assumed to
be present in emissions at the MDL, to establish limits
for the remaining (detected) carcinogenic metals. The
feed rate limit for carcinogenic metals which are
detected in the hazardous waste, but not detected in
emissions, are based on the compliance test; however
these metals should be assumed to be present in the
emissions at the MDL for the purpose of establishing
feed rates for the remaining carcinogenic metals. The
combined risk for either Tier I or Tier n can then be
estimated using the following equation:
Aggregate Risk •
, PR,
'IT
where:
PR,
SL,
desired feed rate (or emission rate) for
pollutant i
Tier I feed rate (or Tier n emission
rate) screening limit for pollutant i
If the sum of the ratios is not greater than 1.0, the
proposed feed rates/emissions are acceptable.
BIF\SECT02.BIF
2-6
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for a given stack (the stack gas flow rate and the
temperature used in the calculation of the TESH must
be confirmed in the field). The difference between the
maximum ground elevation, within 5 kilometers of the
stack, and the stack base elevation, defines the terrain
rise. The TESH is calculated as follows (step-by-step
procedures for calculating TESH are contained in
Worksheet L, Appendix G):
where:
TESH
Ha
HI
Tr
TESH « Ha + HI - Tr
terrain-adjusted effective stack height
(meters)
actual physical stack height (meters)
plume rise as determined from Appendix VI
of 40 CFR Pan 266 as a function of stack
gas flow rate and stack gas exhaust
temperature
terrain rise within 5 kilometers of the stack
(meters)
Adjusting the stack height for local terrain is not
considered to "double count" terrain effects, but rather
to ensure conservative screening limits. These
conservative screening limits are necessary to account
for the wide range of terrain complexities encountered
at real facilities.
The physical stack height used to calculate the
TESH may not exceed the good engineering practice
(GEP) stack height. According to 40 CFR 5l.lOO(ii),
GEP stack height is determined, quantitatively, as the
greatest of the following:
65 meters, measured from the ground-level
elevation at the base of the stack; or
where:
H
H . = H + 1.5L
good engineering practice height, measured
from the ground-level elevation at the base
of the stack
height of nearby stnicture(s) measured from
the ground-level elevation at the base of the
stack
L = lesser dimension, height or projected width,
of nearby structure(s)
For the purpose of determining GEP stack height,
"nearby" is limited to 5 times the structure height or
width, whichever is less (a distance not to exceed 1/2
mile), and in the case of a fluid model or field study is
limited to 1/2 mile.
If the physical stack height (Ha) is found to
exceed the GEP stack height, the GEP value must be
used to calculate TESH.
Several situations exist for which the calculated
TESH is not listed in the Tier I and Tier FJ screening
limit tables. These potential scenarios are:
• The TESH may be between two listed TESH
values;
• The TESH may be greater than all of the listed
TESH values (greater than 120 meters);-or
* »
• The TESH may be less than all of the listed
TESH values (less than 4 meters).
In the first two scenarios, the screening limits for the
next lower TESH value given in the Tier I and Tier n
screening limit tables should be used. If the TESH for
a particular source is less than 4 meters, a TESH equal
to 4 meters should be used to determine applicable
screening limits.
2J Tier III Emissions Limits
The purpose of conducting a site-specific Tier
m analysis is to provide a means of estimating annual
average air pollutant concentrations for use in
determining source emission limits. The emission limit
for each regulated carcinogenic and noncarcinogenic air
pollutant is based on the maximum ground-level annual
average predicted concentration of that pollutant. This
maximum predicted air pollution concentration defines
the MEI concentrations used in the BIF Rule risk
assessment procedures. For an emission limit to be in
compliance, predicted annual impacts based on that limit
must be acceptable compared with allowable levels
(RACs or RSDs, as discussed in Section 23). Site-
specific analyses conducted under Tier m may be used
to test current emission limits and to design new
emission limits for compliance purposes.
Bff\SECT02.BIF
2-8
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If the feed rates or emission rates allowed
under Tier I/Tier n are too restrictive for a facility's
planned operations, the owner /operator may determine
site-specific limits under Tier HI or adjusted Tier I, as
in Sections 7,5 and 2.7.
2.4.1 Faculties Ineligible to Use Tier I and Tier II
Screening Limits
The BIF Rule prohibits the use of Tier I and
Tier n screening limits for facilities in the following
situations, since the limits may not be conservative in
these situations [see §266.106(b)(7)]:
• The facility is located in a narrow valley less
than 1 kilometer (km) wide;
• The facility has a stack taller than 20 meters
(m) and is located such that the terrain rise
within 1 km of the facility exceeds the physical
stack height;
• The facility has a stack taller than 20 m and is
located within 5 km of the shoreline of a large
body of water7 (e.g^ an ocean or large lake); or
• The facility has a stack with a physical height of
less t*"*" 2.5 times the height of any building
within 5 building heights or 5 projected building
widths of the stack (such as the structure
associated with the stack), and the distance
from the stack to the nearest property boundary
is within 5 heights or projected widths of the
associated building.
Facilities that fall under any of the above
conditions, or for which the Director requires that
standards be based on ale-specific air dispersion
modeling, are required to comply with Tier m.1 Tier m
requires site-specific air dispersion modeling to consider
actual meteorological sad terrain conditions (see
discussions in Sections 15 and 2.7).
2.42 Babbie Approach for Multiple Stacks
Because the BIF regulations for metals, HQ,
and Clj are health-risk based, the emission controls are
implemented using a limited "bubble' approach in which
emissions from all hazardous waste combustion stacks
subject to metals and Clj feed rate limits are considered
in demonstrating compliance with the applicable limits.
This approach includes all boilers and industrial furnaces
regulated under the BIF Rule and those RCRA-
regulated incinerators and thermal treatment units for
which feed rate or emission limits have been established
by EPA for metals, d* or Hd
Although it is expected that most facilities with
multiple stacks will use Tier HI air dispersion modeling
to demonstrate conformance with the metals, HQ, and
Tiers I or n may be used.
To use the Tier I feed rate limits or Tier n
emission rate limits for multiple stacks, the
owner/operator must conservatively assume that all
hazardous waste is fed and all pollutants are emitted
from the source with the worst-case stack. The worst-
case stack refers to the stack which provides the worstpr
ens* air dispersion conditions and results in the most*
conservative screening limits. The worst-case stack is
determined from the following equation applied to each
stack:
K-HVT
where:
K » a parameter accounting for relative influence of
ctack height and plume rise
H • physical stack height (meters)
V - flow rate (m3 /second)
T « exhaust temperature (degrees Kelvin)
The stack with the lowest value of K is the worst-case
stack and should be used to estimate the terrain-
adjusted effective stack height (TESH).
1,43 Calculation of Terrain-Adjusted Effective Stack
Height
The terrain-adjusted effective stack height
(TESH) accounts for the physical stack height, the
plume rise, and the local terrain. The stack gas
volumetric flow rate and temperature can be used with
Appendix VI of the BIF Rule to calculate the plume rise
This condition should be evaluated using scientific judgment based on the size of the body of water «ad it* location relative to the source. The
intention is to exclude facilities that may be subject to shoreline fumigation.
The BIF Rule (|266.106(b)(7)) currently requires the use of Tier ID if non-conservative dispersion conditions exist; however, the Agency is
constdenng amending the Rule to allow the use of adjusted Tier I m these cases as well.
-------
Under Tier m, a feed rate limit need not be
established for metals which are not detected in the
hazardous wastes; however, carcinogenic metals which
are not detected in the hazardous waste should be
assumed to be present in the emissions at the MDL for
the purpose of establishing limits for the remaining
carcinogenic metals (Le, those which are detected in the
hazardous waste).
If a facility has detected a carcinogenic metal in
the hazardous waste feed but has not detected the metal
in emissions, then the feed rate limit for that metal is
based on the compliance test; however, the noo-detect
carcinogenic metal should be assumed to be present in
the emissions at the MDL, for the purpose of calculating
the limits for the remaining carcinogenic metals.
The focus of this section is to provide general
guidance on ggrimating maximum annual average
pollutant concentrations. It is assumed that potential
permit applicants reading this section are already
familiar with basic air dispersion modeling principles. It
is assumed that permit writers have limited familiarity
with air dispersion modeling principles; therefore,
allowable techniques and key steps in the overall process
are highlighted in this section.
Two site-specific methodologies for estimating
pollutant concentrations are allowed under the BIF
Rule. The first methodology (dfcmssrd in Section 2J.1)
was specifically developed for use with hazardous waste
combustion regulations and does not require applicants
to perform air dispersion modeling for estimating air
pollutant concentrations. The second methodology
(discussed in Section 2-52) involves air dispersion
modeling pursuant to guidance issued by the EPA Office
of Air Quality Planning and Standards (OAQPS) in its
Guideline on Air Quality Models (Revised) (22,33,34),
herein referred to as the GAQM.'
23.1 Hazardous Waste Coabnstion Air Quality
Screening Procedure (HWCAQSP)
The HWCAQSP contained in Appendix DC to
the BIF Rule conservatively estimates short-term and
annual average facility air pollutant impacts in
emission limits. Developed specifically for
use with hazardous waste combustion regulations, it is
an intermediate option between the Tier n approach
and the detailed, site-specific dispersion modeling
approach. The HWCAQSP procedure is easy and
inexpensive to perform. To ensure a sufficient degree
of conservatism (i.e., where concentrations and risks
tend to be overestimated rather than underestimated),
the HWCAQSP cannot be used if any of the four
screening procedure limitations listed in Section 2.4.1
are true, or if on-site receptors are of concern and the
stack height is less than 10 meters. In any of these
cases, site-specific air dispersion modeling must be
performed.
The HWCAQSP is based on extensive short-
term modeling of 11 generic source types and on a set
of adjustment factors for Mtimating annual average
concentrations from short-term concentrations. The-_
HWCAQSP can be conducted by using a worst-case!
stack and total facility emissions rates or by considering
each stack individually. If separate stacks are used in
the analysis, the ambient impacts from each stack are
summed to determine the total facility impact This
procedure is most useful for facilities with multiple
stacks, large source-to-property boundary ^istaP'-fv and
complex terrain between 1 and 5 km from the facility.
The HWCAQSP is divided into a series of steps
that begin with the acquisition of source input data and
end with a determination of compliance with regulatory
limits. Worksheets and tables to implement the
HWCAQSP are presented in 40 CFR Part 266,
Appendix DC. Many of the preliminary steps are similar
to those associated with establishing source information
needed to use Tier I and Tier n procedures.
232 Site-Specific Air Dispersion Modeling
Site-specific air dispersion modeling conducted
for the purpose of *«t»M«Jii«g emission limits under the
BIF rule should be based on procedures in the
Guideline on Air Quality Models ^Revised) (22, 33, 34).
The GAQM, incorporated by reference as Appendix X
The GAQM is not a static documeat but is periodically updated to reflect clarifications and interpretation* of modeling procedures and to
reflect advances in the fkld of air dispersion modeling. As of the date of this document, the GAQM incorporates revisions via Supplement A
and presents upcoming guidance via a proposed Supplement B. A Notice of Fmal Rulemmking to adopt Supplement B, as revised, is still
pending While use of the techniques dismssftl in Supplement B is encouraged, h must be emphasized that until such time as Supplement B is
finalized, it presents proposed guidance that only should be used on a case-by-case basis in consultation with EPA.
BIF/SECTD2.BIF
2-9
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to the BEF Rule, is the principal source of information
on the proper selection and regulatory application of air
dispersion models. It also provides recommendations on
the relevant databases and requirements for modeling
ambient air concentrations. This section summarizes
procedures contained in the GAQM and provides
additional detail, where necessary, to allow for a greater
understanding of how GAQM techniques may be
applied for the purpose of complying with the BIF Rule.
2.5.2J Screening-Levd Modeling
Ah- pollutant concentrations predicted under
Tier HI can be based on either screening-level or
refined site-specific air dispersion modeling. The
screening level modeling approach incorporates generic
meteorological data in the form of standard
combinations of atmospheric stability class and wind
speed, and is more readily implemented than the refined
modeling approach. Refined dispersion modeling
incorporates actual meteorological data representative of
the site.
Various screening-level techniques are identified
in the GAQM. The BIF Rule specifically identifies the
EPA SCREEN model, as described in the
Procedures for Estimatin e Air
Stationary Sources (30),'° as an acceptable dispersion
modeling technique. The following paragraphs provide
a brief discussion of the model and the inputs required
for its use.
SCREEN is an interactive EPA screening
model that can be used to predict worst-case, short-term
air pollutant impacts from point and area sources. The
SCREEN model is capable of *«tim«ting impacts in both
complex and noncomplex terrain, as well as under
different downwash conditions SCREEN is currently
the only model available for estimating impacts in the
cavity region that develop on the ™»m«»/tiat» downwind
side of structures or terrain obstacles. Air flow within
the cavity is both highly turbulent and generally
recirculating. Because of this redrculation, pollutant
concentrations b this region tend to be greater than
those outside the cavity. In terms of estimating the
MEI, calculation of cavity impacts is important when
stack emissions are subject to downwash and when the
building's cavity region extends beyond the site's
property line. Typically, the cavity region extends within
3 building heights in distance downwind. When
predicting cavity impacts, SCREEN output provides
dimensions of the cavity region.
SCREEN requires input of certain source and
receptor characteristics as well as selection of options
for model execution. Source input requirements and
model options are the same as those used in refined
modeling and are discussed in Section 2.5.22. As a
screening technique, the model assumes that maximum
impacts can be predicted in any direction from the
source. Therefore, receptors (locations where impacts
are predicted) are simply expressed in terms of dis
considered to be downwind of the source. At a
minimum the model user must specify the nearest and
farthest receptor distances at which air pollutant
concentrations are to be predicted. SCREEN will then
automatically calculate impacts at distances within that
range and will interpolate to find the maximum. value
and associated distance. The farthest distance should be
set sufficiently large to ensure that the maximum
concentration is identified. As discussed further in
Section 2522, terrain heights should be input for each
receptor distance if the facility is located in an area of
rolling or complex terrain.
To account for downwash, SCREEN requires
input of a building (structure) height and the respective
maTimiim and minimum horizontal dimensions.
Generally, to evaluate the greatest downwash effects for
each source, the building with dimensions that result in
the highest good engineering practice (GEP) stack
height for that source should be modeled.
The SCREEN model can also be executed
through use of the TSCREEN model. TSCREEN
incorporates the dispersion algorithms used in
SCREEN, and is an interactive screening model for
determining maximum short-term impacts from various,
well-defined air toxic releases. In either case, the
impacts from only a single source (e.g., one stack) can
be estimated with each model execution. When impacts
are required for multiple sources, the sources must be
•See Footnote 8. The SCREEN model is incorporated in the propoced Supplement B to the GAQM and is therefore not yet officially pan of
the GAQM. An important limitation of the current draft venion of the SCREEN model, with respect to the BDF Rule, is that it cao only
estimate shon-term average concentrations. The version of SCREEN adopted in the final rulemaking on Supplement B will include a time-
scaling factor for converting shon-term to annual average concentrations. Until that time, no OAQPS guidance easts for producing annual
average estimates with SCREEN.
BIF/SECT02.BIF
2-10
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processed individually and their impacts summed to
produce the total maximum impact from the facility.
One extremely conservative approach for using
SCREEN for the BIF rule involves comparing the
predicted short-term impacts directly with the
RACs/RSDs. Concentrations predicted for short-term
averaging periods (i.e., 1-hour or 24-hour averaging
periods) are typically much greater than concentrations
predicted for annual averaging periods. However, if the
short-term impacts do not exceed the RACs/RSDs, and
if all cancer risk analyses are acceptable, compliance can
be demonstrated.
2.SJ.2 Refined Modeling
Refined air quality dispersion modeling involves
more detailed decisionmaking and requires more
extensive input than screening-level air dispersion
modeling. It therefore requires more time to perform.
Successful performance of a detailed air dispersion
modeling analysis requires a knowledgeable air quality
modeler, adequate computer resources, and the ability
to assemble the meteorological and source parameter
data required for model input. A refined dispersion
modeling analysis should be conducted if the facility
cannot comply with the limits resulting from Tier I, Tier
n, HWCAQSP, or screening-level dispersion modeling,
or if the facility meets any of the conditions outlined in
Section 2.4.1 (and therefore cannot apply Tier I, Tier n,
or HWCAQSP modeling limits). The benefit derived
from the refined modeling approach is that by
considering the dispersion characteristics of each stack,
and accounting for the variability in actual
meteorological conditions, site-specific estimates of
plume dispersion are obtained.
The remainder of this section discusses the
basic components of a refined dispersion modeling
analysis and cites specific GAQM techniques that are
commonly used in regulatory applications.
Model Sdection-The model selected for refined
air modeling should be the one that most accurately
represents atmospheric transport and dispersion in the
area under analysis. Atmospheric dispersion models
have been developed for both simple and complex
terrain and for rural and urban applications (all defined
in following paragraphs). Thus, the topography and land
use in the area surrounding the facility must be
evaluated to determine the type of model that applies to
the specific situation.
Terrain Type-One of the initial determinations
to make in model selection regards the type of terrain
surrounding the facility. If all of the terrain in the
surrounding area is below the facility's lowest stack
elevation, facility impacts can be adequately addressed
with a simple terrain model. If terrain elevations above
the lowest stack elevation are identified, use of a
complex terrain model is required. Receptors with
terrain elevations between the stack height and the
plume height (intermediate terrain receptors) must be
modeled with both a simple and a complex terrain
model
Urban/Run! Classification-Aside from terrain
type, the second major determination to make in model
selection regards the urban/rural classification for the
area. This determination is typically based on the land
use in the area surrounding the facility. The GAQM
provides guidance on acceptable land use classification
procedures. -.
*•
Sources located in an urban area should be
modeled using urban plume dispersion coefficients,
while sources located in a rural area should be modeled
using rural plume dispersion coefficients. Some models
incorporate both urban and rural dispersion coefficients.
Other models, particularly those addressing complex
terrain, generally accommodate one land use
j t}\f other.
Simple Temio-The GAQM identifies both
simple and complex terrain models that are preferred
for regulatory use. Simple terrain is defined as terrain
elevation below the facility's stack elevation. The simple
or "noncomplex" terrain model recommended for this
situation is the Industrial Source Complex Long-Term
model (ISCLT). The ISCLT model is specific to the
prediction of annual average air pollutant
concentrations. Other models suggested by the GAQM
may be used in consultation with the regional air quality
meteorologist For details on ISCLT model execution
and input requirements, permit applicants or permit
writers should consult the Industrial Source Complex
(ISC) Dispersion Model User's Quide - Second Edition
(Revised! (261.
Complex Terrmin-The need to apply a complex
terrain model is not an uncommon occurrence in air
dispersion modeling analyses conducted for regulatory
use. Complex terrain is defined as terrain elevation at
or above the facility's plume height elevation. Much
Bff\SECr02.BIF
2-11
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attention has been focused within EPA on this aspect of
air dispersion modeling over the past few years."
The complex terrain modeling techniques
discussed in the current GAQM are considered to be
screening, or 'refined" screening techniques. Of the
preferred techniques available, use of the Valley model
is recommended (refer to the Vallev Model User's
Guide (35)). All complex terrain models should be
executed with meteorological data collected on site. If
on-site meteorological data are not available, the Valley
model may be run using 5 years' worth of data from the
most representative off-site location, and an annual
average concentration may be obtained. Use of off-site
meteorological data is not recommended for any other
complex terrain model Other complex terrain models
are available and are discussed in the GAQM. These
models may be used in consultation with the regional air
quality meteorologist.
A refined complex terrain model referred to as
the Complex Terrain Dispersion Model Plus Algorithms
for Unstable Situations (CTDMPLUS) has recently been
developed.12 This model is applicable under all stability
conditions for receptors located on terrain above the
facility's stack. Use of the model requires extensive on-
site meteorological data and detailed, digitized terrain
data. A screening version of CTDMPLUS that does not
require on-site meteorological data is the CTSCREEN
model. Also recently developed, the CTSCREEN model
may be used to obtain conservative, yet realistic
estimates for receptors located on terrain above the
facility's stack height. CTSCREEN incorporates a time-
scaling factor for producing annual average
concentrations of air pollutants.
Intermediate terrain receptors (those with
terrain elevation between the stack height elevation and
the plume centerline elevation) should be modeled using
both a complex terrain and a simple terrain model, with
the highest concentration selected. Simple terrain
models should not be wed to predict concentrations at
receptors with an elevation above that of plume
center line.
Model Control Options-Most models have a
set of regulatory control options that help define the
characteristics of the analysis (e.g., urban or rural land
use) and direct the model to make appropriate
calculations. These control options include treatment
for calms, buoyancy-induced dispersion, wind profile
exponents, vertical potential temperature gradients, and
suck top downwash. Selection of the specific control
options should be performed in accordance with the
recommendations given in the GAQM.
f
Model Availability-Source code or executable
code for the dispersion models can be purchased from
the National Technical Information Service (NTIS) at
(800) 533-6847, or obtained without charge from the
Support Center for Regulatory Air Model's (SCRAM)
Electronic Bulletin Board System (BBS), managed by
the OAQPS Technical Support Division of the Source
Receptor Analysis Branch. The SCRAM BBS can be
accessed at 2400/1200 baud by dialing (919) 541-5742 or
at 9600 baud by dialing (919) 541-1447. Line settings for
2400/1200 baud are 8 data bits, no parity and 1 stop bit.
Other sources of model code include private vendors.
Private vendors frequently supply interactive or menu-
driven data entry programs that can considerably
simplify the modeling effort Modelers should -verify
that they are using the most up-to-date version of the
model(s), particularly when purchasing models through
NTIS or private vendors.
Source Parameters-Certain source parameters
are required for input to air quality dispersion models
(the stack gas flow rate and the gas exit velocity used as
inputs to these models must be confirmed in the field).
The variables typically input for combustion source
stacks include:
Stack height above ground level;
Inside stack diameter,
Gas velocity at stack exit;
Gas flow rate (required for some models);
Gas temperature at stack exit;
Stick-base elevation;
Building dimensions (for stacks below GEP);
Suck coordinates (based on distance from grid
origin); and
Emission rate.
The user's guides for the particular models
provide instruction on the proper units for each source
parameter. For the purpose of demonstrating
"See Footnote 8. As • result, proposed Supplement B to the GAQM presents new piiduce on complex terrain modelinj techniques.
"The CTDMPLUS model s proposed for regulatory use in Supplement B to the GAQM (see Footnote 8).
BIF/SECr02.BIF 2-12
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compliance with the individual metals, HC1, and Q,
limits, the maximum hourly emission rates (accounting
for any add-on control efficiency) should be used.
Operating conditions that maximize emission
rates typically increase plume buoyancy and momentum,
resulting in maximum plume dispersion. Conversely,
reduced operating conditions (e.&, reduced production
rates) typically reduce plume buoyancy and momentum.
Due to these differences in dispersion, operating
conditions that maximize emission rates of pollutants
may not result in maximum ambient ground-level
concentrations. Situations where this may be of
particular concern include:
• Complex terrain;
• Downwash;
• Property boundaries located near the source; or
• Operating conditions which vary source
dispersion parameters (Le., exit temperature
and velocity).
When operating conditions can significantly
affect source dispersion parameters, it may be necessary
to model over the range of source operating conditions
to ensure the ma*?"""" MEI concentration is predicted.
Operating levels at less than 100% of capacity should be
modeled for those cases in which the source operates at
a capacity substantially less than design capacity and in
which changes in source parameters associated with the
operating conditions could result in higher predicted
concentrations. In all cases, the maximum (100%
capacity) operating conditions must be modeled.
The GEP height needs to be determined for
each stack before »«"-"*"»g the air dispersion model.
The physical stack height input for modeling cannot be
greater than GEP stack height (fee Section 2,43).
Dowowash-Building downwash should be
included in the modeling analysis for all stacks with
heights less than the GEP height Further, the potential
for impacts within the cavity region should be evaluated
for stacks below the GEP height (refer to Section
152.1). The ISCLT model contains algorithms for
determining building downwash and should be used for
determining refined concentration estimates, regardless
of the specific terrain situation. Methods and
procedures for determining the appropriate inputs to
account for downwash are discussed in the user's
manual for ISCLT and the G, y*^'n? f?r Pytermination
of firwl FiHrineerinff Practice Stack Heizht (Technical
Support Document for the Stack Height Regulations)
(Revised^ (19).
The GAQM indicates that for complex
situations, such as those involving building wake effects
or diffusion in complex terrain, a physical modeling
analysis in which the atmospheric dispersion patterns are
simulated in • wind tunnel or other Quid modeling
facility may also be useful Selection of this approach
would require both a demonstration of its applicability
and access to the necessary fluid modeling facility.
Guidance for conducting a fluid modeling study is
available in EPA's QTii^fffV? f?r Fluid
AliT?iipliie"c Diffusion (20) and Guideline for Use of
Fluid VfrtHUng to Determine Good Engineerin
Practice fitafft Hffitfr1 (21)-
Meteorological Data-Meteorological data used
as input to an air quality dispersion model should be
spatially and temporally representative of the area of.
interest. These data are typically collected by the f
National Weather Service (NWS) or as part of an on-
site measurement program. Other sources of
meteorological data may include local universities, the
Federal Aviation Administration (FAA), military
stations, or pollution control agencies. The NWS and
military station ^afa may be purchased from the
National Climatic Data Center in Asheville, North
Carolina (for more information, call 704-259-0682).
NWS data are also available on the SCRAM BBS.
Judgments regarding the representativeness of
meteorological data must consider both spatial and
temporal dependence. The facility and meteorological
observation locations must have similar spatial
characteristics for terrain features, land use, and
synoptic flow patterns. In terms of temporal
dependence, the meteorological data set must include 1
years' worth of hourly observations reflecting the four
seasons. If available, 1 years' worth or more of on-site
meteorological data are preferred for use in the air
quality modeling; otherwise, 5 years' worth of
representative NWS data should be used. A period of
5 years is generally adequate for representing both
annual and short-term variations in pollutant impacts.
If historical, representative meteorological data
are not available for the location of interest, the
alternative is to collect 1 years' worth of on-site
meteorological data to conduct an air quality modeling
Bff\SECm.BIF
2-13
-------
analysis. Meteorological data recorded on site must be
validated before use in an air quality modeling analysis.
Guidance on determining representative
meteorological data and recommendations for the
collection and use of on-site meteorological data are
provided in the GAQM, On-Site Meteorological
Proram Guidance for Regulator
Applications (27), «Tid Amhiftnt Monitori'jg
for Prevention fpt Significant Deterioration (PSD^ (15).
Further information on meteorological data collection is
provided in the Quality Ass||rai>p^ HanHivvA for Air
Pollution Measurements Systems: Volume IV.
Meteorological Measurements (28). Any determination
of meteorological representativeness is made on a case-
by-case basis, in consultation with the state or regional
air quality meteorologist.
In terms of meteorological data application,
some models use hourly weather observations and twice-
daily mixing height data, which are preprocessed into a
format suitable for model execution. Models designed
to predict long-term averages, such as ISCLT, commonly
use STAR (Stability Array) summaries, which are joint
frequency distributions of wind speed, wind direction,
and Pasquill-Gifford atmospheric stability class.
Receptor Grids- Various types of receptor grids
can be used to identify locations of predicted ambient
air concentrations. Most models facilitate input of the
receptor grid by providing an option to automatically
generate a grid based on some user specifications, such
as desired interval spacing. In general, receptor grids
are based on either a polar coordinate or Cartesian
coordinate system, or a combination of both systems. In
the Cartesian system, the X-axis is positive to the east
and the Y-axis is positive to the north of a user-specified
origin. The polar receptor system is based on radial
HUtanr^t measured from the grid origin and an azimuth
bearing (angle) measared clockwise from the north. In
the polar coordinate syttem, receptors are usually
spaced at 10-degree intervals on concentric rings.
Radial 4'flf1"*^ from the origin are user-selected and
are generally set equal to the distances to expected
maximum concentrations of the sources modeled. In the
Cartesian system, the X and Y coordinates of the
receptors are specified by the user. The spacing of grid
points is not required to be uniform so that the density
of grid points can be greatest in the area of expected
maximum concentrations.
To establish the location of maximum
concentration, two levels of receptor grids are commonly
used in a refined modeling analysis. A first level, or
•screening-level" grid, is generally comprised of a
moderate number of receptors located uniformly in all
directions from the source. Typically, this screening-
level grid is centered on some feature (e^ a stack)
located within the facility property. A second level, or
"refined" grid, comprised of receptors more densely
located, is then modeled to pinpoint maximum
concentrations based on results using the screening-level
grid. This refined grid is typically centered on areas of
maximum impact identified by the screening-level grid.
From a geographical perspective, receptors
should be located along the property boundary and in
the surrounding area off site. The minimum distance to
off-site receptors is usually defined by the property
boundary or fence line. Receptors should be located at
and within a far enough distance from the source to
ensure that the maximum concentration is identified.
To isolate maximum impacts, the emphasis shoujd be
placed on receptor resolution and location, not 04 the
total number of receptors modeled. Further, for the
purpose of the BIF Rule, receptors must be located
within the property boundary if a person resides on site.
Receptor placement requires special attention
when modeling in complex terrain. In such cases,
highest pollutant concentrations are often predicted to
occur under very stable atmospheric conditions, when
the plume is near, or impinges on, the terrain. Under
these conditions, the plume may be quite narrow in the
vertical terrain, so that even relatively small changes in
a receptor's elevation may make a substantial change in
the predicted air pollutant concentrations.
2J53 Compliance Demonstration
Dispersion Modeling
Based on
The maximum predicted air pollutant
concentration (Le., MEI concentration), due to
emissions from all BIF sources within the facility, is used
to determine compliance for each pollutant modeled.
For noncarcmogenic metals which are detected in the
hazardous waste, HQ and Clj, this predicted maximum,
annual average, ground-level concentration must not
exceed the RAC specified in Appendix IV to the BIF
Rule. For carcinogenic compounds, this predicted
maximum, ••""»! average, ground-level concentration
must not exceed the RSD specified in Appendix V to
the BIF Rule. In addition, the sum of the ratios of
Bff\SECT02.BIF
2-14
-------
I
predicted maximum concentrations to the respective
RSDs must not exceed 1.0 (which corresponds to an
aggregate risk of 10"5). For the purpose of calculating
the summed risk, and subsequently, feed rate limits for
carcinogenic metals which are detected in the hazardous
waste, the owner/operator should assume that any
carcinogenic metals that are not analyzed for or not
detected in the emissions are present in the emissions at
the MDL for that metal For compounds not listed in
Appendices IV or V of the BIF Rule, the MEI
concentration cannot exceed 0.1 pg/m3.
Risks from dioxins and furans must be
estimated in terms of 23,7,8-TCDD equivalents. The
ratio of the MEI concentration to the RSD for 23,7,8-
TCDD must not exceed 1.0. Procedures for determining
TCDD equivalents are provided in EPA Method 23,40
CFR Part 60, Appendix A.
Emissions for substances, except dioxins and
furans, which are not detected at the appropriate
method detection limit (MDL) should still be considered
when conducting dispersion modeling analyses. The
method detection limit for any analytical procedure is
not a fixed value, but varies according to sample volume,
matrix interferences, and the skill and experience of the
analyst. It is not appropriate to disregard the potential
contribution of substances that are not detected (Le., are
below the MDL) in the emissions, but are reasonably
expected to be contained in the waste, since a nondetect
value is not the same as zero. The MDL, therefore,
should generally be used for nondetected substances in
subsequent dispersion modeling unless the
owner/operator obtains Agency approval to disregard
the potential contribution of these substances.
Procedures for handling nondetect values for dioxins and
furans are discussed in Method 23, 40 CFR Pan 60,
Appendix A.
In addition to the compliance evaluation
procedures mentioned above, the BIF Rule requires that
certain information be supplied with the BIF application
to support the demonstration of compliance and the
emission limits on which that compliance demonstration
is based. A key piece of required information that is
established in the dispersion modeling is a parameter
referred to as the "dilution factor," expressed in units of
Mg/m'/g/s. Models will predict dilution factors when
executed with a unit emission rate of 1 g/s. The
dilution factor is source-specific and pertains to the
Tnyrimiim predicted air pollutant concentration. It
essentially reflects the dispersion capability of the source
BrF\SECr02.BIF 2-15
(the higher the dilution factor, the worse the dispersion
parameters for the source). The dilution factor is used
in the adjusted Tier I emissions procedure. For facilities
with a single stack, determination of the dilution factor
is straightforward, as shown in the following equation:
where:
DF
MAI,
ER,
DF - (MAIJ / (ER,)
dilution factor (Mg/m'/g/s)
myrifniim predicted annual average impact
for pollutant i Mg/m5)
emission rate of pollutant i (g/s)
The dilution factor corresponds to a unique
operating condition for the source (refer to the
discussion on source parameters) and to a unique
receptor location (the receptor where the maximum^
impact is predicted). The use of any pollutant emitted;
from the facility, for the particular operating condition'
modeled, will give the same dilution factor. The highest
MAI, concentration over all operating conditions defines
the respective MEI concentration for each pollutant.
The existence of more than one stack at a
facility adds a complicating factor to determining the
dilution factor for each source. Considering that
conceptually, a source has a dilution factor at each
receptor, the facility-wide concentration at each receptor
location is determined in the dispersion modeling as
follows:
MAI
where:
MAI,
ER,
DP.
maximum predicted annual average impact
for pollutant i at receptor r (Mg/m3)
emission rate of pollutant i for source j (g/s)
dilution factor for source j at receptor r
number of sources modeled
-------
The MEI concentration of that pollutant is the highest
MAI predicted for the receptor grid. For a facility with
two sources (i.e., stacks), this equation is as follows:
MAI,, = (ER..-DF,.) + (ER^DFJ
where ER,, and DFlr are the pollutant i emission rate
and the dilution factor for source L, respectively, and
ERn and DFj, are the pollutant i emission rate and the
dilution factor for source 2, respectively. Unless the
source parameters (height, exit temperature, etc.) for
the two sources are exactly the same, the dilution factors
for each source will be different Even then, the dilution
factors may be different due to considerations such as
one source being in closer proximity to the property
boundary than another. Since the dilution factor at each
receptor may vary between sources, the maximum
dilution factor for each source may occur at different
receptor locations.
When more than one source is being modeled,
most models provide the option of determining not only
the maximum impacts resulting from all sources, but
also impacts from each source individually. To simplify
the modeling effort, when many sources and pollutants
are involved, h may be best to obtain individual source
contributions at each receptor. In this case, each source
could be modeled with a unit emission rate (equal to 1
g/s). Model results so derived could be loaded into a
spreadsheet software package, and maximum impacts for
each pollutant calculated in the manner identified in the
above equation. Such an approach could also expedite
determination of optimal emission limits for a facility,
particularly for those with multiple sources.
2.6
Adjusted Tier I Fe
A final method for determining appropriate
feed rate limits is the adjusted Tier I procedure, which
provides more refined feed rate limits than those yielded
under Tier I. Similar to Tier I feed rate limits, the
adjusted Tier I limit* assume all material fed into the
unit is emitted at the same rate at which it is fed. The
primary difference between Tier I and adjusted Tier I
omits is that adjusted Tier I allows consideration of site-
specific dispersion characteristics. The adjusted Tier I
feed rates were back-calculated from the RACs/RSDs
using dilution factors resulting from site-specific dilution
modeling. The advantage of this approach is that it
takes into account site-specific meteorological and
terrain conditions, providing less conservative feed rate
limits than those achieved under Tier I, without
requiring emissions testing. The limits established for
compliance with the BEF Rule may not be exceeded. A
source may not operate at rates above the established
limits part of the time in exchange for not operating or
operating at a lower level at other times.
Under the adjusted Tier I approach, dilution
factors must be estimated using the unit emission rate (1
g/s) dispersion modeling procedures." The procedures
outlined in Section 2J should be followed for the
adjusted Tier I modeling effort Once the dilution
factor for the source has been determined, the site-
specific feed rate limits for each pollutant can be
calculated. As in Tier I, the adjusted Tier I feed rate
limits do not account for any removal of a pollutant in
the facility's Air Pollution Control System (APCS).
To calculate adjusted Tier I feed rate limits, the
acceptable ambient concentrations are divided by the
dilution factor. The acceptable ambient limits are the
RACs for noncarcinogens and the RSDs for
carcinogens. RACs and RSDs are found in Appendices
IV and V of the final BIF Rule, respectively. The
formula used to estimate the adjusted Tier I feed rate
limits is; •—
APR.
RAC.
"DF
where:
AFR, * adjusted Tier I feed rate limit for pollutant
RAC, * reference air concentration or risk-specific
dose for pollutant i (/ig/m3)
DF - dilution factor (/ig/m'/g/s)
This calculation is repeated for each pollutant. If the
proposed pollutant feed rates in the waste do not exceed
the adjusted Tier I limits, they are acceptable. Feed
rates are not established for metals which are not
detected in the hazardous waste feed; however,
carcinogenic metals which are not detected in the
hazardous waste feed should be assumed to be present
at the MDL, for the purpose of calculating the feed
rates for the remaining carcinogenic metals.
When multiple stacks exist at facilities applying
the adjusted Tier I approach, all sources must be
accounted for in the modeling analysis. Each source
must be modeled at a unit emission rate to predict a
"The dilution factor a the concentration resulting from exposure to a unit emiBion nte (1 j/s). Dilution factor units are
BIF/SECT02.BIF 2-16
-------
dilution factor for each source which corresponds to the
facilitys MEI concentration or location. These dilution
factors must be submitted with the BEF application. If
sucks exist which have identical stack parameters (i.e.,
stack height, diameter, velocity, temperature), the stacks
may be modeled as co-located stacks, simplifying the
modeling process. Co-located stacks are modeled as a
single source with emissions released from a common
point In this case, the stack coordinates modeled
should be those corresponding to the closest stack to the
property boundary. Further, the exit velocity and
temperature should be those corresponding to a single
stack. If the exit gas streams of the co-located stacks
have different pollutant mass distributions, the pollutant
mass fractions for the modeled stack must be
redistributed to consider the pollutant distributions from
each stack.
The adjusted Tier I feed rate limit for each
source, «umning an even emissions distribution between
the sources, is calculated as follows:
APR
RAC
where:
APR,
RAC,
DF
adjusted Tier I feed rate limit for pollutant
i (g/s)
reference air concentration or risk-specific
dose for pollutant i (/ig/mj)
dilution factor from source j Qig/m3) g/s
number of sources modeled
This procedure is repeated to determine the appropriate
feed rate limits for each pollutant This equation
calculates a limit for each source assuming the emissions
are evenly distributed After calculating this value, the
owner/operator may desire greater flexibility for a
particular source(s). The limit could be adjusted
upward to allow a particular source to operate at a
higher limit. In doing so, the allowable feed rate limits
for the remaining sources must be adjusted downward
to account for any increased feed rates by a particular
source. Sources with the lowest dilution factor are
capable of destroying waste at a higher rate than those
sources with a higher dilution factor. The total plant
allowable feed rate could be increased by sb»fi'"g some
of the load to the source with the lowest dilution factor.
In all cases, the sum of the dilution factor for each
source times the feed rate limit for each source cannot
exceed the RAC or RSD for an individual pollutant. To
demonstrate this requirement, the following statement
must be true:
RAC>E(AFR,.DF)
where:
RAC,
AFR,
DF,
n
reference air concentration or risk-specific
dose for pollutant i
adjusted Tier I feed rate limit for pollutant
i and source j
maximum dilution factor from SOUTCC j
number of sources modeled
The following example is provided to further
explain this procedure.
A facility has two Hint, each with*
one stack. Site-specific modeling indicates the dilution
factor for Stack 1 (DF,) to be 2.4 /Jg/m'/g/s, while the
dilution factor for Stack 2 (DF,) is 3.0 pg/m'/g/s. The
pollutant being evaluated has a RAC of 10
Assuming the waste is evenly distributed
between the kilns and the emission rates are the same,
the allowable feed rate for either kiln is:
APR,
RAC
RAC
(DP, + DF,)
(2.4 * 3.0)Mg/mVg/s
1.85 g/s
This result implies that up to a 1.85 g/s feed rate could
be fired in both kilns simultaneously without exceeding
the RAC. The total feed rate for the two kilns would be
3.70 g/s.
-------
Assuming the owner/operator desires to fire
Kiln 1 at a higher rate (3 g/s), the allowable feed rate
for Kiln 2 can be calculated as follows:
RAC > I (APR. • DF.) - [(APR, * DF^AFR, * DF,)]
RAC - (APR, « DP,) > (APR, « DF,)
RAC - (AFR.^^
10 pg/m3 - (3 g/s * 2.4 jig/m'/g/s) ^
3.0 "
0.93 gls >AFRj
This result implies that to increase the Kiln 1 feed rate
limit to 3.0 g/s, the Kiln 2 feed rate limit would have to
be reduced to 0.93 g/s to avoid exceeding the RAC.
The total feed rate for the two kilns would be 3.93 g/s,
which is greater than that for the first scenario, where
the feed was evenly distributed.
Bff\SECT02.BrF 2-18
-------
3.0 PRECOMPLIANCE CERTIFICATION
AcnvrnES
Precompliance certification activities cover the
period of time between the effective date of the BEF
Rule (August 21,1991) and the date an owner/operator
submits a certification of compliance documenting
compliance with the emissions limits for metals, HQ,
Clj, PM, and CO/HC, based on compliance testing.
Interim status BIF facilities were required to
submit precompliance certification packages to the
Director of the appropriate federal or state regulatory
agency by August 21, 1991 (40 CFR 266.103(b)). This
section is intended to assist facilities that need to revise
their precompliance certification during the interim
status period and to assist regulators in review of the
precompliance certification documentation and
compliance activities.
In the precompliance certification package, the
owner/operator must certify that when the BIF is
operated within limits (established by the
owner/operator) on EPA-prescribed parameters,
emissions of metals, HC1, Q,, and PM are not likely to
exceed allowable emissions during the precompliance
period. Accordingly, the owner/operator must establish
limits on production rates and feed rates of metals,
chlorine, ash, total hazardous waste, and pumpable
hazardous waste (if applicable). The owner/operator
must also identify the expected values for a number of
key operating parameters that can affect emissions of
these pollutants. Sample Precompliance Certification
Forms PC-1 through PC-8 (provided in Appendix B) can
be used to certify precompliance or to revise
precompliance certification.
By August 21, 1991, an owner/operator was
required to issue a one-time public notice in a major
local newspaper of general circulation providing
information on the facility, its burning operations under
interim status, and the regulatory process required to
comply with the interim status requirements. Each
facility is also required to maintain a publicly available
file of correspondence between the facility and federal,
state, and local regulatory authorities on the facility's
hazardous waste burning activities. Any interim status
facility that did not submit a precompliance package by
thit date was required to cease burning hazardous waste
and to obtain a RCRA permit before resuming
hazardous-waste burning.
All facility operations, including any
precompliance and compliance testing, must be
conducted within the limits established in the
precompliance certification. Therefore, it is to a
facility's advantage for the owner/operator to establish
precompliance certification omits at levels that reflect
the tnyrittmtn feed rates expected during the period
prior to the certification of compliance. Also, before
compliance certification, burning of hazardous waste
with a heating value of lower than 5,000 Btu/lb is
limited to 720 hours (including precompliance and
compliance testing), except in the cases listed in Section
523.6 this document The owner/operator must
maintain records of feed rates and composition and of
specific operating conditions to document that the
precompliance certification limits are maintained.
An owner/operator may choose to revise! the
precompliance certification limits before certification of
compliance based on new data and information. Results
from precompliance testing of the combustion device
and air pollution control system can also better
document the system's performance, determine whether
system modifications or equipment upgrades are needed,
and ensure that, when operated within prescribed
parameters established during the compliance test, the
unit will comply with applicable emissions standards.
3.1
Identification of Key Operating Parameters
For certifying precompliance, the
owner/operator must establish limits for the parameters
shown in Table 3-1 to ensure that emissions of metals,
HC1, a* and PM are not likely to exceed allowable
levels.
Precompliance certification parameters differ
from compliance certification parameters in that the
former do not include limits on CO/HC, combustion
chamber temperature, PM control device inlet
temperature, and APCS-specific operating parameters.
However, because these parameters will affect the
operation of the system, the owner/operator should
consider these parameters when submitting a
precompliance certification package.
BIF\SECT03.BIF
3-1
-------
Table 3-1
Key Precompliance Operating Parameters
Key Operating Parameters for Which PrecompUance limits Must Be Established
Total feed rate of all hazardous wastes.
Total feed rate of all pumpable hazardous wastes.*
Feed rate of each of the 10 BIF-regulated metals in:
Total feed streams,1*
Total hazardous waste feed streams,' and
Total pumpable hazardous waste feed streams.*
Total feed rate of chlorine and chloride in total feed streams.
Total feed rate of ash in total feed streams, except for cement and light-weight aggregate kilns.
Maximum production rate.
"Not applicable if complying with the Tier I or adjusted Tier I metals feed rate screening limits.
*Not applicable for industrial furnaces complying with §266.103(b)(4); instead, such facilities must specify
concentration limits for each metal in collected paniculate matter.
The BIF Rule (56 FR 7134, February 21,1991) specifies that facilities complying with Tier I or adjusted
Tier I metals feed rate screening limits must establish a precompliance limit on the feed rate of each metal
in total hazardous waste feed streams (§266.103(b)(3)(ii)). EPA is considering rescinding this requirement
by amending §266.103(b)(3)(ii)(B) to read Total hazardous waste feed, unless complying with the Tier I or
adjusted Tier I metals feed rate screening limits under §266.106(b) or (e).'
3-2
-------
32 Determination of Operating Conditions
As previously mentioned, all precompliance and
compliance testing must be conducted under limits
established in the precompliance certification. For
maximum operating flexibility, the owner/operator
should establish precompliance certification limits and
compliance certification limits at levels that reflect the
range of conditions expected during present and future
operations. Thus, the owner/operator must consider
how to maximize the desired operating conditions
without exceeding the allowable emissions limits.
Section 3.2.1 discusses parameters for which
limits must be established in the precompliance
certification. Section 3.22 discusses additional
parameters that are not specifically limited during
precompliance; however, they should be considered
during precompliance in order to estimate emissions for
which limits will be established during the compliance
test.
32.1 Precompliance Operating Limits
3.2.1.1 Maximum Feed Rate of Each Hazardous Metal
Typically, emission rates increase with
increasing feed rates. There are three levels of metals
feed rate parameters: maximum combined feed rate of
each hazardous metal in all feed streams (including raw
materials, fuels, hazardous wastes, and other feed
streams into the BIF); maximum combined feed rate of
each hazardous metal in all hazardous waste streams
(including all hazardous waste feed streams, but
excluding any feed streams that are not hazardous
wastes); and <"«*{>"""T combined feed rate of each
hazardous metal in aB pumpable hazardous waste feed
streams (including typically low solids-content liquids,
rather than nonpumpable wastes, which are typically
sludges and solids). The maximum combined feed rate
of each metal in total pumpable hazardous waste
streams is not limited if complying with Tier I or
adjusted Tier I metals feed rate screening limits. These
parameters are measured by monitoring the flow rates
and bdividual metals concentrations of the various feed
streams.
32.12 Maximum Combined Feed Rate of Chlorine In
All Feed Streams
Typically, the HC1 and d, emission rates
increase as the chlorine feed rate increases. This
parameter is measured by monitoring chlorine
concentrations in feed streams and flow rates of feed
streams. The precompliance limit is for total (organic
and inorganic) chlorine.
32.13 Maximum Combined Feed Rate of Ash in All
Feed Streams
Typically, the PM emission rate increases as the
ash feed rate increases. This parameter is measured by
monitoring ash concentrations in feed streams and flow
rates. This parameter, however, does not apply to
cement kirns or light-weight aggregate kilns because the
normal raw materials fed to these devices contain aTiigh
ash content.
3.2.1.4 Maximum Hazardous Waste Feed Rate
There are two levels of hazardous waste feed
rate parameters: (1) maximum combined feed rate of
all hazardous waste feed streams; and (2) maximum
combined feed rate of all pumpable hazardous waste
feed streams. The combined feed rate of all pumpable
hazardous waste feed streams is not limited if complying
with Tier I or adjusted Tier I metals feed rate screening
limits.
For maximum operating flexibility, these
parameters should be maximized in the compliance test
by maximizing the pumpable hazardous waste feed rate,
if possible. If the pumpable waste is a relatively low-
heating-value waste, however, maximizing this parameter
may conflict with maximizing other compliance
parameters, such as combustion zone temperature,
APCS temperatures, and production rate. In such a
case, it may be necessary to set the compliance limits for
some parameters at one set of test conditions and for
other parameters at another set of test conditions.
Section S23& discusses hi more detail resolving
conflicting parameters.
-------
3.2X5 Maximum Production Rate
Depending on the facility and on measurement
capabilities, the maximum production rate may be
represented as raw materials feed rate, thermal input,
steam production rate (for boilers only), or clinker
production rate (for cement kilns).
322 Other Parameters to be Considered During
Precompliance
As part of precompliance certification, the
parameters described in the subsections below, which
include maximum combustion chamber temperature
limits and the temperature of flue gas entering the PM
control device, must be considered to estimate metals,
HO, Clj, and PM emissions during the precompliance
period. Monitoring equipment used to demonstrate
continuous compliance with the limits is not required to
be in place until compliance testing is conducted.
However, once such systems are installed, these
parameters must be continuously monitored, and the
facility must maintain records of actual operating levels,
even if installed during the precompliance period.
3.2.2.1 Maximum Combustion Chamber Temperature
Under Tier n or Tier IE metals compliance,
combustion chamber temperature is limited because an
increase in the combustion zone temperature may lead
to increased metals vaporization, which in turn may
result in increased emissions of hazardous metals.
Because it is difficult to reliably measure the combustion
zone temperature in many BIFs, another sampling
location within the combustion chamber can be used as
an indicator of combustion zone temperature. Any
alternate location for this temperature measurement,
however, should be as close to the combustion zone as
is practical and must be upstream of any quench water
injection. Combustion zone temperature may be
maximized for a BEP in a number of ways, such as
maximizing the heat input from fuel and waste, or
the combustion air flow. (Minimizing
combustion air flow is not a preferred control parameter
because this approach generally conflicts with achieving
the maximum production rate requirement and the
maximum flue gas flow rate requirements for many
APCSs.)
3222 Maximum Flue Gas Temperature Entering the
PM Control Device
The temperature at the inlet to the PM control
device affects the capture efficiency of the devices. This
parameter is controlled at compliance certification under
Tiers n and HI metals compliance. If the inlet
temperature increases, the capture efficiency may
decrease for very volatile metals, such as mercury, which
may remain in vapor form and be inefficiently captured.
The inlet temperature may be maximized by regulating
control parameters, including maximum heat input from
fuel and waste, minimum heat recovery or quench water
flows, minimum air heater leakage, and minimum
combustion air flow. (Maximizing the inlet temperature
is not the preferred control parameter for the same
reason as noted above in Section 3.22.1.)
3J Estimation of Allowable Emissions
Allowable emissions for metals, HO, and
chlorine are estimated for the precompliance
certification using the tiered approach described in
Section 2.0. The Tier I feed rate screening limits* and
the Tier n emission screening limits are presented in
Appendices I-m to the BIF Rule. These screening
limits vary as a function of terrain type, land use
classification, and terrain-adjusted effective stack height
(TESH). The TESH is a value representing the stack
height that takes into consideration plume rise and local
terrain. For more information on the selection and
application of Tier n emissions limits, see Section 2.0.
Allowable emissions limits may also be
determined by performing site-specific dispersion
modeling to determine the dispersion factor for the
facility. The acceptable ambient levels for each
compound (includingnonmetal compounds), represented
by the reference air concentration (RAC) or risk-specific
dose (RSD), divided by the dilution factor, is the
allowable (Tier HI) emission rate for that compound.
Procedures for performing any dispersion modeling
analysis should parallel the procedures outlined in
Section 20.
Two limitations with regard to estimation of
allowable emissions limits should be noted. First, if the
facility has an existing air permit condition that
establishes an emission restriction, the more stringent
limit is the allowable emission limit. For example, if a
Bff\SECr03.BIF
3-4
-------
facility's air permit requires a lower emission rate for a
compound than the limit for that compound estimated
by the precompliance procedures, the permitted limit
must be used in the precompliance procedures. If the
permitted limit for a compound is less restrictive, the
precompliance procedure limit most be used to establish
the allowable limit for that compound. Second, air
emissions from all RCRA-regulated thermal treatment
systems where the parameter (e^, metals, Clj) is
controlled (under permit or interim status controls)
must be included in the assessment of allowable
emissions. Emissions from devices or systems not
covered by RCRA controls need not be included in the
estimates of allowable emissions.
3.4
Estimation of Aetna! Emissions
Emissions of metals, chlorine, chloride, and, jf
applicable. PM, can be estimated by using default
partitioning factors and APCS removal efficiencies
(REs) (discussed in Appendix DC to the BIF Rule), or
by using engineering judgment, as discussed below. The
use of a mass balance approach to estimating emissions
rates is not acceptable for the precompliance
certification.
3.4.1 Use of Engineering Judgment to Estimate
Partitioning and APCS RE Values
Engineering judgment may be used in place of
the conservative default assumptions to estimate
partitioning and APCS RE values, provided the
engineering judgment is properly documented. To
properly document engineering judgment, the
owner/operator must keep a written record of all
assumptions and '^Snfafam necessary to justify the
partitioning factor or APCS RE used. The
owner/operator must provide this record to the
Director, upon request, and must be prepared to defend
the assumptions and calculations. If the Director
believes any data or information used to support the
precompliance certification are not supportable, the
Director may request additional information, a revision
to the precompliance certification, or submittal of the
Part B permit application.
If the engineering judgment is based on
emissions testing, the testing will often document the
emission rate of a pollutant relative to the feed rate of
the pollutant rather than to the partitioning factor or
APCS RE. In this document, this concept is referred to
as the System Removal Efficiency (SRE). The SRE
combines the partitioning and APCS RE effects. The
SRE is defined as:
SRE * (species input - species emitted)/species input
The SRE can be calculated from the
partitioning factor and APCS RE by the following
formula:
SRE - 1 - [(PF/100) x (1 - APCS RE/100)]
where:
PF = percentage of the pollutant partitioned to
the combustion gas
Examples of situations where the use of
engineering judgment may be used to estimate a
partitioning factor, APCS RE, or SRE include: --
*•
• Using emissions test data from the facility to
support an SRE, even though the testing may
not meet full Quality Assurance/Quality
Control (QA/QC) procedures (e.g^ triplicate
test runs). The closer the test results conform
with full QA/QC procedures and the closer the
test conditions conform with the operating
conditions to be established in the facility's
precompliance certification, the more
supportable the engineering judgment will be.
• Using emissions test data to document an SRE
for one metal, including use of a nonhazardous
surrogate metal for another less volatile metal.
• Using emissions test data to document an SRE
from one facility to a similar facility.
• Using APCS vendor guarantees of removal
efficiency.
The measurement of an SRE or an APCS RE
may be limited by the detection limits of the
measurement technique. If the emission of a pollutant
is not detected, the calculation of SRE and APCS RE
should be based on the method detection limit. An
SRE or APCS RE of 100% is not acceptable.
An SRE (and APCS RE) may also be obtained
from test data using nonhazardous surrogate metals.
The advantage of using nonhazardous surrogates is that
because there are no interim status emissions limits on
3-5
-------
these metals, the surrogates can be spiked into the waste
at high concentrations (see Section 523.4 for guidance
on metals spiking). Surrogate metals may only be used
in precompliance tests to obtain data for generating an
SRE. The SRE may then be used to certify
precompliance or to revise the precompliance
certification limits to justify higher feed rates of
hazardous metals for use before and during the
compliance tests. Compliance certification limits would
be based on compliance test data using only the toxic
metals regulated by the BIF Rule.
Barton et al. recommend four metals with a
range of volatility temperatures for selection as
nonhazardous surrogates (2):
• Copper - 26CTF;
• Bismuth - 1150°?;
• Strontium - 169CTF; and
• Magnesium - 2070*F.
Based on volatility temperatures, copper is on
the borderline between volatile and very volatile;
bismuth and strontium are volatile for all BIFs; and
magnesium is volatile for most BIFs. None of these
metals are acceptable as surrogates for very volatile
metals. Nevertheless, since most hazardous metals fall
into the volatile category for most BIFs, there may be
cases where it is to a facility's advantage to use a
surrogate volatile metal (such as bismuth, strontium, or
possibly magnesium) to generate SREs for volatile
metals. As with hazardous metals, SREs for surrogate
metals must be documented.
3.4.2 Options When Estimated Emission Rates
Exceed Allowable Levels
If, after g«fp
"g the procedures described
above, h appears that the desired feed rate of metals,
chlorine, or ash is Bkely to result in an exceedance of
the allowable *™»ft«««H rates, the owner /operator has
several options:
• Perform a more refined emissions evaluation.
For example, if Tier I was used initially, the
owner /operator could use Tier I adjusted for
site-specific dispersion modeling or use Tier n
or Tier ID. If Tier n was used initially, the
owner /operator could use Tier m. If Tier m
was used initially but dispersion was predicted
using a screening model, the owner /operator
could consider using a more comprehensive
model.
• Conduct precompliance emissions testing to
support the use of site-specific partitioning and
APCS RE values rather than use of default
values, or to support the use of less
conservative engineeringjudgment-based values.
• Upgrade the APCS to increase removal
efficiency.
• Reduce the feed rate of the pollutant in
question.
The precompliance certification must reflect
operating conditions, with documented support, to show
that emissions are not expected to exceed allowable
levels.
3.5
Certification of Precompliance
Once precompliance limits have "been
determined based on the procedures described in
Section 33, a precompliance certification package must
be completed and submitted. Precompliance
Certification Forms PC-1 through PC-8 (contained in
Appendix B of this document) are sample forms an
owner/operator can use to document precompliance
certification. Although use of the sample forms is not
required, the forms may also provide owners/operators
and regulators with a useful tool to ensure that
precompliance documentation is complete.
3.6 Precompliance Procedures for Furnaces that
Recycle Collected PM
The BIF Rule requires owners/operators of
furnaces that recycle collected PM back into the furnace
to implement metals controls under one of three
alternatives:
• Semicontinuous stack emissions testing;
• Preconditioning before emissions testing; or
• Kiln dust monitoring.
The precompliance procedures for daily
emissions testing and conditioning before compliance
testing are the standard procedures. Facilities that
choose to monitor metals in collected PM are required
to submit additional information with their
precompliance certification. All three metals
3-6
-------
compliance alternatives for furnaces recycling PM,
including the precompliance certification requirements
for monitoring metals in collected PM, are discussed in
detail in Section 8.0.
3.7 Precompliance Procedures for Furnaces that
Feed Waste at Locations Other Than the Hot
End
Industrial furnaces that feed hazardous waste at
locations other than the hot end, which is where the
product is normally discharged or where fuel is normally
fired, are required to comply with the Tier n standard
for PIC control (Len continuous emissions monitoring
for HC, where HC may not exceed 20 ppmv) and
comply with special restrictions during interim status.
Such facilities are required to continuously monitor HC
and CO concentrations regardless of whether CO levels
meet the Tier I limit of 100 ppmv. These restrictions do
not apply if the hazardous waste is burned or processed
solely as an ingredient Required compliance
procedures for furnaces feeding waste at locations other
than the hot end, including precompliance certification
requirements, are discussed in Section 7.0.
3.8 Public Notice and Maintenance of
Correspondence File
At the time of precompliance certification, a
BIF owner/operator must have submitted notice for
publication in a major local newspaper of general
circulation. A copy of the notice must have been sent to
appropriate state and local government officials, and
evidence of submittal of the notice for publication must
have been provided to EPA.
The owner/operator must also establish and
maintain a correspondence file on site. The
correspondence file nust include, but is not limited to,
copies of all correspondence between the facility and
regulatory officials, all certifications and notifications,
and all EPA and state site visit reports submitted to the
owner/operator.
3.9
Post-PrecomDliancc Certification Activities
After certification of precompliance, an
owner/operator must continuously monitor all
parameters for which precompliance limits have been
established, perform periodic waste analyses, and
ff|gjp>»yring «tiH operating records. These
requirements are discussed in greater detail below.
3.9.1 Continuous Monitoring
A facility must continuously monitor all
parameters for which limits are established in the
certification of precompliance. The parameters may be
monitored on either an instantaneous or an hourly
rolling average basis, as described in |266.103(b)(5).
Feed rates of metals, total chloride and chlorine, and
ash are continuously monitored by multiplying the
concentration of the constituent in the feed stream by
the flow rate of the feed stream. Therefore, the flow
rate of each feed stream must be continuously
monitored. The concentration of each constituent is
found by performing routine waste analyses, as discussed
below. Guidance on continuously monitoring the total
hazardous waste feed rate, total pumpable hazardous
waste feed rate (if necessary), feed stream flow rate, and
production rate is provided in Section 4.0.
331 Waste Analysis
All fuels, raw material feedstocks, and waste
materials fed to the BIF must be analyzed as often as
necessary to ensure that the results are accurate and up-
to-date and to demonstrate that the unit operates within
the precompliance certification limits. Waste
constituents that must be measured include chlorine,
ash, and the 10 BIF-regulated metals. Guidance on
complying with waste analysis requirements is provided
in Section 6.0.
BIF\SECT03.BIF
3-7
-------
3.9.3 Maintenance of Operating Records
Records of engineering and operating data must
be made and kept until closure of the facility.
333.1 Engineering Records
Any calculations or other data used to support
SRE, partitioning factors, or APCS RE determinations
must be documented and retained in the facility's files
until closure of the BIF unit (see 56 FR 42504,
August 27,1991). This requirement also applies to any
precompliance testing results. Although not specifically
required for submittal with the precompliance
certification, regulators may wish to review such
documentation to verify the technical basis for the
operating limits established in the precompliance
certification.
3332 Operating Records
The owner/operator must maintain data and
records to demonstrate that the facility operates within
the limits certified under precompliance. Recordkeeping
requirements for continued interim status compliance
(after compliance certification) are discussed in Section
6.0. Recordkeeping requirements for the precompliance
period are identical to those for the interim status
period following certification of compliance, with the
exception that recordkeeping associated with continuous
emissions monitoring and automatic waste feed cutoffs
is required following compliance certification. If
monitors or feed cutoffs are installed during the
precompliance period, the recordkeeping requirements
also apply at that time.
3.10
of
nlli
Certification
By allowing revisions to precompliance
certifications at any time, the BIF Rule provides
flexibility for owners/operators to modify precompliance
limits. Cases in which an owner/operator may modify
precompliance limits include the following:
• The site-specific data may indicate the
precompliance limits are too restrictive.
Information obtained during interim status may
indicate precompliance limits could be relaxed.
Revising the precompliance certification would
permit the owner/operator to adjust emission
or feed rate limits, allowing greater operational
flexibility.
• A facility must modify its precompliance
certification if significant process or equipment
changes are planned.
To revise a certification of precompliance, a
revised precompliance certification package must be
submitted to the appropriate regulatory Agency. This
submission should also document the reason for the
revision.
Should a precompliance certification be revised,
the facility must operate within the limits established by
the revised precompliance certification. The facility may
begin to operate at the revised precompliance limits
when the revised precompliance certification package
has been submitted to EPA or the state, whichever is
appropriate.
BD-\SECT03.BIF
3-8
-------
4.0 COMPLIANCE INSTRUMENTS
MONITORING REQUIREMENTS
AND
To conduct measurements necessary to
demonstrate compliance with interim status standards,
an owner/operator must install equipment to
continuously monitor CO (and if required, HC) levels,
O2 levels, feed rates for all feed streams (e^, hazardous
waste, other fuels, raw materials), and various process
parameters for each BIF unit burning hazardous waste.
Addidonally, the automatic hazardous waste feed cutoff
system must be operational at the time of the
compliance test The system must automatically cut off
the hazardous waste feed when certain operating
conditions deviate from the operating limits established
in the certification of compliance. This section presents
information regarding:
• Continuous emissions monitoring;
• Process monitoring;
• Automatic waste feed cutoffs and pre-alarms;
and
• Data logging/recording.
4.1
Continuous Emissions Monitorinz
A facility must have all continuous emission
monitor (CEM) equipment in place when submitting the
notice of compliance testing, unless the Director
specifies that equipment must be installed before the
submittal (e.g., the Director may condition a case-by-
case extension request on the installation of CEM
equipment if CO/HC monitoring is deemed necessary
to protect human health and the environment). If,
however, a case-by-case time extension has been
requested, and the Director concurs that CO/HC
monitoring is not necessary for the extension period,
CEM installation may occur after August 21, 1992.
Although the regulations allow the use of temporary
(Le, portable) CEM equipment daring the compliance
test, it is preferred that a facility have the equipment
installed before the test because continuous monitoring
of CO, Oj, (and HC, if necessary) is required after the
compliance test. The CEMs are to be installed as
specified in Appendix DC to the BIF Rule. CEM
performance specifications, data corrections and
reporting, and monitoring CO and Oj in the bypass duct
are described below. Section 6.2.1 provides guidance on
CEM inspection, calibration, and maintenance.
4.1.1 Performance Specifications
4X1.1 CO and Oj Monitors
Continuous emission monitoring of CO and O:
must comply with the performance specifications
contained in Section 2.1 of Appendix DC to the BIF
Rule. The performance specifications provide criteria
that must be met by the monitoring system, but do not
indicate which type of instrument must be used or
provide design criteria for the monitoring system. A
performance test must be conducted after initial
installation, calibration, and shakedown of the monitors
and before the compliance tests, and repeated at least
annually thereafter. Requirements for daily calibration
are also addressed in the performance specifications.
Table 4-1 summarizes the performance specification
requirements for CO and O2 continuous emissions
monitors. A QA program must be established by the
BIF owner/operator to ensure that the required
calibration and performance tests are conducted ?(see
Section 6.0 for further guidance on CEM inspection,
calibration, and maintenance requirements).
4,1.1.2 HC Monitors
The method required for HC monitoring is a
modification of EPA Method 2SA (40 CFR Pan 60,
Appendix A), which uses a flame ionization detector
(FID). The modification specifies the temperature
requirements for a heated system and a sample gas
conditioning system for moisture removal in an unheated
system. Unheated systems may only be used during
interim status if a facility certifies compliance by August
21,1992 (Le., without a time extension) and the facility
explains in the certification of compliance why the use
of a heated system is not feasible.
Because of the limited demonstration of heated
systems, the BIF Rule allows owners/operators who
certify compliance with the HC emissions standard (Tier
n PIC standard) by August 21, 1992 to use an unheated
system. However, the Agency dearly prefers the use of
heated systems. The BIF Rule requires facilities that
use unheated systems to indicate, when notifying of
compliance testing, that an unheated HC monitoring
system is being used for certification and to provide
documentation on why a heated system could not be
obtained or reliably operated before compliance testing
(see sample Compliance Testing Notification Form 2
(CTN-2)). Owners/operators who certify compliance
with an unheated HC monitoring system must install a
heated system before they recertify within the required
Bff\SECT04.BIF
4-1
-------
Table 4-1
Performance Specification Requirements
for Continuous Emissions Monitors
CO Monitors
Low Range High Range
Calibration Drift (CD)
(24 hours)
Calibration Error (CE)
Response Time
Relative Accuracy (RA)b
<6 ppm
<10 ppm*
<2 min
<90ppm
< 150 ppm
<2 min
The greater of 10% of the
performance test method
or 10 ppm
O, Moaiton HC Monitors
<0.5%
-------
3-year period, revise their certification of compliance, or
conduct a trial burn under the permitting process.
The unheated HC monitoring method requires
that the moisture removal device in the sample
conditioning system be maintained at a temperature of
S*C (40*F) or above. This temperature ensures that the
moisture content of the sample gas entering the FID is
reduced to less than 2%. Different techniques of
removing moisture from the sampling stream are
available, including various designs of chillers and
condensers. Owners/operators should choose the
technique(s) best suited to their application. Scrubbers
that purge the sample gas through water or an alkaline
solution are not allowed as part of the conditioning
system because of the potential for the absorption of
organic compounds.
4.1.2 Data Corrections and Reporting
Concentrations of CO and HC in stack gas
must be continuously corrected to a dry gas basis and to
7% Oj. Procedures for making these corrections are as
follows:
1. When ambient air is used for combustion,
measured CO levels must be corrected
continuously for the amount of O2 in the stack
gas according to the formula:
where:
CO,
CO.
E
3.
CO - CO_ x
14
« corrected CO level
* measured CO level
» Oj concentration in the enriched combustion
air (e^, 30% oxygen compared with 21%
Oj in ambient air)
» measured O: concentration in the stack gas
on a dry gas basis
Corrections for O3 when monitoring HC are
made using the same procedures as those
described above for CO.
CO and HC limits are on a dry gas basis.
When instruments that measure CO and HC on
a wet basis are used, a correction factor must
be used to convert the measured value to a dry
basis. The correction factor for humidity must
be determined initially during the compliance
test and at least annually thereafter. .r
All continuous monitoring systems for
measuring CO and HC emissions must
complete a minimum of one cycle of sampling
and analysis for each successive 15-second
period and one cycle of data recording for each
successive 1-minute period. At each successive
minute, the 60 most recent 1-minute averages
must be used to calculate and record an hourly
rolling average (HRA). Both the 1-minute
average and the most recent 60-minute average
are calculated as an arithmetic average:
where:
CO.
com
Y
« corrected CO level
m measured CO level
• measured Oa concentration in the stack gas
on a dry gas basis
When O2 enriched air is used for combustion,
the corrected CO concentration must be
calculated as follows:
CO - CO_ x
14
A,.i
where:
n * number of observations
x, « individual observations
4.13 Monitoring of CO and O, in the Bypass Duct
Most dry process cement kilns with preheaters
or precalciners use a bypass duct to remove 5 to 30% of
lain off-gases to avoid buildup of metal salts that can
affect product quality. The final rule allows cement
kilns to monitor CO and O, in a bypass duct provided:
(1) hazardous waste is fired only in the kiln; and (2) a
minimum of 10% of kirn off-gas is diverted into the
BIF\SECT04.BIF
4-3
-------
bypass duct [see §266.104(g)]. The 10% diversion
requirement is based on the engineering judgment that
at this level of *"1" gas diversion, the bypass gas will be
representative of the kiln off-gas. Additional
information on CEMs and CEM operation may be
found in References 10 and 18. However, Appendix DC
of 40 CFR Part 266 take precedence if there is any
conflict.
42
Process Monitorine
Process monitoring equipment for
demonstrating continuous compliance must be in place
when compliance testing is conducted. All parameters
for which limits must be established (see Table 5-2,
Section 5232) must be continuously monitored. These
parameters include the following, as appropriate: feed
rate of total hazardous waste; feed rate of total
pumpable hazardous waste; feed rate of each of the 10
BIF-regulated metals in total feed streams, total
hazardous waste feed streams, and total pumpable
hazardous waste streams; total feed rate of chlorine and
chloride in all feed streams; total feed rate of ash in all
feed streams; maximum combustion chamber
temperature; production rate; maximum flue gas
temperature entering the PM control device; and other
APCS operating parameters that depend on the type of
APCS in use. Methods for measuring some of these
parameters are discussed in the subsections below.
4JJ Waste Feed Rate
The waste feed rate can be monitored in a
variety of ways, depending on the types of feeds
encountered. Feed rates of metals, total chlorine and
chloride, and ash are monitored by knowing the
concentration of the constituent (Le., metals,
chloride/chlorine, and ash) in each feed stream and
continuously monitoring the flow rate of each feed
stream. Constituent concentrations are determined
through periodic waste analyses (see Section 6.0 for
waste analysis requirements), and feed stream flow rates
can be monitored by the methods described below. The
feeds may be containerized or in bulk form, and may be
solids or sludges, free-flowing liquids, or gases.
42.1.1 Solid-Sludge Feeds
Typical solid/sludge measurement systems are
diftfi^^d below.
Level Indicators-These devices include those
based on mechanical, ultrasonic, nuclear, and radio
frequency principles of operation. Nearly all tank level
indicators will perform best with uniform (free-flowing)
particles. Level indicators aid in distributing the
material evenly within the vessel, allowing for greater
monitoring system accuracy. Typically, these methods
can measure tank levels to within ±1%. Care must be
taken when using such systems to account for changes in
the composition of the feed (i.e., density, moisture).
Stationary Weight Indicators-These devices,
which include weigh hoppers/bins and platform scales,
determine the dead weight of material loaded into a
hopper, bin, or container. After weighing, the contents
are then fed as batches into the process. All of these
weigh systems give fairly precise monitoring of weight
(within ±1%).
Conveyor Weighing Systems-These methods
include belt weighers, weigh belt/augers, and loss-in-
weight feeders. All conveyor weighing systems are fairly
timilar in operation, mainly differing in the location of
the weighing device. In general, the precision of these
systems is approximately ±2%, but tends to decrease as
particles become larger and less uniform in size.
Sludges can be monitored with the systems, provided
that any free liquids can be contained. Screw augers can
often be used in such cases to replace the conventional
conveyor belt
Volumetric Methods-These methods include
calibrated augers and pumps, rotary feeders, and belt
conveyors. These systems are not generally
precalibrated by the manufacturer and therefore must be
calibrated by the user for each particular feed material.
The accuracy of the method depends on steady
operation at a given speed and assumes appropriate
feeders are used to ensure the cavities are always filled
to capacity. Most of these methods use a tachometer
signal to indicate speed, which must be related to the
feed rate by performing calibration tests. These
methods are generally more appropriate as secondary
indicators of feed rate.
Momentum Flowmeters-Two types of solid
flowmeters are available: impact or torque. These
devices work fairly well with dry, flowable materials but
are less accurate if feed particles are very large,
nonuniform, or viscous. The typical precision is within
±2%. Flowmeters are not recommended for use with
sludges because of their viscosity and splashing effects.
Nuclear Absorption-Methods based on
absorption of gamma radiation include nuclear level
Bff\SECT04.BIF
4-4
-------
meters, nuclear belt or auger scales, and a combination
of nuclear density meters and ultrasonic flowmeters.
Nuclear absorption only measures density, therefore,
another instrument must also be used to measure
volume, speed, or another parameter to obtain the feed
rate. Nuclear instruments can be used on nearly any
material including sludges. Radiation absorption is
proportional to the mass present, so that particle size
and configuration do not greatly hinder accuracy.
Sludge operations work best with a nuclear density
detector/ultrasonic flowmeter combination, enabling the
process material to be fed through conventional piping.
Nuclear devices may not be as precise as in gravimetric
systems, but may be sufficient on a practical basis.
42.12 Liquid Feeds
Typical flowmeters used to monitor liquid feed
rates are detailed below.
Rotameter-This type of flowmeter is suitable
for a wide range of liquid viscosities, including some
light-weight slurries. It is calibrated using a fluid of
known density. The reported precision is within ±5% of
full-scale.
Orifice Meter-This instrument is used with
gases and low-viscosity fluids. When used with clean
fluids, the typical precision is ±1% of full-scale. When
used with dirty or viscous fluids, both the precision and
life of the instrument are decreased. A precision of
±5% of full-scale may be more realistic in these cases.
Vortex Shedding Meter-This device is
applicable to low-viscosity fluids and gases under
turbulent flow conditions. The precision is ±2% during
normal operations.
Positive Dtspbcenent Meter-This type of
flowmeter is better suited than other flowmeters for use
with higher viscosity fluids; however, accuracy is highest
when used with a clean, moderately viscous fluid. It
cannot be used with multiphase liquids, gases, or slurries
of varying density.
Mass Flowmeter-This instrument, also known
as a Coriolis flowmeter, applies to liquids of widely
varying viscosity and density, and to most slurries. It has
been advertised for use with gases, but that application
may be rare. The reported precision is within ±1%.
42.13 Gascons Feeds
The best types of flowmeters for measuring
gaseous feeds are the orifice meter and the Vortex
shedding meter, disfyiuf^ above under liquid feeds.
422 Combustion Temperature
Combustion temperature is usually monitored
through the use of thermocouples, optical pyrometers, or
both. Because it is difficult to reliably measure the
combustion zone temperature in many BIFs, another
sampling location within the combustion chamber can be
used as an indicator of combustion zone temperature;
however, this temperature measurement location should
be as dose to the combustion zone as possible and must
be upstream of any quench water injection. Since
temperature limits will be established based upon levels
measured during the compliance test or trial burg, the
consistency of the relationship between the measured
temperature and the combustion zone temperature is
more important than the accuracy of the combustion
zone temperature measurement itself. The location and
method used to monitor the combustion zone
temperature should be clearly documented in the
facility's compliance certification.
422.1 Thermocouples
Thermocouples are available in a variety of
types, with each type constructed of specific metals or
alloys. The temperature ranges and reported accuracy
vary by type. The environment for which the
thermocouple is suited also varies. A summary of
thermocouple types and limitations is given in Table 4-2.
The accuracies given in Table 4-2 do not
consider environmental effects. Thermocouple location
in the combustion chamber, for example, greatly affects
the accuracy of temperature readings. Typically,
thermocouples are located at the gas exit from the
combustion chamber to give the best overall average
combustion chamber temperature. The following factors
should also be considered when »»«n»ning thermocouple
locations:
• Temperature readings will be affected by
radiant pickup or loss if the thermocouple is
located close to and within a direct line of sight
of either the flame or the cold quench chamber.
-------
Table 4-2
Types of Thermocouples
Type
J
E
K
S
R
B
Materials of Construction
Iron/Constantan
Chromel/Alumel
90% Pt-10% rhodium/pure Pt
87% Pt-13% rhodium/pure Pt
70% Pt-30% rhodium/94% Pt-
6% rhodium
Upper
Temp.
CF)
1400
1650
2300
2650
2650
3100
Accuracy
75
50
75
25
25
50
Environment
Reducing, vacuum, or
inert
Oxidizing or inert
Oxidizing or inert
Oxidizing or inert (no
metal tubes)
Oxidizing or inert (no
metal tubes)
Oxidizing or inert (no
metal tubes)
Source:
Complete Temperature Measurement HandtvyA and Encyclopedia (12).
4-6
-------
• To improve the accuracy aod limit wall effects,
the thermocouple well should extend 3 to 6
inches beyond the refractory and should be
located where the gas velocity is high, and not
in a stagnant corner of the chamber.
The use of two thermocouples in separate wells
is recommended to provide a check on continued proper
operation. The difference in the readings between the
two thermocouples should be noted during initial
operation, and should then be checked periodically as an
indicator of problems with one of the thermocouples. If
the difference changes by more than 50*F, both
thermocouples should be checked for proper operation.
Following the above guidelines allows for some
degree of consistency in measuring the combustion
temperature in a BIF. Changes in either the
thermocouple type or location should prompt
reconsideration of the representativeness of the
measurement
4.2.2.2 Optical Pyrometers
Optical pyrometers are typically used to
measure the temperature of the furnace wall or an
object within the furnace but also can be used to
measure the combustion gas temperature. In cases
where measurement of the gas temperature is desired,
the pyrometer is normally equipped with a closed end
tube (much like a thermocouple well, but larger), and
the pyrometer is sighted on the end of this tube. In this
situation, emissivity corrections are not needed. This
configuration is normally used for high temperatures
when contamination or breakage of thermocouples is a
problem and the cost or difficulty of replacement is
high. The pyrometer wfll normally require calibration,
but, when calibrated, should be approximately as precise
as a thermocouple. The effects of cement kiln dust
loadings should be considered when calibrating the
pyrometer. In most cases, however, kiln dust is not
anticipated to adversely affect the ability of the
pyrometer to detect changes in combustion zone
temperature. (Acoustic pyrometers may be appropriate
for monitoring combustion zone temperature in certain
circumstances.)
423 Production Rate
The BIF Rule establishes an operating limit
during interim status on the maximum production rate
of the BIF device, in appropriate units, when producing
normal product.
Depending on the facility and on measurement
capabilities, the •appropriate units" for measuring
production rate may be represented as the raw materials
feed rate, thermal input, or production rate. For
example, a boiler may measure usable steam production
and a cement kiln may measure clinker production.
These production rates could be monitored using the
came techniques described in Section 42.1 for
measuring waste feed rates.
4.2.4 Flue Gas Temperature
Control Device
Entering the PM
The temperature of the flue gas entering the
PM control device must be monitored through the use
of temperature monitoring devices such as
thermocouples or optical pyrometers, as described in
Section 422.
42JS APCS Operating Parameters
Unless complying with Tier I or adjusted Tier
I metals feed rate screening limits and the Tier I or
adjusted Tier I total chlorine and chloride feed rate
screening limits, various APCS-specific operating
parameters must be monitored. Table 4-3 describes the
operating parameters that must be monitored for each
APCS and provides guidance on monitoring instruments.
Other APCSs not explicitly mentioned in the BIF Rule
may require different monitoring and interlock
parameters, as determined on a case-by-case basis.
42.6 Floe Gas Flow Rate
The flue gas flow rate can be determined by
multiplying the flue gas velocity at a given location by
the corresponding cross-sectional area of the duct or
stack. Direct measurement of flue gas velocity can be
accomplished using a pitot tube, annubar, or other
similar direct measurement device. Most facilities locate
a velocity indicator after the APCD to avoid several
potentially significant problems with velocity
measurement These problems include deterioration of
the probes because of high temperature, plugging of
openings in the probe by paniculate matter in the gas,
and stratification of gas flow that makes it difficult to
locate the probe at a point of average velocity. These
problems are sufficient to cause major inaccuracies in
velocity measurement and may cause the indicator itself
to be out of service. The subsections below provide
guidance on indirect measurements of gas velocity.
BIF\SECT04.BIF
4-7
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Table 4-3
APCS-Specific Operating Parameters Which Must be Monitored
APCS
Wet scrubber (including wet
ionizing scrubber)
Venturi scrubber
Dry scrubber
Wet ionizing scrubber or
electrostatic precipitator
Fabric filter
Operating Parameter
• Scrubber liquid-to-gas
(L/G) ratio
• pH of scrubber effluent
• Scrubber blowdown or
suspended solids content of
scrubber water
• Gas pressure drop across
venturi
• Caustic feed rate
• Flue gas flow rate
• Electrical power in kVA to
the precipitator plates, as
measured on the secondary
(high-voltage) side of the
transformer1
• Flue gas flow rate
• Minimum pressure drop
Monitoring Instruments
Liquid flow • see discussion on
flowmeters for liquid feeds, see
Section 42.1; gas flow - see
Section 4.2.6
pH meter
Scrubber blowdown • liquid
meter, see Section 42.1
Suspended solids content of
scrubber water - density
transmitter
Pressure taps on each side of
venturi connected to a A?
transducer
See Section 4.2.1
See Section 4.2.6
Voltage - voltmeter
Current - ampmeter
See Section 42.6
Pressure taps on each side of
fabric filter connected to &P
transducer
The unit of measurement specified in the BIF Rule (§266.103(c)(l)(xii)(A)) is kilovolt-amperes (kVA).
However, there is a phase angle (6) between the voltage (kV) and the current (A) because of variable
inductive or capadtive loads in an ESP. The actual power going to the precipitator plates is therefore kVA
times the cosine of the phase angle (©). This product is known as kilowatts (KW). EPA is considering
incorporating this clarification as an amendment to the BIF Rule.
4-8
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Pressure Drop Across Flow Restriction
Measuring the pressure drop across a flow
restriction such as an orifice plate or venturi chamber is
an indirect measurement of gas velocity. A typical
location of the flow restriction would be in the duct
immediately following the combustion chamber, where
an orifice plate or flow nozzle can be inserted through
a flange, or the entire duct can be tapered into a venturi
section. Pressure taps are then fitted on both sides of
the flow restriction and connected to a *P transducer.
Practical application of this method may be somewhat
limited. The pressure taps can plug with dirt or
corrosion, and other physical phenomena may inhibit
performance of the instruments. The feasibility of
actually instiling an orifice plate or venturi duct may
also be a limitation. Finally, the high pressure drops
caused by the flow restriction itself may increase facility
operating costs.
4J.6J Combustion Air Velocity
A measure of the combustion air feed rate to
the combustion system is another potential indicator of
flue gas velocity. Pitot tubes, annubars, or orifices are
commonly used for this purpose. In principle,
combustion air velocity can be directly related to flue
gas velocity as a function of fuel composition and excess
air levels. Combustion air measurements are
particularly well suited to forced-draft combustion
systems.
4263 Combustion Chamber Pressure
Use of combustion chamber pressure as an
indicator of flue gas flow has limited application at best.
Use of this indicator may be limited to facilities that use
forced- or natural-draft systems. Many facilities with
induced draft (ID) CMS control the fan to achieve a set
combustion chamber pressure or draft. Thus, the draft
is a set variable that wffl remain relatively constant, and
will therefore not indicate variations in flue gas flow.
For example, when a variable throat in a venturi
scrubber is restricted, the gas flow rate and velocity will
decrease even though the pressure in the combustion
chamber remains unchanged. In addition to the above
limitation, combustion chamber pressure is limited as an
indicator of the flue gas flow because it is measured
upstream of the APCD and does not account for the
factors (e.g., air leakage, moisture gain/loss) mentioned
above.
4.2.6.4 Fan Conditions
One indirect method often used as an indicator
of flue gas flow is the monitoring of the induced draft
fan operating conditions. If the gas stream passing
through the fan is the same as or is directly related to
the gas stream passing through the APCD, the fan
operation can be used as a flue gas flow indicator.
Throughput of a fan can be directly linked to
measurable fan parameters, including:
• Fan speed;
• Air density (a function of gas temperature,
absolute pressure, and molecular composition);
• Fan differential (total, velocity, and/or static);
and *r
* «
• Fan power.
Fan manufacturers' performance curves and/or fan laws
are then used to determine the throughput. If the fan
speed and gas density are constant, the monitored
parameter is typically either horsepower (via fan motor
kilowatts or amperes) and/or differential pressure. If
the fan speed and/or gas density are variables, the most
direct approach is to monitor both the horsepower and
pressure and to use fan laws to determine the
volumetric throughput. Other fan parameters may also
be monitored and different fan laws used to determine
flow, however, these alternatives may be more
complicated or less reliable.
43 Automatic Waste Feed Cutoffs fl"d Pit-Alarms
43 J. Requirements for Automatic Hazardous Waste
Feed Cutoff
Facilities operating under interim status are
required to have automatic hazardous waste feed cutoff
systems that engage immediately when operating
conditions deviate from those established during
compliance testing and specified b the compliance
certification. Procedures for determining compliance
limits from the compliance test are presented in
BIF\SECTW.BIF
4-9
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Section 5.0. Operating parameters connected with
automatic waste feed cutoff are:
• Maximum CO concentration in the stack
exhaust gas (100 ppmv under Tier I or based
on compliance test under Tier n);
• Maximum HC concentration in the stack
exhaust gas (20 ppmv), when HC monitoring is
required;
Maximum production
compliance test);
rate (based on
• Maximum feed rate of total hazardous waste
(based on compliance test);
• Maximum feed rate of pumpable hazardous
waste14 (based on compliance test);
• Maximum combustion chamber temperature14
(based on compliance test);
• Maximum flue gas temperature entering a PM
control device14 (based on compliance test);
• Limits on key APCS operating parameters that
must be monitored. These limits are based on
the compliance test, except that minimum
pressure drop across a fabric filter is based on
manufacturer's specification.
Monitoring of all parameters must continue
after a cutoff for any reason and the hazardous waste
feed cannot be restarted until parameters limited by the
certification of compliance comply with limits established
in the certification of compliance. In addition, to
minimi?* emissions of organic compounds after a cutoff,
the minimum combustion chamber temperature that
occurred during the compliancy test must be maintained
for the duration of the time the hazardous waste or
hazardous waste residues remain in the combustion
chamber (see §266.103(g)(l)).
432 Recommendations for Pre-Alarm Systems
422.1 Objectives of a PR-Alarm System
Automatic hazardous waste feed cutoff
occurrences, though necessary to minimi?.* out-of-
compliance operations, are undesirable for several
reasons. First, these cutoffs may contribute to short-
term HC emissions excursions. Second, as with any
disruption in fuel supply, cutoffs may create safety
problems that must be handled by the combustion
control and control interlock system. Third, the time
period between waste feed cutoff and re-establishment
of waste burning represents an increase in the use of
fossil fuel, and a lost opportunity for safe disposal of
hazardous wastes. Therefore, it is clearly in the
owner/operator's interest to minimirr automatic waste
cutoff incidents.
Section 43.1 identifies parameters that trigger
an automatic hazardous waste feed cutoff. Although
events can occur suddenly and without warning to" cause
waste feed cutoffs, certain situations also exist that result
in a slow deterioration of combustion efficiency and
APCS performance. For some of these conditions, it
may be possible for owners/operators to avoid waste
feed cutoffs by using pre-aianns on certain parameters,
followed by corrective measures taken by operating
personnel
This discussion of pre-alarms is necessarily
general, as it is not possible to address every combustion
device/fuel/control system combination that might be
used to combust hazardous waste. Some of the concepts
discussed can be broadly applied, and all require site-
specific examination by the owner/operator. Also, site-
specific determination of pre-alarm levels is necessary.
4222 Candidates for Pre-Alarm Parameters
In planning a pre-alarm system, the
owner/operator must consider the ease, accuracy, and
reliability of measuring each candidate pre-alarm
parameter and must assess the usefulness of the
"Not applicable if complying with the Tier 1 or adjusted Tier I metals feed rate Kreeniog limits.
BIF\SECr04.BIF
4-10
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parameter as an indicator of conditions that are
correctable through operator actions. Candidates for
consideration as pre-alann indicators include:
CO levels;
HC levels;
Oj levels;
Production capacity,
Combustion chamber temperature;
Hazardous waste feed flow rate;
Flue gas flow rate;
PM control device inlet temperature; and
Other APCS parameters.
Of these parameters, CO, HC, and O2 levels, as
well as combustion chamber temperature, are potentially
useful in preventing excessive HC emissions. Emissions
of metals and HC1 are primarily affected by APCS
operations and excessive waste feed and flue gas flow
rates. The use of CO levels as a pre-alann parameter
is discussed in the example given below.
Example for an Approach for a Pre-Alarm
System Based on CO Levels-For virtually any
controlled-combustion device, and particularly for
boilers, the CO concentration in the flue gas is an
extremely useful and sensitive indicator of the
effectiveness with which the device is converting the fuel
to carbon dioxide and water. CO is, in effect, the first
major PIC to appear as 'good" combustion deteriorates
to incomplete combustion. For this reason, and because
monitoring technology is well established, CO monitors
are widely used for boiler tuning and combustion
control. Audible and visual CO alarms can readily be
used to alert the operator to carry out certain system
checks aimed at restoring good combustion conditions,
and thereby reduce CO emissions to normal levels.
Prc-Alarm CO Setpolnts-Establishing pre-
alann levels is a kite-specific activity requiring
observation of the normal CO variations due to control
oscillations and load changes. Consideration should also
be given to establishing pre-alann set points for both
HRA CO and for instantaneous CO readings.
Therefore, the determination of pre-alann setpoints
should be based on trial-and-error testing. If the
setpoints are selected at levels that are too low, the
incidence of false pre-alann signals will be high.
Setpoints too close to the automatic waste feed cutoff
point will not permit sufficient time for the operator to
conduct the necessary checks needed to discover the
problem and take corrective measures. A good starting
point for trial-and-error testing of pre-alann setpoints is
the midpoint between a low HRA CO level, obtained by
closely monitoring 'good* combustion, aad the automatic
waste feed cutoff CO level The appropriate
instantaneous or short-term setpoint can only be
determined through observation of the CO behavior
during normal operation.
Operator Responses-The owner/operator
should respond to a pre-alann signal by carrying out a
series of checks aimed at delecting problems that could
be the cause of a rise in CO levels. Problems that cause
gradual loss of good combustion conditions can arise
from vibration, wear or fouling of burner parts, ambient
temperature and humidity changes, controller drift, load
changes, and changes in the physical characteristics and
heat content of the feed stream.
While an operator's specific CO pre-alann
response procedure should be developed in consultation
with the BEF vendor or a qualified combustion engineer,
there are some general guidelines that apply to n)any
BIFs, particularly boilers. These include:
• Visual flame observation. The appearance of
the flame and the condition of the burner area
can provide important information to the
operator. It is possible to detect plugged or
worn burner tip orifices, damaged diffusers, and
burner throat refractory damage. It is also
possible to make a fairly reliable determination
of whether the CO increase is arising from an
overall lack of O2 or from individual burner
problems.
• Air/fuel ratio controller. If the flame
observation indicates an overall O2 deficiency,
the operator should increase the air bias on the
air/fuel ratio controller. If CO readings do not
immediately drop, the operator should then
inspect the BIF for other air-related problems,
such as:
- Sticking, broken, or maladjusted
controls and linkage for air registers;
— Broken or maladjusted control damper
linkages; or
- Pluggage of the combustor air system
(e.g., paper or other windborne debris
on the air inlet screens).
Bff\SECr04.BIF
4-11
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• Fuel and burner corrections. For multi-burner
units and modern single-burner units equipped
with a spare oil-gun guide tube, it may be
possible to maintain good fuel and waste fuel
combustion while cleaning a plugged burner dp
or replacing an eroded dp. For waste fuels
containing substantial amounts of suspended
solids, tip pluggage and erosion could be a
recurring problem, and procedures for on-line
oil gun removal and dp cleaning are important.
Other fuel-related checks include fuel delivery
pressure, atomizing air or steam pressure, and
if fuel pre-heat is used, fuel temperature. In
some cases, homogeneity of the feed stream
can be increased by better blending practices.
Pulverized coal (PC) systems can be checked
for pulverizer outlet temperature and pressure;
however, many fuel-related problems for PC
systems are not amenable to on-site corrections.
4v4 Data Logging ^Recording
A typical data logger/control system suitable for
use with BDFs is composed of two parts: a data
logger/receiver and an input/controller. The first
component, the data logger/receiver, is directly
interfaced with various field monitors, such as
thermocouples, continuous emission monitors, flow
meters, and pressure gauges. The logger receives inputs
from the various instruments, typically on a 4-20 mA or
0-1 V scale. The logger, previously calibrated for each
instrument's electrical input, interprets the signal and
produces an output field measurement in the
appropriate units of degrees, flow rate, pressure, ppm,
percent of scale, etc. Most loggers also calculate hourly
and daily averages, set off alarms when set points are
exceeded, trigger cutoffs when permit limits are
exceeded, and perform additional data reduction
functions.
The second component, the input/controller, is
used as a means of adjusting process setpoints and
otherwise changing the process. Laboratory and field
data from the facility can be input into the computer
system, and process adjustments are made accordingly.
A typical facility collects data on such waste feed inputs
as ash content, heating value, total organic chlorine,
specific gravity, and viscosity. These values are input
into the computer, where they are logged along with the
process data, and process adjustments are automatically
made with each update on these parameters.
BD?\SECr04.BIF 4-12
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5.0 COMPLIANCE CERTIFICATION
ACTIVITIES
This section discusses specific requirements and
procedures which must be followed to certify compliance
with emissions standards under the BIF Rule. The
section is organized as follows:
• Compliance Schedule (Section S.I);
• Preparation of the Compliance Test Plan
(Section 52);
• Determination and Certification of Interim
Status Operating Limits (Section 53); and
• Options in the Event of Noncompliance
(Section 5.4).
5.1
Compliance Schedule
By August 21, 1992 or by the applicable date
allowed by an extension under §266.103(c)(7),
owners/operators of BIF facilities burning hazardous
waste must conduct compliance testing and submit a
certification of compliance with the emissions standards
for individual metals, HC1, CL., particulates, and CO,
and, where applicable, HC and dioxins/rurans.
Compliance testing must be conducted within the
operating limits established in the facility's certification
of precompliance.
If the owner/operator does not submit the
certification of compliance by August 21, 1992, he/she
must:
(1) Notify the Director that an automatic 12-month
extension to the compliance certification
deadline is being taken during this period, limit
hazardous waste burning to a total of 720
hours, and submit a complete certification of
compliance by August 23, 1993; or
(2) Obtain from the Director a case-by-case
extension of time for submittal of the
compliance certification if compliance with the
time limit is not practicable for reasons beyond
the control of the owner /operator; or
(3) Stop burning hazardous waste and begin closure
activities for the hazardous waste portion of the
facility.
Owners and operators must conduct compliance
testing and recertify compliance at least every 3 years
while operating under interim status. If the
owner/operator misses any of the certification deadlines,
all hazardous waste burning must cease as of the date of
the missed deadline, and closure activities must begin.
In this situation, a facility may not resume burning
hazardous waste except under an operating permit.
Figure 5-1 provides a flow chart for compliance
certification activities.
5.2
Preparation of the Compliance Test Plan
5 J.I Objective of the Test
The primary objective of the compliance test is
to demonstrate that emissions from a BIF are below the
EPA allowable limits while burning hazardous wastes at
the proposed operating limits. This objective can also
be met using compliance test data from a similar on-site
facility in lieu of a compliance test, as discussed in
Section 53-5. The compliance test results will be'ftsed
to establish operating limits that will remain in effect
until the facility conducts another compliance test or
obtains an operating permit, whichever comes first. The
operating conditions during the compliance test should
be selected such that the resulting operating limits yield
the maximum operating flexibility.
5.2.2 Notification of Planned Compliance Test
To ensure adequate test planning a compliance
test notification package under §266.103(c)(2) must be
submitted to the Director at least 30 days before the
scheduled start date of the compliance test. Complete
copies of the test protocol and Quality
Assurance/Quality Control (QA/QC) plan must be
included in this package. The test protocol and QA/QC
plan detail all planned testing and serve as a written test
guide, ensuring that sampling is conducted properly, that
testing activities are coordinated, and that nothing is
overlooked or omitted. (Sampling and analysis
procedures, spiking procedures, personnel qualifications,
and test scheduling should be included in the compliance
test notification package.) Compliance Test Notification
Forms CTN-1 through CTN-4, provided in Appendix C,
are sample forms an owner/operator may use to meet
the requirements of the compliance test notification.
BIF\SECTQ5.BIF
5-1
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NoMyEPA
•ndl^in CtoM*
Figure 5-1. Options in the Event of Noncompliance
5-2
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While the information requested on the sample
forms must be submitted (under §266.103(c)(2)), use of
these particular forms is not mandatory. A complete
listing of all required information is provided with the
sample forms in Appendix C. Section 523 provides
guidance on compliance test design. Aa owner/operator
does not need to wait to receive approval of the
compliance test plan. Unless otherwise notified by EPA,
the facility should proceed with the test according to the
test protocol submitted with the compliance test
notification package.
523 Test Design
A summary of the information to be included in
the compliance test protocol is presented in Table 5-1
and summarized below.
523.1 Number and Duration of Tests
The test protocol should define the number and
duration of tests the facility plans to conduct. The
following discussion highlights these requirements.
Number of Test Runs-To demonstrate
compliance with emission standards, a minimum of three
valid test runs should be conducted at each test
condition. If the facility routinely conducts activities
which could result in a short-term increase in paniculate
emissions (e.g., soot blowing, see Section 523.9), the
first two runs should be conducted at "normal1'
compliance test operating conditions (without soot
blowing), and the third run should be conducted under
operating conditions that will result in the highest short-
duration PM emission rate expected to occur during the
regular operating day. If the facility does not routinely
conduct soot blowing or other activities that would
increase emissions, the third run should be conducted at
normal operating conditions.
If a facility conducts more than three test runs
at a single test condition, aQ runs must be reported and
are considered part of the pass/fail determination unless
a specific reason is identified that invalidates a run.
Additionally, all test runs conducted at compliance test
operating conditions (without soot blowing) must pass
all of the applicable limits. If any of these runs exceed
a limit for PM, HC1, Cl,, CO, HC, dioxins/furans, or
any metal, the facility fails the test and cannot operate
under those failed conditions. Unless the facility passed
the test for other operating conditions (and can
therefore operate under those conditions), it must
immediately revise the operating conditions associated
with the exceedances of the limits(s), submit a revised
certification of precompliance, and certify compliance
within the applicable time deadline.
Duration of Test Rnns-The duration of each
test run is specific to the stack sampling procedures
employed and is discussed as part of the sampling and
analytical procedures. However, certain guidelines can
be used to determine the general duration of a test run.
Manual methods, such as Method S, 40 CFR Pan 60,
Appendix A for particulates, and the EPA Multiple
Metals Train, 40 CFR Pan 266, Appendix DC, take an
average of 2 to 4 hours to complete, including the time
necessary for port changes and leak checks. To
complete three runs at a given test condition, allowing
time for set-up between runs, a minimum of 8 to 10
hours generally will be required. Obviously, more time
may be required if the facility experiences operating or
testing difficulties.
Sampling for CO, O2, HC, and other
continuously monitored parameters, such as combustion
chamber temperature, must be coordinated with, the
measurement of the other pollutants. During each test
run involving measurement of continuously monitored
parameters, a minimum of 180 continuous 60-minute
averages (Le., 3 hours of data) should be obtained. Test
conditions during this test period should be as uniform
as possible. If the three test runs are conducted
consecutively (i.e., without interruption in operating
conditions), a minimum of 10 hours of continuously
monitored data will usually be required: the first hour
to initiate the first hourly rolling average, and then 3
times 3 hours (a total of 9 hours) of continuous 60-
minute rolling averages.
The owner/operator should consider the length
of sampling runs and the overall expected length of the
compliance test when determining the amount of test
wastes and spiking compounds to have on hand. A
conservative estimate of the amount of waste necessary
for each test run and the total amount of waste
necessary must be included in the test protocol.
Additional guidance on planning the test schedule may
be found in Reference 30.
5232 Operating Conditions
Identification of Key Operating Parameters-
Table 5-2 presents key operating parameters for which
BIF\SECTO.BIF
5-3
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Table 5-1
Contents of the Compliance Test Protocol and QA/QC Plan
Compliance Test Protocol
• Identification of key personnel involved in the compliance test, including responsibilities and qualifications.
• For each test condition, description of the following:
- Purpose of test (e.g., to demonstrate compliance with PM, metals, HO, and Clj emission limits when firing
sludges at maximum feed rate and operating at maximum flue gas flow rate);
. Number and duration of test runs;
- Each fuel, raw material, and waste to be fed to the BIF unit(s). Description must include both spike and
normal feed materials and must state, at a minimum the HgaHng value, feed mechanism, and total feed rate of
each feed stream;
- Spiking procedures;
- Planned feed rates of ash*, chlorine and chloride, and each of the 10 BIF-regulated metalsb in:
(i) Each feed stream,
(ii) Total feed streams,
(iii) Total hazardous waste feed streams0,
(iv) Total pumpable hazardous waste feed streams''*; and
- Target levels for all process operating parameters for which limits will be established during compliance test.
• Description of all sampling and monitoring procedures, including a list of all parameters to be monitored and *
reported.
QA/QC Plan
• QA objectives for precision, accuracy, and completeness;
• Sampling and monitoring procedures;
• Sample handling custody, and holding times;
• Calibration procedures and frequency,
• Analytical procedures;
• Specific internal QC checks;
• Data reduction, validation, and reporting procedures;
• Maintenance procedures and schedules for all critical equipment necessary to maintain interim status operating
conditions and to document continuing compliance;
• Assessment procedures for accuracy and precision; and
• Audit procedures, corrective action, and QA reporting.
Teed rate of ash is not limited for cement kilns and light-weight aggregate loins.
Planned feed rate of ash and total chlorine and chloride need only be documented for total feed streams.
'Not applicable if complying with Tier I or adjusted Tier I metals feed rate screening limits.
'The BIF Rule (56 FR 7134, February 21,1991) specifies that facilities complying with Tier I or adjusted Tier I metals
feed rate screening limits must establish a compliance limit on the feed rate of each metal in total pumpable waste feed
streams (§266.103(c)(l)(ii)). EPA is considering rescinding this requirement by considering amending
§266.103(c)(l)(ii)(C) to read Total pumpable hazardous waste feed (unless complying with the Tier I or adjusted Tier I
metals feed rate screening limits under §266.106(b) or (e))."
5-4
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Table 5-2
Key Compliance Operating Parameters
Key Operating Parameters for Which Compliance Limits Must Be Established
Feed rate of each of the 10 BIF-regulated metals in:
— Total feed streams (except that industrial furnaces that must comply with the
alternative metals implementation under §266.103(c)(3)(ii) must specify limits on the
concentration of each metal in collected PM);
— Total hazardous waste feed streams (unless complying with Tier I or adjusted Tier I
metals feed rate screening limits under §266.106(b) or (e)); and
— Total pumpable hazardous waste feed streams.*
Total feed rate of chlorine and chloride in total feed streams.
Total feed rate of ash in all feed streams (except for cement and light-weight aggregate kilns).
Feed rate of total hazardous waste, and (unless complying with the Tier I or adjusted Tier I
metals feed rate screening limits) feed rate of total pumpable hazardous waste.
Maximum production rate when producing normal product.
CO concentration (limit is 100 ppmv unless using Tier n), and where required, HC
concentration (limit is 20 ppmv only for Tier n) in stack gas.
Maximum combustion chamber temperature (unless complying with Tier I or adjusted Tier I
metals feed rate screening limits under §266.106(b) or (e)).
Maximum flue gas temperature entering the PM control device (unless complying with Tier I or
adjusted Tier I metals feed rate screening limits under $266.106(b) or (e)).
Limits for other specified APCS operating parameters under §266.103(c)(2)(a)-(xiii) (unless
complying with Tier I or adjusted Tier I for metals and total chlorine and chloride).
The BIF Rule (56 FR 7134, February 21,1991) specifies that facilities complying with Tier I or adjusted
Tier I metals feed rate screening limits must establish a compliance limit on die feed rate of each metal in
total pumpable waste feed streams ($266.103(c)(l)(u)). EPA is considering rescinding this requirement by
amending §266.103(c)(l)(ti)(C) to read Total pumpable hazardous waste feed (unless complying with the
Tier I or adjusted Tier I metals feed rate screening limits under §266.106(b) or (e)).*
5-5
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limits must be established during the compliance test.
During the compliance test, operating levels for these
parameters must be within the precompliance
certification operating limits. However, compliance
limits will be set from compliance test operating
conditions, not from the precompliance limits. The
owner/operator should establish the compliance
certification limits at levels that will accommodate the
entire range of operating conditions expected during
present and future operations.
The maximum exposure to the MEI for metals,
HQ, or Clj can occur at other than maximum operating
conditions. For example, due to reduced flue gas flow
rate, temperature, and plume dispersion, higher ambient
impacts can occur in complex terrain when operating
below the maximum operating levels. The requirements
for determining the operating conditions resulting in the
maximum ambient impacts are discussed in Section 2.0.
The following discussion presents methods the
owner/operator can use to optimize the operating
parameters listed above. Other methods of controlling
compliance parameters may be appropriate in certain
cases.
Maximum Feed Rate of Each Hazardous
Metal-Typically, metal emission rates increase as the
feed rate increases. There are three levels of metal feed
rate parameters:
• Maximum combined feed rate of each
hazardous metal in all feed streams. This
includes raw materials, fuels, hazardous wastes,
and all other feed streams into the BIF.
• Maximum combined feed rate of each
hazardous metal in all hazardous waste feed
streams (not applicable if complying with Tier
I or adjusted Tier I metals feed rate screening
limits) This includes all hazardous waste feed
streams, but excludes any feed streams that are
not hazardous wastes.
• Maximum combined feed rate of each
hazardous metal in all pumpable hazardous
waste feed streams (typically low solids-content
liquids, rather than nonpumpable wastes, which
are typically sludges and solids).
These parameters are controlled by monitoring
•'•: feed rates and individual metal concentrations of the
various waste streams. Spiking can be used to further
increase metal feed rates. Guidance on metals spiking
is provided in Section 5.2.3.4.
Maximum Combined Feed Rate of Chlorine
and Chloride in All Feed Streams-Typically, the HC1
and Clj emission rate increases as the chlorine feed rate
increases. This compliance parameter is controlled by
monitoring chlorine concentrations in feed streams and
feed rates of feed streams. Spiking can be used to
further increase the chlorine feed rate. The compliance
limit is for total (organic and inorganic) chlorine;
however, with the exception of chlorides of hazardous
metals, only organic chlorine may be spiked to raise
chlorine feed rates in compliance tests.
Maximum Combined Feed Rate of Ash in All
Feed Streams-Typically, the PM emission rate increases
as the ash feed rate increases. The parameter is
controlled by monitoring ash concentrations in feed
streams and feed rates of feed streams. Spiking can be
used to further increase the ash feed rate. _This
compliance parameter does not apply to cement kilns or
light-weight aggregate kilns because the normal* raw
materials fed to these devices contain a high ash
content.
Maximum Hazardous Waste Feed Rate-There
are two levels of waste feed rate parameters:
• Maximum combined feed rate of all hazardous
waste streams. This includes all hazardous
waste streams, but excludes any feed streams
that are not hazardous wastes.
• Maximum combined feed rate of all pumpable
hazardous waste feed streams. This parameter
is not applicable if complying with Tier I or
adjusted Tier I metals feed rate screening
limits.
To avoid conflicts, if possible, the parameters
should be maximized in the compliance test by
maximizing the pumpable hazardous waste feed rate. If
the pumpable waste is a relatively low-heating value
waste, maximizing this parameter may conflict with
maximizing other compliance parameters, such as
combustion zone temperature, APCS temperatures, and
production rate. In such a case, it may be necessary to
set the compliance limits for some parameters at one set
of test conditions and for other conflicting parameters at
BIF\SECTOS.BIF
5-6
-------
r
another set of test conditions. Section 5.13.8 provides
guidance on resolving conflicting parameters.
Maximum Production Rate-A maximum
production rate ensures that the device is feeding raw
materials and nonhazardous fuels during the compliance
test at rates that will not be exceeded after the test
This parameter ensures that the gas flow rate and
paniculate loading are maximized, which tests the ability
of the PM collection system to control metals.
Depending on the facility and on measurement
capabilities, the maximum production rate may be
represented as raw materials feed rate, thermal input, or
steam production rate (for boilers only). Regardless of
the measurement technique, during the compliance test
the facility must be operated to produce its normal
product. For example, a boiler must produce usable
steam, and a cement loin must produce clinker suitable
for making marketable cement.
Maximum Combustion Zone Temperature-A
high combustion zone temperature may lead to
increased vaporization, which may result in increased
emissions of hazardous metals. Because it is difficult to
reliably measure the combustion zone temperature in
many BIFs, another sampling location within the
combustion chamber can be used as an indicator for
combustion zone temperature; however, this
temperature measurement location should be as close to
the combustion zone as is practical and must be
upstream of any quench water injection. It is important
to be able to detect changes in temperature rather than
to know the actual combustion zone temperature.
Combustion zone temperature may be maximized by a
number of control parameters, including:
• Maximizing heat input from fuel and waste; or
• Minimizing combustion air flow. (This is not
the preferred control parameter because it
generally "q^lBftt with achieving the maximum
production rate requirements and the maximum
flue gas flow rate requirement for some
APCSs.)
This parameter is not limited if complying with the Tier
I or adjusted Tier I metals feed rate screening limits.
Maximum Flue Gas Temperature Entering the
PM Control Device-Increased temperature at the inlet
to the PM control device increases the volatility of
metals. Metals that remain in the vapor form in the PM
control device will be inefficiently captured. To ensure
that the compliance test represents worst-case
conditions, the temperature at the inlet to the PM
control device is waited to the maximum observed
during the compliance test The APCS temperature
may be maximized by a number of control parameters,
including:
• Maximising heat input from fuel and waste;
• Minimising heat recovery or quench water
flows;
• Minimising air heater leakage; and
• Minimizing combustion air flow. (This is not
the preferred control parameter because it
generally conflicts with the maximum
production rate requirements and the maximum
flue gas flow rate for some APCSs.)
This parameter is not limited if complying with theJTier
I or adjusted Tier I metals feed rate screening limits.
Maximum CO Emissions Umit-The maximum
CO limit depends on the Tier being used to demonstrate
compliance with CO and HC emissions limits:
• In Tier I, the CO limit is 100 ppmv (corrected
to 7% oxygen), independent of the compliance
test results. There is no reason to attempt to
maximize CO emissions during compliance
testing.
• In Tier n, the CO limit is the CO concentration
demonstrated in the compliance test. CO
emissions typically increase with increasing
combustible-to-air ratio and with poor
combustion. The combustible-to-air ratio is
controlled by feed rates of air, fuel, and waste,
and sometimes by batch or container size. A
large number of parameters can contribute to
poor combustion, including poor burner
operation, low combustion zone temperature,
and inadequate mixing of feed streams.
Maximum HC Emissions Umit-The maximum
HC limit is only applicable if the 100 ppmv CO limit is
exceeded (Tier II), and for cement Kins firing hazardous
waste at locations other than the 'hot end." The limit is
20 ppmv (corrected to 7% O: and reported as propane),
independent of the compliance test results. (Cement
Bff\SECTD5.BIF
5-7
-------
Him c
forFC
mater.
attenr
are g
parac
for fa.
metal
->e eligible for a higher HC limit to account
ssions resulting from organics present in raw
see Section 9.0).) There is no reason to
maximize HC emissions during compliance
,e factors that affect hydrocarbon emissions
Jly the same as those that affect CO
rS-Specific Parameters-APCS-specific
re not controlled during the compliance test
•omplying with Tier I or adjusted Tier I for
Jorine/chloride.
Scrubbers
requirements.) If the flue gas flow rate is
reduced to attain minimum venturi pressure
drop, compliance tests should be performed at
more than one test condition. The compliance
limit* for most parameters will be taken from
the maximum flue gas flow rate condition, but
the compliance limit for the minimum
differential gas pressure across the venturi
scrubber may be taken from a lower flue gas
flow rate test condition. Section 5.23.8
discusses resolving conflicting parameters in
more detail.
Dry Scrubbers
Partic
wet s
durio
rate.
Total
blowc.
thus
entra.
deae
very!-.
tninir-
Ver
the
Pr::
Liquid to Gas CL/G) Ratio.
1 /or HC1 removal decreases with reduced
L/G. This situation is best controlled
by decreasing the scrubber liquid flow
•jjj Scrubber Slowdown or
r :nt of Scrubber Liquid. Reduced
.se* '-he solids content of scrubber liquid,
thv amount of paniculate that is re-
scrubber.
j: pH. The solubility of acid gases
w H. This is less important for HCl
it -ven HCl solubility becomes low at
.Is Minimum pH may be maintained by
vdc wn or by "linitni-Ting caustic addition.
,n S< rubbers
•im Differential Gas Pressure Across
ula;; and HCl removal decreases when
ip across venturi scrubbers is lowered.
ji ,TC minimized by;
the throat area; and
the flue gas flow rate. (This is not
-eferred control parameter because it
LS with the maximum production rate
Caustic Feed Rate. Acid gas removal
decreases with decreasing caustic feed rate.
Flue Gas Flow Rate. A high flue gas
flow rate reduces the residence time and deaeases the
caustic-to-gas ratio. Maximum flue gas flow rate is
typically achieved by operating at the maximum airflow
rate. For most BIFs, this is the result of operating at
peak production rate.
Electrostatic PredpiUtors (ESPs) or Ionizing
Wet Scrubbers
(kVAV3
Reduced electrical power decreases the rate of particle
charging, thus decreasing collection efficiency. A
number of ESP operating and maintenance parameters
may affect ESP power. ESP power can be minimized
by:
• Manually reducing power input, if the ESP is
equipped with such controls;
• Reducing the number of fields in operation; or
• Relaxing the set point of parameter(s) tied to
ESP power. For example, if power is
automatically increased when opacity reaches a
r
IS;
B:
isuremem specified to the BIF Ruk (|266.103(c)(l)(xii)(A)) is kilovolt-amperes (kVA). However, there it a phase angle (6)
41 (kV) and the euncat (A) because of variable inductive or capacitive loads in aa ESP. The actual power (ping to the
is therefore kVA times the cosine of the phase angle (9). This product • known as kilowatts (KW). EPA is considering
. clarification as an amendment to the BIF Rule.
5-8
-------
given set point, the opacity set point may be
increased.
Flue Gas Flow Rate. A high flue gas
flow rate increases the gas velocity and reduces
collection efficiency. Maximum flue gas flow rate is
typically achieved by operating with the maximum air
flow rate. For most BIFs, this is the result of operating
at peak production rate.
Fabric Filters
Minimum Pressure Drop. A low pressure drop
is indicative of torn filters, which leads to high metals
and PM emissions. The compliance limit for minimum
pressure drop should be based on the compliance test.
This parameter is controlled by good maintenance.
S233 Feed Rates
Except under Tier I or adjusted Tier 1 for
metals, metal feed rates are limited on three levels.
Limits must be set on metal feed rates in:
• Total pumpable hazardous waste feed streams;
• Total hazardous waste feed streams, which
includes pumpable and nonpumpable hazardous
waste; and
• Total feed streams.
The compliance test should be designed to
achieve the desired metal feed rate limits considering all
three levels of metal feed rates. For example, metals
spiked into the pumpable hazardous waste also count as
part of the total hazardous waste feed rate and total
feed stream feed rate. IB contrast, metals spiked into
the fuel count as pot of the total feed streams, but do
not contribute to the hazardous waste feed rates.
Feed rates of each metal (and chlorine and ash)
are calculated using the following equation.
Species Feed Rjte •
£(Species Cooceatntion x Feedstream Feed
To obtain the most flexible Tier U or Tier m
compliance limits, feed rates and concentrations should
be selected to reflect the highest levels expected in
present and future operations. Some cases may require
metals spiking to achieve maximum expected metals
feed rates. Guidelines for metals spiking are discussed
below. Maximum compliance test feed rates must not
exceed precompliance certification levels.
5.23.4 Metals Spiting
General Guidelines for Metals Spildng-Ideally,
the following general guidelines should be followed for
spiking the 10 BIF-regulated metals:
• Metals should be spiked in a form which
matches as closely as possible the form of the
metals in the waste. Ideally, actual wastes
containing metals (rather than spiked wastes)
should be used. "-
• Solid wastes should be spiked with solid
compounds with panicles at least as fine as the
waste particles.
• Aqueous wastes should be spiked with water-
soluble compounds.
• Organic wastes should be spiked with organic-
soluble compounds.
Sometimes it is not possible to spike organic
soluble metal compounds into an organic waste feed
stream. For example, organic soluble metal compounds
may be too expensive or may not be available in
sufficient quantity. Aqueous solutions of metal
compounds have been successfully spiked into liquid
organic waste feed streams. In such situations, the spike
solution should be continuously injected into a flowing
waste line upstream of an in-line mixer. The spiking
location should be as close to the burner as possible.
The metals feed rate should not be based on the
concentration of the spiked waste stream (it is difficult
to obtain a representative sample of a two-phase
stream); rather, it should be based on separate
measurements of the feed rates and metal
concentrations of the unspiked waste stream and of the
spiked stream.
-------
Solid wastes are typically spiked with discrete
packets or bottles containing specific weights of
powdered metal compounds. Compounds that have
been successfully used include silver nitrate, arsenic
trioride, barium sulfate, beryllium sulfate tetrahydrate,
cadmium chloride, chromium (TO) oxide, lead oxide,
mercury (II) sulfate, and antimony trioxide.
Aqueous wastes are typically spiked with soluble
metal compounds. In formulating the spiking solution,
it is important to take into account the solubility of the
compound and any possible interactions with other
spiked compounds. Test spiking solutions should be
prepared well in advance to identify any possible
problems. Compounds that have been successfully used
include (5):
• Mixtures of Cr(NOj), • 9H2O, Cd(NO3)2 •
5H2O, and Pb(NO,)2 with total concentrations
of 500-5,000 mg/kgH20.
at a concentration of 3 mg/kg H2O in a
separate solution from the other metals to
prevent precipitation of insoluble lead arsenate.
Other metallic salts that are soluble in water
and have been used in test burns:
NajHAsO4 <
Ba(C,H302)2 • H20
BeSO4 • 4H2O
Cd(N03)2 • 4H20
AgNO,
T1C,H3O2
Other metal compounds which have been
identified (5) as potential spiking compounds
include:
Ag
AgNO,
As
As203
Cr
Cr,03
Cr(NOj),«8H2O
Be
BeSO4«4H2O
Be(NO2)2«3H,0
Be
BeO
Pb
PbO
PbCIj
CrOj
CrCl,«6H20
Ba(metal)
BaSO4
BaCl,«2H2O
BaCOj
Ba(OH)2
BaO
Ba(NOj)2TljCOj
Hg(metal)
HgSO4
HgCl,
HgCl
HgNOj«H2O
HgO
Pb(NO,)2
Cd(metal)
Cd(NO,)2.4H.O
CdClj
CdCO,
Cd(OH)2
CdO
3CdSO4»8H2O
Cd(CJH,02)2«2H20
Sb(metal)
SbA
SbCl,
Tl (metal)
TINOj
71,0,
71,50,
Some of these compounds are very expensive an3rmay
be impractical to spike in quantity.
If a facility elects to comply with the emissions
limit on hexavalent chromium (Cr*') by measuring
emissions of Cr** in addition to measuring total
chromium emissions, special consideration must be given
to the form of chromium used for spiking. Based on
available data, emissions of Cr** result from the feeding
of Cr*' in feed streams to the combustion system. Very
little, if any, Cr** is converted to Cr** in the feed
streams to the combustion systems (16). As a result, if
compliance is based on measured emissions of Cr**, the
compliance test must be designed to feed Cr** into the
combustion system at the highest Cr*' feed rate
expected to occur during subsequent operation of the
system. Further, feed rate limits must be established for
both Cr*4 and total chromium.
Spiking with Cr*3 compounds during a
compliance test is not appropriate for establishing an
operating limit on Cr*' or total chromium feed rates but
is acceptable for establishing an operating limit on Cr*3.
For example, a coal-fired BIF (essentially all chromium
in coal is believed to be Cr*J) that also burns a
hazardous waste stream containing Cr** should spike
with Cr*' during the compliance test and would
establish operating limit; based on both the total
chromium feed rate and the Cr*' feed rate during the
compliance test Determination of the amount of Cr*
Bff\SECT05.BIF
5-10
-------
to be spiked during the compliance test should be based
on the expected level of Cr*' to be burned by the BIF
after certification of compliance.
If the owner/operator deviates from the above
spiking guidelines, documentation should be provided to
show why it is impossible or impractical to follow the
guidelines. This documentation should be maintained
and presented to the Director upon request.
Detailed Guidelines for Metals Spiking-When
spiking is used to ensure maximum feed rates of metals,
the physical and chemical form of the metal must be
considered as well as the method for introducing the
metals into the BIF. Ideally, an actual waste which is
representative of wastes normally handled by the facility
containing the desired metal concentrations should be
used. If such a waste is not available, spiked waste may
be substituted. The conditions experienced by the
metals should conservatively represent the behavior of
all metals in the waste.
Selection of Metal Form. The metal forms
selected for spiking should conservatively simulate the
metals in the waste. The physical and chemical forms of
the metals are important. Typical physical forms
include:
Metals dispersed in a liquid solution;
Metals homogeneously mixed in a solid waste
mixture; and
Metals present as large pieces of solid material.
Nearly all of the metals dispersed in a liquid
waste are vaporized or entrained with the combustion
gas and are passed to the APCS. When metals are
present in relatively homogenous solids, entrainment is
a function of the particle size of the waste.
Vaporization of meudi • this form depends strongly on
operating conditions, tat it generally less than that
observed with metals dispersed in liquids. Vaporization
is limited by the rate at which the metals are able to
diffuse to the surface of the particles and into the flue
gas. Consequently, metals dispersed in liquids have the
greatest potential for partitioning to the flue gas,
whereas large heterogeneous particles or metals in large
pieces have the least potential for partitioning to the flue
gas. These considerations can be used to determine if
a given spiking approach conservatively estimates the
behavior of metals in the waste.
Simulating the chemical form of a metal as it
exists in wastes typically fed to the BIF unit should also
be a goal of the spiking procedure in a compliance test.
Common chemical forms of metals include:
• Inorganic metal oxides;
• Salts;
• Organic salts; and
• Organometallic compounds.
The chemical form of the spiked metals may
affect metals partitioning. For example, when the metal
is spiked as an organometallic compound, it enters the
BIF and vaporizes; once the organic portion of the
molecule is destroyed in the combustion zone, the metal
may rapidly condense. In general, the organometallic
compounds are more volatile than organic salts,
inorganic salts, or oxides. Metals present in the feed as
organometallic compounds have the greatest potential
for partitioning to the flue gas compared with the Jess
volatile chemical species. •;
If data or information are available to show that
the metal in the original waste exists as an
organometallic compound, the spiked metal should also
be introduced as an organometallic compound. Salts or
oxides would not conservatively represent the behavior
of the more volatile organometallic compounds.
Alternatively, spiking an organometallic compound as a
substitute for a less volatile salt or oxide is generally a
conservative approach in a compliance test; however,
this option may not be attractive for a facility since the
cost of organometallic compounds is generally high and
the test results might be more restrictive (due to the
higher volatility of the metal in this form) than the
facility desires.
Method of Spjfaiflg The method of adding the
spiked metal to the waste is an important factor to
consider in the test design. The method of spiking
should represent, as closely as possible, the form of the
metals present in actual hazardous wastes to be burned
in the BIF. If the metals present in the actual waste
matrix are homogeneously distributed within a solid
waste, the spiked metal should also be mixed thoroughly
with the waste before it is introduced to the BIF.
Adding the spiked metal in discrete units to the waste
would not conservatively represent the actual behavior
of the metal in the waste. Smaller particles are more
likely to be entrained and can vaporize faster because
they have a larger surface area per unit volume exposed
to the combustion gas.
BIF\SECTQ5.BIF
5-11
-------
The test d«cign should include procedures to
monitor the addition of metals during the compliance
test, which may require the use of well-calibrated flow
rate measurement devices as well as regular monitoring
of the metals flow rate to the unit. This can be
accomplished for each spiked metal by carefully
monitoring the total waste feed stream flow rate and
taking measurements of the spiked metals
concentrations in the waste feed stream; or by
measuring the spiking rate directly.
It is conservative to assume that the spiked
metal comprises all of the metals feed rate, and this
approach may be appropriate in situations where the
metal concentrations in the wastes are low or difficult to
measure (e^, for a highly heterogeneous solid waste
which may contain chunks of metal). A facility should
clearly evaluate the effect of this approach (i.e., not
analyzing feeds for metals) during the compliance test to
ensure that feed rate limits based on spiking rates alone
reflect the desired operating conditions.
S23JS Preconditioning and Steady State Operation
In general, there is a lag time between the start
of a compliance test and the time at which emissions
reach steady state at the stack. The BIF Rule requires
preconditioning of the BIF before stack emissions
testing is performed so that metals and other pollutant
emissions have reached equilibrium at the test operating
conditions. To ensure preconditioning, waste feeding
should begin at least one residence-time interval before
initiating stack sampling. For many boilers, material
residence time may be very short (e^, a few seconds);
however, to allow time for the system to reach steady
state with respect to the waste feed, it is recommended
that the system be preconditioned for at least 30 to 60
minutes before sampling. In the case of cement kilns
and other BIFs that recycle collected PM,
preconditioning time it more difficult to predict.
Preconditioning of cencot kilns is discussed in more
detail in Section 8.0.
Burning Low-Heating Value Hazardous Waste
The BIF Rule states that before certification of
compliance, the BIF owner/operator cannot feed
hazardous waste that has a heating value of less than
5,000 Btu/Ib, as-generated (although the heating value
of waste as-generated may be increased to above the
5,000 Btu/Ib limit by bona fide treatment; however,
blending to augment the heating value to meet the 5,000
Btu/lb limit is prohibited, and records must be kept to
document that impermissible blending has not
occurred). Exceptions to the restriction that BIFs may
not burn low-heating value hazardous wastes before
compliance certification are:
• Hazardous waste may be burned solely as an
ingredient (see Section 7.0 for criteria for
burning as an ingredient);
• Hazardous waste may be burned for the
purpose of compliance testing (or testing before
compliance testing) for a total period of time
not to exceed 720 hours;
• Low-heating value waste may continue to be
burned if, prior to August 21, 1991, the BIF
operated as an interim status incinerator or
thermal treatment unit and burned hazardous
waste with a heating value of less than 5,000
Btu/lb; or
• Low-heating value waste may be burned. Jn a
halogen acid furnace if the waste was burned as
an excluded ingredient under §261.2(e) before
February 21,1991 and documentation supports
thit rlaim
If a facility plans to burn low-heating value
waste after certification of compliance, it is
recommended that a low-Btu-waste operating mode be
included in the compliance test. It is also recommended
that the low-Btu waste-burning not begin until the
CEMs are operational.
5.2.3.7 Operating Modes
While compliance can be demonstrated with a
single set of test conditions if the design and operating
characteristics of the facility allow this approach, some
faculties may need to operate under several modes to
demonstrate compliance over the full range of desired
operating conditions. In these rasrs, the facilities would
need to establish other sets of worst-case operating
conditions (modes) and to conduct compliance test runs
accordingly. This includes situations where the
maximum ambient impact is predicted to occur (based
on dispersion modeling) at other than the maximum
operating level (see Section 2.0).
Two examples of facilities that would need to
operate under multiple operating modes are:
BIF\SECraS.BIF
5-12
-------
• A facility is planning to bum both liquid and
solid hazardous wastes in a BEF, but not at the
same time. In this case, the facility may elect
to conduct compliance testing under two
modes. One mode of testing would be during
solid waste burning and the other mode during
liquid waste burning. The facility would then
have a different set of operating limits for the
solids-burning mode and for the liquids-burning
mode. A facility may have more flexibility with
two customized modes than with one inclusive
mode.
• A facility is pluming to burn two types of
hazardous wastes, oae with a high concentration
of one carcinogenic metal (e-g., chromium), and
a second with a high concentration of another
carcinogenic metal (e^, arsenic). A high-
chromium mode and a high-arsenic mode may
be preferable in such a case, because if both
wastes are to be burned at the same time, the
aggregate risk of the carcinogenic metals may
exceed the allowable emission limit. The
facility would then have two sets of metal feed
rate limits: one for the high-arsenic mode and
one for the high-chromium mode.
If a facility decides to perform compliance
testing under more than one mode, the test protocol
must indicate the number of modes under which the
facility anticipates operating, and therefore, plans to test.
The operating record must at all times document the
current mode of operation.
S23A Conflicting Parameters
Limits established by the certification of
compliance are based tm operating conditions during the
compliance test DMJ||§ the compliance test, each
compliance parameterjjilnild be operated at the worst-
case conditions anticipated for present or future
operations, to f^t*tMA the most flexible compliance
limits. However, BIFs are complex systems in which
many parameters are related. It may not always be
possible to achieve worst-case conditions for all
compliance parameters simultaneously.
Conflicting parameters are defined as two or
more compliance parameters that cannot be
simultaneously operated at their worst-case conditions.
As an example, maximizing the combustion chamber
temperature may conflict with maximizing the feed rate
of pumpable or total hazardous waste. If the waste has
a lower heating value than the primary fuel, an increase
in the waste feed rate and a decrease in the fuel feed
rate is likely to result in a decrease in the combustion
chamber temperature.
The relationship between compliance
parameters varies from system to system; additional
annflirting parameters may be encountered in specific
systems. Potential conflicting parameters should be
identified in the compliance test protocol. The test
protocol should indicate which parameters conflict, the
reasons for the conflict, and the changes in other
operating parameters that will be made to allow testing
at worst-case conditions for the conflicting parameters.
To overcome a conflict, a facility may test at
two or more sets of conditions under the same operating
mode, as follows:
• A first set of operating conditions to set limits
for all parameters, excluding the one(s) in
conflict; and
• One or more additional sets of operating
conditions to set the limit(s) on the conflicting
parameters(s). Only the conflicting parameters
need be varied from the first set of operating
conditions. All nonconflicting parameters
should be operated at their desired compliance
limits.
The following constraints apply to the additional
sets of operating conditions to set the limit(s) on the
conflicting parameter(s):
• Feed rates of each metal, chlorine, and ash, if
applicable, may not be reduced for the
additional set(s) of operating conditions. The
compliance limit is established from the set of
operating conditions that has the lowest feed
rate; and
• All other parameters should be maintained as
closely as possible to the first set of operating
conditions.
BIF\SECT05.BIF
5-13
-------
5.2.3.9 Soot Blowing
Some facilities may conduct soot blowing or
other routine activities which may result in shon-tenn
increases in PM emissions. To evaluate the impact of
these practices on average daily emissions, one of the
three runs (conducted at each operating condition)
should be conducted during the period of the higher PM
emissions. This run should reflect the potential buildup
of PM, metals, HO, and dj over a normal operating
cycle.
To accomplish this (using soot blowing as an
example), waste feeding should begin immediately
following the last cleaning cycle and occur continuously
until the third test run (including the cleaning cycle) is
completed. If the time interval between cleaning cycles
is other than the BIFs regular cleaning cycle, an
adjustment factor will be needed to compensate for the
differences in time intervals. To minimi** this
adjustment factor, it is beneficial to conduct this run as
closely as possible to a normal cleaning period.
Assuming all three test runs are conducted during the
same day, and the normal interval between cleaning
cycles is more than 8 hours, the run with increased PM
levels should be the last run of the day. The test
protocol must define how the 'soot blowing" run will be
conducted and how the conditions will be compared to
normal operating conditions.
The equation provided below defines how to
calculate daily average emission rates for PM, metals,
HC1, and Clj when an activity such as soot blowing is
included in the testing. The following equation is
applicable regardless of the duration of the individual
test runs or the time soot blowing lasts during the "soot
blowing" test run.
Definitions:
emission rate (for PM, metals, HC1, and Clj,
as appropriate)
average E of samples collected during test
run with soot blowing, corrected to 7% O2
average E of samples collected during test
runs without soot blowing, corrected to 7%
A = hours of soot blowing during the test run
with soot blowing
B * hours not soot blowing during the test run
with soot blowing
S * normal number of hours of soot blowing per
24 hours
R - normal number of hours of operation per 24
hours
Cn * normal number of operating hours between
cleaning cycles
Ct * number of operating hours between cleaning
cycles during testing
The quantity of excess air is not expected to
vary significantly between periods of normal operation
and periods of soot blowing. However, if a significant
variation in the quantity of excess air is expected, an
additional Method 3 or 3A analysis must be conducted,
as outlined in 40 CFR Pan 60, Appendix A to determine
the percent O2 while soot blowing. The percent O, of
the soot blowing run is determined from the following
equation: ~r
%O
JJW
B+A
Definitions:
B
the average percent O2 for the test run
with soot blowing
the percent O, while not soot blowing
hours not soot blowing during the test run
with soot blowing
the percent O2 while soot blowing
hours of soot blowing during the test run
with soot blowing
The %O2jn should be used to correct for O2 during the
soot-blowing test run.
5.2.4 Testing Under the Alternative Metals
Approach
A facility that recycles collected paniculate
matter must demonstrate compliance with metals
standards using one of three metals compliance
alternatives:
• Kiln dust monitoring;
• Semicontinuous stack emissions testing; or
BIF\SECr05.BIF
5-14
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• Preconditioning before emissions testing.
These alternative metals compliance approaches
(including any special test design considerations) are
discussed in detail in Section 8.0.
5 2 3 Data in Lien of Testing
In general, a facility must conduct a compliance
test for each BIF unit to show that emissions are within
the allowable limits and to set operating limits for the
remainder of interim status. Compliance test data from
a similar on-site unit may be used in place of a
compliance test for a BIF.
The following restrictions apply for using data
in lieu of testing:
• The plan to use compliance test data from one
unit in lieu of testing another unit must be
approved in writing by the Director (who will
likely need 60 to 90 days to review and approve
the plan); and
• The comparison of the two units must show the
similarity of:
- Hazardous wastes and other feed
streams;
- Design;
- Operating conditions; and
A detailed discussion of these restrictions is presented
below.
Feed Streams—Hazardous wastes and other feed
streams are considered CBBilar if:
• They are pnxjflcd from the same source; or
• Their analyses are not significantly different
with respect to:
- Physical form;
- Hazardous metals;
— Chlorine;
Ash;
- Heating value; or
— Other attributes the Director considers
important.
Design-Designs of combustion chamber(s),
APCSs, and control systems must be similar.
Combustion chamber designs are similar if they are:
• The same model; or
• The same type with similar design specifications
considering:
- Basic design (e.g, watertube boiler,
dry process cement kiln with
preheater);
— Burner design and/or waste firing
mechanism;
- Design temperature;
- Volume/capacity/residence time;
— Dimensions/shape;
- Refractory and/or heat removal; or
- Other attributes the Director considers
important.
APCSs are similar if they are:
• The same device (i.e., shared with tested BIF
and untested BIF);
• The same model; or
• Constructed of the same components in the
same order with similar design specifications
considering:
- Basic design (e.g., spray dryer,
baghouse, etc.);
- Critical design specifications (e.g.,
air/cloth ratio and pressure drop for a
baghouse); or
- Other attributes the Director considers
important.
Additionally, the systems must have similar controls and
hazardous waste feed cutoffs for both the tested and
untested facilities.
OperatingConditions-The operating conditions
must be similar for both the tested and untested units.
Maintenance-The owner/operator should
provide documentation indicating that both the tested
and untested units are properly inspected and are
maintained in w^'for condition.
BIF\SECT05.BIF
5-15
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Compliance Certification-Certifications of
compliance must be submitted for both the untested unit
and the tested unit. Additionally, compliance limits for
the untested unit will be the same as compliance limits
for the tested unit.
The owner/operator should request approval to
waive compliance testing for a unit well in advance (e.g.,
60 to 90 days) of the planned compliance test to allow
sufficient time for EPA to review the request and issue
approval or disapproval for the use of the data by the
planned test date.
5.2.6 Sampling and Analysis Procedures
Many different types of sampling and
monitoring activities occur during the compliance test.
Flue gas must be sampled for some or all of the
following parameters, depending on the compliance
approach: PM, HC1, Cl,, and metals, and if applicable,
dioxins and furans. Continuous emissions monitoring
must also be conducted for CO and O2, and, if
applicable, HC. All feed streams must be sampled, and
all feed rates must be monitored. Process data on
operating conditions must be collected.
The test protocol should identify each stream to
be sampled, the analytical parameters for each sample,
and the appropriate sampling and analysis methods.
Process streams that must be sampled and analyzed
include all wastes and spiking materials, fuels, raw
materials, stack gases, and byproducts, including ash or
slag. Table 5-3 provides a sample test matrix for a
representative compliance test.
In addition, the facility may choose to sample
and analyze any other process effluents, such as quench
effluent or scrubber Wowdown. While not a
requirement, such sampling and analysis may yield
additional information on system performance and the
fate of metals, HO, or Oj in the system. This
information may be especially valuable if facility
performance during the compliance test fails to meet
expectations.
In general, sampling and analysis methods
chosen for the compliance test should be from one of
the following sources:
• Test Methods for Ev?'"af'"g Solid Wastes:
Physical/Chemical Methods. SW-846. Third
Edition (35);
Code of Federal Regulations, 40 CFR Pan 60,
Appendix A and Part 266, Appendix EX (37);
Waste Combustion (29); and
Annual Book of ASTM Standards (1).
Methods published in SW-846 are the preferred
methods. In addition, the methods contained in 40 CFR
Part 266, Appendix K are required methods. Two
other useful documents for providing additional
guidance on sampling and analysis procedures and
associated quality control are the Hazardous Waste
f QA/QO Procedureif fry f»a?ardous Waste Incineration
(24).
The test protocol should present the sampling
and analysis methods in sufficient detail for field, and
laboratory implementation. Some of the metHbds
described below have several options that may* be
employed by the sampler or analyst. The compliance
test protocol should specify which options will be used.
5.2.6.1 Wastes, Fuels, and Raw Materials
Sampling Methods-Sampling waste feeds, fuels,
and raw materials can involve sampling of solids,
slurries, sludges, and/or free-flowing liquids. In each
case, however, the objective is to obtain a sample
representative of the stream as a whole. Sampling
guidance specific to each type of material (liquid, solid,
etc) can be found in SW-846, and in the Handbook on
Quality Assurance /Qualify Control (QA/QC)
Procedures for Hazardous Waste Incineration (24).
Organic and aqueous liquid feed samples should
be collected every 15 minutes during the test run and
composited for the entire run to provide a single
integrated sample for analysis. The liquid feed samples
are typically collected from a sample tap or similar
device in the feed line or tank. The sample tap is
flushed (allowed to flow briefly) before each sample is
collected to ensure that any stagnant accumulation in the
tap does not affect the sample integrity or its
representation of the waste feed pumped to the burner.
A tninimiim volume of approximately 50 ml should be
collected for each subsample; the total composite sample
volume for the run should not be less than 1 liter. The
owner /operator may justify less frequent sampling if
Bff\SECT05.BIF
5-16
-------
Table 5-3
Sample Test Matrix of Sampling and Analysis Parameters and Methods
Sample
Liquid Organic
Waste
Aqueous Waste
Sampling Frequency
for Each Run
One grab sample every 15
min composited into one
sample for each run
One grab sample every 15
min composited into one
sample for each run
Sampling Method
Tap (S004)'
Tap (S004)1
Analytical
Parameter
Ash
Total
chlorine
Ash
Chloride
Chlorine
Metals'
Preparation Method
NA
5050°
NA
NA
5050*
Acid digestion (3050)'
and/or organic
dissolution (3040)'
Analytical Method
Calorimeter (D240-87)b
Ignition (D482-87)b
Viscomeler (D-88-81)b
SW-846 Method4
Ignition (D482-87)*
SW-846 Method4
9250", 9251d, 9252d, or
9253C
ICP (6010)d; GFAA
(7000 series)4 and
CVAA (7470-7471 )d as
needed
{Jt
NA - Not applicable.
'Sampling and Analysis Methods for Hazardous Waste Combustion (29).
b!986 Annual Book of ASTM Standards (1).
'Proposed SW-846 method.
"Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods. SW-846. Third Edition
'Metals to be analyzed will he As, Cd, Cr, Be, Sb, Ba, Pb, Hg, Ag, and Tl.
rMM5-MM = Method 5 for multiple metals. MM5-PCI = Method 5 for particulale and HCI.
'40 CFR Part 60, Appendix A. . .,
h40 CFR Part 266, Appendix IX. ' '•
(35).
-------
Table 5-3 (Continued)
Sample Matrix of Sampling and Analysis Parameters and Methods
Sample
Containerized
Solid Waste
Bulk Solid Waste
Sampling Frequency
liar Each Run
Grab repnaeatative
samples from each drum
composited into one sample
for each run
One grab sample for every
IS min composited into one
sample for each run
Sampling Method
Scoop (SOOT)'
Scoop (SOOT)'
Analytical
Parameter
Total
chlorine
Ash
Metals
Total
chlorine
Ash
Metals'
Preparation Method
5050°
NA
Acid digestion (3050)
and/or organic
dissolution (3040)
5050°
NA
Acid digestion (3050)
and/or organic
dissolution (3040)'
Analytical Method
9250", 9251d, 9252*. or
9253C
Ignition (D482-8T)b
ICP (6010);d GFAA
(7000 series)*1 and
CVAA (T4TO-T4Tl)d as
needed
9250d, 9251-, 9252", or
9253*
Ignition (D4820-8T)k
ICP (60IO)a; GFAA
(TOOO series)1* and
CVAA (T4TO-T4T1)" as
needed
V"
I—ft
00
NA - Not applicable.
ste Combustion (29).
"Sampling and Analysis Methods for i
b1986 Annual Book of ASTM Standards (1).
'Proposed SW-846 method.
''Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods. SW-846. Third Edition (35).
'Metals to be analyzed will be As, Cd, Cr, Be, Sb, Ba, Pb, Hg, Ag, and Tl.
'MM5-MM = Method 5 for multiple metals. MM5-PCI
f40 CFR Part 60, Appendix A.
h40 CFR Part 266, Appendix IX.
Method 5 for paniculate and HCI.
-------
Table 5-4
Analytical Methods for Metals in Feed Streams
Constituent
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Lead
Mercury
Silver
Thallium
Analytical Method'
7040
7060,b 7061b
6010,7080
6010, 7090, 7091
6010, 7130, 7131
6010, 7190, 7191
6010, 7420, 7421
7470," 7471s
6010, 7760s
6010, 7841
•SW-846 methods.
'This method includes digestion for aqueous matrices (no separate digesdon method is necessary).
This method includes digestion for all matrices (no separate digesdon method is necessary).
RPF\008
1003-01.rpf
5-21
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The HCI and Clj emissions are measured using
one of two methods described in 40 CFR Part 266,
Appendix DC Both methods involve a manual sampling
train method with impingers containing weak sutfuric
acid-absorbing solution for collection of HCI followed in
series by impingers containing a sodium hydroxide-
absorbing solution for collection of Cl,. Method 0050 is
an isokinetic method designed for use when droplets
may be present in the stack gas. Method 0051 is a
nonisokinetic, midget impinger method. It is both
acceptable and recommended to combine paniculate
and HCl/Clj sampling into a single isokinetic Method 5
train modified by placing the HCI and Clj absorbing
solutions in the appropriate impingers.
Sampling for the 10 BIF-regulated metals of
concern requires the use of the EPA Multiple Metals
Train described in Methodology for the Determination
of Metals Emissions in Exhaust Gases From
Waste Incinerators yd Similar Combustion Processes.
found in 40 CFR Pan 266, Appendix DC. The train is
similar in configuration to a standard Method 5 train,
with a filter to collect PM, a series of impingers with
absorbing solutions, and provisions for measuring the
sample gas volume. The absorbing solutions consist of
dilute nitric acid in hydrogen peroxide for collection of
all of the metals of concern except mercury, followed in
series by an acidic potassium permanganate solution for
collection of mercury.
Using the above multiple metals method for
chromium yields a total chromium value. If the
owner/operator wishes to perform sampling specifically
for hexavalent chromium, a separate sampling train can
be used, as described in Methodology for the
Determination of Hexavalent O"*QnjJHjp Envssionsfrom
Stationary Sources, found in 40 CFR Pan 266, Appendix
DC Stack emissions are collected isoidnetically from the
stack with a specially designed recirculatory train. In
this method the uapiager reagent is continuously
recirculated to the nozzle, i*'mimmnjt the reduction of
hexavalent chromium to the trivalent form in the
sampling train.
Continuous Emissions Sampling Methods-
Continuous measurements of CO and O2, and, if
applicable, HC, are required during the compliance test
and continuously thereafter. Information on monitor
specifications and the format for compliance with the
Tier I CO and Tier n CO/HC limits can be found in
Section 4.0, and required performance specifications for
the monitors are presented in 40 CFR Pan 266,
Appendix DC. Before the compliance test, a
performance specification test must be performed for
each monitor; requirements for this test can be found in
of 40 CFR Part 60, Appendix A.
Before the compliance test, all CEMs must be
calibrated in accordance with the method specifications.
Before the first run, each monitor must be zeroed and
spanned, using zero grade air for the HC zero gas and
prepurified nitrogen for the remaining analyzers. In
addition, the following checks must be made for each
test run:
• A system leak check for each monitor must be
performed in accordance with manufacturer
specifications before and after each test run.
• Final zero and span calibrations for each
analyzer must be performed at the end of the
test run. The initial and final zeros and spans
must agree within 3% of the span gas.
Analysis of Stack Samples-Analysis for *PM
involves drying and weighing the filter from the Method
5 train in accordance with EPA Reference Method 5.
The probe rinse is also evaporated to dryness and
weighed. This information can be recorded on
Worksheet 8 in Appendix G.
The analytical method for HCl/Clj in stack gas
samples is the Protocol for Analysis of SaTT|ples from
HCl/O-t ^n'ssion SamplipgTra'"$ found in 40 CFR
Pan 266, Appendix DC. Each absorbing solution (weak
acid solution for HCI and caustic solutions for Clj) is
analyzed separately for Cl by ion chromatography. Clj
reacts with the caustic solution to form half HCI and
half hypochlorite (H,O + Oj - H* + CT + HC1O);
ion chromatography detects only the HCI. Therefore, to
calculate the total Cl present, the Cl results from the
caustic solution must be multiplied by 2 to account for
hypochlorite formation. Results of this analysis must be
recorded as HCI and Cl,. Worksheet 8 in Appendix G
can be used to document these results.
Analysis of multiple metals train components
for total metals is performed using tVn» Methodology for
the Deterrn'nation of Metals FmU<;inn<; in Exhaust
Gases from Hazardous Waste Incinerators tn^ §imilar
Combustion Processes, found in 40 CFR Part 266,
Appendix DC. Sampling train components are recovered
and digested in separate front-half (i.e., nitric/peroxide
impingers in the sampling train) and back-half (i.e.,
BIF\SECT05.BIF
5-22
-------
Table 5-3 (Continued)
»
Sample Matrix of Sampling and Analysis Parameters and Methods
Sample
Slack Gas
Sampling Frequency
lor Each RIM
214-hour composite per nui
214-hour composite per run
214-hour composite sample
per run
214-hour composite sample
per run
Continuous
Continuous
Continuous
Sampling Method
MM5-PCT
MMS-MMr
EPA Method 3B«
EPA Method OOIO"
EPA Method 10*
EPA Method 2SAb
EPA Method 3Ah
Analytical
Parameter
Paniculate
HCI/CI,
Moisture
Temperature
Velocity
Melalsd
Oxygen
CDD/CDF
CO
HC
o,
Preparation Method
Desiccation
NA
NA
NA
NA
Acid digestion
NA
EPA Method 8280d
EPA Method 10*
EPA Method 25Ah
EPA Method 3Ah
Analytical Method
Gravimetric EPA RMS
Ion chromatography
Gravimetric
Thermocouple
Pilot tube
ICP (6010)'; GFAA
(7000 series)4 and
CVAA (7470-7471 )d as
needed
Orsat
EPA Method 8280*
EPA Method 10*
EPA Method 25Ah
EPA Method 3Ak
NA • Not applicable.
"Sampling and Analysis Methods for Hazardous Waste Combustion (29).
b!986 Annual Book of ASTM Standards (1).
'Proposed SW-846 method.
"Test Methods for Evaluating Solid Wastes; Physical/Chemical Methods. SW-846. Third Edition (35).
'Metals to be analyzed will be As, Cd, Cr, Be, Sb, Ba, Pb, Hg, Ag, and Tl.
'MMS-MM = Method 5 for multiple metals. MMS-PCI = Method 5 for participate and HCI.
•40 CFR Part 60, Appendix A. . .,
h40 CFR Part 266, Appendix IX. "'
-------
additional data are provided to show that the
homogeneity and composition of the waste feed streams
do not vary. Other methods available for sampling free-
flowing liquids from drums, tanks, or impoundments
include a coliwasa (composite liquid waste sampler),
weighted bottle, or dipper. Sampling methods and
equipment required for viscous liquids, slurries, sludges,
and solid waste feeds are listed below (refer to SW-846
for details on each of the methods).
Method Name
TVDC of Waste
Thief (grain sampler) Dry powder or granules
Trier (corer) Sludge or moist solids
Trowel (scoop) Moist or dry solids
Auger Packed solids
Samples of solid waste can be obtained from
containers, waste piles, or from the process feed system,
such as a conveyor belt or an auger system. For
containerized waste, a grab subsample should be
obtained from each container; bulk feeds must be
sampled every 15 minutes. As for liquid feeds,
individual subsamples are composited into a single
sample for each stream for the run.
Analytical Methods-All waste feed, fuel, and
raw materials samples must be analyzed for the
following constituents: ash, total chlorine, and the 10
BIF-regulated metals of concern.
The analytical method for ash in feed streams
consists of sample drying and ignition, ASTM Method
D482-87. The analytical method for total chlorine in
feed streams is a combination of ASTM and SW-846
methods. Total chlorine (as total halogens) may be
determined by first combusting the sample according to
proposed SW-846 Method 5050 or the combustion step
in ASTM D808, followed by analyzing for chloride
according to existing SW-846 Methods 9250,9251,9252,
or proposed SW-846 Method 9253. The final
gravimetric step described in ASTM D808 is not
recommended because this method is less sensitive (has
a higher method detection limit) than the SW-846
methods. An option for determining total chlorine in
aqueous feed streams is to analyze for both total organic
halogens according to SW-846 Methods 9020 or 9022
and inorganic chlorine according to the methods listed
above. If chlorine is to be speciated from other
halogens, the use of ion chromatography is
recommended.
Sample preparation techniques for metals in
feed streams include the following SW-846 methods:
Method 3005. acid digestion of wastes for total
recoverable or dissolved metals for analysis by flame
atomic absorption spectroscopy (FLAA) or inductively
coupled argon plasma emission spectroscopy (ICP);
Method 3010. acid digestion of aqueous samples and
extracts for total metals analysis by FLAA or ICP;
Method 3020. acid digestion of aqueous samples and
extracts for total metals analysis by graphite furnace
atomic absorption spectroscopy (GFAA); Method 3Q4Q.
dissolution procedure for oils, greases, or waxes; and
Method 3050. acid digestion of sediments, sludges or
waxes.
Methods for the analysis of metals in feed
streams are provided in Table 5-4. The methods consist
of ICP, direct absorption, flame atomic absorption, and
furnace atomic absorption methods: Method 7061
gaseous hydride method for arsenic; and the manual
cold-vapor techniques for mercury consisting of Method
7470 for mercury in liquids, and Method 7471^* for
mercury in solids.
5.2.6.2 Stack Samples
During the compliance test, stack gas must be
sampled for the following parameters: PM, moisture,
CO, Oj, and, if applicable, HC, HC1, dj, metals, and
chlorinated dioxins and furans. The temperature and
stack gas flow rate, if applicable, must be measured
during the sample collection as specified in the methods.
Sampling and analysis methods are contained in 40 CFR
Part 266, Appendix DC, and in 40 CFR Part 60,
Appendix A.
Manual Sampling Metbods-PM and moisture
are measured with a standard Method 5 (40 CFR Part
60, Appendix A) train consisting of a paniculate filter,
a series of condensate impingers, and provisions for
measuring the sample gas volume. The sample is
collected isoldneticaUy over the sampling period,
completely traversing the stack, as required by the
method. The minimum volume of sample required is
approximately 60 ft3, with the total sampling time
dependent on the stack gas flow rate and paniculate
loading. The total period of time necessary to complete
the sampling effort must include the time necessary for
port changes and for performing appropriate leak checks
before and after sampling and during port changes.
BIF\SECnJS.BIF
5-20
-------
acidic permanganate impingers) fractions. Materials
collected in the sampling train are digested with acid
solutions to dissolve inorganics and to remove organic
constituents that may create analytical interferences.
Acid digestion is performed using conventional
Parr Bomb or microwave digestion techniques. The
nitric acid/hydrogen peroxide impinger solution, the
acidic potassium permanganate impinger solution, and
the probe rinse and digested filter solutions are analyzed
for mercury by cold vapor atomic absorption
spectroscopy. With the exception of the permanganate
solution, the remainder of the sampling train catches are
analyzed for Cr, Cd, Be, Pb, T\ Sb, Ba, and As by ICP
or atomic absorption spectroscopy (AAS). Graphite
furnace AAS is used for analysis of Sb, As, Cd, Pb, and
Tl, if these elements require greater sensitivity than can
be obtained by ICP. A list of analytical methods for
metals in stack samples is provided in Table 5-5.
If separate sampling is performed using a
hexavalent chromium sampling train, analysis of the
collected sample is by ion chromatography equipped
with a post-column reactor and wavelength detector (see
40 CFR Pan 266, Appendix DC, Section 32).
S2.7 Quality Assurance/Quality Control
Proper QA/QC procedures are critical in
performing the compliance test and generating valid test
results. For this reason, a QA plan must be included as
pan of the written test protocol. The purpose of the
QA plan is to help ensure that the monitoring, sampling,
and analytical data meet specific data quality objectives,
and to provide the framework for evaluating data
quality. Specific procedures and guidance for preparing
a QA plan can be found in the Handbook on Quality
Assurance/Quality Control (QA/QC) Procedures for
Harardous Waste Incineration (24>). The contents of a
typical QA plan are summarized in the following
sections.
5J.7.1 QA and QC Objectives
QA objectives for precision, accuracy, and
completeness should be listed for each major
measurement parameter, including all pollutant
measurements. If all the QC data meet the objectives,
the compliance test results can be judged as having an
acceptable quality level. Specific QC procedures and
associated acceptance criteria are presented in the
above-referenced handbook and in the referenced
methods and should be summarized in tabular form in
the test protocol.
52.72 Sampling and Monitoring Procedures
Sampling and monitoring procedures should be
summarized in the test protocol in a table that lists the
sampling points, the sampling frequency, and the total
number of samples, including duplicates and blanks.
Quality assurance consists, in part, of using standard
reference methods and sampling procedures that call for
the collection of a sufficient mass of HCI, Clj, and/or
metals in the stack gas sample to permit quantitation at
the appropriate screening limit. The mass of a
constituent in the sample must be within the calibration
range of the method to ensure accurate measurement.
52.13 Sample Handling, Custody, and Holding Tunes
Each sample should be identified in the test
protocol, along with the appropriate holding times and
any associated preservation techniques for each analysis.
•
All sample-handling procedures for the
compliance test should be described, including sample
labeling, preserving, packing, shipping, and laboratory
and field storage procedures. All documentation
practices should be described, including the use of field
log books, sample analysis request forms, laboratory
traceability log books, and field traceability forms.
Storage of samples for archive purposes should also be
covered.
52.7.4 Specific Calibration Procedures and Frequency
The majority of measurements made during the
compliance test are performed using standard EPA
reference methods. Calibration procedures described in
the method protocols should be referenced in the test
protocol. Particular attention should be paid to all
process monitors and continuous monitors. Calibration
procedures and frequencies should be summarized in a
table.
52.7 £ Analytical Procedures
Analytical procedures should follow EPA
standard methodology. All samples, along with the
associated analytical procedures, should be identified in
a table in the test protocol. Analytical procedures
unique to the compliance test should be contained in an
Bff\SECTQS.BIF
5-23
-------
Table 5-5
Analytical Methods for Metals in Stack Samples
Constituent
Antimony
Arsenic
Barium
Beryllium
Pfldfniiim
Chromium (total)
Chromium (VI)
Lead
Mercury
Silver
Thallium
Analytical Method*
7041
7060,k 7061b
6010,7080
6010, 7090, 7091
6010, 7130, 7131
6010, 7190, 7191
40 CFR Part 266, Appendix DC
6010, 7420, 7421
7470,e 7471"
6010, Tiff?
6010, 7841
•SW-846 methods.
*This method includes digestion for aqueous matrices (no separate digestion method is necessary).
clon chromatography involving a post-column reactor.
dThis method includes digestion for all matrices (no separate digestion method is necessary).
RPF\008
1003-Ol.ipf
5-24
-------
appendix All modifications of standard methods, along
with reasons for the changes, should be identified.
5.2.7.6 Specific Internal QC Checks
For each analytical method, specific laboratory
internal QC procedures should be described in detail.
These procedures should each have an associated QC
objective. The instrument check standard, the surrogate
spiking levels, the component to be spiked, the type and
number of blanks, the spiking levels of the blank, the
blank acceptance criteria, and the required analyses of
duplicate samples should be described, as appropriate
for the particular method.
5.2.7.7 Data Reduction, Validation, and Reporting
For each major measurement parameter, the
following items should be included in the test protocol:
• A brief description of the data reduction
scheme for nonroutine methods, including all
validation steps and equations used to calculate
the final results;
• A list of all final experimental data to be
reported in the compliance certification
package; and
• A list of all QC data to be reported in the
compliance certification package.
For data reduction schemes in which
calculations are specified in the methods, only a
summary need be presented; however, the steps in the
data reduction process should be identified. Validation
of analysis results can be performed in many different
ways, but the central concept is that QC results should
be within the specified acceptance criteria for any given
analysis.
Of particular importance is the evaluation of
blank data. Blank results provide a qualitative (not
quantitative) indication of potential sample
contamination; therefore, routine correction of any stack
gas sample results for blank results should not be
performed, regardless of the type of blank.
52.7A Routine Maintenance Procedures and
Schedules
A list of all critical equipment necessary to
maintain interim status operating conditions and to
demonstrate continuing compliance should be provided
in the test protocol For each measurement device (e.g.,
CO monitor, feed rate monitor, combustion chamber
pressure monitor, etc.), a maintenance procedure and
maintenance schedule should be outlined.
5.2.7.9 Assessment Procedures for Accuracy and
Precision
The formulas for assessing precision and
accuracy are given in the equations provided below. If
the number of data points (n) is less than 4, precision is
expressed as range percent (RF):
RP
X.-X,
avgX
100
where:
X, - highest analytical result
Xj • lowest analytical result
n
avgX « 1 E X,
n 1-1
If n is 4 or greater, precision is expressed as relative
standard deviation:
RSD
(standard deviation]
average value J
100
If using reference material of known concentration,
accuracy is usually expressed as accuracy (A):
^ ( concentration found in sample
I known concentration
BIF\SECTQS.BIF
5-25
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If accuracy is being determined by adding a known
quantity of an analyte (spiking), it is usually expressed as
% recovery (R):
%R
100
where:
Q«
Q,.
0,
quantity of analyte found in the spike sample
quantity of analyte found in the unspiked
sample
quantity of the added spike
5.2.7.10 Audit Procedures, Corrective Action, and QA
Reporting
This section of the QA part of the test protocol
must cover all QA activities for audit procedures and
corrective action. For the compliance test, all QA/QC
audits and reports must be identified. A minimum of
one audit of overall data quality must be performed and
documented by the applicant. All audits, major
problems, and significant corrective action must be
reported to QA personnel, project management, and
corporate management. The types of reports submitted
(e.g., audits) and the recipients (e.g., project leader)
must be identified in this section of the test protocol.
5.2.8 Personnel
The test protocol must identify key personnel
involved in the compliance test, along with their
qualifications and responsibilities. At a «*""""m", the
following persons should be identified: the facility-
designated signatory, die overall compliance test project
manager, the field sampling manager, and the QA
coordinator. Because of the complexity involved in this
type of sampling effort, the field sampling manager must
have experience in performing this type of sampling.
While not mandatory, it is highly recommended that the
facility obtain the services of a qualified stack-sampling
firm. In-house personnel may be used to perform the
compliance test provided that the personnel are
qualified.
5.2.9 Scheduling
Table 5-6 provides a sample schedule for
compliance certification. Sufficient time must be
allotted to adequately design and implement the test
protocol. The actual time necessary to prepare for and
conduct each test will vary by facility.
5.2.10 Compliance Test
EPA and state representatives, at their option,
may choose to attend the compliance test as observers.
However, because the interim status program is to be
self-implementing, with limited involvement by EPA or
state regulatory personnel, there is no requirement for
the Region or state to approve the test plan prior to the
performance of the test.
Worksheets are provided in Appendix G to
assist the owner/operator in reducing the raw data
generated during the compliance test. An
owner/operator may use these worksheets to generate
information that is required to complete the compEance
certification package, however, the worksheets are not
required. The worksheets assist in calculating inputs of
chlorine, ash, and metals, and stack emission rates and
concentrations of PM, HC1, Clj, and metals.
Many records are generated during a
compliance test, including test planning documents, field
record sheets, field notes, strip charts, process data
records, laboratory data sheets, and other information
and records supporting the compliance certification
package. All this information must be maintained in a
file at the facility and be available for inspection by
regulatory personnel on request Information supporting
the compliance test must be kept on file until closure of
the facility. It is acceptable to store these data on
computer disks or microfiche, as long as the information
is available for inspection. (Refer to Section 5.4 for
more information on recordkeeping.)
5-J
Determination and Certification of Interim
Status ODeratinc Limits
Within 90 days of completing compliance
testing, and based on the results of the compliance test,
Bff\SECnJS.BIF
5-26
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Table 5-6
Sample Compliance Certification Schedule
Item
Begin to Prepare Compliance Test Protocol
Select Test Contractor (Optional)
Conduct Pretest Site Visit by Contractor (Optional)
Notify Regulatory Agencies in Writing
Acquire All Wastes and Spiking Compounds
Begin Facility Preparation
Install Necessary Sampling Access
Number and Weigh all Containerized Solid Feed
Conduct Test
Complete Sample Analysis
Conduct Data Validation and Interpretation
Begin to Prepare Test Report and Compliance Certification
Package
Submit Compliance Certification to EPA
Approximate Schedule
3 months before test
3 months before test
3 months before test
At least 30 days before test
1 month before test
2-3 weeks before test
1 week before test
2-3 days before test
1-2 weeks
1-1*4 months after test
lfc-2 months after test
Immediately following test
90 days after test
RPF\008
1003-01.rpf
5-27
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the owner/operator must submit to the Director or
appropriate regulatory agency a certification of
compliance with the emissions standards established in
the BIF Rule, establishing limits on the operating
parameters specified in §266.103(c)(l). The compliance
certification serves as the basis for defining limits on the
facility hazardous-waste burning activities for the
remainder of operation under interim status. Along
with the limits on operating parameters (specified in
J266.103(c)(4)), the list of information provided at
§266.103(c)(4) must also be submitted. The information
requirements, along with sample forms that may be used
in the compliance certification package, are also
provided in Appendix D.
The procedure to certify compliance is designed
to be self-implementing, i.e., it is the responsibility of
owners/operators to define their own compliance test
operating conditions, conduct the test, evaluate the test
results, and use those results to define post-compliance
certification interim status operating limits that are both
in compliance with the regulations and acceptable to the
owner/operator for long-term facility operations.
Feedback normally provided by regulatory agencies
during a full-scale permitting effort is not a part of this
procedure.
A facility must determine both operating and
feed rate limits based on the results of the compliance
test. Operating conditions and feed rates established
from the compliance test must not be exceeded during
subsequent operation under interim status.
Operating limits for all parameters listed in
§266.103(c)(l) are calculated from data obtained during
each valid run of the compliance test using either of the
following procedures:
1. instantaneous Limits. A parameter may be
measured and recorded on an instantaneous
basis and the limit is then calculated as the
time-weighted average of the parameter during
all runs.
2. Hourly Polling Average Limits. A parameter
may be measured on a continuous basis (e.g.,
detector response is evaluated every 15 seconds
without interruption) and recorded as the
1-minute average value at least every 60
seconds. An hourly rolling average of the 60
most recent 1-minute averages is also recorded
by this system. The operating limit is then
established as the average over all valid runs of
the highest or lowest, as appropriate, hourly
rolling average for each run.
Feed rate limits for metals, total chloride and
chlorine, and ash are established by knowing the
concentration of each substance in each feed stream and
the flow rate of the feed stream.
Under |266.103(c)(4)(fv)(C), compliance with
feed rate limits for the carcinogenic metals (arsenic,
beryllium, cadmium, and chromium) and lead may be
demonstrated either on an hourly rolling average basis
or on up to a 24-hour rolling average basis. If the
owner /operator elects to use an averaging period from
2 to 24 hours:
1.
3.
The feed rate of the metal is determined from
the compliance test data as the average over all
test runs of the highest hourly rolling average
feed rate for each run.
The feed rate of each metal is limited at any
time to 10 times the feed rate that wot03 be
allowed on an hourly rolling average basis.
The rolling average for the selected averaging
period is defined as the mean of the 1-hour
block averages for the averaging period. A
1-hour block average for any hour is the mean
of the 60, 1-minute averages for that clock hour
As noted in Section 5.23, it may be necessary
in some situations (e.g., for BTPs burning a wide variety
of waste streams containing differing amounts of Cr*'
and Cr*3) to establish separate feed rate limits for total
chromium and for Cr*' to ensure that the amount of
Cr** fed to the BIF does not exceed the level
demonstrated during the compliance test.
Post-compliance certification interim status
limits for CO, HC, and PM are also determined through
compliance testing; however, the compliance test serves
as a verification for pre-established limits. For example,
the CO limit (Tier I) is set at 100 ppmv at 7% O5, if the
highest 60-minute averages for CO during all runs do
not exceed this level. If any of the runs exceed this
level, however, the limit (Tier D) is set at the average of
the highest 60-minute averages for CO for all runs
measured during the compliance test. If a facility
operates under Tier II and does not request an
alternative HC limit, HC emissions are limited to 20
ppmv at 7% O2. The highest 60-minute averages for
BIF\SECT05.BIF
5-28
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HC during any of the runs may not exceed 20 ppmv.
For PM, the facility must demonstrate that each non-
soot blowing run and the time-weighted average (TWA)
of all runs do not exceed the 0.08 gr/dscf PM standard
5J.1 Sample Calculations
To determine minimum or maximum operating
limits for process or APCS parameters, an average of
the highest or lowest 60-minute averages for all runs for
a specific test condition is typically required. This 60-
minute average can be estimated as:
Avg-.
5.4
Options in the Event of NoncompHance
N
where:
Avg
Avg.,
average of highest or lowest (as
appropriate) 60-minute averages for all
runs for a specific test condition
individual highest or lowest 60-minute
average for each run for a specific test
condition
number of runs
Certain activities occur during a standard
operating day which may lead to a buildup of PM,
metals, HO, and Qj over a normal operating cycle. It
is necessary to calculate the time-weighted average
emissions resulting from such operations. The equation
provided for soot blowing in Section 523.9 can be used
for this purpose.
5.3.2 Compliance Ccrtificatioo
A complete list of the information required for
compliance certification is provided in §266.103(c)(l)
and (4) and in Forms CC-1 through CC-5 in Appendix
D. While the use of these forms is not mandatory, they
are provided to assist the owner /operator in submitting
the required information; the required information must
be submitted in writing to the Director within 90
calendar days of completion of the compliance test.
Separate documentation must be prepared for each BIF
unit tested.
If a facility is unable to comply with the
deadlines for submitting a compliance certification or
recertification, the owner /operator must either obtain a
time extension under §266.103(c)(7), or terminate
hazardous waste burning on the date the deadline is
missed and begin closure of hazardous waste portion of
the BIF facility. Appendix F contains a sample time
extension request form.
Under §266.103(e), if a facility does not comply
with the interim status compliance schedule for
precompliance, compliance, or periodic recertification,
hazardous waste burning must stop, closure must begin,
and hazardous waste burning may not resume without a
RCRA operating permit Figure 5-1 illustrates the
options available for faculties that cannot meet the
compliance schedule.
5.4.1 Antomatk 12-Month Extensions
An owner/operator of a BIF that has not
submitted a certification of compliance with interim
status requirements by August 21,1992, but who intends
to resume hazardous waste burning in the future, can
take an automatic 12-month extension under
f266.103(c)(7)(i)(B) to delay certification of compliance
until August 21,1993. Hazardous waste burning during
this 12-month period is limited to 720 hours and is
allowed only for the purpose of precompliance testing,
compliance testing, or pretesting to prepare for
compliance totting Although *h« extension is
automatically granted, the owner/operator must submit
a notification to the Director by August 21, 1992,
indicating that the facility will limit operation to comply
with these restrictions. If the facility does not submit a
certification of compliance by the end of the 12-month
extension period, the owner/operator must either cease
burning hazardous waste and implement closure of the
affected units, or have been granted a case-by-case
extension, as described below.
-------
5.42 Case-by-Case Extensions
Under §266.1Q3(c)(7)(ii), an owner/operator
may request a case-by-case time extension by submitting
an extension request to the Director. Such requests
should be submitted well in advance of the applicable
regulatory deadline to allow sufficient time for Agency
review. The Director can grant such a request in
written correspondence to the owner/operator if he/she
determines that the owner/operator has made a good-
faith effort to comply with the requirements in a timely
manner, but for reasons beyond his/her control, is not
able to meet the certification of compliance deadline.
These reasons could include, but are not limited
to, inability to complete modifications to an air pollution
control system in time to conduct the compliance test to
support the certification; seasonal operations that restrict
the facility's ability to generate representative wastes for
the compliance test; unplanned outage of the facility due
to equipment problems just before the scheduled
compliance testing; or high HC levels attributable to
organics in raw materials (Section 9.0).
The extension request should also provide
support for the additional time requested and be
submitted well in advance of the applicable deadline to
allow adequate time for making a determination. EPA
will respond in a letter to grant or deny the extension.
The Director can limit the length of the extension and
may impose conditions to ensure that the BIF will
operate in a manner that protects human health and the
environment until compliance is certified. For example,
the Director may condition an extension on the
installation of CEM equipment if he/she feels CO/HC
monitoring is necessary to protect human health and the
environment.
A case-by-case extension may be requested and
granted for any interim status deadline (except for the
precompliance certification deadline). For instance, a
case-by-case extension may be granted to an
owner/operator who (1) elected to take the 12-month
automatic extension but is still unable to comply (for
reasons beyond his/her control) at the end of the 12-
month period, (2) has an existing case-by-case extension,
or (3) cannot comply with the recertification schedule
(for reasons beyond his/her control).
5.43 Closure
If a facility chooses to dose or must dose (i.e.,
did not comply with a certification deadline), the facility
must implement dosure activities as specified in
§266.103(1). When dosing a BIF, all hazardous waste
and hazardous waste residues (induding, but not limited
to, ash, scrubber water, and scrubber sludges) must be
removed from the unit. In addition, the owner/operator
must comply with the general interim status dosure
requirements of {265.111 through 265.115, as amended.
These requirements specify dosure performance
standards; submission of and compliance with a written
dosure plan; disposal or decontamination of equipment,
structures, and soils; and certification procedures for
dosure.
Under J265.112(a), every BIF owner/operator
must have a written detailed dosure plan on file at the
facility within 6 months after the effective date of the
rule, February 21, 1992. This dosure plan must be
submitted to the Director at least 45 days before the
date on which an owner/operator expects to begin
partial or final dosure of any BIF.
Under §265.112(d)(2), for an owner/operator
who fails to meet any interim status certification
deadlines, the date "when he/she expected to begin
dosure" is within 30 days after the applicable deadline.
Interim status certification deadlines include those for
certification of precompliance, certification of
compliance (whether complying by August 21, 1992 or
under a time extension), and periodic recertification.
For any other BIF owner/operator who doses during
interim status operation (Le., one who doses before
August 21, 1992, or one who submits a complete
certification of compliance by the applicable deadline
and then chooses to dose during interim status), the
date "when he/she expects to begin dosure" is either 30
days after the date on which the final known volume of
hazardous waste was received, or if there is a reasonable
possibility that the unit will receive additional hazardous
waste, no later than 1 year after the date on which the
unit received the most recent volume of hazardous
waste.
Under J265.113(a), within 90 days after either
(1) receipt of approval of the facility's dosure plan, or
(2) receipt of the final volume of hazardous waste (a
facility has received "the final known volume of
hazardous waste* on the date any interim status
certification deadline is missed), whichever is later, all
hazardous waste must be treated, removed from the unit
or facility, or disposed on site, in accordance with the
facility's approved dosure plan (unless a longer period
is granted by the Director).
BIF\SECr05.BIF
5-30
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Under §265.113(b), within the subsequent 90
days, all other closure activities must be completed
(unless an extension to the closure period is approved by
the Director). Under §265.115, within 60 days after
completion of all closure activities, the owner /operator
must submit a certification that the BIF was closed in
accordance with the approved closure plan. Once a BIF
closes, a RCRA permit is required before hazardous
waste burning can resume.
BIF\SECTQ5.BIF 5-31
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6.0 POST-COMPLIANCE
ACTIVITIES
CERTIFICATION
This section discusses the requirements for the
demonstration of continued compliance with the interim
status requirements of the BIF Rule after an
owner/operator submits a certification of compliance.
(.1
Waste Analysis
Until an operating permit is issued, all fuels,
raw material feedstocks, and waste materials fed to the
combustion device must be routinely analyzed (as often
as necessary) for operating parameters under
|266.103(c) defined in the facility's compliance
certification package to ensure that the BIF operates
within these limits when there is hazardous waste in the
unit This requirement applies during all phases of
interim status operations, including the precompliance
period. These parameters include chlorine, ash, and
metals, as well as analyses to verify the absence of
certain dioxin-containing wastes that the facility is
prohibited from burning under §266.103(a)(3) while
operating under interim status. If any operating
conditions change, including changes in feed stream
characteristics, that would result in an exceedance of an
operating limit specified in the compliance certification,
the owner/operator must submit a revised certification
of compliance in accordance with §266.103(c)(8).
In addition, under $265.13, the owner/operator
must obtain detailed chemical and physical analyses of
representative samples of each hazardous waste burned
in the BIF. These analyses must be repeated as
necessary to ensure that they accurately describe all of
the hazardous waste being burned or processed in the
BIF. At a m'""""f"t the analyses must be repeated:
(1) whenever the owner/operator has reason to believe
that the process or operation generating any of the
hazardous waste hat changed; and (2) for facilities that
accept hazardous waste generated off site, whenever the
results of a "fingerprint" analysis indicate that the
incoming hazardous waste shipment does not match the
description on the manifest or shipping paper. The
fingerprint analysis that must be performed by BIFs that
accept hazardous waste generated off site must also
include a visual inspection of the waste as well as a
determination that the waste matches the manifest or
shipping paper.
The facility must develop and implement a
written waste analysis plan, as specified in §265.13, that
describes the procedures the owner/operator will use to
comply with the above requirements. The plan must
contain a description of all sampling parameters,
sampling and analytical methods, analytical quality
control, and any other requirements necessary to
characterize the waste stream. The plan must include
procedures for performing both the fingerprint analysis
and the complete waste characterization. The waste
analysis plan must be kept on file at the facility.
Documentation of the waste characterization
should include, at a minimum:
• Dates the samples were obtained;
• Sampling methods used to obtain the
representative samples;
• Name of the laboratory performing the
analyses;
• Sample preparation and analysis methods;
• Dates the analyses were performed; r_
• Results (values and units); and *!
• Analytical QC results and assessments of data
quality.
The waste sampling and analysis methods
should be SW-846 methods (34) where applicable.
Alternate methods may be used provided the methods
meet or exceed the comparable SW-846 performance
criteria. In cases where an SW-846 method is not
available for a particular constituent of concern, Le., the
constituent is an Appendix VTEL, Part 261 constituent
reasonably expected to be contained in the waste but for
which there is no appropriate SW-846 method, or
analytical standards for a constituent are not available,
the facility should contact its EPA Regional office for
guidance. The associated QC procedures, including
method detection limits for any alternate methods, must
be equivalent to the SW-846 QC procedures. Copies of
all routine analytical documentation must be placed in
the facility's operating record.
Calibra nd Equipment
&2.1 Continuous Emission Monitoring Systems
Performance specifications for continuous
emission monitoring (CEM) systems (CO, O,, and HC)
for BIFs are provided in detail in Section 2.0 of
Appendix IX to the BIF Rule. Appendix IX also
includes specifications for the installation of CEM
systems. These specifications include performance
Bff\SECID6.BIF
6-1
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specifications (calibration drift, calibration error,
response time, and relative accuracy) and measurement
location specifications. Span values necessary for Tier
I and Tier £1 compliance also are discussed in
Appendix DC.
The owner/operator must establish a QA
program for the evaluation and monitoring of CEM
system performance. The minimum requirements for
this program include: (1) a daily calibration check for
each monitor; (2) a daily system audit; (3) a quarterly
calibration error (CE) test; and (4) an annual
performance specification test The facility may
continue normal operations, including hazardous waste
burning, during the short calibration time needed by
state-of-the-art CEMs. A calibration time of 15 to 20
minutes is typical for each CEM.
Reporting requirements call for a tabular
summary of all parameters that are scheduled for
assessment: calibration drift (CD), relative accuracy
(RA), response time, or calibration error (CE). All
records must be maintained as described in Section 63.
622 Automatic Waste Feed Cutoff Systems
The automatic waste feed cutoff system, along
with its associated alarms, must be tested for operability
at least once every 7 days when the facility is burning
hazardous waste, unless the owner/operator
demonstrates that such inspections will upset or restrict
operations and that less frequent inspections are
adequate. This demonstration must be part of the
operations record. At a minimum, the waste feed cutoff
system must be tested every 30 days.
Tests of the waste feed cutoff system are meant
to verify operation and are not meant to require
dismantling or nrnfbfiH1"* calibration. To test the
system, the shutoff "valve* needs to be activated once
during the weekly imppftkrcv, a check of every input to
the safety system does not have to activate the valve.
However, if the valve is "fail safe* (Le, remains in the
closed position in the event of a failure), only the
control panel circuits and associated alarms need weekly
testing; the valve need not be activated. This can be
accomplished with an electronic loop test for the
components of the system, including sensors, which tests
the operability of the circuit without actually dosing the
fail safe* valve and stopping flow.
If the waste feed cutoff system "trips" (i.e., waste
feed is cut off due to a process operations excursion
from specified limits) during a 7-day period, the actual
trip will satisfy the need to test the valve. However, the
other components of the cutoff system still need to be
tested to ensure they are functioning properly.
Except as discussed above for 'fail-safe' valves,
the waste feed must be stopped during the system test.
One alternative facilities may wish to consider is to have
a manually lockable bypass valve around the automatic
waste feed shutoff valve. This bypass valve must be
locked dosed during normal operation but would be
opened by qualified personnel during testing of the
automatic valve to prevent disruption of the waste feed.
If this approach is used, records must be maintained
that document the position and condition (normally
locked dosed) of the bypass valve.
In accordance with 40 CFR 265.15 (General
Inspection Requirements), interim status facilities must
develop and follow a written schedule for inspections of
equipment, such as the waste feed cutoff system, that
are important to preventing, detecting, or responding to
environmental or human health hazards. The
procedures for testing the automatic waste feed cutoff
system must be detailed in the inspection schedule.
6JJ Fugitive Emissions Systems
During interim status, BIFs must comply with
the requirements in §266.103(h) to control fugitive
emissions from the combustion zone. Identical
requirements are imposed on permitted units under
$266.102(e)(7). These requirements include: (1)
keeping the combustion zone sealed against fugitive
emissions, (2) maintaining the combustion zone at less
than atmospheric pressure, or (3) an alternative method
of control that the owner/operator can demonstrate
provides fugitive emissions control equivalent to that
achieved by operating at less than atmospheric pressure.
Similar requirements are imposed on incinerators under
}264345(d).
The objective of these requirements is to ensure
that potentially toxic gases are not emitted through
leaking seals, access doors, expansion joints, or openings
in the combustion device. Of particular concern are
fifftl^ on Viln< and other rotating equipment that can
become worn or out of alignment. Although most of
BIF\SECT06.BIF
6-2
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these units are designed to operate under negative
pressure, the potential exists for gas pressures to exceed
atmospheric when containerized wastes burst upon
To comply with these provisions, the owner/
operator of a positive-pressure BIF must establish an
inspection and maintenance program to demonstrate
that: (1) the unit is being regularly inspected to identify
leaking seals or other openings through which fugitive
gases could potentially be emitted, and (2) any such
leaks are promptly corrected. For example, as part of
the BIF operator's daily inspection activities, all seals,
access doors, expansion joints, and other openings from
the BIF should be visually inspected for any sign of
leaks. In addition, a monthly inspection of the BEF
using a hand-held carbon dioxide (COj) monitor,
infrared camera, or some other means may be useful in
confirming that no leaks exist For example, a leak
through a defective seal on a positive-pressure BIF
should be observable using a CO2 monitor to look for
elevated CO2 levels near the leak. The results of all
such inspections and associated maintenance activities
must be maintained as part of the unit's operating
record.
The owner /operator of a negative-pressure BIF
that feeds containerized wastes must demonstrate by
actual measurements, engineering calculations, or other
methods that the unit does not generate pressures
greater than atmospheric when waste containers burst.
If this analysis indicates that temporary positive
pressures can be generated, the BIF must establish an
inspection and maintenance program similar to that
required for positive-pressure BIFs.
During interim tfat1f*, the facility must maintain
an operating record documenting all pertinent operating,
maintenance, monitoring, and inspection activities to
demonstrate compliance with the BEF regulations (see
$266.103(k)). In addition, a BIF correspondence file
must be maintained. |266.103(k) also requires the
owner/operator to maintain the operating record until
closure of the boiler or industrial furnace. The
operating record must be sufficient to allow a RCRA
inspector to evaluate whether a facility has been
operating in compliance with the BIF regulations.
Information which should be placed in the
operating record includes:
• A description of the type, quantity, and date(s)
for each hazardous waste received and/or
handled at the facility, and the date(s) on which
the wastes were burned or otherwise disposed.
• The location of each hazardous waste within
the facility and the quantity at each location.
• Records and results of all waste analyses and
waste characterization (see Section 6.1 for
waste analysis requirements).
• Records from all continuous emission monitors
for CO, Oj, and if applicable, HC Continuous
emissions monitoring requirements and options
for recording CEM data are discussed in
Section 4.0.
• Records from all monitoring of process
operating parameters, including temperature,
pressure, feed rate(s), concentration(s), flow
rate,' production rate, and any APCD operating
parameters for which limits have been
established (see Section 4.0 for process
monitoring requirements and options for
recording these data).
• Records associated with the handling of
combustion residues. At a mini"""" the
following must be recorded: (1) concentrations
of 40 CFR, Part 261, Appendix VTO toxic
constituents that are present in waste-derived
residues; and (2) if the waste-derived residue is
compared with normal residue (see Section 11.0
and S266.112(b)(l) for guidance on residue
comparison), two additional items must be
recorded: (a) the concentrations of 40 CFR
Part 261, Appendix Vin constituents that are
present in normal residues, and (b) data and
information including analyses of samples if
necessary, obtained to determine if changes in
raw materials or fuels would reduce the
concentration of toxic constituents of concern in
the normal residue.
Records associated with inspections,
calibrations, and equipment maintenance (see
Section 62 for inspection, calibration, and
equipment maintenance requirements).
BIF\SECn)6.BIF
6-3
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• Records documenting the dates, times, and
reason(s) for any automatic waste feed cutoffs,
as well as instances where the automatic waste
feed cutoff was not activated when parameters
reached cutoff levels, including the reasons and
the corrective actions taken.
• Summary reports and details of all incidents
that require implementation of the contingency
plan (required information is specified in
§265J6(d)).
• If a facility is operating under an extension or
is recertifying for new conditions (see
Section 6.4 for revised certification and
recertification requirements), records must be
maintained to document that the allowable 720
hours of waste burning are not exceeded.
• Any facility-specific issues or unusual
occurrences, including any signs of leaks, spills,
or fugitive emissions from the BIF unit or
associated equipment (e.g. pumps, valves, pipes,
fuel storage tanks, etc.).
The owner/operator must record all monitoring
information and data on a real-time basis, with the date
and time clearly discernible on each record. All waste
feed records and analytical results must be clearly
marked to show the time at which the wastes were fed
to the combustor. Facilities that have demonstrated
compliance for multiple sets of operating modes (see
Section 523.1 for guidance on multiple operating
modes) must keep records that clearly show the set of
feed rate limits and operating restrictions under which
the facility is operating at a given time.
For facilities with multiple feed streams, the
records must clearly show the concentrations and
corresponding feed rates of chlorine, ash, and each
metal in each stream on a real-time basis so that
compliance with the appropriate feed rate limits can be
demonstrated. To facilitate retrieval and analysis of
material feed data, use of a computerized data storage
and retrieval system is recommended. With the
exception of lead and carcinogenic metals, sufficient
information must be available to calculate feed rates and
demonstrate compliance on an hourly rolling average
basis. For lead and carcinogenic metals, compliance can
be demonstrated on an (up to) 24-hour rolling average
basis.
Data may be recorded using units of
measurement similar to those used in the instrument's
record as long as they may be readily converted to units
that are appropriate to the operating limits. Each
instrument should be identified with a code number, and
the manufacturer's name and model number, or other
unique identifier. Calibration methods for the
instruments should be noted.
All records (including those stored
electronically) should be easily accessible during
inspections. Records should be maintained in a central
location, either in a hard copy format or an electronic
format, which can be accessed when requested.
Separate detailed files should be maintained for each
type of required activity. A dairy master log can then be
maintained that cross-references all records required by
5266.103. Records must be kept until closure of the
facility, with the following two exceptions: (1) exempt
faculties (e-g^ smelters, small-quantity burners) must
retain records for only 3 years under J266.100(c)(l)(iii)
and (f)(3) and §266.108(e), and (2) inspection records
and results of inspections need be kept only 3 yean, as
specified in §265.73(b)(5).
6.4 Periodic Recertiflcation and Revised
Certification of Compliance Requirements
Once a facility has demonstrated compliance
with the interim status requirements described in the
preceding sections of this document and has submitted
a complete certification of compliance to the appropriate
regulatory authority, the facility should operate within
the limits (Le., operating limits and emission standards)
at all times, whether or not the facility is burning or
processing hazardous waste (i.e., higher emissions
resulting from the burning or processing of unregulated
waste should not occur until closure and
dff-fYn^apiitiatinn are conducted). Furthermore, because
of the potential for degradation in the operating
performance of combustion devices and air pollution
control devices over time, all interim status facilities are
required to conduct a recertification compliance test at
least once every 3 years to demonstrate that the unit's
operation is still in compliance with the allowable
emissions rates. This is the periodic recertification
required by §266.103(d). In addition, an owner/operator
may recertify compliance (and thus, associated operating
and emissions limits) at any time (i.e., before required
3-year periodic certification is due). This is the revised
certification of compliance allowed by §266.103(c)(8).
BIF\SECT06.BIF
6-4
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The requirements for a revised certification of
compliance and a periodic recertification are essentially
the same as those required for the certification of
compliance required by J266.103(c). Specifically, the
facility must perform a compliance test to demonstrate
compliance with emissions standards for PM, metals,
HO, Clj, CO, and if applicable, HC. (When recertifying
under §266.103(c)(8) or (d), a facility must demonstrate
compliance with the HC limit (if applicable) using the
heated monitoring system specified in 40 CFR Part 266,
Appendix DC) All notification and cubmittal
requirements discussed in earlier sections must be
followed, including submittal of a written test protocol.
Finally, compliance must be certified by submitting a
new certification of compliance based on the new test
results. These requirements are discussed in more
detail in the following paragraphs.
Within 3 years of the signature and submittal of
the facility's most recent compliance certification
package, the owner/operator must recertify compliance
by conducting a new compliance test and submitting a
new certification of compliance package. The new
compliance test can be conducted at any time during the
3-year period and can be conducted for the purpose of
either recertifying the existing operating limits or
establishing revised operating limits.
Performing a compliance test to recertify
current operating limits is most suitable for a faculty
that has not experienced any substantive changes either
in the type or quality of wastes fed to the combustion
system, or in the system operation, or enforcement
actions.
However, if a facility wants to increase or
change other operating parameters and limits, the
owner/operator mutt conduct a compliance test to
document compliance at the new conditions. No
parameters or limits may exceed levels established in the
precompliance certification, and testing at the new
conditions must not exceed 720 cumulative hours of
operations before submittal of the new certification to
EPA or the state. The limitation of 720 hours of testing
is based on hours of waste feeding at the proposed
operating conditions. The 720 hours may occur during
a number of short-term tests conducted over a time
period of several months and need not be continuous.
Written records documenting the number of testing
hours must be maintained by the owner/operator to
demonstrate compliance with this limitation.
Documentation of new compliance test results
must be submitted within 90 days of completion of the
test If a facility has successfully demonstrated new
operating limits, it may begin operating under the new
limits once a complete, signed, and dated new
certification of compliance package has been submitted.
At that time (i.en ^e signature date on the
recertification package), the new 3-year certification
period begins, and any previously submitted compliance
certifications are superseded. As a result, if the facility
plans to continue operating at existing operating
conditions, as well as at new operating conditions, the
existing conditions must be recertified in addition to the
new conditions.
If results of compliance testing (for purposes of
recertifying compliance or revising compliance
certification) show that allowable emission limits have
not been met, within 90 days of the test, the
owner/operator should: (1) submit the test rtiults
indicating which aspects of the test were failed,
(2) submit a revised precompliance certification based
on the engineering knowledge resulting from the failed
test, and (3) submit a revised test plan for a new
compliance test and notify the Director of the date for
the revised test (see J266.103(c)(2)).
After a failed test, a facility may continue to
burn hazardous waste only if: (1) operating conditions
do not exceed the revised precompliance limits, (2) the
facility has previously certified compliance at the
planned operating conditions, and (3) the facility has not
failed a compliance test at the planned operating
conditions. Under §266.103(e), if a new compliance test
and certification package are not completed before the
end of the 3-year periodic certification period, the
facility must either cease burning hazardous waste or
request a case-by-case time extension under
266.103(c)(7)(ii). Guidance on both of these options is
provided in Section 5.0.
6-5
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7.0 SPECIAL REQUIREMENTS FOR BOILERS
AND INDUSTRIAL FURNACES FEEDING
HAZARDOUS WASTE AT LOCATIONS
OTHER THAN THE HOT END
The hot end of the combustion device is the end
where products are normally discharged.gr where fuels
are normally fired." Although the requirements apply
to any industrial furnace that feeds hazardous waste at
locations other than the hot end, the discussion in this
section is primarily directed toward cement kilns. The
hot end of a cement kiln is considered to be the lower
end, where fuels are normally fired .or where clinker
(product) is discharged.
These special requirements (discussed in more
detail in Section 7.1) are specified in the BIF Rule to
ensure adequate destruction of the hazardous waste
because the DRE standard (which requires a
demonstration by trial burn that organic constituents in
the hazardous waste are destroyed) is not applicable
during interim status. These special requirements do
not apply if the hazardous waste is fed solely as an
ingredient (as explained in Section 12). Precompliance
certification requirements for BIFs that feed hazardous
waste at locations other than the hot end are described
in Section 73.
7.1
Soecial Reonirements
The special requirements that apply to kilns that
feed hazardous waste fuels at locations other than the
hot end during interim status are provided in
§266.103(a)(5) and summarized below:
(1)
(2)
(3)
The facility must monitor for HC and comply
with the Tier II standard for PIC control,
regardless of the faculty's CO level
The
gas temperature at the location
waste b being fired must be
where the
maintained it a minimum of 1800*F.
The owner/operator must determine that
sufficient oxygen is present to combust the
(4)
waste and retain documentation to this effect in
the facility record.
Hazardous waste must be fed only into the kiln
itself, not into a precalciner or preheater.
7X1 HC Monitoring
BEFs firing hazardous waste fuels at locations
other than the hot end during interim status must
monitor HC and either comply with the 20 ppmv HC
limit or apply for an alternative HC limit. For such
faculties, the requirement for mandatory HC monitoring
is in addition to the CO monitoring requirement, and
applies even if the facility's CO level is less than
100 ppmv.
7X2 Temperature Control at Feed Location
To be eligible to feed hazardous waste fuels at
locations other than the hot end of the kiln during
interim status, an owner/operator must demonstrate
that the combustion gas temperature at the point wnere
the waste is being fed is at least 1800*F. If the facility
feeds containerized waste such that the container is
propelled into the interior of the loin, the temperature
measurement point is the point at which the waste in the
container is exposed to combustion gases - generally the
location where the container impacts the charge bed.
The facility must document the point of impact. Also,
if the kiln is using a "trap door'-type device in the kiln
wall to introduce waste into the middle of the kiln, the
measurement location would be at the device opening
for noncontainerized waste, and at the charge bed
impact point for containerized waste (9).
The measurement locations may or may not be
routinely accessible by normal measurement means. In
cases where containers impact inside the K'"t it may be
sufficient to demonstrate that temperatures upstream
(Le., toward the feed end of the kiln) of the impact
point, at locations normally monitored by the facility, are
in excess of 1800T. Temperatures at the end of the kiln
should be measurable »«ng the techniques discussed in
Section 4.0.
"The February 21.1991 final BIF Rule identified special requirements for boilers and ioducrrial furnaces firing hazardous waste at locations
where products are normally discharged and where fuels are normally fired. The special requirements defined by the final BIF Rule
unintentionally applied to halogen acid furnaces (HAFt) and other industrial furnaces that feed hazardous waste where fuels are normally fired
but that discharge products at another location. However, because EPA expects the interim Status CO standards to effectively control organic
emissions from these furnaces, the special requirements are unnecessary. Therefore, EPA revised the applicability of the special requirements on
August 27,1991 to exclude devices such as HAFs.
BIF/SECT07.BIF
7-1
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The BIF Rule requires a one-time
documentation that the combustion gas temperature at
the feed location is 180CTF or greater. The BIF Rule
does not require that this temperature be monitored.
7J.J Determination of Adequate Oxygen for
Combustion
Owners/operators of furnaces that feed
hazardous waste fuels at locations other than the hot
end during interim status are required to demonstrate
that adequate oxygen is present to combust the waste
and must retain documentation of this determination in
the facility record (§266,103(a)(5)(i)(B)). This
requirement, combined with the other requirements
discussed in Sections 7.1.1, 7.1.2, and 7.1.4, helps to
ensure that adequate destruction of the waste is
achieved, since the DRE standard (which requires a
demonstration by trial burn that organic constituents in
the waste are destroyed) is not applicable during interim
status.
The following two approaches can be used by a
facility to determine that adequate oxygen is available
for combustion:
(1) Conduct emissions testing (Le., DRE trial burn)
to show that the facility can achieve at least
99.99% DRE for POHCs fed at the intended
waste feed locations; or
(2) Conduct measurements at the feed locations (or
a location representative of the feed locations)
and/or perform calculations to show that the
oxygen level at the feed locations is adequate to
achieve a minimum of 99.99% DRE for toxic
organic constituents in the waste.
Under either approach (described in more
detail below), an owner/operator should submit a
description of the procedures he/she intends to follow
to demonstrate that adequate oxygen is available to
destroy the waste, along with the compliance test
notification package. If a DRE trial burn will be
performed, the trial burn plan should also be included
with the compliance test notification package.
7.13.1 DRE Trial Barns to Demonstrate Adequate
Oxygen
One approach for demonstrating adequate
oxygen for combustion is to conduct a DRE trial burn.
To demonstrate that destruction of a waste is adequate
by conducting a DRE trial burn during interim status, a
facility should conduct a DRE trial burn as it would for
compliance with the RCRA Part B permit requirements.
The trial burn plan should be included with the
compliance test notification package. This plan should
dearly identify the waste feed locations, purpose of the
DRE testing, rationale for selection of POHCs, test
conditions, sampling and analytical methods, QA/QC
procedures, and any additional information needed to
clearly describe the planned testing and data evaluation.
The DRE trial burn must be conducted as part of the
compliance test, and the results must be used to
determine interim status operating limits.
There are two major differences between the
trial burn requirements under interim status and those
specified under the RCRA Part B permit:
(1) Burning of dioxin wastes is prohibited during
interim status regardless of the result of the
DRE trial burn. Specifically, if a facility ftfccts
POHCs that are more difficult to destroy than
dioxin/rurans and demonstrates 99.9999% DRE
on the POHCs, the facility is still prohibited
from burning these wastes during interim
status.
(2) The owner/operator should consult with EPA
on the selection of POHCs for the DRE trial
burn before submitting the trial burn plan with
the compliance test notification package;
however, the rule does not require EPA
approval of the trial burn plan.
Guidance on the selection of POHCs for a
DRE trial burn is provided in Section 10.0.
It may be possible for a facility to design the
DRE testing during interim status such that the data are
acceptable for submittal to EPA in lieu of a DRE trial
burn conducted at the time of the permit application.
However, in evaluating the suitability of the data
submitted in lieu of an additional DRE trial burn at the
time of the permit application, the Director will consider
the level of review and oversight provided by the
regulatory agency at the time of the trial burn, changes
in operations that may have occurred since the time of
the trial burn, and additional information collected by
the Agency since the time of the trial burn.
Bff\SECn>7.BIF
7-2
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In addition, because the interim status
requirements are largely self-implementing, with limited
oversight by the regulatory officials, conduct of a DRE
trial burn to comply with the demonstration of adequate
oxygen does not replace the temperature, CO/HC
monitoring, and other requirements for facilities feeding
hazardous waste fuels at locations other than the hot
end. All the controls listed in §266.103(a)(5) remain in
effect during interim status.
7.13.2 Measurements and/or Calculations
Demonstrate Adequate Oxygen
to
A second approach for demonstrating adequate
oxygen for combustion is to document through
measurements and/or calculations that a facility's
combustion system is designed and operated in such a
way as to achieve 99.99% or greater destruction of toxic
organic constituents in the waste. These calculations can
include measurement data on the oxygen levels at the
feed locations (or locations representative of the feed
locations) to show that the oxygen levels present during
operation exceed those levels theoretically required.
Such calculations should consider other factors that
affect combustion, including temperature, residence
time, turbulence or mixing, waste feeding mechanisms,
and oxygen content.
Owners/operators who choose to use this
approach should provide details on the calculations used
to demonstrate adequate destruction of the waste,
including planned waste feed locations, operating
conditions, etc., in their compliance test notification
package.
7.1.4 Feeding of Hazardous Waste Directly into
Cement Kilns
As indicated above, firing hazardous waste fuels
into locations not conducive to complete waste
combustion, such as preheaters or precalciners, is not
allowed under interim status. Since these units normally
operate at lower temperatures than those in the actual
Irilns it is uncertain whether sufficient destruction of the
organics in the waste material can be achieved, and no
test results are currently available to indicate actual
destruction and removal efficiencies when firing
hazardous waste fuels into preheaters or precalciners.
A facility has the option of proposing to burn waste in
a preheater or a precalciner during the permitting
process as a part of the Part B permit application.
Testing under this waste-burning scenario could be
incorporated into the trial burn plan, allowing evaluation
of the ability of the preheater or precaliner to
completely destroy organic constituents in the waste.
12 Criteria for Burning Hazardous Waste goldy
asanlnzrcdjent
The special requirements for BIFs feeding
hazardous waste at locations other than the hot end of
the furnace do not apply if the facility is burning or
processing the hazardous waste solely as an ingredient.
A hazardous waste is considered to be burned solely as
an ingredient if it is used to produce a product or to
replace a similar raw material Materials that are
burned (even partially) for destruction or energy
recovery are not burned solely as an ingredient Three
criteria are used to determine whether hazardous waste
is burned solely as an ingredient- (1) the concentration
of nonmetal constituents in the waste, (2) the heating
value of the waste, and (3) the use of the waste as a raw
material substitute. These criteria are discussed below.
7 J.I Concentration of Noametal Constituents (n the
Waste
To be considered an ingredient, a hazardous
waste (as-fired) must contain a total of 500 ppm or less
by weight of the nonmetal constituents listed in 40 CFR
Part 261, Appendix VID. If the waste has a total
concentration of these compounds of greater than 500
ppm, the waste is considered to be burned (at least
partially) for destruction. The concentration of
nonmetal compounds in a waste as-generated may be
reduced to the 500 ppm limit by bona fide treatment
that removes or destroys nonmetal constituents.
However, blending for dilution to meet the 500 ppm
limit is prohibited, and documentation that the waste has
not been impermissibly diluted must be retained in the
facility record.
Two alternatives are available for determining
the content of nonmetal 40 CFR Part 261, Appendix
Vm constituents in a waste stream. If the waste stream
contains insignificant amounts of organic material, a
screening analysis for total organics can be performed,
along with analyses for any nonmetal inorganic
Appendix Vm constituents (such as cyanides) that could
reasonably be expected to be present in the waste
stream. The sum of these analyses must be less than
500 ppm by weight. Alternatively, the facility may
choose to perform an Appendix VIII scan for
constituents that could reasonably be expected to be
Bff\SECT07.BIF
7-3
-------
present m the waste. The facility should document the
Appendix Vm constituents excluded from analysis, along
with the reasons for the exclusion. Sampling and
analysis performed in support of this requirement should
be incorporated in the facility's waste analysis plan.
Additional information on sampling and analytical
methods is provided in Section 5.0.
7 22 Heating Value of Hie Waste
To qualify as an ingredient, a hazardous waste
(as-fired) must also have a heating value of less than
5,000 Btu/Ib. If the waste has a heating value of 5,000
Btu/Ib or greater, EPA considers the waste to be
burned (at least partially) for the purpose of energy
recovery, rather than solely for use as an ingredient.
The heating value of a waste as-generated may be
reduced to below the 5,000 Btu/Ib limit by bona fide
treatment that removes or destroys organic constituents.
Blending to augment the heating value to meet the 5,000
Btu/lb limit is prohibited, and documentation that the
waste has not been impermissibly blended must be
retained in the facility record. Sampling and analysis
procedures used to determine the heating value of the
waste must be included in the facility's waste analysis
plan.
122 Use of the Waste as a Raw Material Substitute
For a hazardous waste to be a legitimate raw
material substitute, the facility must demonstrate the
similarity between the waste and the raw material being
replaced. See 56 FR 7185 (February 21, 191) for
additional information.
Certification
To certify precompliance, facilities that feed
waste at locations other than the hot end of the kiln
must submit documentation of compliance with the
requirements of |266.103(a)(5)(i)(A), (B), and (C).
Precompliance Certification Form 8 (PC-8) can be used
but is not required to submit this information. In
addition to submitting this information, owner /operators
must submit all other applicable information required in
the precompliance certification package. Appendix B
contains precompliance forms which may be used,
including Form PC-8.
Bff\SECT0731F 7-4
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8.0 METALS COMPLIANCE ALTERNATIVES
FOR FACILITIES THAT RECYCLE
COLLECTED PARTICULATE MATTER
BIFs that recycle collected paniculate matter
(PM) must comply with the same emissions standards
for metals that apply to all BIFs burning hazardous
waste. Because the recycled PM can affect metals
emissions, these facilities must use one of the following
three monitoring alternatives to demonstrate compliance
with the metal standards of §266.106(c) or (d):
• Kiln dust monitoring;
• Semicontinuous stack emissions t*f*'ng^ and
• Preconditioning before emissions testing.
These three alternative approaches for
demonstrating compliance with metals standards are
applicable only to facilities that recycle collected
paniculate matter (dust). Recycled dust is defined as
any dust (or material made from dust) that is collected
in an air pollution control system (APCS) from an
industrial furnace and is recharged to the furnace on a
regular basis (within 48 hours of collection), regardless
of the type of dust that is recharged. As an example, if
only cyclone dust is recycled and ESP dust is discarded,
the facility must comply with one of the alternative
metals approaches. Dust that is slurried, pelletized, or
made into bricks, may also be considered recycled dust.
Under interim status, one of the three
alternative metals implementation approaches must be
used by an industrial furnace that recycles collected PM.
Under the operating permit, however, the BIF Rule
allows the Director to approve these or alternative
implementation approaches. The operating
requirements that must be specified in the permit when
an alternative implementation approach is used are
listed in §266.102(e)(4X2i).
The initial date for implementation of the
metals standards under any of the alternative compliance
approaches depends on which option is selected.
Facilities initially choose an alternative metals option at
precompliance certification. If a facility elected to use
the Itiln dust monitoring approach, the precompliance
procedures described in Appendix DC of the BIF Rule
were to have been implemented by August 21,1991.
Upon certification of compliance (no later than
August 21, 1992 unless a time extension is granted), a
facility must comply with the compliance procedures for
this kiln dust monitoring approach, also outlined in
BIF\SECT08.BIF
Appendix IX of the BIF Rule. If a facility chooses
either semicontinuous stack emissions testing or
preconditioning, it must follow the same precompliance
procedures that apply to all boilers and industrial
furnaces, as described in Section 3.0. The
semicontinuous stack emissions testing or
preconditioning procedures must be implemented at the
time of the compliance test.
Facilities that decide to change options during
the precompliance period must submit a revised
certification of precompliance suitable for the selected
metals compliance alternative.
The three metals compliance alternatives are
described in more detail in Sections 8.1, 82, and 83,
respectively. The use of the different alternatives is
discussed in Section 8.4, and special concerns are
addressed in Section 8.5.
8.1
Kiln Dust Monitorinc
Under the kiln dust monitoring alternative, a
facility must comply with the same emissions standards
and must set operating limits for the same parameters
as regulated BIFs that do not recycle collected PM. An
exception is that a limit on the maximum feed rate of
each metal in the total feed stream is not required.
Although feed rate limits for each metal must be
established for total and pumpable hazardous waste
(except as noted below), feed rate limits for metals are
not required for raw materials and nonhazardous waste
fuels. Instead, the owner/operator must monitor and
set a limit on the myrimnm concentration of each metal
in the collected PM. This limit is based on •enrichment
factors" that relate the concentrations of the metals in
the PM to the concentrations of the metals in the stack
emissions.
Determination of the enrichment factor for
precompliance can be based on: (1) conservative default
assumptions provided in the Methods Manual, or (2)
engineering judgement. For certification of compliance,
the enrichment factor for each metal must be
determined experimentally in a series of tests conducted
during and immediately after the compliance test. To
verify continued compliance, an owner/operator must:
(1) monitor the feed rates and operating parameters for
which limits were established, and (2) conduct sampling
and analysis for the metals concentration in the collected
PM to ensure that the metals concentrations do not
exceed the compliance limits.
8-1
-------
Detailed procedures for the kiln dust
monitoring alternative are provided in Section 10 of
Appendix DC to the BEF Rule, and are summarized
below.
8.1.1 Determination of Precompliance limits
Precompliance limits for all compliance
parameters, except for the maximum feed rate of each
metal in the total feed stream, and the metals
concentrations in the collected loin dust, are established
using the same procedures as for all BEFs. For the
collected PM dust metals concentration limit (DMCL),
only the "conservative limit," described in Section 8.13,
is established for each metal. This limit is based on an
enrichment factor (EF) estimated using conservative
default assumptions ('safe enrichment factors') or best
Engineering judgment. The following conservative values
for the safe enrichment factors (SEFs) may be used:
• SEF * 10 for all hazardous metals except
mercury. Therefore, SEF » 10 for antimony,
arsenic, barium, beryllium, cadmium,
chromium, lead, silver, and tti«ii»nn
• SEF « 100 for mercury.
The SEF is used instead of the EF in the equation in
Section 8.13 to estimate the conservative DMCL.
Engineering judgment may be used in place of
conservative default assumptions provided the
engineering judgment is documented. The facility must
keep a written record of all assumptions and calculations
necessary to justify the SEF. The facility must provide
this documentation to EPA with the certification of
precompliance and be prepared to defend these
assumptions and calculations. Examples of where the
use of engineering judgment is appropriate include:
• Use of data from precompliance tests;
• Use of data from previous compliance tests;
and
• Use of data from similar facilities.
If the collected PM metals concentration is
exceeded more than 5% of the time during
precompliance, a facility has 720 hazardous-waste-
burning hours to submit a revised certification of
precompliance. A more detailed description of
precompliance limits is provided in Section 10 of
Appendix DC to the BIF Rule.
g.1.2 Determination of Compliance Limits
For compliance limits, a series of 'initial* tests
is required to establish the enrichment factors necessary
to calculate the limits on the concentration of each
metal in the collected PM. The enrichment factors are
determined by simultaneously measuring metals
concentrations in the PM collected and emitted from the
APCS. The initial test series consists of at least 10
single test runs conducted within a 14-day period. No
more than two tests may be conducted per day.
During testing, the facility must follow a normal
schedule of kiln dust recharge and must generate
normal, marketable product using normal raw material
and fuel under normal operating conditions. Before
sampling, the facility should precondition the kiln to
ensure that metals emissions reach steady state (see
Section 83 for guidance on preconditioning). The
facility must also demonstrate that the PM limit and the
Tier HI or Tier n metals emission standards arerpot
exceeded during the test.
Three of the first five 'initial* tests must be
compliance tests in conformance with 40 CFR
266.103(c); Le, they must be used to determine
m«Tuniim allowable feed rates of metals in pumpable
hazardous wastes and in total hazardous waste feed, as
well as to determine other compliance limits. This does
not mean that a complete compliance test is required
every time the initial tests are repeated. For example,
if initial tests are repeated because a quarterly
enrichment factor verification test indicates the
enrichment factor has increased for a single metal (e.g.,
lead), the compliance test conditions that need to be
maintained are only those related to emissions of that
metal (e.g., feed rate of lead in pumpable and total
hazardous waste, combustion chamber temperature,
APCS temperature, production rate, feed rate of
chlorine in total feed streams, or limits for paniculate
control in the APCS).
If separate runs are tested due to conflicting
parameters, •initial" tests should include both sets of
runs. If compliance limits are sought for more than one
operating mode, a separate series of "initial" tests should
be run for each operating mode (leading to a separate
set of enrichment factors for each operating mode).
The remaining initial tests, (i.e., those that are
not compliance tests) do not need to be conducted at
compliance limit conditions; however, they must be
BIF\SECTOB.BIF
8-2
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conducted at the compliance limit production rate, and
the feed rates of metals in pumpable and total
hazardous wastes must be at least 25% of the
corresponding feed rates during compliance testing. An
owner/operator may find it necessary to spike metals
during the initial tests to achieve 25% of the compliance
test metals feed rates.
The kiln dust metals concentration is used as an
indicator for metals emissions from the stack. For this
reason, subject to the practical constraints of the system,
dust samples must be taken so that they are
representative of the last device or stage in the APCS
series (i.e., as dose to the stack as practicable). The
sampling location used for the "initial' tests to determine
the enrichment factors will be the same as that to be
used for the daily /weekly analyses to monitor the kiln
dust metals concentrations and for the quarterly tests to
verify the enrichment factors.
8.13 Calculation of Kiln
Concentrations Limits
Dust Metals
The kiln dust metals concentration limit is
calculated using the following equation:
Turin tin*
The kiln dust metals concentration limit (DMCL) is
based on the Tier m (or Tier II) metals emissions limit,
the paniculate matter emissions limit (PMEL), and the
enrichment factor (EF). The enrichment factor is
calculated from "initial" test data during the compliance
phase according to the procedure described in
Appendix DC to the BIF Rule. The default "safe
enrichment factors" described in Section 8.1.1 may be
used for precompliance.
A facility may wish to increase its kiln dust
metals concentration limit by self-imposing a lower PM
emissions limit. Using the equation shown above, a
lower PM emissions limit results in a higher dust metals
concentration limit This may be to a facility's
advantage if a lower PM limit decreases the number of
metals that need to be monitored because the Tier in
limit for the metal is greater than the PM limit (Section
8. IS). If a facility elects to use a lower PM limit, that
value becomes the compliance (or permit) limit.
There are two levels of bin dust metals
concentrations limits: (1) a violation limit based on the
95% confidence level enrichment factor, and (2) a
conservative limit based on 2 times the 95% confidence
level enrichment factor or the 99% confidence level
enrichment factor, whichever is less restrictive.
Statistical methods for determining the 95% and 99%
confidence level enrichment factors are given in
Appendix DC to the BIF Rule.
If the enrichment factor cannot be determined
(Le., the concentration in APCS dust is nondetectabte),
the enrichment factor is assumed to be 100. This factor
is quite restrictive; therefore, an owner/operator may
find it advantageous to spike metals to avoid nondetects
in the APCS dust. If the concentration of a metal is
nondetectable in the APCS dust in some initial tests, but
is detectable for that same metal in other initial tests, it
is allowable (in the determination of the 95% or 99%
confidence level enrichment factor) to use only the
enrichment factors taken from the "detectable" tests,
subject to the following restrictions:
• No determinate enrichment factors (i.e., the
metal was detected) may be discarded; and
• Enrichment factors from at least 10 "initial"
tests must be used for each such metal
(therefore, more than 10 initial tests may be
required).
8X4 Cotttiaoed Compliance Daring Interim Status
A facility demonstrates continued compliance
with the kiln dust monitoring alternative during interim
status by maintaining the concentration of each metal in
the collected kiln dust (PM) below the Itiln dust metals
concentration limit (DMCL) for that metal, as described
in Section 8.13. A "conservative" and "violation" dust
metals concentration limit are calculated for each metal.
Sampling and analysis of loin dust for "critical" metals is
required on each day hazardous waste is burned.
Sampling and analysis is required on a weekly basis for
metals concentrations that are less than 10% of the
"conservative* limit ("noncritical" metals), as described in
Section 8.13, after 30 consecutive daily samples. A
noncritical metal may be reclassified as critical if it
exceeds 10% of the conservative limit for any daily or
weekly sample. Quarterly verification that the
enrichment factor has not increased significantly is also
required. Section 10 of Appendix DC to the BIF Rule
provides details on the procedures for demonstrating
ccf 'if« ore1
-------
continued compliance under the Hi" dust monitoring
alternative. As with all BIFs, a facility must also
maintain all other applicable compliance parameters
within limits established by its certification of
compliance to show continued compliance.
The consequences of exceeding the kiln dust
metals concentradon limit are also d«*nssH is detail in
Section 10 of Appendix DC to the BIF Rule. The
'conservative" limit for a metal may be exceeded 5% of
the time (3 out of 60 consecutive samples) without
penalty. If the "violation" limit is exceeded at any time,
if the conservative limit is exceeded more than 5% of
the time, or if a quarterly test shows the enrichment
factor has increased significantly, the limits on feed rates
for metals in pumpable and total hazardous wastes must
be immediately reduced by 50% of the compliance test
limits for the metals in exceed ance. Repeated
exceedances result in cumulative 50% reductions (e.g-,
two excursions result in a 75% reduction). The
reductions remain in effect until a revised certification
of compliance or precompliance is submitted.
If a facility submits a revised certification of
precompliance or compliance, recent data (including the
lain dust metals concentrations excursions) must be
considered in revising the feed rates for metals in
pumpable and total hazardous wastes. In the
compliance phase, a facility is allowed up to 720
hazardous waste-burning hours to repeat the "initial"
tests and recertify. During this time, a facility must
continue with daily kiln dust monitoring, and each time
a limit for a metal is exceeded more than 5% of the
time, the feed rate limit for that metal must be reduced
by another 50%. Penalties for excursions (e-g^ feed rate
reductions as described in Appendix IX) take effect as
soon as the facility it aware that an excursion has
occurred - no more than 48 hours after the sample with
the excursion was taken.
8.1.5 Using the PM Emissions Limit in Lien of Dust
Coocentndoa Limits
Under the kiln dust monitoring alternative,
facilities are not required to monitor or set limits on
metals concentrations in raw materials or fuel. In
addition, kiln dust metals concentration limits are not
required for any metal that has a Tier ffl (or Tier n)
allowable emissions limit greater than the PM limit (i.e.,
compliance with the PM limit ensures compliance with
the metals emissions limit even if the PM is pure metal).
However, facilities are required to comply with metals
feed rate limits given under f 266.103(c)(l)(u)-
This option of using PM limits in lieu of dust
concentration limits may not be protective of human
health and the environment if:
• There is no continuous monitor for PM
emissions; and
• The metal is volatile at the temperaturef at
which emissions measurements are made.
To address these concerns, facilities electing to comply
with this option should consider continuously monitoring
stack gas opacity with a transmissometer. The facility
could then establish, as an additional operating limit, the
maximum opacity observed during a successful PM
compliance test. It may not be appropriate to use PM
limits in lieu of dust limits for the following metals
either because they are inherently volatile or because
they may be volatile in the presence of chlorine at the
low emissions levels allowed by the Rule: mercury,
arsenic, lead, and chromium.
The following example illustrates the
comparison of the Tier m emissions limit with the PM
emissions limit:
An industrial furnace that recycles collected
particulate matter has a PM limit of 0.08
gr/dscf and has a Tier ffl emissions limit of
50,000,000 g/hr for barium. The facility has a
stack gas flow rate of 200,000 dscf/min and a
stack gas oxygen concentration of 4%. The
mass-based PM limit is: 0.08 gr/dscf x 200,000
dscf/min x dilution correction factor [(21%-
4%)/(21%-7%)], which is equal to 19,000
gr/min, or 18,000,000 g/hr. Thus, for this
facility, the Tier m allowable emissions limit
for barium is greater than the PM emissions
BIF\SECrW.BIF
8-4
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limit. The facility will not be able to emit
barium at the allowable level and still comply
with the PM emission limit Therefore, if the
facility remains in compliance with the PM
limit, h will not exceed the allowable barium
emission rate. In this situation, barium need
not be monitored in the collected dust, and the
facility should consider continuously monitoring
PM emissions via an opacity monitor and
complying with a maximum opacity limit
established based on the compliance test
(If a facility operates under a more stringent
state implementation plan (SIP) standard or
NSPS standard for PM emissions, that more
stringent standard must be used in place of the
0.08 gr/dscf PM limit.)
The waiver for monitoring a metal in collected
dust where the PM limit is lower than the emissions
limit for the metal can apply to carcinogenic metals
under the following procedures. The BIF Rule requires
that the summed risk for all carcinogenic metals cannot
exceed 10"5. To implement this provision, the BIF Rule
limits: (1) the sum of the ratios of actual emission rates
to allowable emission rates for carcinogenic metals
under Tier II; and (2) the sum of the ratios of actual
ground-level concentrations to allowable ground-level
concentrations for carcinogenic metals under Tier ID.
To ensure that the cumulative risk does not
exceed 10"', the sum of these ratios for all carcinogenic
metals cannot exceed 1.0, as described in detail b
Section 2.0 and §266.106(c)(2) and (c)(3). If a facility's
Tier in or Tier n emission limit for one or more
carcinogenic metals is greater than the facility's PM
standard, the facility must assume that each metal of
concern ultimately may only be emitted at a rate
equivalent to the PM f^fff*™* limit
Using this approach, the Tier n ratio for each
carcinogenic metal becomes the ratio of the PM
emission limit to the Tier II emission limit for the
specific metal. Under Tier ffl, the allowable ground-
level concentration of each carcinogenic metal is related
to an emission limit by dispersion modeling. The ratio
for each carcinogenic metal then becomes the ratio of
the PM emission limit to the Tier O emission limit for
the specific metal. Again, the sum of these ratios must
not be greater than 1.0. The equations given in
|266.106(c)(2) and (c)(3) can be modified as follows:
ACn
AER.
ERSL,
N v
_ _X_
- tf ERL -
where:
AER -
ERSL -
N
ERL, -
actual emission rate for metal i
emission rate screening limit for metal i
number of carcinogenic metals (up to 4)
tier n or Tier HI emission rate limit for
metal i
facility's PM emission limit
To implement this waiver, a facility shdoid
consider monitoring opacity during the PM compliance
test, and establishing the maximum observed opacity
level as an interim status operating limit. The facility
should consider factors that may affect the correlation
between the opacity and the PM emissions rate when
deigning the compliance test. Changes in the fuel type
(or mix) and raw material mix and b other operating
conditions may affect the opacity reading, and should be
considered when establishing the maximum opacity level.
Opacity depends primarily on the particle
concentration, the optical path length, the optical
properties of the particle, and the particle size
distribution.
Opacity and paniculate emission measurements
taken from a cement lob, a lignite-fired boiler, and a
bituminous coal-fired boiler reported by Beutner (3)
have shown that PM emission rates for a single facility
are proportional to the opacity readings for that facility,
although the slope of the correlation will vary from one
facility to another. As such, the maximum opacity level
established for one facility cannot be used for another
facility, and even for the same facility, the maximum
opacity level should be established if the critical
parameters identified above are changed. Thus, when
the facility changes fuel type (or mix), or the raw
material mix, the owner/operator must determine if the
correlation between opacity and PM emissions has
changed.
Bff\SECine.BiF
8-5
-------
Information on the application of opacity
monitors, including transmissometers, is given in
References 14 aad 32.
Transmissometers have been used for over 20
years and are the most widely used CEM in operation.
Available data show that transmissometers are reliable
over a wide range of opacity and PM emission levels
(Le, levels of less than 0.01 gr/dscf to 0.15 gr/dscf).
Transmissometers must be carefully calibrated. OAQPS
has established requirements for CEM installation,
calibration, maintenance, and operation in Performance
Specification 1 of 40 CFR Pan 60, Appendix B.
This specification requires performance of a
three-point calibration check of the CEM using optical
calibration filters. Performance Specification 1 has an
allowable error in calibration of 2%, such that at the low
range (e.g., 5%; cement kiln opacities are typically
between 2 and 20%), the relative error can be relatively
large. However, the instrument is still capable of
detecting variations in ESP performance or other factors
that may affect PM emissions even at low opacity levels.
Facilities electing to comply with the kiln dust
monitoring alternative must carefully select an
instrument that is sensitive at the expected range of PM
emissions for the facility. This is especially true for BIF
units complying with PM emissions limits that are more
stringent than BIF Rule requirements such as SIP or
NSPS limits in the range of 0.01 gr/dscf. Finally,
because it is not feasible to conduct opacity
measurements in a wet (below the dewpoint) stack, in
these cases this alternative is not applicable.
Testing
Under the scmicontinuous (tack emissions
testing alternative, a facifity must verify compliance with
the metals emissions staadards by conducting daily stack
sampling using the EPA Multiple Metals Train (see 40
CFR Pan 266, Appendix IX). Since the metals
emissions are monitored directly, there is no need to set
or comply with limits on parameters for control of
metals emissions, including: metals feed rates in
pumpable hazardous waste, total hazardous waste, or
total feed streams; maximum combustion chamber
temperature; maximum temperature entering the APCS;
or APCS parameters for paniculate control.
A compliance test must be conducted to
demonstrate compliance with organics and chlorine
emissions standards and to set limits on the parameters
for control of organics and chlorine emissions.
Compliance limits must be established for the maximum
production rate, maximum CO (and HC under Tier n)
concentration, maximum feed rate of total hazardous
waste, and maTimnm chlorine feed rate in total feed
streams. Maximum ash feed rate in total feed streams
is also limited in all BIF devices except cement kilns or
light-weight aggregate kilns.
The stack samples collected under this
alternative will take several days to analyze; therefore,
violations of the metals emissions standards will not be
detected immediately, and thus countermeasures cannot
be taken until well after the violations occur. To
prevent such violations from occurring, a facility is
required to characterize its waste to a sufficient extent
to determine if changes in the metals content may affect
the ability of the facility to meet the metals emissions
standards.
As stated above, daily emissions testing for
metals must be performed using the EPA Multiple.
Metals Train. Emissions for each metal must not
exceed the Tier IE (or Tier n) emissions limits. No
adjustments to Tier in or Tier n limits are allowed to
account for reduced operating hours (or days) for
facilities that operate less than 24 hours per day. As an
example, if a facility only burns hazardous waste for 8
out of 24 hours, it is not allowed to triple the hourly
emission limit When a facility recycles PM, metals
emissions may take a long time to respond to a decrease
in metals feed rates; thus, metals originally fed with the
hazardous waste may remain in the recycle loop and be
emitted after the hazardous waste feed has been cut off.
Sampling must be conducted for a minimum of
6 hours each day. One exception is that if a facility
burns hazardous waste for less than 6 hours during a
particular day, it must perform emissions testing for the
portion of the day the facility is feeding hazardous
waste. Emissions testing must follow the guidelines
specified in Appendix DC to the BIF Rule. Waste
should be fed for a time period of at least one solids
residence time before sampling.
An owner/operator must conduct sampling
while burning normal hazardous waste under normal
Bff\SECT08.BIF
8-6
-------
APCS conditions. "Normal" conditions are defined as
conditions that are routine operations. A facility may
not adjust its operation (e.g., run at significantly lower
metals feed rates) to minimiy^ metals emissions during
the 6-hour test period. A facility must characterize its
waste to a sufficient extent to document "normal"
operations.
SL3 Preconditioning Before Emissions Testing
Under this alternative, preconditioning is
required to ensure that metals emissions reach "steady-
state* values before compliance testing. The same
operating conditions and spiking procedures that will be
used during the actual test must be used during
preconditioning.
Determination of the preconditioning time may
be made during preparation for the compliance test or
in advance of the test. The metal with the longest
equilibrium time may be used as an equilibrium
indicator for other metals. Comparison of the time
required to reach equilibrium for different metals may
be made using data from the facility in question or from
a similar facility. The procedures used to determine if
the system has reached steady-state before compliance
testing, including the results of any preconditioning
testing, must be clearly described in the compliance test
plan. A facility may determine that equilibrium has
been reached either indirectly by monitoring the
concentrations of metals in collected PM or directly by
monitoring metals emissions.
A facility may best determine that the system
has reached steady state with respect to metals by
monitoring the metals emissions over time (i-e., using
the EPA Multiple Metals Train). Because a
considerable period of time is required to obtain and
interpret analytical remits of metals stack testing
(usually 2 weeks or more), the procedure is best
completed as a separate preconditioning test before the
compliance test. The objective of preconditioning is to
determine the minimum time required for metals
spiking to precondition the system before samples are
collected.
A facility may minimize the number of stack
samples required in the preconditioning test by
monitoring the concentrations of metals in collected PM,
and then conducting stack testing when the
concentrations in collected PM reach a steady value.
This approach is specifically useful for facilities with on-
site analytical capabilities for metals in solid matrices.
Unless the facility has documentation of the relationship
between metals concentrations in collected PM and in
stack emissions, it is not acceptable to base the
preconditioning time only on the analysis of dust
samples.
If a facility has information from other testing
that indicates the time needed to reach steady-state,
such information and conclusions should be clearly
described in the compliance test plan. Preconditioning
testing may not be necessary in this situation.
A facility is considered to have reached
equilibrium in response to a change in the metals feed
rate when the concentration of each metal in collected
PM, or the metals emissions rate, has reached 90% of
its steady-state value given the constraints of the system
and the variability of the data. Equilibrium can be
determined by applying a least-squares curve fit to the
time-resolved data to estimate the best-fit steady gate
value. The functional form of the time response* may
vary from system to system.
Under the preconditioning alternative, a facility
is required to establish and comply with limits on the
feed rate of each metal in all feed streams, including
raw materials feed streams. For some facilities (e.g.,
cement kilns), raw materials are blended from a number
of sources. Often, the simplest approach to monitoring
the feed rates of metals in the raw materials is to
measure the concentrations and feed rates of the
blended raw materials. Facilities that recycle collected
PM often blend the PM with raw materials. Although
recycled PM is not normally considered a feed stream,
it is allowable (but not required) to use the
concentration of the blended raw materials (including
the recycled PM) in the calculation of the feed rate of
metals in all feed streams, as long as this is done
consistently in the compliance test/trial burn and in the
monitoring for continuing compliance.
8.4 Using Different Metals Comnliance
Alternatives
A facility is allowed to use different metals
compliance alternatives for different metals. For
example, it may be to a facility's advantage to use the
kiln dust monitoring alternative for nonvolatile metals
that have Tier m limits greater than the facility's PM
limit. As discussed in Section 8.1.1, under certain
conditions, no monitoring of metals feed rates in
BrF\SECn».BIF
8-7
-------
pumpable and total hazardous waste or kiln dust
concentrations of these metals is required because
compliance with the PM emission standard (including
continuous monitoring of PM emissions) ensures
compliance with the metal emissions standards. A
facility may wish to use the preconditioning alternative
for other metals to avoid the complexity of daily
monitoring of loin dust metals concentrations.
Concerns
&5.1 Metals Emissions from Bypass Stacks
Bypass stacks are frequently used in dry process
cement kilns to divert a portion of the hot flue gas
(typically around 10%) so that it bypasses the preheater.
Since the volatile metals in the bypass gas are not
recirculated into the cement kiln, this practice reduces
the buildup of alkali metals in the system and thus
reduces operational problems caused by alkali metal
buildup. Since volatile metals are concentrated in the
bypass gas, metals emissions from a bypass stack can be
as h'gh as metals emissions from a main stack. A
compliance test/trial burn must therefore measure
metals (and PM) emissions from both the bypass stack
and the main stack.
A facility should also perform the following
j«lc< while conforming or complying with the metals
standards under a specific alternative:
• For facilities that elect to use kiln dust
monitoring, monitoring of PM from both the
bypass and the main APCS is required to
demonstrate compliance with metals standards.
The measured kiln dust concentration for each
metal for the bypass and main APCS are
compared to the kirn dust metals concentrations
limits for that metal for the bypass and main
APCS, respectively. The kiln dust metals
concentration Emit for the APCS is determined
n«ing t fractional Tier m emissions limit for
each stack. The fractional Tier ID emissions
limit can be calculated using the following
equation:
L*. -IRAC-.
where:
d^ , and d^^, are the dispersion coefficients for
stacks 1 and 2, respectively.
The facility should choose a value for Tier
m_^, and then calculate the value of Tier
lTT|Bitl using the above equation.
• For facilities that elect to comply with metals
standards using semicontinuous stack emissions
testing, daily stack testing should be performed
on each stack.
• For facilities that elect to comply with metals
standards n»ing preconditioning, metals
emission measurements should be made on
each stack, and operating limits should be
established on both the main and bypass APCS
parameters.
8JJ APCS Main and Bypass Considerations for
Sharing the Same Stack
If a BIF that recycles collected PM has two
APCSs (e.g-, main and bypass) sharing the same stack,
the following approach is recommended:
• Kiln dust monitoring is not appropriate in this
situation. Unless multiple metals train samples
can be taken from the individual ducts before
the two streams are mixed, it is not possible to
determine an enrichment factor for each APCS,
and thus it is not possible to conservatively set
dust metals concentrations limits for each
APCS.
BIF\SECTOB.BIF
8-8
-------
Semicontinuous stack emissions testing
procedures are not affected by this
configuration. Daily multiple metals train
samples should be taken on the shared stack.
Preconditioning is appropriate for this
configuration; however, metals compliance
limits should be set on APCS parameters for
both APCSs.
I
t
i
I
I
I
BIF\SECTt>e.BIF 8-9
-------
9.0 ALTERNATIVE HYDROCARBON LIMIT
FOR CEMENT KILNS
The BIF Rule provides an alternative
hydrocarbon (HC) limit for industrial furnaces that
cannot meet the Tier n PIC controls (L&, HC limit of
20 ppmv) because of organic matter in normal raw
material For example, cement facilities use raw
materials cuch as day, shale, and limestone that often
contain organic compounds (e.&, kerogens). Some of
the organic compounds are volatilized and emitted from
the kiln as HC as the raw materials are heated in the
kQn before calcination. An HC monitor in the stack of
cuch a furnace measures both the raw material-related
HC and the fuel-related HC, although the raw material-
related HC are not associated with waste combustion.
Accordingly, the BIF Rule provides a waiver provision
that allows HC concentrations of greater than 20 ppmv,
provided that the HC levels when burning hazardous
waste are no higher than when hazardous waste is not
burned.
Under the alternative hydrocarbon provision,
the Director may establish an alternative HC limit on a
case-by-case basis under a Part B permit proceeding.
The alternative HC limit is set at a level that ensures
that flue gas HC (and CO) concentrations are not
greater than when the facility is not burning hazardous
waste. Owners/operators who wish to establish an
alternative HC limit must comply with the following
requirements:
• Submit a Pan B permit application that
includes a proposed baseline HC level based on
testing;
• Develop an approach to monitor over time
changes in the operation of the facility that
could reduce the baseline HC level;
• Demonstrate that the facility is designed and
operated to T"IM«*{». HC emissions from fuels
and raw materials when the baseline HC (and
CO) level is determined and when hazardous
waste is burned;
interim status, f^
the interim limits
comply
and HC
with the interim limits on CO
presented in the Part B permit application;
Conduct emissions »*«»«"g during the trial burn
to: (1) determine the baseline HC (and CO)
level; and (2) demonstrate that, when hazardous
waste is burned, HC (and CO) emissions do
not exceed the baseline level; and
Conduct emissions testing during the trial burn
to identify the types and concentrations of toxic
organic compounds that are emitted; conduct
air dispersion modeling to predict the maximum
annual average ground-level concentration of
each organic compound; and demonstrate that
maximum annual average ground-level
concentrations of the toxic organic compounds
do not exceed acceptable ambient levels
established in the BIF Rule.
Each of these requirements is
further below.
Cement loins monitoring HC emissions in a
bypass duct are not eligible for the alternative HC4imit
(see 40 CFR 266.104(0 and (g)). Flue gases in "the
bypass duct are not expected to contain organics
volatilized from raw materials and must meet the Tier
I or Tier n PIC (CO/HC) controls.
9.1
Application
The alternative HC limit is established under a
facility's operating permit. As discussed in the preamble
to the BIF Rule (56 fE 7156, February 21, 1991),
considerable interaction is needed between an applicant
and a permit writer to evaluate the HC baseline
protocol and associated information required to ensure
that an alternative HC limit is protective, whereas the
interim status standards were intended to be largely self-
implementing. Interim status facilities that wish to apply
for an alternative HC omit must certify compliance with
all other emissions standards according to the
compliance certification schedule. Such facilities may
request a case-by-case time extension for compliance
with the PIC controls (as well as for other emissions
standards). The applicant for the time extension must
have submitted a complete Part B permit application,
the information described below and must
comply with the proposed interim limits on HC and CO.
The Director's evaluation of the permit
application and proposed interim limits will likely take
a considerable amount of time. Owners/operators
should submit the time extension request and permit
application early enough before the August 21, 1992
deadline for certification of compliance (submittal
WFvSECTTO.BIF
-------
•even! months before the deadline is recommended), to
allow time for review of the time extension request If
approved, the baseline levels submitted by the applicant
serve as interim status limits, pending more extensive
review of the Part B permit application.
The data requirements for cubmittal with the
Part B permit application (or Class 3 permit
modification request, as appropriate) for facilities
requesting an alternative HC omit are listed in 40 CFR
27022(b). These data requirements include:
• Documentation that the furnace is designed and
operated to ^nfaimby- HC *«^ff«^»«* from fuels
and raw mater**!* The necessary
documentation is
93.
further in Section
Documentation of the proposed baseline flue
gas HC (and CO) concentration, and
supporting data. Determination of ****> K^^lim»
emissions is discussed in Section 92.
Test bum protocol to confirm the baseline HC
(and CO) level Information to be included in
the test protocol and test design are discussed
in Section 9 .12.
Implementation plan to monitor over time
operations that could reduce the baseline HC
level, as discussed in Section 9.4, and
procedures to periodically confirm the baiHinr
HC level.
Trial burn plan for emissions testing, as
disnififird in Section 9.5.
Any odier information the Director may require
to support the alternative HC limit
The alternative HC (and CO) emissions level
must be determined from continuous HC (and CO)
monitoring data collected during a "baseline* test The
baseline HC (and CO) level is defined as the average
over all valid baseline test runs of die highest hourly
roOing average value for each run.
Baseline testing must be conducted without
burning hazardous waste and while producing normal
product under normal operating conditions while feeding
normal feedstocks and fuels.
The determination of baseline HC emissions is
discussed in more d**«ii below.
f JJ Definition of Normal Operations
f.2Xl Normal Raw Materials
Most cement kirns are located at or very near
die source of raw materials necessary for cement
production. Types of raw materials necessary for
production inrhi^f limestone, ft*«v or clay and
These raw g»
predominantly
fy 80%), ^ffirem dioxide
(approximately 15%), aluminum oxide (approximately
3%), and ferric oxide (approximately 2%). One of the
primary sources of organic material in raw material feed
is thought to be certain types of shale, kerogen in
To 4wvTH>f-Bt tfrat raw materials fed
baseline testing are normal, die facility should provide
data to show that die raw materials are die same or
substantially similar to raw materials normally fed to die
process. In particular, materials should not be brought
in from ntbfr locations (unless ***** is tb? normal,
documented practice of die facility), or quarried from a
separate VpcnHop specifically for die baseline test Raw
mffM-ialt fed /fairing the frf«*i«T»* test should represent
die normal variation in organic content fed to die kiln,
bat should not be artificially ("spiked") high in organic
material.
9.1.1.2 Normal Fads
Typical nonwaste fuels used in cement kilns
include pulverized coal, petroleum coke, fuel oil, and in
some cases, natural gas. These fuels can be fired singly
or in nyH"***"1", as a mixture or in different locations
in the kiln system.
To demonstrate dial nonwaste fuels burned
during b*^"** »*tti"g are normal, die same restrictions
apply as for raw materials. The fuel must be of die
same type or grade as is normally fired into die kiln
system. In addition, if multiple fuels are fed, die ratio
of die types of fuels fed must remain die same as in
normal operation.
BIF\SECID93IF
9-2
-------
In certain cases, cement kilns that have been
burning waste fuels for a Jong time may have
permanently altered fuel feed mechanisms in such a way
that nonwaste fuels can no longer be fired in sufficient
quantities to adequately determine a HiifHhiy These
facilities should make temporary arrangements, such as
firing fuel oil in place of waste fuels for the *«aff*f;"*
test, even if fuel oil would not be a normal nonwaste
fuel for this facility. The facility must describe the
situation in detail, including steps taken to mitigate the
problem, in the request for thy extension.
Normal Product*
Various types of cement are produced for a
variety of uses. Examples of variations in the types of
cement available include quick- (a few minutes) versus
slow-setting (an hour) cement, and cement of varying
color (white versus grey). For the purpose of baseline
testing, normal product can be defined as the same type
and grade of cement that is normally produced in the
bin. In addition, the product produced during testing
must be within specifications for the product normally
produced.
Normal Operating Conditions
During the baseline test, process operating
conditions must be maintained within tby ranges
associated with normal operation. The process
parameters of particular concern include production
rate, process temperatures, and oxygen levels in the kUn
(see Section 93 for further discussion on design and
operation to nmmm HC emissions).
922 Test Protocol
Before conducting the initial baseline test, the
facility should prepare a baseline test protocol
Preparation of a protocol ensures that the test will be
properly planned and carried out, and that the test data
will serve the purpose for which k is intended, namely,
ftft«h%Kfr»g the HC/CO baseline. In addition, a test
protocol must be submitted with the Part B application
to confirm the baseline. The same protocol can be used
for both purposes.
The protocol should specify the process
conditions, test methods, number and duration of tests,
test schedule, and quality assurance/quality control
measures to be taken to ensure data quality, among
other things (see Section 5.0 for more details on
compliance test planning). The following specific
information must be mriudrd in the test protocol
(|27022(b)(3)):
• Types and flow rates of aU feed streams;
• Point of introduction into the industrial furnace
for each feed stream;
• Total organic carbon content (or other
appropriate measure of organic content) of
»i«*h nonfuel feed ttmn'.
Operating condftiony that affect combustion of
fuel(s) and destruction of HC emissions from
ftonfuel sources.
Continuous emissions monitors must be used to
data for CO, Oj, •««*i HC fnrisiiiffns on an hourly
rolling average bas
If the facility is unable to install permanent
monitors in time to meet tfr^ submittal deadline
portable monitors may be used. Monitoring with these
portable monitors must continue after the compliance
test until permanent monitors are installed.
The test must consist of a minimtiffi of
valid runs, with each run consisting of a minimum of
3 hours of sampling time. It may be appropriate to
sample for longer time periods, especially given the
extended solids residence times nr^n***^ with most
kilns. It is of primary importance that the kiln be
operated under steady-state conditions during the testing
to generate valid baseline data.
Facilities are also required to develop
procedures to periodically confirm the baseline HC
level The frequency and testing protocol for the
periodic baseline confirmation should be included in the
test protocol
In some cases, it may be necessary or advisable
for the facility to establish multiple modes of operation,
mrludhig mode-specific baselines. Examples of these
cases include the production of more than one type or
grade of cement product, or the use of different
(nonwaste) fuels at different times (a facility may use
coal or coke part of the time, and fuel oil the rest of the
time). If a facility chooses to •^frfy?* multiple modes
of operation, and therefore multiple baselines, testing to
establish each individual baseline must be performed.
BZF\SECT09.BIF
9-3
-------
In addition, recordkeeping must dearly show that a
facility is operating under the proper baseline at any
given time. Alternatively, a facility may establish one
baseline at the conditions resulting in the lowest HC
level, and comply with that baseline for all modes of
operation.
922 Determination of Baseline Levels from Test
Data
Baseline levels for both CO and HC are
determined from test data as the average (over aD valid
runs) of the highest hourly rolling average value for each
run. This is the same method as that used for
determining limits on other operating conditions, such as
feed rates and temperature. Specific details on
determining highest hourly rolling averages from test
data can be found in Section 5.0.
93 Demonstration of Pc?t£fl Bfd Operation to
Minimize HC Emissions
The owner/operator of a facility applying for
the alternative HC limit must demonstrate that the
facility is designed and operated to mnrimfrr
hydrocarbon emissions from fuels and raw materials
during operation and when the baseline HC (and CO)
level is determined (40 CFR 266.104(0(1) and
270.22(b)(l)).
Examples of situations in which the system is
not designed and operated to mmhnire HC (and CO)
levels during baseline testing include the following:
• Coal is mixed with raw material, which is fed
into a cement kfln preheater such that the coal
can contribute to HC e
Cement kfln starry water contains enough
organic compounds to significantly contribute to
HC emissionst
Waste fuels, such as tires, are burned in a
manner that could contribute to HC emissions;
The furnace is not operated and designed to
emissions of hydrocarbons emitted
from raw material (in general, the more quickly
the raw material is exposed to temperatures at
which HCs undergo complete combustion, the
lower the HC emissions); or
Normal fuels are not burned under good
combustion conditions. For example, burners
are not operated with appropriate atomization
and air /fuel firing ratios.
The burden of proof is on the facility to supply
HC emissions are as low as is
feasible. A variety of possible forms of such
exist, depending on a facility's current
practices.
One of die primary reasons for requiring
demonstration of low HC emissions is to prevent a
facility from increasing its HC ffmminm before
performing baseline testing to provide a "buffer* that
would make M easier to burn hazardous waste without
elevating HC ••«««"*« beyond normal levels.
Consequently, "•"* way to demonstrate that HC levels
nave not changed over time is to supply ^"^""^rtit*fT
of measured HC levels (or in the absence of a HC
monitor, CO levels) during normal operations.
Documentation of HC levels can include
historical data dating back several months, as in the case
of a furnace with recently installed monitors, or even
several years, as in the case of a furnace with monitors
m operation for a longer time. Data collected until the
submittal of the Part B permit application can also be
ntfd to document baff^*1"1 HC •*"««»""* The facility
must demonstrate that its normal operations were not
modified to gradually or suddenly increase its normal
levels of HC or CO. Over such aa extended time
period, there may be very legitimate changes in HC or
CO levels, e^ a change in feed materials or a change
in fuel type; however, the facility would need to supply
explanations for such changes.
Another approach is to show that a facility's
practices and design are generally consistent
with practices in the industry. In other words, relatively
high HC (or CO) f"t««"««f may be associated with a
certain practice, but the practice may be very
commonplace, and the resulting HC emissions may be
typical Such comparisons should clearly indicate the
iriln type, CTHnparuo" of raw muff"*!* and products,
fuels used, etc.
Documentation of recent inspections of the
combustion system should also be provided.
BIF\SECTD9.BIF
9-4
-------
9A
Mnnitnrlno gf flf^ IMS in the Bflf*""* HP
Levels
a result of the design or operating change, all
other parameters held constant
As part of the Part B application, the applicant
must develop an approach for monitoring over time any
changes in the operation of the facility that could
significantly reduce baseline HC or CO levels. If the
actual baseline levels are significantly reduced, the
respective alternative limits must also be reduced. This
requirement is designed to prevent a facility from
which is ^fr\ reduced
without a corresponding drop in the HC limit, allowing
the facility to potentially emit a higher level of waste
fuel-related hydrocarbons.
The baseline monitoring plan should dearly
identify operating changes that may affect the raw
material HC (and CO) baseline level. For each such
change, the plan should identify the action that will be
taken to determine whether the HC (and CO) baseline
level has been affected. Facility changes that potentially
affect baseline levels include: changes in the
concentration of organic matter in the raw material;
changes in the concentration of organic material in the
raw material required to produce a different product;
changes in fuels; and changes in the concentration of
organic compounds in the slurry water used for a wet
cement
The following procedures may be appropriate
elements of the monitoring plan:
• Periodic Feed Monitoring. The applicant
should periodically sample all feeds to the kiln
and analyze for total organic carbon (TOC),
comparing the cumulative total to the total
TOC determined during the initial baseline test.
A monitoring frequency of once a week may be
appropriate. If the TOC level drops below a
certain preset value proposed by the applicant,
baseline •***«*£ should be repeated.
• Eval|iation of Operating_ChfS££2 Retesting of
the baseline HC (and CO) level may be
necessary if any changes are made to facility
design and operation that would potentially
affect the baseline, including changes in the
type or quantity of nonwaste fuels fed to the
kiln. Baseline testing may not be necessary in
this case if the owner /operator can show that
the HC (and CO) emissions do not change as
9JS Emission* Tffti"* Poring the Trial Bnrn
Emissions tef**"g is required during the trial
burn, as disrm**^ below. The trial burn plan must
provide the testing protocols for all emissions testing
dated with the alternative HC limit Additional
information on developing a trial burn plan is provided
in Section 10.0. The trial burn plan must be submitted
to the Director with the Part B permit application.
Determination of BiMUne HC Levels
during the trial
born to confirm the baseline HC (and CO) levels
proposed m die permit application. Baseline testing
must be conducted a>£ to the baseline test
protocol described in Section 922.
9JJ Demonstration that Emissions Do Not Exceed
Baseline Levels When Boning Waste If
The BIF Rule limits HC (and CO) emissions
while burning hazardous waste to the levels determined
during baseline tiering rf***iA*Ting the normal variation
in the operation of the system. Emissions testing must
be conducted during the trial burn for each mode of
operation to demonstrate that baseline HC (and CO)
levels are not exceeded when burning hazardous waste.
In addition, emissions of other pollutants, such as metals
and particulates, may not exceed allowable levels.
933 Determinatioa of Toxk Organic Emissions and
Bisk AssessBMnt
The BIF Rule requires the owner/operator to
wndwt fnitfit'on* t»*tit*f snd risk assessment to
demonstrate that organic emissions are not likely to
pose unacceptable health risks, despite the elevated HC
emissions levels. The owner/operator must conduct
emissions testing during the trial burn to identify and
quantify the organic compounds listed in 40 CFR Part
261, Appendix Vm that maybe emitted from the device
while hazardous waste is burned. The test procedures
to be used will be specified by the Director on a case-
by-case basis.
As a practical matter, the owner/operator
should propose a sampling and analysis approach in the
trial burn plan for consideration by the Director. The
WF\SECTD9.BIF
9-5
-------
nature of the organic gmi««f«t« and the results The facility must certify compliance with the
of any previous Mni«Jnm testing should be used as the other emissions standards (e.g-, metals, particulates)
basis for the sampling and analysis scheme. Two according to the prescribed schedule.
possible test protocols that may be used for this purpose
are discussed in the preamble (56 FR 7157, February 21,
1991).
The emission rates of the 23,7,8-tetr*- through
octa-congenen of chlorinated dibenzo-p-diatias and
dibenzofimas (CDDs/CDFs) must be determined as
part of th* emissions ****"«£ and risk
Method 2?, Determination of P<^yt*hjopf|a|tftd
from Stationary Sources should be used for this
determination, and the risks from CDD/CDF congeners
should be estimated using a 23,7^-TCDD toxuaty
equivalence factor (see 40 CFR Part 266, Appendix DC).
The owner/operator is required to use the
results of the organics emissions *****»& along with air
dispersion modeling, to predict the maximum annual
avenge ground-level concentrations for each organic
compound. Dispersion modeling must be conducted
to the procedures in EPA's Gu]jy|jn? 9B
Qualftv Models (Revised) (Section 2jQ). The maximum
annual average ground-level concentrations may not
exceed the acceptable ambient levels prescribed in 40
CFR 266.104 (f)(3)(hr).
9.6 ReoaimryTft} f^ later*"* Status
The facility must document the baseline
emission levels determined from testing by submitting
the baseline information, fr"*"***^ a summary of test
results, as part of the case-by-case time extension
request Once the extension request is submitted, the
facility must adhere to the interim HC (and CO) limits
rporating die limits into the automatic
waste feed cutoff) at proposed in the request, until
otherwise notified by the regulatory agency or until
August 21, 1992, whichever comes first If the extension
is not approved by August 21, 1992, hazardous waste
bunung must cease (except for testing under an
mrtor««tfc extension). The permit writer will review the
extension request to confirm the adequacy of the
proposed CO and HC limits, and may request additional
documentation, impose time limits, and/or require
changes to the proposed limits, as appropriate.
BIF\SECrW3IF 9-6
-------
I
10.0 PERMITTING
10.1 Introduction
Under the BIF Rule, EPA expanded its controls
on hazardous waste combustion to regulate burning and
processing of hazardous wastes in boilers and industrial
furnaces. The rule subjects owners and operators of
BIF units to standards which define the acceptable
management of hazardous waste in treatment, storage,
and disposal facilities (TSDFs). These standards can be
found in 40 CFR Part 265 for interim status facilities
and in Part 264 for permitted facilities. The BIF Rule
also subjects BIF units to standards developed
specifically for BIF units. These standards can be found
in Part 266, Subpart H.
Owners/operators of BIFs currently burning or
processing, or planning to burn or process, hazardous
waste must operate under either interim status or permit
standards based on the BIFs status. Interim status
standards apply to BIFs that meet the definition of
'existing or in existence"17 and that have not been
permitted. Permit standards apply to BIF units that
have been permitted. BIFs that were not "existing or in
existence" are considered "new" facilities and may not
begin construction or hazardous waste-burning or
processing operations until a permit has been obtained.
Table 10-1 lists documentation requirements for
"existing" and "new" facilities with newly regulated BIFs.
10.1.1 Existing Faculties
Although RCRA specifies that facilities must
obtain a permit to operate, it was recognized that it
would take many years for EPA to issue all permits.
Therefore, interim status is used to allow owners and
operators of existing BIF units, which are required to
comply with the interim status standards of Part 265 and
the substantive emission controls for metals, HC1,
particulates, and CO (and, where applicable, HC,
dioxins and furans), to continue operating until their
permit application is requested by EPA," and either
issued or denied by the Agency.
As explained below, to obtain interim status:
(1) some existing facilities were required to submit a
RCRA Section 3010 Notification of Regulated Waste
Activity (EPA Form 8700-12, July 1990 edition1*) (this
is also the form used to obtain an EPA RCRA
Identification Number); and (2) all existing facilities
were required to submit a Part A Permit Application
(EPA Form 8700-23, January 1990 edition"). Generally,
an interim status facility that had previously submitted
a Part A identifying non-BIF units and their operations
was required to revise and resubmit it to the appropriate
EPA Regional Office by August 21,1991 to reflect the
addition of the newly-regulated BIF units; however, if a
BIF unit was identified on a previously submitted Part
A, it is recommended that the facility contact their EPA
Regional office to confirm that the BIF information-was
correctly completed.
Facilities with BIFs that were "in existence" can
be placed into five general categories. Specific
procedural interim status and permitting requirements
are summarized below for each of these categories:
1.
status or
nm
with BIF subiect
to RCRA regulations for the fjr?f tirng A
newly regulated facility under this category is a
facility which has one or more BIFs on site and
does not have other RCRA-regulated units on
site. To obtain interim status, a Part A must
have been submitted by August 21, 1991; in
addition, BIFs that were handling hazardous
waste fuel on February 21, 1991 were required
to submit a RCRA Section 3010(a) Notification
of Regulated Waste Activity (EPA Form 8700-
12) by May 22, 1991 to obtain interim status, if
not previously done so under §26635. The
"To meet the definition of 'existing or in existence,* the BIF must have been in operation burning or processing hazardouc waste on or before August
21,1991, or construction of the facility (including the hazardous waste-burning or processing equipment) must have commenced on or before that
date (see f266.1(O(«)U)(u))-
•Under |270.10(e)(4), an owner/operator may voluntarily submit the Pan B application at any time without waiting for EPA to request it. This may
be advantageous, for instance, if the owner/operator wishes to modify the existing BIF in a way not allowed during interim status.
"These forms are currently under revision. The facility should use the latest version of the form at the time of revision.
BIF/SECnO.BIF
10-1
-------
Table 10-1
DaewBOstatloai RetplrcBMts for Exist!.* art New Facilities with Newly Regulated BIFs
3010 Notiricalion
(EPA Form 8700-12)
Part A Permit
Application
(EPA Form 8700-23)
Precompliance
Certification
Compliance
Certification
..-,;... Eiistaag racaWha
m.»_. aju—j^i-^^*-- l^aAhBaMat Bk\
I^OT •TWWIMHay ••WM W
KlM'''uata*i fWlfc MT
Suatfact •» RCRA
IUfufa far flnt Ttaa
Submit lo EPA by May 22,
1991, if facility was
fuel on February 21. 1991,
if not previously submitted
Submit lo BPA by August
21. 1991
Submit to EPA by August
21, 1991
Submit to EPA by August
21, 1992 or as extended
IrtartajiMMRCRA
WSBBty WlUl fMWij
•uriiiiiiir
SkouM have bee*
submitted to EPA
before initiation of
hazardous waste activity
Submit revised Part A
to EPA by August 21,
1991
Submit to EPA by
August 21, 1991
Submit to EPA by
August 21, 1992 or at
extended
Pmto4KC*A
racOt* Whfc Newly
lUfuJrtcd UP
submitted lo EPA before
initiation of hazardous
waste activity
Submit Class 1
modification (e.g., could
be a revised Part A) to
EPA by August 21, 1991
Submit to BPA by
August 21, 1991
Submit lo EPA by
August 21, 1992 or as
extended, unless permit
modification issued by
that date ., ....
^^ Aoc*OU.I«a
fM.n\«l
•ai Interim awtasltCRA
IMto'w Sternal With
NcwIylUflulaMMP
Should have been
submitted to BPA before
initiation of hazardous
waste activity
Submit revised Part A or
Class 1 modification lo
EPA by August 21, 1991
Submit to EPA by August
21, 1991
Submit lo EPA by August
21, 1992 or as extended,
unless permit modification
issued by that dale
PnrJaty Witt BIT Ua* Vmttr
RCMA iafanrXir Standards
Should have been submitted
lo EPA before initiation of
hazardous waste activity
If BIF was operating under
inlerim status incinerator
standards and/or if BIF not
allowed by EPA to continue
permit review process, submit
revised Part A to EPA by
August 21, 1991
If BIF was operating under
interim status incinerator
standards and/or if BIF not
allowed by EPA to continue
lo EPA by August 21, 1991
If BIP was operating under
interim status incinerator
standards and/or if BIF not
allowed by EPA to continue
lo EPA by August 21, 1992 or
as extended
NewrnrJfcty
Not applicable11
Submit to EPA as
part of RCRA permit
application
Not applicable
Not applicable
9
1st
"Facility has inlerim status units that are not Bin (e.g.. storage tanks, thermal treatment units).
Facility has permitled units that are not BIPs (e.g., storage tanks, thennal treatment units).
^Facility has inlerim status and permitted units on site that are not BIFs (e.g., storage tanks, thennal treatment unto).
Facility is still required to file for an liPA identification number. • «l
RPF\008
1003-01 rpf
-------
Table 10-1 (Continued)
DooMatatatloa Reqnlrraents for Existing and New Facilities with Newly Regulated BIPs
DiraBBMiaifM
Part B Permit
Application
Public Notiftcatioii by
Applicant of Request
for Permit
modificaikM Published
in Local Newspaper
HHcrtai Manai wr wttntH
Sattjact to RCRA
Rafwtetfaw for Aral Thaw
When requested by EPA,
submit by dale sel (which
will be at least 6 months
after request)
Not applicable
Exists** Facattfes
lajliraai fta»a» RCRA
aa» a**- H llfSaaV ftl |
•TBCaVMj ffTHB IVcVHJ
RHaiilii»nr
When requested by
EPA. submit by dale
sel (which will be at
least 6 months after
request)
Not applicable
Pcrmgtctf RCRA
FaKflMy With Nwly
RcnataMBir
Submit Qass 3
modification to EPA by
February 17, 1992
Not applicable for Class
1 modification; publish
within 7 days before or
after submitlal of Class 3
modification
•PAdJttfM ^Bflia* tMi i !•• i 1
•'•CaaffJij ffTNal rvTffamimi
•aMl latefiai Star** RCRA
IMni' «•«•!• nsttl With
Nwrfy Rctwtotcal Bir
if revised Part A
submitted on August 21,
1991, submit Part B by
dale sel by Agency (which
will be at least 6 months
after EPA request); if
Qass 1 modification
submitted by August 21,
1991, submit Class 3
modification to EPA by
February 17, 1992
Not applicable unless
facility submits Class 3
modification in which case
within 7 days before or
after submittal of Class 3
modification
Parlay WwJt BIT Da* tMcr
RCRA heaatraMr ftawdarwi
If revised Part A was
submitted on August 21, 1991,
submit Part B by date sel by
Agency (which will be al least
6 months after EPA request);
if facility in process of
obtaining incinerator permit,
continue process if EPA
allows; if facility operates
under incinerator permit.
continue operation until
permit is reopened or expires,
then submit BIF permit
application
Not applicable
NewFadlry
Submit to EPA al
least 180 days before
physical construction
expected to begin
Not applicabk
'Facility has interim status units that are not BIFs (e.g., storage tanks, thermal treatment units).
^Facility has permitted units that are not BIFs (e g., storage tanks, thermal treatment units).
^Facility has interim status and permitted units on site that are not BIFs (e.g, storage tanks, thermal treatment units).
Facility is still required to file for an HPA identification number.
RPF\008
1003-01 rpf
-------
Table 10-1 (Continued)
DecMaventatloa Reonlreneats for Existing and New Facilities with Newly Regulated BIFs
NotfficMiM Sent by
Applicant to Parties
on Facility Mailing
List
Public Meeting hcM by
Applicant
EriMaai rariHtiM
fk|_4 aWaBMaatawaaiMBW •**•.!..*.* ia*k
nvM •rwwiMaiay flaVj^Va* w
IHtCVIM SKMaM WT aAVHNl
Rli»iraa»a»iWlt»,aUr
Majact M RCRA
Raialatiiai fcr Hrat ThM
Not applicable
Not applicable
la*ariai States RCRA
rtdaV WUh Newfr
R4V*M*IMr
Kin* «»i«>IJr«ihlf
nul •ppWCaWK
Nol applicable
rVn^MMCRA
•riKaWy WHfc Newly
K««aia4c4Mr
Within 90 day* after
Qacs 1 modilicalion is
effective; within 7 days
before or after cubmiltal
of Class 3 modification
For Class 3
modifications, no later
than 15 days before close
of 60-day comment
period
BP«JK*_. Whft. ^ *-- *
'•cany **aui rvraaanaai
•Ml tetoriai Statas RCMA
Uaito' M 9to aarf With
Ncirfr lUfdMarf Mr
Same as Public
Notification
For Class 3 modifications,
no later than 15 days
before dose of 60-day
comment period
raeiaxy VffHB Mr MM uaMMr
Not applkabk
Not applicabk
Itfavn* VaMaaVU-j
Not appltcablc
Noc applicable
'Facility has interim status units that are not BIFs (e.g., storage tanks, thermal treatment units).
Facility has permitted units that are not BIFs (e.g., slorage tanks, thennal Irealment units).
Facility has interim status and permitted units on site that are not BIFs (e.g., storage tanks, thermal treatment units).
Facility is still required to file for an HPA identification number. • • |
RPF\OOB
inOJ-OI rpf
-------
following BEFs only had to submit a Part A by
August 21, 1991 in order to obtain interim
status:
• A BIF at a newly regulated facility that
was not handling hazardous waste fuel
on February 21,1991, but was doing so
on or before August 21, 1991;
• A BIF at a newly regulated facility that
was "under construction" on February
21, 1991 but not handling hazardous
waste fuel on that date; and
• A BIF at a newly regulated facility that
was constructed or began operation
after May 22,1991, but before August
21, 1991.
All of the above facilities must have begun
complying with the BIF interim status standards
(§266.103) by August 21,1991, and must submit
Part B of the permit application to EPA by the
date set by the Agency. The owner/operator
will be given at least 6 months to submit Part B
after receiving a request to do so.
Interim status RCRA facility with newly
regulated BIF. A facility with a non-BIF
RCRA unit (e.g., a storage tank) regulated
under Part 265 interim status standards was
required to submit to EPA by August 21,1991,
a revised Pan A of the permit application to
add the newly regulated BIF and to begin
complying with the BIF interim status standards
({266.103) by August 21, 1991. Part B of the
permit application must be submitted to EPA
by a date specified by the Agency, which will be
set at least 6 months after the owner/operator
receives EPA's request for the submission.
3. Pennitted RCRA facility with newlv regulated
BIF. An owner/ operator of a facility
permitted for a non-BIF RCRA unit was
required to submit a Class 1 permit
modificadon for die newly regulated BIF by
August 21,1991 (see §270.42(g)), to send notice
of the modificadon to persons on die facility
mailing list wititin 90 days after die requested
change is effective, and to begin complying with
die BIF interim status standards (§266.103) by
August 21, 1991. Consequently, die
owner /operator must have submitted to EPA a
certification of precompliance by
August 21, 1991.
By February 17, 1992, a Class 3 permit
modificadon must have been submitted to EPA
(see §270.42(g)). Briefly, under Class 3
procedures (see §270.42(c)), within 7 days
before or after submission of the modification,
the applicant must send notice of the
submission to persons on the facility mailing list
and publish this notice in a major local
newspaper of general circulation. The notice
must announce a 60-day comment period on
the modificadon request, and a date, time, and
place for a public meeting to be held by the
applicant at least 15 days after the notification
request and no later than 15 days before the
close of the 60-day comment period. AfteAhe
comment period, the modificadon will follow
the procedures in 40 CFR Part 124. The
Director will grant or deny the permit
modificadon request and respond to significant
written comments received during the comment
period.
By August 21, 1992 or as extended, a
compliance of certification must be submitted
to the Agency, unless a RCRA permit is issued
by that date.
Facility with permitted
interim status
RCRA *Uts on
and with newly regulated
BIF. An owner/operator of a facility that has
both non-BIF permitted and interim status units
on site has the opdon of following procedures
described in Category 2 above for an interim
status RCRA facility with a newly regulated
BIF or in Category 3 above for a permitted
RCRA facility with a newly regulated BIF.
Note that, as listed in Table 10-1, if the facility
submitted to EPA a revised Part A on August
21, 1991, the facility must submit Pan B of the
permit application by the date established in
EPA's request to do so, which will be at least 6
months after the request; however, if the facility
submitted to EPA a Class 1 modificadon by
August 21, 1991, the facility must submit its
Class 3 modificadon request to EPA by
February 17, 1992.
BIFNSECT10.BIF
10-5
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5. Facility with BIF in>H i|nder RCRA incinerator
standards. A facility with a BEF regulated
under the interim status incinerator regulations
became subject to the BIF Rule on
August 21, 1991, and was required to submit a
revised Part A on that date (if necessary). A
facility in the process of obtaining an
bcinerator permit may be allowed, at EPA's
discretion, to continue the permit process; if a
permit is issued, EPA will add conditions to the
permit, as necessary, to ensure that the unit
complies with the requirements applicable to
BIFs. Facilities that were operating under an
incinerator permit may continue to do so until
the permit is reopened or expires. At that
time, the unit will be permitted as a BIF.
10.1.2 New Facilities
BIF units that were not 'in existence* as defined
by |266.103(a)(l)(ii), Le., were not in operation or under
construction on August 21, 1991, are considered "new
facilities* and are ineligible for interim status. To obtain
a permit, new facilities must obtain an EPA
identification number in addition to submitting Part A
and Part B of the permit application. The permit
application, under §270. l(b), must be submitted to EPA
at least 180 days before physical construction is expected
to commence. Neither construction nor hazardous-
waste-burning operations may begin until the
owner/operator has received a RCRA permit.
10.2
Overview of Permittinc Procedures
Permitting procedures for BIF units are similar
to those that apply to hazardous waste incinerators.
Owners/operators of BIF units are required to
submit a comprehensive RCRA permit application that
covers general information (Part A) as well as detailed
aspects of the ^'py operation, and maintenance of the
individual facility (Part B). This information enables
EPA to evaluate the proposed design and operation of
the BIF unit. When a facility is owned by one person or
company, but is operated by another person or
company, it is the operator's duty to submit the permit
application and obtain the permit The owner, however,
must also sign the permit application. EPA is the
regulatory agency responsible for evaluating permit
applications and issuing permits for BIF units until
states become authorized to implement the BIF
regulations. One copy of the permit application should
also be sent to the state regulatory agency, as a counesy.
10.2.1 Existing Facilities
The permit process for existing facilities consists
of the following steps:
1. Submission of the permit application (Parts A
andB);
2. Review of the permit application;
3. Performance of the trial burn (unless data in
Heu of a trial burn are acceptable);
4. Tentative permit determination;
5. Public comment on tentative permit
determination; and
6. Final permit determination. [V
»
These steps are described in more detail below.
10.2.1.1 Submission of the Permit Application
As shown on Table 10-1, existing facilities were
to have submitted, if necessary, a Part A or a revised
Part A, or a Class 1 modification for the newly regulated
BIF, to EPA no later than August 21, 1991. For
facilities that submitted a Part A by that date, the
Part B is required to be submitted when requested by
EPA; the submission date will be set at least 6 months
after the request For facilities that submitted a Class 1
modification by August 21,1991, a Class 3 modification
to include the BIF unit(s) must be submitted to EPA by
February 17,1992. Part B of the permit application and
Class 3 modification requests must include a trial burn
plan or the results of a trial bum. EPA recommends,
but does not require, that a trial burn plan (instead of
trial burn results) be submitted as part of the Part B or
Class 3 modification request in the event EPA
determines that more information or parameters are
needed to adequately test the performance of the BIF.
10.2.12 Review of the Permit Application
Once the owner/operator of an existing facility
has submitted an application, EPA determines whether
all the required information has been submitted (see
H270.13, 270.14, 27022, and 270.66) and whether the
Bff\SECno.BIF
10-6
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trial burn as planned will adequately test the
performance of the BEP. (If trial burn data from the
same BEF unit are submitted at this time, EPA reviews
the information to evaluate the unit's performance; in
the case where data in lieu of a trial burn are submitted,
either from a similar unit or previous compliance test
data from this same BEF, EPA will review the data.) If
the application is not complete or if it does not satisfy
the technical requirements of the BIF Rule and other
RCRA regulations, EPA will send a Notice of
Deficiency (NOD) letter describing the additional
information that is required. Failure to provide
requested information can result in denial of the permit
If the permit application and trial burn plan is
deemed complete and technically adequate, the facility
will conduct the trial burn before the Agency will make
a decision to tentatively grant or deny a permit. If trial
burn results or data in lieu of conducting a trial burn
are submitted and EPA uses these data to waive the
trial burn requirements, a draft permit will be prepared
by the permit writer.
10.2.1.3 Performance of the Trial Born
Unless data in lieu of a trial burn are submitted
and acceptable, an owner/operator must conduct a trial
burn in accordance with their trial burn plan. EPA and
state authorities must be notified well in advance since
their representatives will generally attend the trial burn.
Following the trial burn, the owner/operator must
submit data and information to EPA on the
performance of the BEF unit during the trial burn. The
owner/operator may be able to submit data in lieu of a
trial burn; this option is described in Section 10.63. In
either case, EPA reviews the information and may
request additional data.
KU.1.4 Tentative PomH Determination
If the results of the trial burn or data submitted
in lieu of the trial burn demonstrate that the BIF unit
meets performance standards, and the permit
application indicates compliance with RCRA facility
standards, EPA will prepare a draft permit which
incorporates applicable technical requirements and other
conditions based on the data gathered pertaining to the
BEFs operation. These other conditions are divided into
two groups: (1) those applicable to all permits (called
general conditions), and (2) those applied on a case-by-
case basis. If it appears, however, that the facility is
BIF\SECno.BIF
unable to meet the applicable performance standards, a
•Notice of Intent to Deny* is prepared.
10.2.1.5 Public Comment on Tentative Permit
Determination
Once the draft permit (or notice of intent to
deny) is completed, EPA is required to give public
notice and allow 45 days for interested persons to
submit written comments. A public hearing is held
during this time, if requested. EPA must also issue
either a fact sheet (40 CFR 124.8) or a statement of
basis (40 CFR 124.7) to inform concerned parties about
the permit process that is taking place. These
supporting documents are sent to the applicant and, on
request, to any other interested persons.
10.2.1.6 Final Permit Determination
After the comment period closes, EPA prepares
a response to all «igntfi«m> public comments and maVes
the final decision whether to issue or deny the permit.
If denied a permit, an existing facility must either
comply with closure/post-closure requirements or appeal
the permit decision. Once issued, RCRA permits are
valid for up to 10 years. During the term of the permit,
situations may arise which may cause the permit to be
modified. EPA may modify permits for a variety of
reasons under §270.41, including:
• Substantial alterations or additions are to occur
at the facility,
• New information about the facility becomes
available; or
• New statutory or regulatory requirements affect
existing permitted activities.
The permittee may also request a permit
modification for the above reasons (e.g., the facility
increases its waste management capacity or plans to
burn different wastes). These permit modifications are
generally classified as follows:
• Class 1: Routine changes and corrections of
errors (J270.42(a));
• Class 2: Common or frequently occurring
changes needed to maintain a facility's
capability to manage wastes safely or conform
to new requirements (§270.42(b));
10-7
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• Class 3: Major changes that substantially alter
the facility or its operations (§270.42(c)); and
• Modifications initiated by the Agency (§270.41).
Appendix I to $270.42 lists classes and types of permit
modifications.
1022 New Facilities
The permit process for new facilities consists of
the following steps:
1. Submission of the permit application (Parts A
and B, including the thai burn plan);
2. Review of the permit application;
3. Tentative permit determination;
4. Public comment on tentative permit
determination;
5. Permit determination;
6. Performance of the trial burn (unless data in
lieu of a trial burn are acceptable); and
7. Final operating conditions determination.
KU.2.1 Submission of the Permit Application
Physical construction of a new BEF that will
burn hazardous waste may not begin until Parts A and B
of the permit application have been submitted and a
RCRA permit has been issued. RCRA regulations state
that applications should be submitted at least 180 days
before expecting to »«•*««*•"•» construction. To avoid
incurring construction delays, the Agency cautions
potential applicants to tabmit their permit applications
early enough to accommodate such concerns.
KUJ.2 Review of the Permit Application
As for existing facilities described in 10.2.1.2
above, EPA performs a technical review of the permit
application to determine if the BIFs design and trial
burn plan are adequate to demonstrate that the unit is
likely to meet the performance standards and RCRA
regulations. During this review, EPA may send Notices
of Deficiency (NODs) asking for more information.
Failure to provide the requested information can result
in denial of the permit.
10.2.2.3 Tentative Permit Determination
If, based on information contained in the permit
application, EPA determines that the BEF is unable to
meet applicable performance standards and RCRA
requirements, a "Notice of Intent to Deny" is prepared.
If EPA considers the application and trial burn
plan complete and technically adequate, EPA will
prepare a draft permit The draft permit will include
the trial burn plan, facility design specifications, and
operating conditions under which the facility is expected
to meet the performance standards. If data in lieu of
conducting a trial burn are submitted and EPA deems
k acceptable, the waiver of the trial burn will be
incorporated into the draft permit. The option to
submit data in lieu of a trial burn is ^'^f^wf in Section
10.63. r_
10.2.2.4 Public
Comment
Au OD
on Tentative Permit
EPA publishes a notice of availability of the
draft permit and trial burn plan, or the notice of intent
to deny, whichever applies, for public comment and
allows 45 days for interested persons to submit written
comments. A public hearing is held during this time, if
requested. EPA must also issue either a fact sheet (40
CFR 124.8) or a statement of basis (40 CFR 124.7) to
inform concerned parties about the permit process that
is taking place. These supporting documents are sent to
the applicant and, on request, to any other interested
persons.
Permit Determination
After the dose of the comment period, EPA
prepares a response to all «ignifi<-ant public comments
and makes the final decision whether to issue or deny
the permit. Under the appeal process, the facility may
appeal if the permit is denied or may appeal certain
conditions of the granted permit In addition, anyone
who commented on the draft permit may appeal the
final determination.
Because operational data are needed to develop
permit conditions for a BEF (as for an incinerator), EPA
issues a four-phase permit Based upon operating
conditions proposed for the trial burn, the permit
Bff\SECno.BIF
10-8
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contains specific operating conditions for all four
phases • prethal burn period, trial burn period, post-trial
burn period, and final operating period for the life of
the permit. Once trial burn results are evaluated, the
Director makes any necessary modifications to final
permit operating requirements to ensure compliance
with the performance standards.
The predial burn period or start-up/shake-
down period (Phase One) establishes conditions for the
purpose of determining operational readiness following
completion of construction (see J270.66(b)(l)). This
phase allows limited burning of wastes (the minimum
time needed) to help stabilize the new BIFs operations
and to prepare the BEF for the trial burn. This time
period is restricted to 720 hours of operating time, but
at the applicant's request, may be extended once for up
to an additional 720 hours. The Phase One conditions
include allowable hazardous waste feed rates, operating
conditions, and, based on EPA's engineering judgment,
other requirements sufficient to meet applicable
requirements.
Phase Two of the permit covers the trial burn
period (§270.66(b)(2)) for which operating conditions
will be established based on the trial bum plan and
modified at EPA's discretion. Emissions and operating
conditions are monitored during the trial burn and the
resulting data are submitted to EPA within 90 days of
the trial burn completion.
Phase Three covers the post-trial burn period,
while the trial burn results are being analyzed and
reviewed by the Agency. The BIF may be allowed to
operate under pretrial burn limits and conditions, unless
other conditions are specified by EPA during this phase.
Based on the trial bum results, the Director
may make any necessary modifications to the Phase
Four (final operating period for the life of the permit)
to ensure compliance wkh the performance standards.
Any modifications to these permit conditions must be
made according to 1270.42.
If the BIF does not pass the trial burn, the
permit may be modified to allow an additional trial
burn; however, this would be considered a major
modification of the permit and would require a new
public comment period.
Once issued, RCRA permits are valid for up to
10 years. During the term of the permit, situations may
arise that necessitate permit modification. These
situations are described in Section 10.2.1.6.
10.2.2.6 Performance of the Trial Bum and Final
Operating Conditions Determination
Unless data in lieu of a trial burn are submitted
and acceptable as described in Section 10.63, an
owner /operator must conduct a trial burn in accordance
with the trial burn plan. The trial burn will generally be
attended by the state and federal EPA staff. Following
the trial burn, the owner/operator must submit data and
information to EPA on the performance of the BIF unit
during the trial burn. EPA will review the trial burn
and determine the final operating conditions for the life
of the permit.
103 Preparation of a RCRA Permit Application
The RCRA permit application consists of Xyo
Parts, A and B. Part A of the application is a start,
standard form (EPA Form 8700-23, January 1990
edition) that requests general information about the
facility and the processes to be used to treat, store, and
dispose of hazardous wastes; the design capacity of each
process; and the specific hazardous wastes to be handled
at the facility during the interim status period. Once
Part A is submitted to EPA, changes in hazardous
wastes handled, changes in the design of the facility,
changes in processes, and changes in ownership or
operational control at a facility during interim status
may only be made in accordance with the procedures
specified in 40 CFR 270.72. Changes in design capacity
and changes in processes require prior EPA approval.
Changes in the quantity of waste currently specified on
the Pan A can be made without submitting a revised
form, provided the quantity does not exceed the design
capacity of the unit.
Part B of the permit application requires the
owner/operator to provide detailed information about a
facility. Since there is no standard form for Pan B, the
owner/operator must rely on the regulations (for BIFs,
40 CFR Parts 266, Subpart H and 270) to determine
what to include in this part of the application. Before
preparing the permit application, the owner/operator
should arrange a meeting with the EPA permit writer to
discuss the permit application and ask questions
concerning the preparation of the information and the
BIF\SECno.BIF
10-9
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format to be used. One suggested permit application
format is as follows:
• Section A • Part A Application;
• Section B - Facility Description;
• Section C - Waste Characteristics;
• Section D - Process Information;
• Section E - Groundwater Monitoring (not
applicable to BIFs);
• Section F - Procedures to Prevent Hazards;
• Section G - Contingency Plan;
• Section H - Personnel Training;
• Section I - Closure Plans, Post-Closure Plans,
and Financial Requirements;
• Section J • Corrective Action for Solid Waste
Management Units
• Section K - Other Federal Laws; and
• Section L - Certification.
The owner/operator should also add a section that will
include information on air emissions from process vents
required by 40 CFR Part 264, Subpart AA, and air
emissions from equipment leaks required by 40 CFR
Pan 264, Subpart BB and 40 CFR Part 264, Subpart
CC»
The trial burn plan is part of Section D -
Process Information. The plan can either be included
within Section D, or bound as a separate document. If
bound as a separate document, a reference should be
made in Section D that the Process Information is
included in the separately bound trial burn plan. The
trial burn plan will normally be submitted with the
balance of the permit application, but may be submitted
separately, when necessary, because of timing or EPA
review constraints. Preparation of the trial burn plan is
disrwsy/i in Section 10.4.
Class 3 permit modifications require the same
type of information at a permit application. The
owner/operator should ttk the EPA permit writer if the
modification can be prepared as an addendum to the
existing permit application or if the existing permit
application must be modified and resubmitted in its
entirety. An addendum is preferable because only
sections of the Mating permit application that have
changed due to the addition of the BIF unit would need
to be modified. Sections that have not changed would
not need to be repeated.
10.4
PreDaration of the Trial Bum Plan
The two major purposes of the trial burn must
be considered when preparing the trial burn plan. First,
the trial burn should demonstrate that the BIF is
capable of meeting the emissions standards (DRE,
paniculate and metals emissions, and HC1 and Clj
emissions). Second, the trial burn must define the
worst-case conditions for the unit and demonstrate that
the unit can meet the emissions standards under the
worst-case operating conditions, which will then be
established as permit conditions. Table 10-2 lists the
major information that must be included in the trial
burn plan portion of the Part B application.
In addition, the following EPA guidance
documents on preparing and conducting trial burns for
hazardous waste incinerators can also be used as sources
of information and applied to BIF units since the
combustion issues are similar:
on Setting Permit Conditions"
Trial Burn Results (23); *
• Hazardous Waste Incineration Measurement
Guidance Manual (25); and
• Quilitv Assurance /QmO'tv Control fQA/QO
Procedures for Hazardous Waste Incineration
(28).
KM.1 Restrictions on Operating Conditions During
Precompliance, Compliance, and Permit
Periods
Table 10-3 provides a summary of the
restrictions on operating conditions during
precompliance, compliance, and permit periods.
10.4.2 Coaflktinf Parameters and Test Design
fv>nfHrting parameters, defined as two or more
operating parameters that cannot be simultaneously
operated at their worst-case conditions, should be
considered in test design. Conflicting parameters are
generally first encountered during the interim status
compliance test; however, some facilities that receive
EPA approval to conduct a combined trial
burn/compliance test burn will not deal with conflicting
parameters until this trial burn stage.
"Although Subpart CC is currently in proposed form (56 FR 33491, July 22,1991), it it anticipated tbat it will be finalized prior to teuance of any
final BIF permit decisions. 10-10
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Table 10-2
Contents of • Trial Born Plan
Trial Bon Plan
• Detailed engineering description of the boiler or industrial furnace:
- Manufacturer's name, model number.
- Type.
- Maximum design capacity.
- Description of the feed system for the hazardous waste, fuel, and other feedstocks.
- Capacity of hazardous waste feed systems.
— Description of automatic waste feed cutoff system(s).
— Description of stack gas monitoring and any pollution control monitoring systems.
• Description of each feed stream and waste that will be burned during the trial burn and a discussion of bow
they represent the worst-case conditions for the BIF:
- Heating value.
- Source, composition, and chemical analysis, if possible.
- Levels of antimony, arsenic, barium, beryllium, cadmium, chromium, lead, mercury, silver, fh*n«'"",
total chlorine/chloride, and ash. ":
- Viscosity or description of physical form.
- Identification of organic to 40 CFR Part 261, Appendix Vm hazardous constituents present in the feed
stream.
- An approximate quantification of 40 CFR Part 261, Appendix Vm hazardous constituents in the
hazardous waste.
~ Description of blending procedures, if applicable, prior to firing.
• Operating conditions during the trial burn, a discussion of how they represent the worst-case conditions for
the BIF, proposed permit operating conditions, and anticipated results from these conditions.
Description of the air pollution control system, its operating conditions, and a discussion of how the test
conditions represent the worst-case conditions for the BIF.
Test protocol:
- Operating conditions for emission control equipment.
- Sampling and monitoring procedures, equipment, frequency, analytical procedures, and proof that they
will satisfy the requirements of the tests.
- Quality Assurance/Quality Control (QA/QC) Plan.
- Test schedule.
- Shutdown procedures in the event of equipment malfunction, including hazardous waste feed cutoffs
and emissions controls.
- Identification of ranges of hazardous waste feed, feed rates of other fuels and feedstocks, and other
parameters affecting the ability of the BIF to meet emissions standards.
- Other necessary information.
RpF\ooe
1003-Ol.rpf
10-11
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Table 10-3
Operating Parameters For Which Limits Are Established
During PrecompUance, Compliance, and Permit Periods
Total feed rate of hazardous waste
Total feed nte of pumpable hazardous waste
Feed nte of each of the 10 BEF-regulated metals in:
. Total feed streams
. Total hazardous waste feed streamse>>)-
TLimits not applicable if complying with Tier I or adjusted Tier I for metals aad tool chlorine and chloride.
'During compliance, minimum combustion chamber need only be maintained following a waste feed cutoff, for the duntkm that the waste
remains in the chamber.
JNot applicable if complying with Tier I or adjusted Tier I total chloride and chlorine feed nte screening limitt.
TT* final BIF Rule specifies that facilities complying with Tier I or adjusted Tier I metals feed nte screening limitt must establish limits for
these parameters during interim status (precompliance or compliance, as noted). EPA is considering amending the rule to rescind the
requirements for facilities complying with Tier I or adjusted Tier I metals feed nte screening limitt to establish limitt on these panmeten.
RPF\008
1003-01.rpf
10-12
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To receive the most flexible permit limits
possible, each operating parameter should be tested
during the trial burn at the worst-case conditions
anticipated for present or future operation. However,
BIFs can be very complex systems in which many
parameters are related Although every effort should be
made to do so, it may not always be possible to test all
operating parameters at their desired extremes
simultaneously.
The approach for dealing with conflicting
parameters is discussed in Section 5.23.8. During the
trial burn, one additional potential conflict arises since
worst-case organic destruction (closely linked to DRE)
occurs at the lowest combusdon chamber temperature;
however, worst-case metals emissions are considered to
occur at the highest combustion chamber temperature.
Potential conflicting parameters should be
identified in the trial burn plan, along with the reasons
for the conflict, and the changes in other operating
parameters that will be made to allow testing at worst-
case conditions for the conflicting parameters. The trial
burn plan should also provide a description of all
operating conditions for each test and a discussion of
how the test results are interrelated.
10.4.3 POHC Selection
Principal organic hazardous constituents
(POHCs) are compounds selected by the facility and
approved by the Director to demonstrate in a trial burn
that the facility achieves the required destruction and
removal efficiency (DRE), which is 99.99% for
hazardous organic emissions and 99.9999% for certain
dioxin and furan Mn««in«« One or more POHCs must
be selected for each waste feed stream; the required
DRE must be demonstrated for each POHC during the
trial burn. Current Afency policy on POHC selection
is given in References 13 and 23 and are summarized
below.
POHC selection should be based on the
following criteria:
• The degree of difficulty of destruction of the
organic constituents in the waste; and
• The concentrations or mass of 40 CFR Part
261, Appendix Vm organic in the waste feed
considering the waste analysis results submitted
with the Part B permit application.
Although POHCs are generally selected as
compounds present in the waste that are listed in 40
CFR Part 261, Appendix Vm, the Director may select
surrogate POHCs which are not present in the waste
and/or are not listed in Appendix VHI.
In addition to these criteria, there are several
practical constraints that should be considered in the
selection of POHCs. POHCs should be selected which
are:
• Measurable by reliable and conventional
techniques;
• Not PICs of the fuel, the hazardous waste, or
the other POHCs;
• Not likely to upset the operation or product of
the faculty,
• Feedable and meterable;
• Not dangerous to handle (Le., not highly Joxic
or explosive); and •'.
• Available in quantity at a reasonable cost.
Further, the Agency recommends that other
characteristics like compound structure be considered in
POHC selection since compounds of similar chemical
structure are likely to react similarly in a combustion
system.
POHC selection begins with examination of the
waste streams that will be burned at the facility, to
identify any Appendix Vm organics present in these
streams. Generally, a concentration of 100 ppm in the
waste may be considered significant; however, lower
concentrations of substances with potentially high health
or environmental impact or materials that may create
public or regulatory concern may also be considered.
To allow for variations in sampling and analysis,
the quantity of each POHC that is fed to the BIF during
a trial burn should be sufficient to demonstrate a greater
percent DRE than required. Consideration must be
given to the analytical method detection limit for the
respective emissions testing procedure. The amount of
POHC fed should be approximately 10* times the
method detection limit (MDL) to show greater than
99.99% DRE, and 107 times the MDL to show
99.9999% DRE.
POHC compounds selected for the trial burn
should be at least as difficult to destroy as any
hazardous compound found in the waste. There are a
number of systems that have been used to rank
BIF\SECT10.BIF
10-13
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compounds in order of destruction difficulty. The two
methods that are commonly used in permitting are the
heat of combustion index and the thermal stability index
(TSLoO2).
In the heat of combustion index, the compounds
which have the lowest heat of combustion are ranked as
most difficult to destroy. This index is listed in
Manual for HaTardous Waste Incinerator
Permits (11) and other documents.
The TSLoO2 index was developed by the
University of Dayton Research Institute (UDRI) under
contract to EPA. In the TSLoO2 index, compounds are
ranked according to their thermal stability under low
oxygen conditions. The compounds that require the
highest temperatures to achieve destruction are ranked
as most difficult to destroy. The TSLoO2 ranking relies
on tests that subject samples of the compound to
temperatures of up to 1,000*0 in a nitrogen atmosphere
and measure their degree of destruction after 2 seconds.
Representative compounds from all major groupings of
40 CFR Pan 261, Appendix vm compounds have been
tested, and the index for the remainder have been
estimated. The TSLoO2 index is still being refined as a
result of ongoing experimental studies.
A copy of the ranking, which includes
experimental results through the end of the 1990 fiscal
year, is included in Appendix H. Applicants should use
the most current index available when developing a trial
burn plan. When this ranking is used, it is
recommended that POHCs be selected from those
compounds for which actual experimental data exist.
Guidelines for the use of the TSLoO2 index are
included in Appendix D of Guidance op Setting Peppij
Conditions *nf* P?P9TTJM Trill BWB Results (23).
The BIF Rule allows the selection of surrogate
POHCs, Le., compouBdB which are not present in the
waste and/or are not fisted in Appendix vm of 40 CFR
261. The use of surrogate POHCs may be proposed if
the compounds present in the waste are impractical for
POHC selection because of the considerations listed
above, or because of high cost, high toxicity, sampling
and analysis problems or if the facility believes it is
more appropriate to select POHCs for which
experimental data exist. A permit applicant seeking the
use of surrogate POHCs must submit, in the trial burn
plan, adequate documentation of the relationship
between the ORE of the surrogate POHC and the
DREs of the Appendix vm compounds in the waste.
Two surrogate POHC concepts that have been advanced
are the use of SFf and/or the use of POHC 'soups.'
The pros and cons of SF6 have been discussed in the
BIF preamble (56 fE 7147, February 21,1991).
10 J5 Extrapolation/Interpolation of Met«U
Emissions Data
Extrapolation/interpolation of test data can be
used to develop operating limits (e.g., metals feed rate
limits) from test data obtained at operating conditions
that are different from the limits. Extrapolation means
setting limits outside the bounds (above or below) of
test results, and interpolation means setting operating
limits between the bounds of the test results.
This subsection discusses the specific
circumstances in which extrapolation/interpolation may
be used for setting permit operating limits. Because
extrapolation/interpolation of data is valid only in
certain circumstances, and because EPA is abler to
provide only limited oversight during interim status", it
should not be used for compliance certification.
Operating conditions demonstrated during the
compliance test provide the basis for limits established
in the compliance certification, as discussed in Section
5.0.
10J.1 Theoretical Background
Extrapolation/interpolation of test data must
consider the relationship between the emissions rate of
a metal from a BIF and the feed rate of the metal.
Because this relationship is not linear,
extrapolation/interpolation may result in
nonconservative limits, and is therefore inappropriate in
some cases.
The emission rate of a metal depends on
numerous operating parameters, including the feed rate
of the metal, APCS parameters, gas velocity, operating
temperatures, etc. The feed rate of a metal to a BIF
varies as a result of (1) changes in the concentration of
metals in the feed materials to the BIF (wastes, fuels,
and raw materials); and (2) changes in the feed rates of
the various materials to the BIF. Consider a simple
case where metals are being fed to a BIF from a single
nonpumpable feed stream. The expected effect of
increasing the metals feed rate on metals emissions from
a BIF, where the other operating parameters are held
constant, is shown in Figure 10-1.
Bff\SECT10.BIF
10-14
-------
I
I
Zone I
(Vaporization) I
I
Figure 10-1(«)
Metal Feed Rate In Liquid
I
I
Zone I |
(Viporizttkn) I
J.
I
Zonell
(Bntnimnent)
Figure 10-l(b)
Metal Feed Rate IB Solid
(Liquid Feed Rate is CoMtant)
I
Zooel
I
Zonen
Zone in
Figure 10-l(c)
Metal Feed Rate IB Liquid
(SoUd Feed Rate ta Constant)
Figure 10-L Typkal RriatJoaiihip Between Metals Feed Rate and Emfarions Rate
-------
For low metals feed rates, metals behavior is
controlled mainly by vaporization (Zone I), as shown in
Figure 10-1 (a). Metals tend to vaporize until the
combustion gas becomes saturated with metal
compounds. The quantity of a given metal that will
saturate the gas is determined by the effective vapor
pressure of the metal, which depends on the
temperature, and may depend on the concentration of
chlorine, oxygen, and/or sulfur in the gas. If the vapor
pressure is high enough to completely vaporize the
metal without saturating the gas (Le., at relatively low
metal feed rates), an increase in the metals feed rate
results in an equivalent (1 to 1) increase in the amount
of metals emitted. Eventually, as the metals feed rate
continues to increase, the gas becomes saturated with
metal compounds.
After the saturation level is reached, the metals
emission rate becomes a function of the particle
entrainment rate, and the metals concentration on those
particles (Zone II). The total metals emissions rate
continues to increase with increasing metals feed rates
because of increased metal concentrations in the
entrained ash particles. However, because no additional
amount of metal can vaporize, the metals emissions rate
in Zone n does not increase as rapidly as in Zone I.
A more complex case is one in which metals are
being fed to a BIF from both liquid and solid feed
streams. The expected effect of an increase in the feed
rate of metals in the solids feed stream when the other
operating parameters are held constant is shown in
Figure 10-l(b). This is similar to the simple single feed
source case of Figure 10-l(a) except that there is an
offset in metals emissions as the feed rate of metals in
the solid feed stream approaches zero because of the
emissions from the liquid feed stream.
The expected effect of increasing the feed rate
of metals from the iqud feed stream on metal
emissions, where the Other operating parameters are
held constant, is shown m Figure 10-l(c). For low metal
feed rates, metal behavior is controlled mainly by
vaporization (Zone I). Metals from both feed streams
tend to completely vaporize until the combustion gas
becomes saturated with metal compounds. As the feed
rate of metals from the liquid stream becomes higher
than the saturation point (Zone n), all of the metals fed
with the liquid feed stream will vaporize; however, only
a portion of the metals fed with the solid feed stream
will vaporize, and the remainder will remain in the ash.
In this example, further increases in metal feed
rates result in a slight increase in metal emission rates
because of the increase in the metals concentration of
the entrained particles. Finally, a point is reached where
the metals in the liquid feed stream alone are sufficient
to saturate the gas. As metal feed rates increase beyond
this point (Zone m), further increases in the feed rate
of metals in liquid feed streams result in a direct
increase in the amount of entrained metals.
The relationship between metal feed rates and
metal emissions is linear within each of these three
zones. Furthermore, the contributions of the liquid and
the solid feed streams are expected to be additive.
Thus, as long as the extrapolation/interpolation is
conducted over a limited range (Len not over either of
the breakpoints of Figure 10-l(c)), extrapolation/
interpolation is appropriate for situations where the
metal feed rate changes in both the solid and the liquid
feed streams, and the following equations apply:
SFL - SF,
LFL - LF, *
(SF, - SF,)
(LF, -
where:
SF
LF
i
2
L
feed rate of the metal in the solid feed
stream
feed rate of the metal in the liquid feed
stream
emission rate of the metal
test condition 1
test condition 2
the extrapolated or interpolated limit
condition
The above theoretical treatment assumes that
there is a single stable solid form of the metal over the
range of extrapolation. In situations where the metal
has an affinity for the clinker/aggregate/slag (e.g.,
arsenic), there may be a number of stable complexes,
and the saturated vapor pressure may change with the
BDF\SECT10£IF
10-16
-------
concentration of metals in the solids. In this case,
Figure 10-1 would be expected to change as follows:
• Zone I would be unaffected. The metal
emissions rate in the "vaporization* zone would
be linear with the metals feed rate.
• A sharp break at the saturation point would
still be evident.
• An increased metal feed rate in Zones n and
HI would result in an increase (probably
nonlinear) in vaporization with a
correspondingly nonlinear increase in the metal
emission rate. The nonlinear impact would be
greater in Zone II than in Zone ID.
However, because the nonlinear relationship is likely to
be approximately linear over a small range, this does not
necessarily preclude the use of the above extrapolation/
interpolation equations over a small range of metal feed
rates.
10.5.2 Extrapolation to Different Feed Rates
Figures 10-2(a) and (b) illustrate examples of
extrapolation/interpolation of test data to establish
metal feed rates, using the above theoretical background
on metal emissions. In Figure 10-2(a), the measured
metal emissions (Point 1) are greater than the allowable
emissions, determined from dispersion modeling. A
linear extrapolation back to the allowable maximum
emissions level (Point 2) provides a proposed metal feed
rate limit (Point 3). However, because of the
nonlinearity of the metals emission curve, the actual
emissions produced at the proposed feed rate limit
(Point 4) are still higher than the maximum allowable
level. The largest allowable metal feed rate should be
smaller (Point 5). Because of this type of
nonconservative result, a downward linear extrapolation
of data is not recommended; actual data should be used
in this situation.
In Figure 10-2(b), the measured metal
emissions (Point 1) are below the allowable emissions.
In this case, the extrapolation to Point 2 would produce
a lower proposed feed rate limit (Point 3) than that
which should actually be allowed (Point 5). Therefore,
upward extrapolation would be theoretically conservative
in this case. Such upward extrapolation may be
reasonable for justification of limited (e.g., 720 hours)
testing at higher metals feed rates; however, it is not
Bff\SECno.BIF 10-17
generally recommended for setting permit limits because
of the lack of validation data.
One situation which may warrant the use of
upward extrapolation is when the projected emissions at
the extrapolated feed rates are far below the Tier in (or
Tier n) emission limits. For example, suppose a facility
runs a trial burn using typical waste without spiking, and
the metal emissions are 20 times lower than the Tier UI
limits. In this case, the permit writer could reasonably
allow upward extrapolation to set a metals feed rate
limit somewhat higher (e-g, double the feed rate based
on the trial burn). This would theoretically result in
metal emissions which are 10 times lower than the Tier
m limit. Allowing extrapolation in such cases would
eliminate the need for expensive metals spiking to
achieve flexible, but still conservative, metals feed rate
limits.
10.5.3 Interpolation to Different Feed Rates
An approach that is subject to fewer
uncertainties is interpolation between data points. This
approach is illustrated in Figure 10-3. Suppose two tests
were conducted in a trial burn, each at a different
metals feed rate. One test (Point 1) resulted in
emissions above the limit, and one test (Point 2)
resulted in emissions below the limit. These two points
define the actual emissions curve observed during the
test over the range of metal feed rates that were
examined. If the range of feed rates was small, linear
interpolation can be used as shown in the figure to
determine the metal feed rate that just meets the limit
(Point 3), and the theoretical metal feed rate limit that
corresponds to the maximum permissible emission rate
can be established (Point 4).
In considering this approach, the
owner/operator and permit writer should carefully
review the overall range in metal feed rates represented
by the available test data, as well as the variation in
other operating parameters, to ensure that the linear
interpolation is applicable. For example, in a situation
where one test was conducted at metal feed rates above
the saturation point and one test below the saturation
point, interpolation could result in error. Because it is
not possible to determine whether the data points
straddle the saturation point, EPA recommends
establishing the feed rate limits at the demonstrated
levels (Point 2) in these situations and does not
recommend the use of interpolation.
-------
Ffcure 10-2(«)
i
TtM
Lntf
S J
Figure 10-Kb)
Lml
Hfnn 10-2. Foteatial Retuto ofEitnpolatkw of Tort Ban Data
10-18
-------
I
Figure 10-3. Potential Effects of Interpolating Between Test Results
-------
where available data show they pose minimal risk to
human health and the environment. These include:
• BIFs burning low risk wastes; and
• Specific types of boilers burning certain classes
of waste.
The facility must submit documentation that
demonstrates that the BIF meets the requirements of
the low risk waste exemption or special operating
requirements (SOR) as specified in |27022(a). In
addition, under J27022(a)(6), it is possible to submit
data in lieu of a trial burn if the data demonstrate a
unit's compliance with the BIF Rule.
10.6.1 Low Risk Waste Exemption
Section 266.109 allows EPA to waive the DRE
trial burn standard for certain boilers and industrial
furnaces, and if the BIF is exempt from the DRE trial
burn, possibly the trial burn for paniculate matter
(PM).J1 These facilities are not exempt from other
portions of RCRA regulations, such as notification of
hazardous waste activities, the need to obtain permits
for storage of hazardous wastes, or other BIF emissions
standards.
To qualify for the low risk waste exemption, the
device must first satisfy the following operating
requirements of §266.109(a)(l):
1.
At least 50% of the fuel (the primary fuel) is a
fossil fuel, fuel derived from a fossil fuel, tall
oil, or, if approved on a case-by-case basis by
the appropriate regulatory authority, other
nonhazardous fuel with combustion
characteristics similar to fossil fuel. The
percentage of primary fuel is determined on the
basis of either the beat input (Le, Btu/hr from
the primary verm aQ fuels) or the mass feed
rate (Le., Ib/ir of the primary fuel versus the
waste fuel), depending on which method results
in the lower mass hazardous waste feed rate.
The primary and hazardous waste fuels have a
as-fired heating value of 8,000 Btu/lb.
4. The stack gas concentration of CO is < 100
ppmv hourly rolling average (on a dry basis
corrected to 7% OJ. The device is not eligible
for the alternative standard for HC emissions
(<20 ppmv hourly rolling average, reported as
propane, on a dry basis corrected to 7% O2) if
the BIF falls under the low risk waste
exemption.
5. The waste does not contain nor is it derived
from acutely hazardous (dioxin-listed) wastes
listed under 126131 (specifically, the waste
streams F020, F021, F022, F023, F026, and
F027, which are related to the manufacture,
disposal, and use of chlorophenols,
chlorobenzenes, chlorohexanes, and
hexachlorophene).
In addition, the following actions must be
implemented to demonstrate that the BIF will not pose
unacceptable adverse risks to human health:
*
• Identify and quantify the nonmetal compounds
listed in 40 CFR Pan 261, Appendix VIII that
could be present in the hazardous waste;
• Calculate reasonable, worst-case emission rates
for each constituent identified above;
• Use air dispersion modeling to predict the
maximum annual average ground-level
concentration of the constituents identified
above; and
• Ensure that ground-level concentrations of the
constituents predicted above do not exceed
levels established in §266.106(a)(2)(iv).
These procedures require calculation of the
worst-case emissions of the Appendix VIE! organics
which may be fed to the BIF, a value that can be used
in a maximum exposed individual (MEI) exposure
calculation for the system. The hazard levels are
determined following the procedures for dispersion
3.
The hazardous waste is fired directly into the
primary fuel flame zone.
"A waiver from the PM compliuce test required under interim status is not available under the low risk wute exemption.
BDF\SECnO.BIF
10-20
-------
modeling and risk estimation given in f266.106(h).
Maximum ground-level exposure is limited as follows:
• For noncarcinogenic compounds, the maximum
annual average ground-level concentration is
the RAC specified in Appendix IV of 40 CFR
Part 266;
• For carcinogenic compounds, the ratio of the
maximum ground-level concentration to the
RSD given in Appendix V of 40 CFR Part 266
must be calculated for each compound. The
cum of these ratios cannot exceed 1.0; and
• For other 40 CFR Part 261, Appendix Vm
constituents, the maximum ground-level
concentration is <0.1
If it is determined that the BEF is exempt from
the DRE standard and trial burn, it is also eligible for
the waiver of the PM standard and the PM trial burn.
To be eligible for this exemption, the BEF must satisfy
the Tier I or adjusted Tier I metals feed rate screening
limits under §266.106(b) or (e).
A waiver from the DRE and PM trial burn
requirements does not exempt a facility from other
RCRA regulations, including other BEF emissions
standards and notification and recordkeeping
requirements.
10.6.2 Waiver of DRE Trial Burn for Boilers
Operating Under Special Requirements
Section 266.110 exempts certain boilers from the
DRE standard and trial burn requirements if certain
conditions are met. These faculties are not exempt from
other portions of the RCRA regulations, such as other
emissions standards, Modification of hazardous waste
activities, or the need to obtain permits for storage of
hazardous wastes.
To qualify for this exemption, the device must
first satisfy the following operating requirements of §
266.110(a):
1. At least 50% of the fuel (the primary fuel) is
fossil fuel, fuel derived from a fossil fuel, tall
oil, or, if approved on a case-by-case basis by
the appropriate regulatory authority, other
nonhazardous fuel with combustion
characteristics similar to fossil fuel. The
2.
3.
4.
5.
6.
7.
8.
9.
percentage of primary fuel is determined on the
basis of either the heat input (Le., Btu/hr from
the primary fuel versus all fuels) or the mass
feed rate (Le., Ib/hr of the primary fuel versus
all fuels), depending on which method results in
a lower mass hazardous waste feed rate.
The primary and hazardous waste fuels have a
minimum as-fired heating value of 8,000 Btu/lb.
Boiler load (actual at any time versus design or
maximum firing rate) is always 40% or greater
of full load on a Btu basis.
The hazardous waste is fired directly into the
primary fuel flame zone.
The HRA stack gas CO concentration is < 100
ppmv (on a dry basis corrected to 7% O,). The
device is not eligible for the alternative
standards for HC emissions if the BEF falls
under this waiver.
The waste does not contain nor is it derived
from acutely hazardous (dioxin-listed) wastes
listed under {26131 (specifically, the waste
streams F020, F021, F022, F023, F026, and
F027, which are related to the manufacture,
disposal, and use of chlorophenols,
chlorobenzenes, chlorohexanes, and
hexachlorophene).
The boiler must be a watertube type that does
not feed fuel using a stoker or stoker type
mechanism to feed the waste (see Appendix A
for a description of boiler types and fuel-firing
The viscosity of the waste fuel, as-fired, must be
.< 300SSU.
The wastes must be atomized by the nozzles to
the following minimum specifications depending
on the method of atomization:
must pass through 200-mesh
(74 microns) screen; or
Rotary cup. At least 70% must pass
through 100-mesh (150 microns)
screen.
Bff\SEcno.BlF
10-21
-------
10.6J Data Submitted in Lien of Trial Burn
In general, a facility has to conduct a trial burn
to demonstrate compliance with emissions standards and
to obtain a permit The BIF Rule allows an
owner/operator of a BIF unit to submit data from a
similar BIF in lieu of a trial burn for the untested unit;
however, in EPA's experience with incinerators, this is
a difficult waiver to obtain. Parameters that must be
compared are those listed in Table 10-1 Data in lieu of
a trial burn can be used under the following conditions
as specified in |27022(a)(6):
• The plan to use such data must be approved by
the Director.
• The information must provide a comparison of
the two units and show similarity of:
- Hazardous waste feed and other feed
streams;
- Design; and
— Operating conditions.
A comprehensive discussion on the
determination of similarity is provided in Section 5.0.
The similarity required to waive the permit trial burn is
generally the same as the similarity required to waive
the interim status compliance test, with the following
exceptions:
1. The similar BIF from which data will be used
for the trial burn waiver does not have to be
located at the same site as the untested BIF.
1 Previous data from the same BIF (e.g.,
compliance test data) may be used.
3. At the discretion of the Director, similarity
requirements may be relaxed to include
-------
11.0 MANAGEMENT OF RESIDUE
Owners and operators of regulated BDFs are
subject to the same hazardous waste identification and
listing criteria and requirements under 40 CFR Part 261
that apply to other hazardous waste treatment, storage,
and disposal facilities. Under RCRA regulations, waste
(residue) derived from the treatment of listed hazardous
waste is also considered hazardous until and unless it is
delisted (40 CFR 2613(c)(2) and (d)(2)). In this
discussion, residue refers to the wastes or unmarketable
products of combustion and is differentiated from
marketable products. Combustion or processing of
hazardous waste in BIFs is considered to be a type of
treatment, regardless of the type of combustion device
or the purpose of the burning; therefore, residue
generated from the burning of listed hazardous waste in
BIFs remains listed hazardous waste, except for residue
excluded under the Bevill amendment, as discussed in
Section 11.1 below.
11.1
Residue Excluded Under the Bevill Amendment
Under the Bevill amendment [RCRA Section
3001(b)(3)(A)(i-iii)], certain residues are excluded from
being considered hazardous waste pending completion
of special studies by EPA to determine whether they
should be regulated under RCRA Subtitle C. These
residues are:
• Specified residue generated from the
combustion of coal or other fossil fuels;
• Solid waste from the extraction, benifitiation,
and processing of ores and minerals; and
• Cement kiln dust
Subject to conditions given below, the BIF Rule
retains the Bevill ynfhn««p« for residues from the
following devices:
• Boilers burning primarily coal;
• Industrial furnaces processing primarily normal
ores or minerals; and
• Cement kilns processing primarily normal raw
materials.
The Bevill exclusion takes precedence over the
"derived-from" rule under §2613(c)(2); that is, residue
that is excluded under the Bevill amendment is not
considered a hazardous waste at this time, and therefore
is not subject to the RCRA hazardous waste
management standards (including the Land Disposal
Restrictions) as long as the burning or processing of
hazardous waste does not significantly affect the
character of the residue.
To determine whether the character of a
residue has been significantly affected by the burning or
processing of hazardous waste, and therefore whether
the Bevill exclusion can be claimed, a two-part test, the
so-called "Bevill test,* is required under the BIF Rule.
The residue is eligible for the Bevill exclusion as long as
it passes either part of the test. Pan One may be used
for some compounds, and Part Two for others.
11.1.1 Part One of the Bevill Test
Under Part One of the Bevill test,
concentrations of all 40 CFR Part 261, Appendix Vffl
toxic compounds reasonably expected to be present in
the hazardous waste, as well as all Part 266, Appendix
Vm compounds (PICs) that may be generated as
products of incomplete combustion, must be analyzed in
the waste-derived residue and compared to baseline
concentrations in normal residue (generated by the BIF
without the burning or processing of hazardous waste)
to determine whether the residue has been "significantly"
affected by the burning or processing of the hazardous
waste.
A statistical test is used to compare these
constituent concentrations in the hazardous waste-
derived residue to the baseline concentrations. The
upper tolerance limit at 95% confidence with a 95%
proportion is established for constituents of concern in
the baseline (normal residue). The statistical test is
described in Appendix DC to the BIF Rule as revised by
an August 27, 1991 Technical Amendment (56 FR
42509). Additional statistical guidance, including
procedures for handling nondetect values, is provided in
Reference 31.
11.L2 Part Two of the Bevill Test
Under Part Two of the Bevill test,
concentrations of toxic constituents in the hazardous
waste-derived residue are compared to constituent
health-based limits contained in 40 CFR Part 266,
Appendix Vn. A comparison is made to determine
whether toxic compounds in the hazardous waste-derived
BIF\SECT11.BIF
11-1
-------
residue are present at levels higher than the health-
based limits. The toxic constituents of concern are the
same as those in Part One of the test, that is Part 261,
Appendix Vm and Part 266, Appendix VIQ compounds.
For nonmetals, the toxic concentration of each
constituent in the residue is compared to the health-
based limit for that constituent For metals, however,
the concentration of each toxic constituent in the
Toxicity Characteristic Leachate must not exceed the
health-based limit for that constituent For Pan 261,
Appendix Vm nonmetal compounds for which adequate
health effects data are not available, the Agency has
conservatively set a health-based limit, based on total
concentration (rather than extract concentration), of
0.002 ug/kg for such nonmetals.
1L2 Sampling of Residue
Normal residue should be characterized by
analyzing 10 samples that represent a minimum of 10
days of operation. The 10 days need not be consecutive
days. Composite samples may be used for analysis;
however, the compositing period may not exceed 24
hours.
Hazardous waste-derived residue must be
characterized by analyzing 1 or more samples
composited over a period not to exceed 24 hours.
Multiple samples may be analyzed, or multiple
subsamples may be taken to form a composite sample,
provided the sampling period does not exceed 24 hours.
General guidance on compositing normal and
hazardous waste-derived residue samples is provided in
Chapter 13 of SW-846 (16), which describes waste and
effluent sampling and analysis for incinerator permitting.
These sampling procedures are also applicable to
compositing residue sampks required by the BIF Rule.
According to these procedures, a composite sample
must be formed from a «"«"«"m of 4 subsamples "that
provide integration over both the depth and the surface
area of the waste as contained [in the structure].' The
same strategy also applies to sampling ash and residue.
'reasonably expected* by documenting the hazardous
waste composition and providing waste analysis results.
For example, if a facility burns a particular listed
hazardous waste, it should either analyze the hazardous
waste-derived residue for all constituents typically
associated with that waste (that appear in either Part
261, Appendix VHI or Part 266, Appendix VHI), or
should explain why a constituent would not be present
in the residue.
The recommended analytical methods for
analyzing normal and hazardous waste-derived residues
are contained in SW-846. If necessary, alternate
methods may be used, as long as the methods meet or
exceed the SW-846 method performance criteria.
When requesting laboratory analytical services,
a list of specific anarytes (Part 261, Appendix Vm
constituents reasonably expected to be present as well as
Part 266, Appendix Vm PICs) should be provided to
the laboratory by the facility, since this list may, in some
cases, include compounds not routinely analyzed bfjthe
laboratory.
The hazardous waste-derived residue must be
sampled and analyzed as often as is necessary for the
owner/operator to determine whether the residue is
excluded from or regulated under RCRA Subtitle C. If
the residue is analyzed less than daily, however, and a
subsequent analysis shows that the residue fails both
parts of the Bevill test, all residue generated since the
previously passed test will be considered hazardous
waste, and therefore will be fully regulated. If a facility
has reason to expect that a particular Part 261,
Appendix VITJ constituent is present in the hazardous
waste-derived residue, but no SW-846 method is
available to analyze the constituent, the facility must use
an alternate method to quantify the concentration of the
constituent in the residue.
Using methods from SW-846, an
owner /operator must analyze residue samples for all
Part 261, Appendix Vffl waste, as well as for all 40 CFR
Part 266, Appendix Vm PICs. The facility should be
able to support the list of compounds it selects as
Bff\SECni.BIF
11-2
-------
12.0 REFERENCES
1. American Society for Testing and Materials.
Pennsylvania.
Annual Book of ASTM Standards. Philadelphia,
2. Barton, R.G., WJD. Clark, W.R. Seeker. Tate of Metals in Waste combustion Systems.' Journal of
Combustion Science and Technology Vol. 74, pp. 327-342, 1990.
3. Beutner, H.P. 'Measurement of Opacity and Paniculate Emissions with an On-Stack
Transmissometer." Journal of the Air Pollution Control Association. VoL 24, No. 9, p. 865, 1974.
4. DeUinger, B., J. Torres, W. Rubey, D. Hall, J. Graham, and R. Games. 'Determination of the Thermal
Stability of Selected Hazardous Organic Compounds.* Ha/fj-^y* Wyfity VoL 1, No. 2, 1984.
5. DeUinger, B., W. Rubey, D. Hall, and J. Graham. 'Incinerability of Hazardous Waste."
Waste and H^rdm^ Materials. VoL 3, No. 2, p. 139-150, 1986.
6. Eicher, T. and Cudahy. E/'pf Hence Wi*^
£Hft'
Persective. Presented at
the ASME/EPA Workshop on the Control of Metal Emissions from Waste Combustion Devices. '.
November 7-8, 1991.
7. Graham, J., D. Hall, and B. DeUinger. Environmental Science Technology. Vol. 20, No. 7, pp. 703-710,
1986.
of the Thermal Destructibilitv of
8. Hall D., W. Rubey, and B. DeUinger.
Wastes Using the TDAS. United States Environmental Protection Agency, EPA/600/2-84/138, NTIS
PB 232487, 1984.
9. Hansen, E.R. "New Way to Burn Hazardous Waste.* Rock Products, pp. 41-43, April 1990.
10. Jahnke, J. Gopfouous Air Pollution Source Monitoring Systems. United States Environmental
Protection Agency, EPA/625/6-79/005, 1979.
11. MITRE Corporation. Guidance Manual for Ha*vdous Waste Incinerator Permits. EPA-SW966, NTIS
PB84-100577, 1983.
12. Omega
Inc. Complete Temperature Measurement Ha"dbook »nd Encyclopedia. 1986.
13. United States Environmental Protection Agency. "Request for Guidance in Designating POHCs.*
Region II Air tpd Water Waste Management Division. January 13, 1988.
14. United States Environmental Protection Agency.
4- Trassometer Systems: Operation a"d Maintenance. An
84/004. 1986.
15. United States Environmental Protection Agency. A/"b«?"t Monito^pg
Course. EPA 450/2-
for Prevein o
Deterioration (PSDV EPA/450/4-87/007. Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina, May 1987.
BIF
sectlZbif
12-1
-------
16. United States Environmental Protection Agency. Development of Stack Testing Procedures for
Measuring Hexavalent Chrom'||rn Emissions from Hazardous Waste Incinerators. Atmospheric
Research and Exposure Assessment Laboratory.
17. United States Environmental Protection Agency. Engineering Handbook for Hazardous Waste
Incineration. EPA-SW-889. NTIS PBS 1-248 163. 1981.
18. United States Environmental Protection Agency. Gaseous Continuous Emis-wmi Monitoring Systems -
Performance Specification Guidelines for SO,. NO.. CO.. O> TRS. EPA/450/3-82/026. NTIS PB 83-
161646. 1982.
19. United States Environmental Protection Agency. G, y*d^'pe for Petenn'^fifm of Good
Practice Stack Height rTee^n'fjd Support Docii|inent for the Stack Hf'hf Regulatio
EPA/450/4-80/023R. NTIS PB-85-225241. Research Triangle Park, North Carolina, 1985.
20. United States Environmental Protection Agency. Guidance for Fluid Modeling of
Diffusion. EPA/600/8-81/009. NTIS PB81-201410. Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina, 1981.
21. United States Environmental Protection Agency. QyitfeHne for Use of Fluid, M^yltpg *° Determine
Qft9ook on Q, yl'fy Assuranr^ytjuality Control
(QA/QO Procedures for HaMffoVft Waste Incineration. EPA/625/6-89/023. Center for
Environmental Research Information, January 1990.
25. United States Environmental Protection Agency. Hi?i"'^ous Waste Incineration Measurement Guidance
Manual. Volume in of the Hazardous Waste Incineration Guidance Series. EPA/625/6-89/021. 1989.
26. United States Environmental Protection Agency. Industrial Source Complex (ISO Dispersion Model
User's Guide. Second Edition (Revised1). Volumes 1 and 2. EPA/450/4-88/002 and EPA/450/4-
88/002D. NTIS PB-88-171475 and PB-88-171483. Research Triangle Park, North Carolina, 1987.
27. United States Environmental Protection Agency. On-Site Meteorological Progry '""? TV Meteorological Measurements. EPA/600/4-82/060.
Environmental Monitoring Systems Laboratory, Research Triangle Park, North Carolina, February
1983.
BDF
§ectl2.bif 12-2
-------
I
1
29. United States Environmental Protection Agency. Sampling ""^ Analysis Methods for Hazardous Waste
Combustion. EPA/600/8-84/002. NTIS PB89-159396. 1984.
30. United States Environmental Protection Agency. s^TMning Prf>cedures for Estimating the Air Quality
[mpact of Stationary Sources. EPA/450/4-88/010. Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina, August 1988.
31. United States Environmental Protection Agency. Statistical Analysis of Ground-Water Monitpring Data
at RCRA Facilities. EPA/530/SW/89-026. NTIS PB89-151047. Office of Solid Waste, Waste
Management Division. April 1989.
32. United States Environmental Protection Agency. Study on Benefits of Coa^nuous Opacity Monitors
Applied to Porflanift Cymant K£]ft Office of Air Quality Planning and Standards, May 15,1991.
1 33. United States Environmental Protection Agency. Supplement A to Guideline on Air Quality Models
I (Revised). EPA/450/2-78-027R. NTIS PB88-150958. Office of Air and Radiation, and Office of Air
Quality Planning and Standards, Research Triangle Park, North Carolina, June 1987.
34. United States Environmental Protection Agency. Supplement B to Guideline on Air Quality Models
(Revised). Draft. Office of Air and Radiation, and Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina, September 1990.
35. United States Environmental Protection Agency. Test Methods for Evaluating folid Wastes:
Physical/Chemical Methods. SW-846. Third Edition. Office of Solid Waste and Emergency Response,
November 1986.
36. United States Environmental Protection Agency. Vallev Model User's Guide. EPA/450/2-77/018.
i NTIS PB-274054. Research Triangle Park, North Carolina, 1977.
37. United States Government Printing Office. Code of Federal Regulations (CFR). 40 CFR Parts 60 and
266. Washington, D.C., 1991.
BIF
«ect!2.bif 12-3
-------
APPENDIX A
DESCRIPTION OF DEVICES SUBJECT TO BIF REGULATIONS
-------
APPENDIX A
DESCRIPTION OF DEVICES SUBJECT TO BIF REGULATIONS
Appendix A describes the basic technology of
devices subject to BIF regulations. A brief description
of the characteristics and operation of boilers and
industrial furnaces is provided in Sections A.1 and A^,
respectively. A representative schematic diagram of
each device and additional references on BIFs are also
provided.
AJ Boilers
A boiler is an enclosed, pressurized device
constructed to produce steam or hot water for electrical
generation (utility boilers) or for on-site process needs
(industrial boilers). Boilers cover a wide range of sizes,
from small, pre-assembled (packaged) units of 1,000
Ib/hr steam capacity to field-erected boilers capable of
producing up to several million Ib/hr of steam. In 40
CFR Section 260.10, EPA defines a boiler as an
enclosed device using controlled flame combustion and
having the following characteristics:
(1) The unit must have physical provisions for
recovering and exporting thermal energy in the
form of steam, heated fluids, or heated gases.
(2) The unit's combustion chamber and primary
energy recovery section(s) must be of integral
design. To be of integral design, the combustion
chamber and the primary energy recovery
section(s) (such as waterwalls and superheaters)
must be physically formed into one
manufactured or assembled unit
(3) While in operation, the unit must maintain a
thermal energy recovery efficiency of at least 60
percent, calculated in terms of the recovered
energy compared with the thermal value of the
fuel.
(4) The unit must export and utilize at least 75
percent of the recovered energy, calculated on
an annual basis. In this calculation, no credit
shall be given for internal uses such as
preheating of combustion air or fuel, or driving
combustion air fans or feed water pumps (16).
Boilers are typically classified either by the
method of heat transfer or by the fuel-firing system
employed. The various fuel-firing classifications are
introduced in Section A.1.1. Heat-transfer boiler
classifications (watertube, firetube, and cast iron) are
described in Sections A.12, A.L3, and A.1.4,
respectively. Additional information on boilers may be
obtained in References 9,11,12, and 13.
AJJ F»d Flriflf in BoOen
The majority of boilers are fueled by coal, oil,
or natural gas. Wood, bagasse (dry sugar cane pulp),
municipal waste, industrial waste, and refuse-derived fuel
also may be used as fuel in boilers. The principal
distinction among these boilers is the fuel-firing
mechanism used. The two major types of fuel-firing
mechanisms are stoker and suspension firing
Stoker-fired boilers are designed to burn_solid
fuels (primarily coal) on a bed. Stoker firing systems
can be subdivided into three groups: underfeed,
overfeed, and spreader stokers. The fuel feed area of
an underfeed stoker boiler is depicted in Figure A-l. In
underfeed stokers, solid fuel is fed to the bottom of the
fuel bed, where moisture and volatiles are driven off and
the coal is coked. The volatiles rise through the bed
and undergo combustion above the bed. Rams force
new fuel into the bottom of the fuel bed, pushing the
coked coal to the top of the bed and out onto side gates.
The combustion air typically enters through the side
gates. In an overfeed stoker, the coal is fed onto a
moving grate that moves through the furnace chamber.
Combustion air is fed through the bottom of the grate.
"Spreader" stokers are overfeed stokers in which the fuel
is evenly spread by feeders over the fuel bed;
combustion air is provided both over and under the
grate (14).
Suspension-fired boilers can be subdivided into
single and opposed-wall-fired boilers, tangential boilers,
and cydone-fired boilers. Suspension-fired boilers
typically have the capacity to burn gas, oil, pulverized
coal, or a combination of these fuels. In single- and
opposed-wall-fired boilers, burners are mounted
horizontally on the walls of the combustion chamber.
Tangential-fired units have a square cross-sectional
shape, and burners are mounted in the corners.
Cydone-fired boilers feed the fuel and combustion air
circumferentially into a water-cooled cylindrical
combustion chamber (15).
A-l
-------
f
*
'I
•••V
-------
Watertnbe Boflm
In a watertube boiler, hot combustion gases
flow around heat-transfer tubes containing water. The
water is either heated or converted to steam and exits
t}ff tubes into common enannftU and «t».am outlets. A
watertube boiler fired by pulverized coal is depicted in
Figure A-2. Watertube boilers can either be field-
erected or packaged units with capacities ranging from
less than 10 x 10* to over 250 X 10* Btu/hr thermal
input These boilers can generate high-pressure, high-
temperature steam up to 1,750 psi and 1,000*F. With
typical thermal efficiencies of approximately 80 percent,
the steam/hot water production capacity of watertube
boilers ranges from 10,000 Ib/hr to over 250,000 Ib/hr.
Watertube boilers may burn coal, oQ, gas, and other
fossil and nonfossil fuels. Packaged watertube boilers
typically use only oil and natural gas, while field-erected
watertube boilers can accommodate virtually aD fuels
(4, 14).
AX3 Firetube Boilers
In firetube boilers, hot combustion gases flow
through the inside of tubes while the water, steam or
other fluid to be heated flows outside and around the
tubes. A schematic of a common type of firetube boiler
is presented in Figure A-3. Firetube boilers are usually
limited to less than 30 x 10* Btu/hr thermal input The
upper pressure limits on firetube boilers range from 150
to 250 psig. Firetube boilers typically have substantially
smaller capacities than watertube boilers; nearly all
firetube boilers are packaged units and primarily oil- or
gas-fired.
Firetube boilers constitute the largest portion of
small- and medium-sized industrial boilers. Depending
on the tube orientation, most industrial firetube boilers
currently available can be subclassified as either
horizontal return tube (HRT), Scotch marine boilers,
firebox, or vertical boilers (14).
AX4 Cast ITM Batten
Cast iron boilers utilize irregularly shaped heat
exchangers and hence cannot be classified as either
watertube or firetube. Combustion gases are directed
through some of these passages, transferring heat
through metal walls to water or another fluid in adjacent
passages. Cast iron boilers have a smaller capacity than
watertube and firetube boilers, with a maximum capacity
of 10 X 10* Btu/hr thermal input (1). The pressure
Emits range from 15 to 100 psi for steam and hot water
units, respectively (14). Cast iron boilers are typically
used for producing low pressure steam or hot water for
commercial or institutional establishments (4).
AJ Industrial Furnaces
EPA defines industrial furnaces as those
designated devices that are an integral part of a
manufacturing process and that use thermal treatment
to recover materials or energy (40 CFR 1260.10).
Twelve devices are designated as industrial furnaces:
cement Mnc- Km» Kins; aggregate loins (including light.
weight aggregate kirns and aggregate drying kilns used
in the asphaltic concrete industry); halogen acid
furnaces; phosphate kflns; coke ovens; blast furnaces;
«m*ltifig melting, and refining furnaces; titanium dioxide
chloride process oxidation reactors; methane reforming
furnaces; pulping liquor recovery furnaces; and
combustion devices used in the recovery of sulfur values
from spent sulfuric acid. The majority of the regulated
industrial furnaces are comprised of cement kilns, time
Hint light-weight aggregate Hin^ asphalt drying Hin^
blast furnaces, halogen acid furnaces, sulfur recovery
furnaces, and coke ovens. These devices are described
in Sections A2.1 through A2£, respectively. r r
•
•>
AJ.1 Cement Kilns
Rotary cement kilns are inclined rotating
cylinders, refractory lined and internally fired, to calcine
a blend of raw materials (e.&, limestone, clay, shale, and
iron ore). Figure A-4 presents a schematic flow
diagram of a straight rotary cement kiln. Cement kilns
range from 60 to 760 feet long and 6 to 25 feet in
diameter (15). They are constructed of steel <^f'"g«
lined with refractory brick. The kiln is inclined (3-8*)
and rotates at approximately 1 rpm on its longitudinal
axis. Raw materials are fed into the upper end, while
fuels are typically fed into the lower end so that the flow
of exhaust is countercurrent to that of feed material.
The raw materials begin to soften and fuse at
temperatures between 2£50 and 2,700*F to form the
clinker product The clinker is subsequently cooled,
ground, and mixed with other materials to form
Portland cement The average wet process kiln has a
capacity to produce 260,000 tons of clinker per year.
The dry process kilns have an average capacity of
360,000 tons of conker per year (5). KUn emissions are
typically controlled by fabric filters or electrostatic
precipitators (ESPs).
Cement may be produced by two processes, a
wet and dry process. In the wet process, the raw
materials are ground into a slurry containing 30% to
35% water and fed into the kiln. In the dry process, raw
materials are ground dry and fed into the kilns. Wet
A-3
-------
STEAM
OUTPUT'
COMUSIKM AM
FlfutA-2. MmtedCwl-FlredWitBtBbeBaffcr
-------
flfare A3. FMr-Pan Flrctabe Bolter (7)
A-S
-------
TO AIR
POLLUTION
CONTROL
SYSTEM
BACK END
FRONT END
FIRING HOOD
3-—FUEL
COOLING
GAS FLOW
— SOLID/LIQUID
A-4. Schematic Flow Diagram of • Straltht Rotary Kiln
-------
process plants use longer kilns (450-750 ft) to obtain the
necessary heat transfer for water evaporation. Kiln
length at dry process plants depends on whether a
preheater and/or precalciner is used (5).
Cement kiln configurations are typically of three
forms: (1) rotary kiln only, (2) rotary kiln with
preheater, and (3) rotary kiln with preheater and
precalciner. Figure A-5 presents a schematic flow
diagram of a cement kfln with a preheater. A preheater
system uses kiln exhaust gas to raise the solids
temperature and partially calcine the charge prior to
feeding the solids into the rotary kiln. A precalciner is
otially a suspension preheater that is equipped with
an auxiliary firing system attached to the lower stage of
the preheater tower. A kiln equipped with a precalciner
produces 50-70% more clinker than a kiln of equal
diameter equipped with a conventional preheater (10).
Additional information on cement loins maybe obtained
in References 3, 8, 10, and 18.
Unw Kilns
The calcination of limestone to lime occurs
similarly to Portland cement production, as described in
Section Ail, except that lime (CaO) is only an
intermediate in cement production. Although a variety
of kiln types can be used (e.g. rotary, fluidized bed,
vertical shaft, and rotary hearth kilns), about 90% of
lime producers use the rotary kiln (see Figure A-4) (5).
Lime kiln sizes may reach 500 feet long and 17 feet in
diameter (15). The kilns are operated at maximum
temperatures of 1,800 to 230CTF and are typically sloped
3-5*. The average fuel requirement for the heat of
reaction is 7 x 10* Btu/ton. Kiln production rates range
from 250 to 2^00 tons/day (5). Coal accounts for
almost 70% of the fuel used in lime production; natural
gas is used for 23%; oil, liquified petroleum gas (LPG),
electricity, and other fuels comprise the remainder.
Emissions from lime kirns are commonly controlled with
fabric filters, ESPs, and venturi scrubbers.
A13 Ufht.Weight Aggregate (LWA) Kilns
The term light-weight aggregate' applies to a
range of special use aggregates which have a specific
gravity well below normal sand and gravel (5). These
aggregates may be used in concrete in place of sand and
gravel or stone, resulting in a concrete of the same
strength but weighing approximately one-third less than
concrete.
The LWA Itiln is similar to those used in the
fime and rotary cement kiln processes as described in
Sections AJL1 and A.2,2, respectively. LWA kilns are
typically between 120 to 300 feet long, 7 to 10 feet in
diameter, and refractory lined. The raw material
(typically day, shale, or slate) is crushed and introduced
at the upper end of a rotary kiln (sloped 3-4*). In
pttf'iig through the lpi"t the materials reach
temperatures of 1,900 to 2,100*F. Internal gases cause
the material to expand and are retained in the material
when it cools and K»n«ti
-------
4TH STAGE
(SEPARATING)
CYCLONE
BUCKET
ELEVATOR"
TO AIR
POLLUTION CONTROL
SYSTEM
ROTARY FEEDER
RAW MATERIAL
1ST STAGE
CYCLONE
2ND STAGE
CYCLONE
3RD STAGE
CYCLONE
KILN
C
TO AIR
POLLUTION CONTROL
SYSTEM
AIR QUENCHING COOLER
Figure A-5. Schematic Flow Dtagraai of a Rotaiy Cencat Kiln and
-------
COAWC m .
AtCUCCAU V7
«inMC* >*-*
PILE
FEEDER*-^ - -
EXHAUST TO
AIMSPHERE
FMC
ACCfttGAIC
STMMGE
MtE
MJOIM.L
AO MJECTION
AJLfTORAQE
* ^^^J -
GAS FLOW
Figure A-6. Topical Batch-Mix Asphalt Concrete Plant (5)
-------
f
\
f
The combustion zones in both the batch-mix
and drum-mix drying M**« are f"««iay The flame is
short and releases sufficient heat to raise the
temperature of the aggregate to approximately 300*F.
Combustion zone temperatures are typically in carets of
1^00*F. Emissions from the aggregate drying kQns are
commonly controlled by fabric filters or scrubbers.
AU5 Blast Furnace Systems
A blast furnace is a vertical shaft furnace that
nses carbon in the form of coke to reduce iron oxide
ores to pig iron for use in the iron and steel industry.
Raw materials (primarily iron ore, coke, and limestone)
and energy are supplied to the furnace and molten iron
and slag are withdrawn by several major auxiliary
equipment hems which may be arranged as depicted in
Figure A-7 (5).
Blast furnaces vary in size from approximately
90 to 150 feet in height and 17 to 45 feet in diameter
(2). Capacities typically range from 500 to 7,000 tons of
iron product per day (6). Temperatures in the
combustion zone are approximately 2,800*F. A blast
furnace is a vertical, cylindrical structure composed of a
top section, an inwall, a bosh, and a hearth. The solid
raw materials, commonly termed "burden", are charged
into the top of the blast furnace. Hot gases rising from
the lower sections of the furnace dry and preheat the
burden in this top section. The top gas is also
frequently used as fuel for preheating stoves, on-site
boilers, coke ovens, reheating furnaces, or internal
combustion engines. These preheated combustion gases
enter the hearth, the lower section of the furnace,
through nozzles, tuyeres". Frequently, hydrocarbon
additives or oxygen may be injected through the tuyeres.
Presently, the fuel oil is also injected through the tuyeres
(17). The main section of the furnace, where iron
oxides are reduced to free iron, is known as the inwall.
This section extends outward from the top of the bosh
section. Coke luiuboslioo occurs in the bosh section
which extends from the widest part of the inwall down
to the tuyeres. A manifold, commonly termed a "bustle
pipe*, often encircles the bosh section of the furnace,
directing hot air from the furnace stoves to the tuyeres
around the perimeter of the hearth. The iron product
formed in the upper sections of the furnace accumulates
in the hearth and is periodically removed (5).
Air emissions from blast furnaces are typically
controlled in two or three stages to control high
concentrations of paniculate matter. First stage control
usually consists of either a settling chamber or a cyclone
to remove large particulates. Second and third stage air
emission controls are typically performed using a wet
scrubber, venturi scrubber, or ESP (5).
JLU6 Halogen Add Furnaces (HAFs)
HAFs are defined as furnaces that: (1) are
located at the site of a manufacturing process; (2)
process hazardous wastes with a minimum as-generated
(5) halogen content of 20 percent by weight to produce
an acid product with a minimum halogen content of 3
percent by weight; and (3) use the acid product in the
manufacturing process (16). HAFs are typically
modified firetube boilers which process chlorinated or
brominated secondary materials with 20 to 70 percent
halogen content (by weight) to produce an acid product,
either hydrogen chloride (HO) or hydrogen bromide
(HBr) by scrubbing acid from the combustion gases.
HAFs that generate and export steam meet the
of a boiler under 40 CFR 1260.10 and thus
wul be regulated as boilers. The halogen acid product
has a halogen content that ranges from 3 to greater than
25 percent by weight. Most halogen-bearing materials
reclaimed in HAFs are burned partially for energy
recovery because substantial usable heat energy is
released by the materials during combustion. The
materials typically have an as-fired heating value of
approximately 9,000 Btu/Ib, and the heat released
results in thf thermal degradation of chlorinated organic
compounds to form HQ or HBr (16).
AJ.7 Sailor Recovery Systems
Sulfur recovery furnaces are employed to
recover sutfuric acid from used ("spent") sulfuric acid
and other sulfur-bearing wastes. The spent acid is
commonly contaminated with water, organic*, inorganics,
and other materials from process use. In the recovery
furnace, the spent acid and/or other sulfur-bearing
wastes are thermally decomposed into sulfur dioxide
(SOj), carbon monoxide (CO), carbon dioxide (COj),
and water vapor. Heat for the acid decomposition is
provided by banting natural gas, oil, or a liquid or
gaseous waste stream. Feed stream rates are controlled
to achieve 8 to 14 percent SO, in the exhaust gases;
temperatures may reach 2,000*F (5). Typically, the
furnace is a horizontal, cylindrical, refractory-lined
chamber which may be 40 feet long and 14 feet in
Aitrnftrr A schematic of a typical sulfur combustion
furnace is presented in Figure A-8.
Furnace rxhtust gases are cleaned and then
passed through converted catalyst beds to recover the
sulfur. Auxiliary equipment includes two stages of
emissions controls; pre-converter and post-convener
controls. Pre-converter controls remove particulates,
metals, and hydrogen chloride (Hd) prior to the
A-10
-------
RON CUE—i
UMESTONE-
COKE—•
SLAG LAOLE
•LAST
rURNACC
OUST CATCHER
I-CAS WASHER
STOVES
-STOVE
STACK
RON LADLE
r BYPASS
STACK
APCO
Flgnre A-7. Blirt Fnrnicc with Awdllaiy Equipment (5)
-------
MY MM
-aKNTAOD
-sum*
-FUGLOL
MS OUTLET
I
"
Figure A-*. SvlAir Conbrndon Fornice
-------
exhaust gases entering the converted catalyst beds to
avoid contaminating or plugging the catalyst beds. Pre-
converter controls on be cyclones, scrubbers,
electrostatic precipitaton, or gas dryers. Downstream of
the converter bed, the exit gases are controlled to limit
of SO2 and acid mist Post-converter controls
for SO, can be alkali absorption systems, sodium suttate
to bisulfate scrubbers, or ammonia scrubbers. Controls
for acid *"»«* include electrostatic precipitaton, packed
bed scrubbers, and molecular sieves (17).
A-Z4 Coke Ovens
Coke ovens are industrial furnaces in which
industrial coal is carbonized. A coke oven typically
consists of many narrow chambers arranged side by side
and separated by walls of silica brick. The walls contain
heating flues in which combustion gas is burned to
provide heat for carbonization. Thus, the coal in the
ovens is indirectly heated through the silica brick walls
(7)-
A schematic of a common type of coke oven is
presented in Figure A-9. Dimensions of a typical coke
oven are 40 feet long and 10 to 20 feet high. At the top
of one or both ends of the oven, refractory-lined
standpipes conduct the volatile carbonization products to
a horizontal collecting main which conveys the products
to the chemical recovery plant. Spent combustion gases
from the heat flues enter the regenerators under the
ovens where most of the residual heat is given up. The
flue gases then pass into the stack flue and out of the
system. Wall temperatures in the oven chamber may
reach 2^00*F, and coking time is 16-22 hours for the
manufacture of blast-furnace coke and 24-36 hours for
the manufacture of foundry coke (7).
A-13
-------
Vtntiltting rir duet
I I I I
Stetion through fkM Mil Section tfwough own vtd ng*mritar
Through
Figure A-9. 6-m High Koppen-Becker Combination Undeijet Coke Oven (7)
A-14
-------
REFERENCES
2,
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14
15.
16.
17.
18.
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BVound Tnformadon
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of Hi«wdous Wastes in Boilers and Industrial Furnaces. VoL L January 1987. NTIS PB-87- 173829.
U.S. Environmental Protection Agency. Pen°H Writer's Guide to Test Burn Data: Hazardous Waste
Incineration. Office of Research and Development Washington, D.C EPA Publication No. EPA-625/6-86/012.
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Devitt, Tn et al. The Population and Characteristics of Industrial and Commercial Boilers." PEDCo
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P'jmipy of Ht^rdous Wastes in Boilers and Industrial Furnaces. VoL n. January 1987. NTIS PB-87- 173837.
» *
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Directory of Iron and Steel Works of the U.S. and Canada. Published by the American Iron and Steel Institute.
Washington, D.C. 1984.
Greenberg, J. Industrial Furnaces, Ovens, Kilns, Dryers, Boilers, Incinerators.* Seminar Presented by AT.
Kearney Inc. to the U.S. Environmental Protection Agency, rhuaimati^ OH. February 26, 1981.
yjrt.Qthtner Encyclopedia of Chcf'Ta] Tfflbf^TtYi Third Ed^ Volume 6. Wiley-Interscience. 1979.
Peray, Kurt E. The Rotary
Koolhaas, B. and Ltfr«*«n. O.
Verein Deutscher Zementwerke
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Kill* 2nd Edition. New York: Chemical Publishing Co, Inc, 1986.
Handbook. Berun: Baoverlag GMBH, 1983.
Ty^bp"iogv of Cement Mmfotfunjg Berlin: Bauverlag,
Duda, WJ1 OgmCTt-Data-Booki International Process E3gjggenj}g_jn_the Cement ^"dustrv. Methods of
Cylqidftion. Ftonaulas, PitgriTn^ii ^yfllTfi^ Tables. Berlin: Bauverlag, 1977.
Singer, J.G., Editor. Combustion: Fossil Power Systems. Connecticut: Combustion Engineering, Inc, 1981.
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nfnrmation. Volume
North American Manufacturing Co. North Am^ "<^»" Co^nbustion Handbook. Second Edition. Cleveland, 1978.
Steam /Its Generation and Use. New York: Babcock & Wilcox Co, 1975.
A-15
-------
i
I
APPENDIX B
SAMPLE PRECOMPLIANCE CERTIFICATION FORMS
-------
APPENDIX B
SAMPLE PRECOMPLIANCE CERTIFICATION FORMS
Precompliance Certification Forms PC-1
through PC-8 are cample forms which an
owner/operator can use to certify precompliance with
the interim status requirements of |266.103(b). Use of
these particular forms is not mandatory. The forms are
intended to assist the BIF owner/operator in providing
the information prescribed in |266.103(b)(2) for
precompliance or revised precompliance certification. If
multiple BIFs burn hazardous waste at a site, the
information prescribed in |266.103(b)(2) must be
submitted for each unit
Not all of the forms are applicable in all cases,
and in some situations only portions of a particular form
should be completed. The attached •ffc«<*ii€t of
Required Precompliance Certification Forms' is
provided to assist in determining which forms are
appropriate in particular situations. Additionally, the
sample forms provided are largely based upon a
scenario in which the air pollution control system
(APCS) and stack are unique to the BIF unit The
owner/operator or permit writer may need to modify
the forms to accommodate situations in which an APCS
or stack is shared by more than one BIF unit (or
conversely, one BIF unit utilizes more than one APCS
or stack). For industrial furnaces which recycle
particulate matter, sample forms (including the
precompliance form) and instructions are found in
Appendix E. For industrial furnaces feeding hazardous
waste at any location other than the product discharge
end of the device, the information on sample form PC-8
(contained in this appendix) must be submitted. A
description of the sampk forms and a summary of the
required information are provided below. The
owner/operator is directed to §266.103(b)(2) for a
complete listing of the information required for
precompliance certification.
Form SOB-1: Notification of Small Quantity Burner
EjgniDtion
Form SQB-1 may be used for the one-time
Small Quantity Burner Exemption Notification. The
form will assist the owner /operator in determining the
allowable quantity of hazardous waste to be burned at
the facility under this exemption. The number and type
of units that wul be "Curing the exemption must be
noted on the form. The calculations for the terrain-
adjusted stack height and the resulting allowable
quantity of hazardous waste to be burned must be
provided for each applicable device. Facilities burning
hazardous waste prior to August 21, 1991 must have
submitted this information prior to that date. Facilities
burning hazardous waste after August 21, 1991, must
submit the information prior to burning hazardous
waste.
Form PC-1: Certification of Allowable Feed Rates
Prior to Compliance Testing
Form PC-1 can be used to provide geoeral
facility information, including the EPA facility** ID
number, name, address, and contact person, and a listing
of the hazardous waste combustors at the facility. The
type and size of the BIFs must be noted, and the air
pollution control system (APCS) must be described.
Also as part of this information, a scaled plot plan of
the entire facility must be attached, along with various
equipment schematic drawings. The signature of the
owner /operator is required to certify the truth, accuracy,
and completeness of the certification of precompliance.
Form PC -2; Calculation of Estimated Uncontrolled
Emissions for Each Feed Strr^nr for Compliance with
the PM. Metals. HCL and CL S*
If the owner /operator chooses to comply with
the Her n or Tier m metals or HCl/Qj emissions
limits, Form PC-2 can be used to calculate estimated
uncontrolled emissions for a single feed stream, as
required by f266.103(b)(2)(ii). If complying under Tier
I or adjusted Tier L Form PC-2 is used only to
determine compliance with the PM standard. A
separate form must be completed for each feed stream
of each unit If the unit operates under different modes
(see 523.7), a separate form must be submitted for
each feed stream of each unit under each operating
mode. Each of the operating modes should be
distinguished by a separate letter code (e-g. Mode A and
Mode B). The feed stream must be described, and it
must be noted whether the stream is pumpable or
B-l
-------
CHECKLIST OF REQUIRED PRECOMPLIANCE CERTIFICATION FORMS
APPLICABILITY
Small Quantity Burners
AH Precompliance Facilities
Precompliance Facilities Using Tier 1
.,.. . .. .
Precompliance Facilities Using Adjusted
Tier I Based on Screening Procedure
(Single Stack)
Precompliance Facilities Using Adjusted
Tier I Based on Screening Procedure
(Multiple Stacks)
,. a -Kt' 11 • *j- J
Frecompiunce Facilities Using Adjusted
Tier I Based on Dispersion Modeling
Precompliance Facilities Using Tier II
REQUIRED FORMS
• SQB-1
• Worksheet 1 (Appendix H)
• PC-1
• PC-2
• PC-3
• PC-4
• PC-5
• PC-6
• Worksheet 1 (Appendix H)
• PC-7
• Chapter 5 Worksheets
(Appendix IX to the rule)
• PC-4B
• Chapter 5 Worksheets
(Appendix DC to the rule)
PC-4C
PC-7
PC-2
PC-3
PC-4
Worksheet 1 (Appendix H)
PC-5
RELEVANT PORTION OF REQUIRED FORM
• Entire Form
• Steps 1, 3, 4 and 5
• Entire Form
• Items 1, 2, 3, and 4;
Item 5 - Entire 'Feed Rate* Column;
Item 5 - Entire *Ash/PM* Line;
Item 6 - If engineering judgement is used.
• Item 1
Item 2 - Entire "PM" Line;
Item 3 - If engineering judgement is used.
• Entire "PM* Line
• Entire Total Feed Streams* Column;
Entire Total Hazardous Waste Feed Streams* Column.
• Entire Form
• Entire Worksheet
• Entire Form
• Steps 1-7
• Entire Form
• Entire Worksheet
Entire Form
Entire Form
Entire Form
Entire Form
Entire Form
Entire Worksheet
Entire Form
K»
NRJ/NW-048
-------
CHECKLIST OF REQUIRED PRECOMPLIANCE CERTIFICATION FORMS
(Continued)
APPLICABILITY
Precompliance Facilities Using Tier III
Based on Screening Procedure (Single
Stack)
PnMvimnlMiuw PanKtiM I (MM Ttfr III
rleCOmpUaDCG racinuea USIug IHSI iii
Based on Screening Procedure (Multiple
Stacks)
Precompliance Faculties Using Tier III
Based on Dispersion Modeling
. t. ...... _
Precompliance Industrial Furnaces That
Recycle Particulate Matter
Precompliance lodusttiu Furnaces That
Peed at Other Than the Product
Discharge End
REQUIRED FORMS
• PC-2
• PC-3
• PC-4A
• PC-4
• Chapter S Worksheets
(Appendix IX to the rule)
• PC-5
• PC-2
• PC-3
• PC-4B
• Chapter S Worksheets
(Appendix IX to the rule)
• PC-5
• PC-2
• PC-3
• PC-4C
• PC-4D
• PC-4
• PC-5
• AM 1 (Appendix F)
• PC-8
RELEVANT PORTION OT REQUIRED FORM
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Steps 1-7
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Entire Worksheet
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Entire Form
• Entire Form
NW/NW-048
-------
nonpumpable. The firing system used with the feed
stream must also be noted. To estimate uncontrolled
feed rates for ill constituents must
be fisted. The factor for partitioning to the combustion
gas and the basis for the factor (either supportable
engineering judgment or EPA-prescnbed default values)
must be indicated for each constituent The use of
judgment and the default •*ayyp*V*tt for
determining partitioning factors are
Section 3.5 of this document. If engineering judgment
is used to determine any of the p"*itimri^£ factors, the
basis for the judgment must be described and certified
by a registered professional engineer. ^^"1^""' must
be reported in gr/dscf for PM and in g/hr for aO other
Form PC-3; Calculation of T(ftfi F-ff*V •ted Controlled
Emissions for Complianot with the P^* Stfflltfll*'4 B**4
Tier II or III Metals. HCL and CL $*»i»dards
When complying with the PM standard and the
Tier n or m metals and HCl/dj standards, Form PC-3
can be used to document and calculate controlled
emissions, as required in |266.103(b)(2)(iv). A separate
form must be submitted for each mode of operation for
each unit. The total estimated uncontrolled emissions
are calculated by summing the product of the feed rate
and the partitioning factor for each constituent (reported
on Form PC-2). The estimated APCS removal
efficiency (RE) for each constituent and the basis for
each (either supportable engineering judgment or EPA-
prescribed default values) must be documented. The
use of engineering judgment to determine an APCS RE
is discussed in Section 3.5. The procedures for
determining default values for APCS RE are discussed
in Section 8.0 of Appendix DC to the rule. As with the
partitioning factors, if engineering judgment is used to
determine any APCS RE, the basis for this judgment
must be described and certified by a registered
professional engineer. Once the APCS RE has been
determined for each constituent, the estimated
controlled emission rate is calculated by multiplying the
estimated uncontrolled emission rate by 1 - APCS
RE/100.
Form PC-4: Comparison off?*** Allowable Emission
Rates to Total Emission Rates for Compliance with the
PM Standard and Tier I! or HI Metals. HCL and CL
When complying with the PM standard and the
Tier H or ID metals and HQ/dj standards, a
comparison of allowable emission rates and estimated
emission rates must be made, as required in
|266.103(b)(2)(vi). The comparison must be made for
each mode of operation for each unit If Form PC-4 is
used to provide this information, the allowable emission
rate for each constituent and the basis for determining
die allowable emission rate (Tier n, Tier m, or existing
permit) must be listed. Emission Kmitt based on Tier n
are listed in reference tables provided in Appendices I
through HI of Part 266 to the rule. Tier m emission
limits must be determined by conducting dispersion
modeling, and then using the results to back-calculate
allowable *»«««"" rates from the applicable RAC and
RSD values. The RAC and RSD values are listed in
Appendices IV and V to the rule. If the facility has an
y**Tf*1>g permit and the permit limit for any constituent
is more stringent than the allowable emission rate under
this rule, the permit Emit is the allowable emission rate.
Once the total allowable emission rates are
determined, the total estimated controlled e»"««t">n rates
must be compared to the allowable rates to deteriadne
whether the facility is in compliance with the emission
standards. For facilities complying with Tiers n or m,
the total ffthnatfd ffyptrollfd emissions transfer from
those calculated on Form PC-3. For carcinogenic
metals, the sum of the ratios of the estimated emissions
to the allowable emissions cannot exceed 1.0 to ensure
that summed health risk does not exceed 1 in 100,000.
Facilities using Tier HI to demonstrate
compliance will need to complete Forms PC-4A, PC-4B,
PC-4C, and PC-4D as fpff^iH in the expanded
instructions for footnote V on Form PCM. Worksheet
1 in Appendix G provides instructions for determining
stack parameters, terrain type, and land use information.
Screening procedures adopted by the EPA's OAQPS are
described in Guidelines on Afc Quality Models (1) and
Pdrcs fo
(2)
Another alternative
screenng procedure is the Hazardous Waste
Combustion Air Quality Screening Procedure
(HWCAQSP) described in Appendix DC to 40 CFR Part
266. Guidance on obtaining meteorological data to
support these forms is provided in Section 15.1.4 of this
document If the HWCAQSP is used, site-specific
meteorological data is not required. The maximum
annual average dilution factor, determined from
dispersion modeling results or in Step 7 of the
HWCAQSP, must be provided.
B-4
-------
Form PC'S: Documentation of Feed R»*» limitt fnr
Ash. Metal*. VfQ Chlorintp During Pr*comi>M*net
Period
Form PCS can be used for esti
precompliance period feed rate Emits for Tiers II and
m.1 Feed rate limits need to be Mt«KKn»»*«i for each
mode of operation for each unit These Emits are
calculated by gumming feed rates Ested on an applicable
Form PC-2's.
form PC^i C"B^cui*tJon and Doc*|i>fPtDtlon of Tier 1
Feed lRffT l-**"its for Me**** ffl Chlorint During
Period
Form PC-6 can be used to calculate and
document feed rate limits for metals and chlorine under
Tier I for the certification of precompliance. Feed rate
Emits must be established for each mode of operation
for each unit Feed rate limits for chlorine and the
noncardnogenic metals are prescribed in reference
tables in Appendices I and n of Part 266 as a function
of terrain-adjusted effective stack height, complex or
noncomplex terrain, and urban or rural land use.
Worksheet 1 (Appendix G) provides instructions for
determining these dispersion parameters.
Documentation of the dispersion parameters must be
provided with the certification of precompliance and can
be provided using Form PC-4C.
Feed rate Emits for the carcinogenic metals,
however, cannot be taken directly from the reference
tables because the tables prescribe feed rate limits
•miming only one carcinogenic metal k fed (and
emitted). The feed rate Emit in the reference table is
based on the risk-specific dose at the 10* risk level.
Given that the rule requires that the summed risk for all
carcinogenic metals cannot exceed IVs, the feed rate
limit for a carcinogenic Beta! will be lower than that
prescribed by the reference tables when more than one
carcinogenic metal is fed. To dftfr*1***** whether the
desired feed rate for a carcinogenic metal is acceptable
(Le., will not result in a summed risk exceeding Iff5), the
sum of the ratios for all the carcinogenic metals of the
desired feed rate to the feed rate limit provided in the
reference table cannot exceed 1.0. If the sum of the
ratios does not exceed 1.0, the desired feed rate Emits
represent the precompliance period feed rate Emits. If
the sum of the ratios exceeds LO, the feed rates must be
reduced (or the owner/operator should eanyfa
complying under adjusted Tier I, Tier n, or Tier HI).
Form PC-7; Docn«n«^t»tiftn of Adjusted Tier I Feed
Kate Ui«
-------
the device to document compliance with the
requirements of }266.1Q3(a)(5)(i)(A), (B), and (C). The
owner/operator must identify each location where
hazardous waste is fed to the device. The minimum
temperature at each of these locations must be stated,
as well as the basis for determining the temperatures.
The owner/operator must also identify oxygen
requirements for combustion and oxygen availability at
each such location. The basis for determining oxygen
requirements and availability must be described. For
cement kiln systems, the owner/operator must certify
that the waste is fed directly to the kiln (not the
precakiner or preheater).
9
I
B-6
-------
REFERENCES
1. U.S. Environmental Protection Agency. Guidei'ng 9* ^'r
-------
SMALL QUANTITY BURNER FORM 1 (SQB-1)
NOTIFICATION FOR SMALL QUANTITY BURNER EXEMPTION
1.
2.
EPA facility ID Number:
Facility Name:
Contact Person:
Telephone Number
Facility Address:
3.
4.
5.
Number and Type (boiler or
industrial furnace) of Units
on-site. (If more than 3
units, list additional units at
bottom of page.)
Terrain-adjusted effective
stack height for each BIF
unit (list stack height of
additional units at bottom of
page)/
The maximum quantity of
hazardous waste that will be
burned per month for each
BIF unit (gallons/month)
#1:
#2:
#3:
#1: meters
#2: ' meters
#3: meters
#1: gal/month
#2: gal/month
#3: gal/month
f
"Supporting documentation for terrain-adjusted effective stack heights should be provided by completing and attaching
Worksheet 1 (Appendix G), Steps 1, 3, 4, and 5 only. A separate worksheet should be filled out for each BIF meeting
the small quantity burner exemption requirements.
I certify under penalty of law that each boiler or industrial furnace unit listed in this notification is
operating as a small quantity burner of hazardous waste and is in compliance with all of the
requirements of 40 CFR 5266.108.
I certify that this information was prepared under my direction or supervision in accordance with
a system designed to ensure that qualified personnel gathered and evaluated the information.
Signature:.
Title: _
Date:
NRJ/NW-048
1016-03.nrj
-------
PRECOMPUANCE CERTIFICATION FORM 1 (PC-1)
CERTIFICATION OF ALLOWABLE FEED RATES PRIOR TO COMPLIANCE TESTING
L EPA facility ID Number
2. Facility Name:
Contact Penan:
Telephone Number
Facility Address:
3. List an HWCs at facility by type
(boiler, industrial furnace,
incinerator); if matt than 3 units, Hst
additional units at bottom of page.
#1:
*£
#3:
4. Type and Size of Boiler or Industrial Furnace (e.g., 100 million Btu/hr natural gas-fired boiler
with four front-wall burners, 100 ton/hr wet process cement kiln): __
(Note: Thermal input in Btu/hr must always be stated regardless of unit type.)
5. Attach (a) scaled plot plan showing entire facility and location of unit(s) and (b) schematic
drawing showing combustor; fuel, feedstock, and waste feed systems; air pollution control
devices; continuous emission monitoring systems; and stack. Drawing should clearly indicate
location and design capacities (kg/hr) of all feed systems, and location of all CEM sampling
points.
6. Description of air pollution control device(s), including flue gas temperature (°F) at inlet to
paniculate matter control system (e.g., 3-field ESP with design PM emissions of 0.03 gr/dscf,
inlet temperature of 700°F):
r penalty o/ ftav a^at taiv auwvaiion waa prepared uader my direction or nupcrvipott m accordaacc with a
el property gathered aad evaluated the information aad supporting documentation. Copiec of aO
deaigned to ensure
that qualified pi
modeling results, aad other information vied to durrmiaf eonformance with the requirements of | V6.103(b) are available at the facility and can be
obtained from the facility contact penon acted above. Baaed on my inquiry of the penoa (or peraoat) who manage* the facility, or thcee penont
directly responsible for gathering the information, the information Mbmittad •, to the baft of my knowledge aad belief, true, accurate, aad complete.
I am aware that there are Bgnifieant penalties for MbnrttiBg fabe mformation, mcMing the poaBbffity of fine aad imprMonment for knowing
I atao ackaowledfe that the operating limitt eatabncbed m th> eextifkatiua pocuant to i 266.103OX3) aad (4) are eaforceabk mnits at which the
facility can tepUy operate during intehm «atu» until: (1) a reviled certificatioB of precomptiuce » wbautted; (2) a certification of compliance »
submitted, or (3) an operating permit m iamed.
Signature:.
Date:
Title:
NRJ/NW-Ott
100941JUJ
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PRECOMPLIANCE CERTIFICATION FORM 2 (PC-2)
CALCUIATION OF ESTIMATED UNCONTROLLED EMISSIONS FOR EACH FEED
STREAM FOR COMPLIANCE WITH THE PM, METALS, HO, AND d2 STANDARDS
Complete a separate form for each feed stream under each mode of operation for each unit
listed on Form PC-1.
1. Unit #: (see Form PC-1, Block 3); Mode (letter): ; Feed Stream #:
2. Description of Feed Stream (Include Gross Feed Rate of Feed Stream (g/hr»:
I
3. Feed Stream Characteristics (check one):
Pumpable Nonpumpable Chlorine/Hydrogen Ratio
4. Firing System (check one): Suspension-fired Bed-fired
5. Estimated Uncontrolled Emissions.
Ash/PM*
Chlorine and
Chloride
Antimony
Anenic
Barium
Bervflium
Cadmium
C^fomium
Lead
MCICUCT
Silver
Thallium
Feed Rate
fl»Rta/hrt
futitfaajoc
Factor* Sn
HQ:
CU:
Bask*
Estimated
• •
6. If any partitioning factors are based on engineering judgment, a qualified, registered
professional engineer must describe basis (attach additional sheets) and certify the following:
ttacta
I certify under penalty of law that thit document and all
eyctem designed to aanre that qualified penonnel property
nts were pupaicd under my direction or supervisee in aceordaaee with a
r and evaluate the information submitted. Baaed on my inquiry of the
penoo (or penonc) who maaafe the system, or thoae penont directly responsible for gathering the information, the mformatioa aubmitted
it, to the beat of my kBowkdge and belief, true, accurate, and complete. I am aware that there are aifnirkaat penalties for (ubmittin{ false
information, J^*UAJ*I the poatMIity of fine and impriaonmcat for knowing violation*.
Signature:
Title: _
Date:
"Enter paititionmi (to the eombuatioB pa) factors baaed OB default values or engineerinc judgment
'indicate whether partitioning factor baaed on default values (D) or on engineering judgment (E).
•Calculated estimated uncontrolled emissions using the following equations:
Ash (in gr/dsef): (FR * W) •*• Bow Rate (dacftn) x 0257
All other constituents (m g/hr): (FRxPF)
'Cement and light-weight aggrepte aims are not required to monitor ash in teed streams.
-------
PRECOMPLJANCE CERTIFICATION FORM 3 (PC-3)
CALCULATION OF TOTAL ESTIMATED CONTROLLED EMISSIONS FOR COMPLIANCE
WITH THE PM STANDARD AND HER D OR m METALS, HO, AND Qj STANDARDS
Complete a separate form for each mode of operation for each unit
1. Unit #: ; Mode Getter): (use same identification codes as on Form PC-2)
2. Estimated Controlled Emissions
Consttfueot
PM
Hd
o,
Antimony
Arsenic
Barium
Beryllium
PaiitMiiim
I, T^|f HHilllHl
Lead
Mercury
Silver
Thallium
Total Estimated ItacontroQcd
Emissions* (g/hr)
APCS RE*
Bask*
Trtal Eftunntad
Controlled Emissions'
(gr/dscf)
(g/hr)
(g/hr)
(g/hr)
(g/hr)
(g/hr)
(g/hr)
(g/hr)
(g/hr)
ffe/hr)
(g/hr)
(g/hr)
(g/hr)
3. If any APCS REs are based on engineering judgment, a qualified, registered professional
engineer must describe basis (attach additional sheets) and certify the following:
I certify under penalty of law that this document and aO attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person (or persons) who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are pgnifie^at penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations.
Signature:.
Date:
Title:
Total uncontrolled nuances for each constituent for «H feed streams (turn of
•Eater APCS RE baaed on default wines at enpneermj judgment.
"Indicate whether APCS RE bated on default values (D) or on enpaeeiiaf judgment (E).
Total Estimated Controlled Emissions - (Total Estimated Uncontrolled Furnr"-*) * f 1-APCS REY
100
fraa individual Forms PC-2).
i ted,
itroOed emisfiow (TECE) to the proper oaits as foOowc PM((r/dKf) • flECE/Flow Rate (dKfm)] x 0.2S7
NRJ/NW448
100943JU]
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PCX)
COMPARISON OF TOTAL ALLOWABLE EMISSION RATES TO TOTAL EMISSION RATES FOR COMPLIANCE WITH THE
PM STANDARD AND TIER II OR III METALS, HC1, AND Cl, STANDARDS.
Complete a separate form for each mode of operation for each unit.
Unit #: ; Mode (letter): (use same identification codes as on Form PC-2)
Constituent
PM (gr/dsd)
HCI(g/hr)
CMg/hr)
Antimony (g/hr)
Arscnk (g/hr)
Barium (g/hr)
„. f n. \
Beryllium (g/nr)
Cadmium (g/hr)
Chromium (g/hr)
Lead (g/hr)
Mercury (g/hr)
Silver (g/hr)
Thallium (g/hr)
Total
Total Aiowable
EflrinMNi RateT
Basis'
Total Estimated
Controlled Emission Rate*
Ratio of Estimated to
Allowable Emission Rate4
•
for nets* Ha aMC^lMirt
attached expanded instrvctioas.)
^rtkate whether tcrtalallowaMeenlMtofMe for each
limit ^a j.
•From Form fC-3. Cannot exceed total aloMMe emMon rote.
'Ratio of toul estimMed emisciont divided by total illoinble embsiofw.
•Sam of ratkw for individual meiab. Musi not exceed 1.0 to ensure that summed health risk does Ml eiceed 1 in
NRJ/MW-OM
I009-04.nrj
For PM .Indicate 0.08 tr/dKf or • more stringent standard tf applicable (See
'
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PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4) (continued)
COMPARISON OF TOTAL ALLOWABLE EMISSION RATES TO TOTAL EMISSION RATES FOR COMPLIANCE WITH THE
PM STANDARD AND TIER II OR III METALS, HC1, AND Cl, STANDARDS.
Expanded instructions for footnote """ -
Tier II and III allowable emission rates are determined as follows:
Tier II - Complete and attach Worksheet 1 (Appendix G). Specify allowable emissions based on the screening tables in
Part 266.
Tier 111. HWCAQSP. Single Stack - Complete and attach Form PC-4A and Steps 1-7 of Chapter 5 worksheets in Appendix IX to
Part 266. Enter the allowable emission rate from Form PC-4A.
Tier III. HWCAQSP. Multiple Stacks - Do Not Complete Fora PC-4. Complete and attach Form PC-4B and Steps 1-10 of
Chapter 5 worksheets in Appendix IX to Part 266. Document feed rates on Forms PC-2 and PC-5 for each stack.
Tier III. Dispersion Modeling - Complete and attach Forms PC-4C and PC-4D based on dispersion modeling parameters. Enter
the allowable emission rate from Form PC-4D.
•'•V
NW/NW-048
1009-
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4A)
CALCULATION OF ALLOWABLE EMISSION RATES FOR COMPLIANCE WITH THE TIER HI METALS, Ha, AND Cl,
STANDARDS USING THE HAZARDOUS WASTE COMBUSTION AIR QUALITY SCREENING PROCEDURE FOR SINGLE
STACKS.
Constituent
HC1
0,
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
RAC or RSD (ug/m*)
Dilution Factor
(ug/m'/g/s)'
Allowable
Emission Rate (g/bf)*
•Complete Steps 1-7 of Chapter 5 worksheets in Appendix DC to 40 CFR Part 266. Attach the worksheets from Chapter 5. The dilation factor is the highest maximum
annual dispersion coefficient recorded under Step 7(c).
^Calculate allowable emissions as follows:
Allowable Emissions (g/hr) - JRAC or RSD (ug/m^/Dilution Factor ["g/"1)] ,3500
L ..... (g/sccJJ '
•Attach a USGS topographic map (or equivalent) showing facility location and surrounding land within 5 km of the facility.
-------
PRECOMPLIANCE CERTIFICATION FORM 8 (PC-8)
DOCUMENTATION FOR INDUSTRIAL FURNACES FEEDING HAZARDOUS
WASTE AT ANY LOCATION OTHER THAN THE HOT END OF THE DEVICE
For industrial furnaces that feed hazardous waste for any purpose other than as an
ingredient at any location other than the hot end of the device, documentation of
compliance with the following must be submitted as part of the precompliance
certification:
(A) The hazardous waste shall be fed at a location where combustion gas
temperatures are at least 1800°F;
1. List each location where hazardous waste is fed, and minimum temperature
at that location:
Location Minimum Temperature
Describe the basis for determining the temperatures at these locations
(attach additional sheets if necessary):
(B) The owner/operator must determine that adequate oxygen is present in
combustion gases to combust organic constituents in the waste and retain
documentation of such determinations in the facility record;
3. For each location where hazardous waste is fed, list the oxygen necessary
for combustion of waste and compare that to the oxygen available:
Location % Oxygen Needed % Oxygen Available
4. Describe the basis for making these determinations (attach additional
sheets if necessary):
(C) For cement kiln systems, the hazardous waste shall be fed to the kfln (not the
precalciner or preheater).
5. Signature Date:
(if applicable)
NW/NW-048
10164)4 juj
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4B)
COMPARISON OF TOTAL ALLOWABLE AMBIENT CONCENTRATIONS TO TOTAL PREDICTED AMBIENT
CONCENTRATIONS FOR COMPLIANCE WITH TIER III METALS, HCI AND a, STANDARDS USING THE HAZARDOUS
WASTE COMBUSTION AIR QUALITY SCREENING PROCEDURE FOR MULTIPLE STACKS.
Constituent
HQ
Cl,
Antimony
Barium
Lead
Mercury
Silver
Thallium
Arsenic
Beryllium
Cadmium
Chromium
Total
Maximum Annual
Average
Concentration
C. (ug/m1)'
RAC or RSD
(ug/m>)
Ratio of Estimated
to Allowable
(Q/RACorRSD)
-
Ratio (from Previous
Column) If
More Than One
Carcinogenic Metal*
Note: Attach * USGS topographic map (or equivalent) showing facility location and furrounding land within 5 km of the facility.
•Complete Slept MO of Charter 5 worksheet* m Appendix IX to Put 266. Attach the worksheets from Chapter 5. Eater the mumwm Mimml Menp concentration. C. Ow/nt*) for each constituent from
Step 10 (I). ^ -»v-w /
*nie feed rate Hmto for each metal when feeding more than one cardnogeale metal may be the desired reed rate, protoeh that the nm oT the ratio. oT the denied amnal averate to the RAC or RSD does
not exceed t.O.
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4C)
REFERENCE INFORMATION FOR DISPERSION MODELING FOR COMPLIANCE WITH THE TIER in OR ADJUSTED TIER
I METALS, HO, AND a, STANDARDS.
Incinerator Stacks
A. Stack Parameters
Stack Height (meters)
Exhaust Temperature (*K)
Inner Stack Diameter (meters)
Exit Velocity (m/sec)
Flow Rate (cubic m/sec)
Latitude
Longitude
GEP Stack Height (meters)
B. Dispersion Modeling
Screening procedure or dispersion model/version used:
Source and date of meteorological data (e.g., NWS station name, years):
Terrain type: Complex or Noncomplex
Land Use: Urban or Rural
Maximum annual average (i.e., MEI) dilution factor (ug/mj per g/scc):_
Attach a USGS topographic map (or equivalent) showing facility location, surrounding land within 5 km of facility
and indicate MEI location with an "X."
NRJ/NW-048
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4D)
CALCULATION OF ALLOWABLE EMISSION RATES FOR COMPLIANCE WITH THE TTER HI METALS, HC1, AND
STANDARDS USING DISPERSION MODELING.
Constituent
HCi
Cla
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
RAC or RSD
(ug/m')
Dilution Factor
(ug/m'/g/s)'
Allowable
Emission Rate (g/tor)*
•From dispersioa modeling. Complete and attach Form PC-4C.
'Calculate allowable emissions as follows:
Allowable Emissions (g/hr) - |RAC or RSD (tif/m')/Dilution Factor ["g/"1]! x 3,600
I I S/«c J J
•'•7
-------
PRECOMPLIANCE CERTIFICATION FORM 5 (PC-5)
DOCUMENTATION OF FEED RATE LIMITS FOR ASH, METALS, AND CHLORINE DURING PRECOMPLIANCE PERIOD
Complete a separate form for each mode of operation for each unit. Attach Form AM-1 for industrial furnaces recycling particulate
matter,
Unit #: ; Mode (letter): ; (use same identification codes as on Form PC-2)
Constituent
Ash (e/hrV
Chlorine and
Chloride (e/hrt
Antimony fe/hr)
Arsenic fe/hr)
Barium ( g/hr)
Beryllium fa/hr)
Cadmium (e/hr)
Chromium fa/hrt
Lead (e/hrt
Mercury f e/hrl
Silver f £/hr)
Thallium fff/hr)
Feed Rate Limits
Total Feed
Streams'
Total Hazardous
Waste Feed
Streams
Total Pumpable
Hazardous Waste
Feed Streams*
Feed Rate of Total Hazardous Waste (g/hr):
Feed Rate of Pumpable Hazardous Waste (g/hr):
Maximum Production Rate of Device (in appropriate units):
(Tier II and III only)
• For aU Tien. Total for all feed streams (total all Form PC-2's).
" For Tiers II and HI only (total of applicable Form PC-2's). '
* Cement and light-weight aggregate kites are not required to monitor ash in feed streams.
MRI/NW-Ott
-------
PRECOMPLIANCE CERTIFICATION FORM 6 (PC-6)
CALCULATION AND DOCUMENTATION OF TIER I FEED RATE LIMITS FOR METALS AND CHLORINE DURING
PRECOMPLIANCE PERIOD
Complete a separate form for each mode of operation for each unit.
Unit #: ; Mode (letter): (use same identification codes as on Form PC-2)
CoMtftnent
Chlorine (Ib/hr)
Antimony (g/hr)
Barium (g/hr)
Lead (g/hr)
Mercury (g/hr)
Silver (g/hr)
ThaOium (g/hr)
Arsenic (g/hr)
Beryllium (g/hr)
Cadmium (g/hr)
r*L. • t /U \
(Jnromium {g/nr)
to* Rate Limit
from Reference
Tabled
Desired
Peed Rate
(8/kO*
Ratio of Desired
Peed Rate to
Reference Table
Peed Rate Limit*
fe/fc)
Peed Rate Limit
When Feeding Mote
Than One
Carcmogenk Metal1
(8/fc)
•Attach Worksheet 1 (Appendix O).
•Deahed feed fate • the MB of the I
PC-2 fora* Chlorine arart be converted to appropriate MN§ at foBowK CUoriae Qb/lu) • (Chtoitae Peed Rate (g/hr)/4S3A|
, the feed rate Hmta provided • the reference table* (Appendices I and It of Part 266) are baaed on a KT' cancer n* from each metal To ewme that the
a not eaeeed 10-' at required bjr 1266.106, the Mm of the ratio* of the derired feed nte divided by the reference table feed rate Hmtt for the four metab
The feed nte limit for each Metal when feeding i
limit does not exceed 1.0.
tint frOM an
not exceed 1.0.
: thaa one carciMcnk awtal may be the dedied feed late, provided that the com of the ratio* of the deriied feed rate to the reference table feed nte
NRJ/NW4MS
1009-06.nri
-------
PRECOMPLIANCE CERTIFICATION FORM 7 (PC-7)
DOCUMENTATION OF ADJUSTED TIER I FEED RATE LIMITS FOR METALS AND CHLORINE DURING
PRECOMPLIANCE PERIOD
Complete separate form for each mode of operation for each unit.
Unit #: ; Mode (letter): (use same identification codes as on Form PC-2)
CtMMtkuent
Chlorine*
Antimony
Barium
Lewi
Mercnrv
Silver
Thallium
Arsenic
...
D^aTym|IID
Cadmium
r^. •. •_:.•«•
(Jnrofflium
RACorftsb
(«8/«*)
Dirotion Factor*
(ug/m'/g/s)
Allowable Peed
Rale Limit*
(g/hO
Desired
Feed Rate*
(SAO
Ratio of Dedred
Feed Rate to
Allowable Peed Rate*
Feed Rate UmJtWbeo
Feeding More Than One
Cfednognfe Metar*
(i/hr)
•UK the foMowMf dftrtfcM factor depeadb« on the modeUac or i
UK QW dtflltMM fedOl* dctCfWil
•mfpi
i tke modelMf.
• Complete Step* 1-7 of Chapter 3 wortaheea to Appc^fa IX to tfce rate «rf attecfc tat •oiUfct m. The daadoa factor h the
coefficient recorded wilder Step 7(c).
HWCAQSr.M»HtoteSuda-D«N««IJi»PW*fC.7. UM forai FC4B iMtewl, rad AKMMM feed nte* OH POTOM rC-2 MM! rC4 for
ANombk Feed (|/hr) • RAC or RSD/DihKkMi Fbttor] 13,600
•Deilnd feed me b tke MM of tke feed rate* tnm tadMdMl PC-2 fotM.
«U«der •djwtod Tier I, MMMC dm •• cklottae b edited m CV
•1^ MM aitlnofenk MUl^ tte eniMon nte IMl bMk<»lcrfM^ lb eMmc tkM the Mmned iWt fro«
•II four meub doe* not exceed Wr», M required by 1266.106, the ram of the ntkw for the fo«r metab of the desired feed (|/hr) wte. divided by the feed nte Unit when only one cuicinofenic metab b fed
(t/hr), moil not exceed 1.0.
The feed me Hmll for each metal, when feed** more dm one eMctoofenlc wet.l, nuy be the deriretf feed nte, prodded ltu< the nm of the nitiot of the derired feed rate to the feed rate limit, wfcea on*
one cnrcmoeenk metal b fed, does not exceed 1.0. • 'V
NRI/NW-048
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APPENDIX C
SAMPLE COMPLIANCE TEST NOTIFICATION FORMS
-------
APPENDIX C
SAMPLE COMPLIANCE TEST NOTIFICATION FORMS
At least 30 days prior to the scheduled start
date of the compliance test, the owner/operator must
submit to the Director a written notice that includes all
information specified in §266.103(c)(2). Compliance
Test Notification Forms CTN-1 through CTN-4 are
sample forms which an owner/operator can use to meet
the requirements of this written notification. Use of
these particular forms is not mandatory. If multiple
units are to be tested, a separate notification should be
prepared for each unit.
Forms CTN-1 through CTN-4 (or equivalent
information in a different format) must be submitted in
all cases. For industrial furnaces which recycle
paniculate matter, Form AM-2 (form and instructions
in Appendix E) or an equivalent must be submitted in
addition to CTN-1 through CTN-4. The sample forms
provided are largely based upon a scenario in which the
air pollution control system (APCS) and stack are
unique to the BEF unit. The owner/operator or permit
writer may need to modify the forms to accommodate
situations in which an APCS or stack is shared by more
than one BIF unit (or conversely, one BIF unit utilizes
more than one APCS or stack). Provided below are
descriptions of the sample forms and a summary of the
required information. The owner/operator is directed
to §266.103(c)(2) for a complete listing of the
information required for compliance test notification.
Ipfnrmatjon
This form can be used to identify the facility by
EPA facility ID number, name, address, and contact
person. All hazardous waste BIFs, incinerators, and
other thermal treatment devices for which metals or
chlorine emissions are controlled under a RCRA
regulatory program must be listed. See {266.106 and
§266.107. Additionally, the person/company responsible
for conducting the compliance test must be identified,
and a statement of qualifications for that
person/company must be attached. The planned
compliance test date(s) and the purpose of the planned
test (initial certification, revised certification or
recertification) must be stated. Finally, the signature of
the owner/operator is required.
Form CTN-2: Unit Description
Form CTN-2 can be used to provide a
description of the BIF to be tested. A description of the
type and size of the unit, along with a description of the
APCS, is required. Also required is a scaled plot plan
of the entire facility, as well as various equipment
schematic drawings. Installed CEMs must be noted. If
an unheated HC monitoring system will be used, the
reason(s) why a heated system could not be obtained or
reliably operated for compliance testing must be
documented. An unheated system may be used onlv. for
certification of compliance within 18 months of. the
publication date of the rule; see |266.103(c)(5). Any
additional information that would be useful in
understanding the unit design or operation should also
be included. If a conflict between compliance
parameters will necessitate conducting tests at additional
conditions for a given mode (as discussed in 523.8 of
this document), the parameters in conflict and the
reason for the conflict must be listed.
Form CTN-3: Description of Planned Testing
The planned compliance test can be
summarized on Form CTN-3. If the unit operates under
different modes (see 523.7), separate documentation is
required for each test mode for each unit. Each of the
test modes should be distinguished by a separate letter
code (e.g., Mode A and Mode B). If the
owner/operator has documented a conflict in
determining parameters that necessitates testing at an
additional set of conditions for a given mode (see
523.8), separate documentation is required to describe
the additional set of test conditions. The two sets of test
conditions should be distinguished by a 1 or 2. A brief
description of the mode and test conditions should be
provided. The purpose of each test and the planned
operating conditions must be indicated. The planned
production rate of the unit during the test should be
specified in terms of steam produced (Ib/hr) (boilers
only), thermal input (Btu/lb), or raw materials feed rate
(Ib/hr). The PM control device inlet temperature must
C-l
-------
also be stated.1 Other key parameters, discussed in
|266.103(c)(l), for which operating limits will be
established during the compliance test, must also be
identified. Descriptions of the fuel, raw material, and
waste are required, including type, category, heating
value, and feeding method for each stream. Feed rates
r of ash, chlorine, and metals for each feed stream must
L also be listed.2 The information listed on Form CTN-3
must be consistent with the facility's written test
protocol The written test protocol and Quality
j Assurance/Quality Control (QA/OC) Plan must be
I included with the notification of compliance testing.
Sections 523 and 52.7 provide guidance on the contents
r of the test protocol and QA/QC Plan.
Form CTN-4: Documentation of Planned Versos
Allowable Feed Rate Limits
* Form CTN-4 compares the planned feed rates
of ash, chlorine, and metals in total feed streams, total
! hazardous waste feed streams, and total pumpable
hazardous3 waste feed streams to the levels that were
certified as allowable on Form PC-5 of the
precompliance package. A separate Form CTN-4
should be completed for each test mode of operation for
each unit. Planned feed rates for each of the three feed
stream categories are based on the information on the
corresponding Form CTN-3. Feed rates for total feed
streams, total hazardous wastes, and total pumpable
hazardous wastes cannot exceed the certified
precompliance levels. If a facility would like to test at
feed rates greater than these previously certified rates,
a revised certification of precompliance must be
submitted with the compliance test notification to ensure
that the higher feed rates are not likely to result in an
ice of the emission
i
I
I
I
I
1
1
i
'All facilities with dry PM contra) devices that opente at inlet temperatures between 450*F aad 750'F and industrial furnaces with HC emissions
greater than 20 pporv because of high organic owner in raw materials must demonstrate that emmriont of dioaas and furans will not result in an
increased cancer risk to the MEI of greater than 1 in 100,000.
The feed rate of ash is not required for cement and light-weight aggregate kilns, and the feed rate of metals in aonhazardous waste feed streams
(i.e., nw materials, fossil fuels) is not required for industrial furnaces complying with the alternative metals imptemeatation approach prescribed
in Section 10 of Appendix DC to the rule.
The BIF Rule (56 FR 7134) specifies that facilities complying with Tier I or adjusted Tier I metals feed rate screening limits must establish a
compliance limit on the feed rate of each metal in total pumpable hazardous waste feed streams
(| 266.103(c)(lXii))- EPA is considering rescinding this requirement by amending | 266.103(cXlXiiXQ to read Total pumpable hazardous
waste feed (unless complying with the Tier I or adjusted Tier I metals feed rate screening limits under f 266.106(b) or (e));'
» C-2
-------
COMPLIANCE TEST NOTIFICATION FORM 1 (CTN-l)
GENERAL FACILITY AND PLANNED TESTING INFORMATION
[ JInitial Certification [ ]Revised Certification [ ]Recertification
1.
2.
EPA facility ID Number:
Facility Name:
Contact Person:
Telephone Number:
Facility Address:
3.
4.
List all hazardous waste combustors
at facility by type (boiler, industrial
furnace, incinerator); if more than 3
units, list additional units at bottom
of page.
Person responsible for conducting
compliance test:
(Attach statement of qualifications)
Telephone Number:
Company Name:
Address:
5.
Planned date(s) of compliance test:
»»
#1:
#2:
#3:
Signature:
Title:
Date:
NRJ/NW-042
lOOMLnrj
-------
COMPLIANCE TEST NOTIFICATION FORM 2 (CTN-2):
UNIT DESCRIPTION Unit # (see Form CTN-1, Block 3)
Complete a separate form for each unit Attach additional sheets if necessary.
1. Type and Size of Boiler or Industrial Furnace (e.g., 100 million Btu/hr natural gas-
fired boiler with four front-wall burners, 100 ton/hr wet process cement kiln):.
2. Attach (a) scaled plot plan showing entire facility and location of this unit and (b)
schematic drawing showing combustor; fuel, feedstock, and waste feed systems; air
pollution control devices; continuous emission monitoring systems; and stack.
Drawing should clearly indicate location and design capacities (kg/hr) of all feed
systems, and location of all continuously monitored parameter sampling points.
3. Description of air pollution control devices (e.g., 3-field ESP with design PM
emissions of 0.03 gr/dscf):
Is APCD Shared with other device(s) or Unique (circle correct answer); if shared,
will other device(s) be in use during the test? Yes No
4. List of installed continuous emission monitors:
Carbon Monoxide; Oxygen; Hydrocarbons;
Description of hydrocarbon monitor:
Heated system; minimum CEM system temperature (°C):
Unheated system; minimum CEM system temperature (°C):
If not using a heated system, explain why and briefly describe sample gas
conditioning system:
5. Description of Stack:
Shared with other device(s) or Unique (circle correct answer); if shared, will other
device(s) be in use during the test? Yes No
6. Other information useful to understanding unit design or operation (Note: if it is
expected that a conflict between parameters will arise, such that more than one test
condition under a given mode is needed in order to determine a parameter, indicate
the parameter and the reason for conflict):
NRJ/NW-042
100W2.ni)
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COMPLIANCE TEST NOTIFICATION FORM 3 (CTN-3)
DESCRIPTION OF PLANNED TESTING
Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit
1. Unit # _ ; Mode (letter) _ ; Test Condition (1, 2, or N/A)' _
Brief Description of Mode and Test Condition: _
2. Purpose of Test (c^ to demonstrate compliance with PM, metals, HC1, and Clj emission limits when firing
sludges at maximum feed rate and flue gas flow):
3. Attach a complete copy of QA/QC Plan and test protocol.
4. Planned Operating Conditions:
Max. Production Rate (specify units')
Max. PM Control Device Inlet Temp (*F)*
Max. Combustion Chamber Temp. CD
APCS Operating Conditions (list applicable parameter*, see | 266.103(c)(lXix-
nii):
5. Fuel, Raw Material, and Waste Description:
Tviv ff 9 tinuid slurfre Hrumm^H fp|jri* ppfl *h»l*^
r*trrnrv (r v Pii»l D>w Mirenilc Putnpxhl* HW Nmtfiiimruhlr VTUA
Typjfil HntifiB Value fRtu /1M
Hna/ Fprf tf ff atnfni7^ri lani*^H frmvitv ^»H)
Mi [iiii«l (pft\ marmml ^^^ nr vntlr* fff\
THtfl! F**rf R»te ffft\r\*
Ash Feed Rjte (t/hr)*
CMnrin? »nA Oilnridc fofhr}
Antimnnv (o /\\r\
Ai^^fiir (ofl\r\
Rarium ^0/hr^
R^rvlliiifn (tt/\iT\
f^aHmiiim (o/\tf\
fTirrtitiiiitn (ofhr\
l^aH ^iv/Kr^
M*»rmirv /'ff/hr^
^i*krpr f'o/hr^
TThallitiTTi (o /h^
r.
•
Dcscripdcm of Each Feed Stream*
If facility wiO conduct tests at only one set of test conditions for the sated mode, enter N/A If two sets of conditions will be run for the
mode, fiH out a separate form for each set of test conditions. Identify each test condition as 1 or 2.
M>wner»/operatort of dry PM control devices tbat operate at an inlet temperature between 450*F and TSO'F must document tbat emissions
of dkwns and fount will not result in an increased MEI cancer risk of greater than 1 in 100,000.
•Copy form and add additional paces if firing more than four streams during test.
'Rates must not exceed those certified on Form PC-5.
•Not applicable for cement kilns and light-weight aggrepte kilns.
NRJ/NW-042
-------
COMPLIANCE TEST NOTIFICATION FORM 4 (CTN-4)
DOCUMENTATION OF PLANNED VERSUS ALLOWABLE FEED RATE LIMITS
Complete a separate form for each mode of operation for each unit.
Unit*:
Mode (letter):
Constituent
Ash (g/hr)'
Chlorine and
Chloride (g/hr)
Antimony (g/hr)
Arsenic (g/hr)
Barium (g/hr)
Beryllium (g/hr)
Cadmium (g/hr)
Chromium (g/hr)
Lead (g/hr)
Mercury (g/hr)
Silver (g/hr)
Thallium (g/hr)
Planned Feed Rate*
Total Feed
Streams
t
Total
Hazardous
Waste Feed
Streams'
Total Pumpable
Hazardous Waste
Feed Streams
Allowable Feed Ratesk
Total Feed
Streams
Total
Hazardous
Waste Feed
Streams
Total Pumpable
Hazardous
Waste
Feed Streams
• Sum of applicable feed streams from all form CTN-3'».
* From Form PC-S.
• Not applicable if complying with Tier I or adjusted Tier I metals feed rate screening limits.
' Not applicable for cement kilns and light-weight aggregate kilns.
•'•'i
NRJ/NW-042
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APPENDIX D
SAMPLE CERTIFICATION OF COMPLIANCE FORMS
-------
APPENDIX D
SAMPLE CERTIFICATION OF COMPLIANCE FORMS
Forms CC-1 through CC-5 are provided as
sample forms an owner/operator can use to certify
compliance with the interim status standards. Although
use of these forms is not required, the information
required on the forms must be submitted in writing to
the Director within 90 calendar days of the completion
of the compliance test; see |266.103(c)(4). If multiple
units were tested, separate documentation must be
prepared for each unit. All unit, operating mode, and
test condition identification codes should be identical to
those used in the Compliance Test Notification forms.
Forms CC-1 through CC-5 (or equivalent
information in a different format) must be submitted in
all cases. For industrial furnaces which recycle
paniculate matter, Form AM-3 (form and instructions
in Appendix E) or an equivalent form must be
submitted in addition to CC-1 through CC-5. The
sample forms provided are largely based upon a
scenario in which the air pollution control system
(APCS) and stack are unique to the BIF unit. The
owner/operator or permit writer may need to modify
the forms to accommodate situations in which an APCS
or stack is shared by more than one BIF unit (or
conversely, one BIF unit utilizes more than one APCS
or stack). A description of the sample forms and a
summary of the required information are provided
below. The owner/operator is directed to
J266.103(c)(4) for a complete listing of the information
required for compliance certification.
Form CC-1:
•I FarMltv anil T*«Hne Infn
ution
Form CC-1 on be used to identify the facility
by EPA facility ID number, name, address, and contact
person, and to indicate the type of BIF tested. The
person/company responsible for conducting the
compliance test must be recorded, and a statement of
qualifications for that person/company must be
attached. The dates of the testing and the purpose of
the test (whether initial certification, revised
certification, or recertification) must be noted. The
person responsible for QA/QC must be identified, and
a statement that procedures prescribed in the QA/QC
Plan have been followed (or an explanation and
justification of any deviation(s) from the plan) must be
attached. The signature of the owner /operator is
required, certifying the truth, accuracy, and
completeness of the certification of compliance.
Form CC-2: Deviations from Submitted Notification of
Compliance Test
Form CC-2 can be used to identify any changes
made to the tested unit's configuration or to the planned
test conditions that would alter the information
submitted on the Compliance Test Notification forms.
The changes and the reasons why the changes were
necessary must be described. Also, information from
amended Forms CTN-2 and CTN-3, as applicable,
should be attached. 1r
•
Form CC-3: Summary of Compliance Test Emissions
Form CC-3 can be used to summarize emissions
data from all of the runs conducted at a given test
mode. Separate documentation is required for each
mode of operation the facility establishes and tests.
Each of the test modes should be identified by the letter
code (e.g. Mode A or Mode B) used in Compliance
Test Notification Form 3 (CTN-3). Separate
documentation is also required if the facility conducts
tests at more than one set of test conditions for a given
mode. In such a case, conditions should be identified by
the same number code (1 or 2) used for the test
condition in CTN-3.
Most of the information required on this form
can be transferred from the worksheet provided in
Appendix G or as noted below (note that unit
conversions may be necessary when transferring
information from the worksheets):
CO and HC levels: CEM monitoring results;
PM emissions: Worksheet 8, Line 35;
HQ emissions: Worksheet 9, Column h;
Clj emissions: Worksheet 9, Column i; and
Metals emissions: Worksheet 10, Line 8.
D-l
-------
If the unit routinely blows soot or performs
some other activity that increases short-term emissions,
average emissions for PM, HO, Q* and metals should
be determined using the equation for emission rate in
Section 523.9. If such activities were not incorporated,
calculation of average emission rates (Le, average for
the entire test) is not required. Emission rates for PM,
HO, dj, and metals for all runs conducted without soot
blowing (or other activities) and the average emission
rate (if soot blowing or other activities occurred), cannot
exceed allowable levels. The allowable emission rates
listed on this form must correspond to those listed in
Form PC-4. If the emission rate for any parameter
exceeds the allowable level, the facility must immediately
submit a revised certification of precompliance. Options
in the event of noncompliance are discussed in Section
5.4.
Form CC-4: Summary of Compliance Test Operating
Conditions
Form CC-4 can be used to summarize operating
conditions during each run of a given mode. A separate
form must be completed for each run at each test
condition for each mode of operation. As with the
information specified on Form CC-3, most of the
information on this form can be easily transferred from
monitoring system results or from the worksheets in
Appendix G (note that unit conversions may be
necessary when transferring infonnation from the
worksheets):
• PM Control Device Inlet Temp (*F): Provide
run average and highest 60-minute rolling
average values measured by data acquisition
system;
• Combustion Chamber Temperature (*F):
Provide run average, highest 60-minute rolling
average, and lowest 60-minute rolling average
values measured by data acquisition system;
• Production rate (Ib/hr of steam produced or
raw material fed, or Btu/lb of thermal input):
Provide run average and highest 60-minute
rolling average values measured by data
acquisition system;
• APCS Operating Conditions: See list of
applicable APCS operating limits in
|266.103(c)(l)(ix-xiii). Provide run average
and, as appropriate, highest or lowest 60-minute
rolling average values measured by data
acquisition system.
Mass feed rates: Worksheet 3;
Thermal feed rates: Worksheet 4, Unes 3 and
4;
Ash feed rates: Worksheet 7, Lines 3 and 4;
Chlorine feed rates: Worksheet 5, Lines 3 and
4;
Metals feed rates: Worksheet 6, Line 4 for
each metal.
Form CC-S: Summary of ODer>ti"g
Feed Rat
Limits for a Specific Mode
Form CC-S can be used to combine informafran
from each run to define the operating limits
corresponding to a specific mode of operation. The
mode tested and the runs that comprised the mode must
be labeled. Indicate if more than one set of conditions
was tested under the mode (e.g., Mode: A; Test
Conditions: 1 and 2; Run Nos.: 1-3, 4-6). Also, place an
asterisk by any parameter limits that were determined
under the second set of conditions (Section 523.8
discusses which limits should be set from the second set
of conditions).
Operating Umits, maximum feed rate Umits, and
CO, HC, and PM Umits must be listed. Much of the
infonnation needed to calculate limits is presented on
Forms CC-3 and CC-4. Procedures for determining
compliance limits, and where the infonnation can be
found, are presented below:
• Maximum PM Control Device Inlet
Temperature (*F): Average over all runs of the
highest 60-minute rolling average for each run
conducted at a given set of test conditions (all
Forms CC-4 for each mode); or if complying on
an instantaneous basis under
|266.103(c)(4)(iv)(A), the time-weighted
average temperature for each mode;
D-2
-------
Maximum Combustion Chamber Temperature
(*F): Average over all runs of the highest 60-
minute rolling average for each run conducted
at a given set of test conditions (all Forms CC-
4 for each mode); or if complying on an
instantaneous basis under §266.103(c)(4){iv)(A),
the time-weighted average temperature for each
mode;
Production Rate: Average over all runs of the
highest 60-minute rolling average for each run
conducted at a given set of test conditions (all
Forms CC-4 for each mode); or if complying on
an instantaneous basis under
|266.103(c)(4)(iv)(A), the time-weighted
average production rate for each mode;
APCS Operating Limits: List applicable APCS
operating limits, see §266.103(c)(l)(ix-xiii);
limits based on average over all runs of the
lowest 60-minute rolling average (highest for
flue gas flow rate and, if chosen, suspended
solids content of scrubber water) for each run
of a given set of test conditions (all Forms CC-
4 for each mode); or if complying on an
instantaneous basis under5266.103(c)(4)(iv)(A),
the time-weighted average value for each mode;
Maximum Total HW and Total Pumpable HW
Feed Rates, as applicable: Average of mass
feed rates from all appropriate streams for runs
of a given set of test conditions (appropriate
streams on all Forms CC-4 for each mode);
Maximum Total Chlorine and Ash Feed Rates:
Average of total chlorine and total ash feed
rates for runs of a given set of test conditions
(all Forms CC-4 for each mode);
Maximum Total Metals Feed Rates: Average
of total feed rate for each metal for runs of a
given set of teat conditions (aD Forms CC-4 for
each mode).1
CO, HC, and PM Limits: If the CO HRA
during all valid runs are 100 ppmv or less, the
CO limit is 100 ppmv. If the CO HRA exceeds
100 ppmv during any valid run, the HC limit is
20 ppmv and the CO limit is the greater of
either 100 ppmv or the average of the HRA
levels measured during all valid runs. If the
HC HRA during any valid run exceeds 20
ppmv, the BIF is out of compliance unless it is
an industrial furnace eligible for the alternative
HC limit The PM limit is 0.08 gr/dscf or the
level in any existing permit, whichever is more
stringent.
The BIF Rule (56 FR 7134) specifies that facilities complying with Tier I or adjusted Tier I metals feed rate screening limits must establish a
compliance limit on the feed rate of each metal in total pumpable hazardous waste feed streams (| J66.103(cXlXu))- EPA is considering rescinding
this requirement by amending i 266.103(c)(lXii)(C) to read Total pumpable hazardous waste feed (unless complying with the Tier I or adjusted Tier
I metals feed rate screening limits under f 266.106(b) or (e)).'
D-3
-------
COMPLIANCE CERTIFICATION FORM 1 (CC-1)
GENERAL FACILITY AND TESTING INFORMATION
f llnitial Certification [ IRevised Certification [ ]Recertification
1. EPA facility ID Number
2. Facility Name:
Contact Person:
Telephone Number:
Facility Address:
3. Type of boiler /industrial furnace.
4. Person responsible for conducting
compliance test: (Attach statement of
qualifications)
Telephone Number:
Company Name:
Address:
5. Date(s) of compliance test:
6. Person responsible for QA/QC:
Title:
Telephone Number
••
Attach a statement certifying that procedures prescribed in QA/QC plan submitted with Compliance Test
Notification Form 3 (CTN-3) have been followed, or a description of any changes and an explanation of why
changes were necessary.
I certify under penalty of law that thai mformation was prepared under my direction or supervision in accordance with a system designed to ensure
that qualified personnel properly poured and evaluated the mformation and supporting documentation. Copies of an emissions tests, dispersion
modeling results, and other information used to determine conformance with the requirements of |266.103(c) are available at the facility, and can be
obtained from the facility contact person listed above. Based on my inquiry of the person or persons who manages the system, or those persons
directly responsible for ptberug the mformation, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
I am aware that there are nyifi^nt penalties for submitting false mformation, including the possibility of fine and imprisonment for knowing
violations.
I also acknowledge that the operating conditions established in this certification pursuant to |266.103(cX
-------
COMPLIANCE CERTIFICATION FORM 2 (CC-2)
DEVIATIONS FROM SUBMITTED NOTIFICATION OF COMPLIANCE TEST
1. Were there any changes in the unit configuration prior to or during testing that would alter any of the
information submitted on Form CTN-2 of the unit's Notification of Compliance Test? Yes No
If yes, describe these changes and why they were necessary and attach an amended Form CTN-2 describing
the unit as actually tested. (Attach additional sheets if necessary).
Were there any changes in the planned test conditions prior to or during testing that alter any of the
information submitted on Form CTN-3 of the unit's Notification of Compliance Test? Yes No
If yes, describe these changes and why they were necessary and attach amended Form CTN-3 describing test
conditions. (Attach additional sheets if necessary.)
NRJ/NW-050
1009-02.ni]
-------
COMPLIANCE CERTIFICATION FORM 3 (CC-3)
SUMMARY OF COMPLIANCE TEST EMISSIONS
Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit.
1. Use the same identification codes as on Form CTN-3 for the following:
Unit # _ ; Mode (letter) _ ; Test Condition (1, 2 or N/A)* _
Brief Description of Mode and Test Condition: _
2. Purpose of Test (e.g., Demonstrate compliance with PM, metals, HC1, and
sludges at maximum feed rate and flue gas flow):
emission limits when firing
3. Attach a complete copy of QA/QC results for each test
Hithett 60-tnin rolling iv»
If facility conducted tects it only one set of Met oooditioai for the stated mode, eater N/A. If two sea of ten conditions were run for the
node, fill out a aepunte form for each set of tett condiboot, identifying the ten coodition (1 or 2) at OB Form CTN-3.
If toot blowing or other daily activity that increases the PM emiaww nte was incorporated into the testing, calculate avenge uciag
•quatioo provided in iactrucrions.
Allowable levels are the tame at indicated on Form PC-4.
Check if each non-cootblowui| run and avertfe an lea thin or equal to allowable.
Indicate tootblowing time or time of other activity that was incorporated into the testing.
-------
COMPLIANCE CERTIFICATION FORM 4 (CC-4)
SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS
Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3
aad CTN-3.
1. Unit #: ; Mode: ; Test Condition (1, 2, or N/A): ;
Run No.: ; Test Date:
2. Run Start Time (hrmin):
; Run End Time (hrmin):_
If there were any interruptions in sampling, discuss cause, duration, and impact on
campling:
3. Operating Conditions:
Max. Production Rite (specify units)
Max. PM Control Device Inlet Temo.f *FV
Max. Combustion Chamber Temp. (*Ff
!266.io3
-------
COMPLIANCE CERTIFICATION FORM 5 (CC-5)
SUMMARY OF OPERATING AND FEED RATE LIMITS FOR A SPECIFIC MODE
1. Unit #: ; Mode: ; Run Nos.: ; Test Date:
2. Operating Condition limits1
Max Combustion Chamber Temp (*FV
APCS Operating Conditions (list applicable parameters, see f 266.103(cXlX«-
nii)):
Max. Production Rate (specify units)
Max. Total HW Feed Rate ft/hr)
Max Total Pumpable HW Feed Rate (i/hrtk
Max Total Chlorine and Chloride Feed Rate ft/hrl
Max. Total Ash Feed Rate (g/hr)d
3. Maximum Metals Feed Rates
Barium (|/hr1
Lead (e/hrt
Thallium (j/hr)
Total Feed Streams*
Total HW
Feed Streams*
Total Pumpable
HW Feed Stream*;.
4. CO, HC, and PM Limits
CO (ppmv @ 7% O,)f*
PM (tr/dtrf @ Tte O,)'
'Asterisk any parameter not determined under the primary test conditions.
Not applicable if complying with T«er I or adjusted Tier I metals feed rate screening limits.
*If applicable, attach documentation that the inrr-**** cancer risk to the MEI from emission* of dioxins and furans is not greater than 1 in
100,000.
Slot required for cement and light-weight aggregate kilns.
Not required for furnaces monitoring metals concentrations in collected PM.
If under Tier I, CO limit is 100 ppmv. If under Tier n, limit is the average over all runs of the HHA CO level for each run.
*If under Tier L HC limit is not applicable. If under Tier D, limit is 20 ppmv.
*If a furnace cannot meet the Tier D 20 ppmv HC limit because of organic matter in raw material feedstocks, the interim HC and CO limits are
the baseline limit* proposed in the Part B permit application or the limits established by the Director as a condition of a time extension for
certification of compliance.
\).08 gr/dscf or existing permit, whichever is more stringent
NRJ/NW-050
-------
APPENDIX E
ALTERNATIVE METALS IMPLEMENTATION FOR FURNACES
THAT RECYCLE COLLECTED PARTICIPATE MATTER
-------
APPENDIX E
ALTERNATIVE METALS IMPLEMENTATION FOR FURNACES
THAT RECYCLE COLLECTED PARTICULATE MATTER
Owners and operators of furnaces that recycle
collected paniculate matter (PM) must comply with one
of three monitoring alternatives given in
f 266.103(c)(3)(ii): (1) daily monitoring of collected PM
to ensure that metals levels do not exceed limits that
relate concentration of the metal in the collected PM to
emitted PM; (2) daily stack sampling for metals; or (3)
conditioning of the furnace system prior to compliance
testing to ensure that metals emissions are at
equilibrium with metals feed rates. The final rule
requires these facilities to comply with the same
certification schedules and procedures (with the few
exceptions described below) that apply to other BEFs.
Additional sample certification forms, particular to
furnaces recycling collected paniculate matter, and a
summary of the required information are provided
below.
E.1
Precompliance Certification
Facilities that choose to comply with the metals
standards by sampling daily from the stack or
conditioning the furnace system (options 2 and 3 above)
must follow the same precompliance procedures as
other BIFs (Appendix B). Furnaces that monitor metals
in the collected paniculate matter must also set
precompliance limits on parameters listed in sample
precompliance Form AM-1.
To determine a "conservative" dust metal
concentration limit (DMCLJ for each of the ten
hazardous metals, the applicable PM standard must be
determined. An owner/operator may choose either the
most stringent applicable paniculate matter limit (PML)
or an even stricter, self-imposed limit (if controlling PM
emissions is easier than reducing kiln dust metal
concentration). The allowable emission rate for each
metal can be determined from look-up tables (see final
rule) for either Tier H or Tier m, depending on the
chosen option. A Safe Enrichment Factor (SEF) for
each metal can be based on default values (SEF* 100
for mercury, SEF=10 for all other hazardous metals) or
engineering judgment. Further guidance is provided in
Section 82 of this document If engineering judgment
is used to determine any SEF, the basis for that
judgment must be described and certified by a registered
professional engineer. Finally, the DMCL. for each
metal must be calculated using the equation on Form
AM-1 and documented to meet precompliance
certification.
E2 Compliance Test Notification
In addition to providing the information in
Compliance Test Notification Forms CTN-1 to CTN-4
(Appendix C), all furnaces that recycle collected PM
should submit sample Form AM-2 or the equivalent
information in a different format. By submitting this
form, a facility declares which option it has chosenrto
implement the metals standards. By choosing Optidfi 1,
a facility agrees to follow the special testing
requirements prescribed in Section 82 of this document.
Precompliance limits for the DMCLe's of each metal
must be listed here as well. Furnaces which choose to
implement daily stack testing for metals emissions
(Option 2) declare that they are required to establish
operating limits only for those parameters listed on
Form AM-2 (see $266.103(c)(3)(ii)(B)). Finally,
choosing Option 3 notifies the Director that during the
compliance test, the furnace will be conditioned to
ensure that equilibrium (with respect to metals fed into
the system and metals emissions) will be reached before
sampling occurs.
EJ Certification of Interim Status Operating
.Ljmijs.
Form AM-3 is provided as an sample form
which an owner/operator of a furnace monitoring
metals in recycled PM (Option 1) can use to document
compliance certification. This information must be
submitted with the applicable information on Forms CC-
1 through CC-5 (Appendix D) within 90 calendar days
of the completion of the compliance test. A separate
Form AM-3 for each mode of operation documents
values of the enrichment factor measured for each metal
E-l
-------
over a minimum of JQ runs. Using Worksheet AM-1 (in
this Appendix), values of EFwt, EFW1, and the SEF for
each metal can be calculated. Once these statistical
parameters have been derived, the 'conservative' and
•violation* Dust Metal Concentration Limits (DMCL^)
can be calculated using the PM and Tier n or in
emission limits from Form CC-3 in the equations below.
M
Facilities that chose Options 2 or 3 on Form
AM-2 must provide certification information as
instructed by Appendix D with the exception that
furnaces which opt to sample emissions from the stack
on a daily basis need not monitor parameters that are
not listed on Form AM-2 under Option 2.
E-2
-------
ALTERNATIVE METALS PRECOMPLIANCE CERTIFICATION FORM AM-1
CALCULATION OF THE "CONSERVATIVE" DUST METAL CONCENTRATION
UMTP
1. Applicable PM Standard" (PML): Ib/hr
2. Unit #: (use same identification code as on Form PC-1, Block 3)
3. Estimated Conservative Dust Metal Concentration Limits (DMCLJ:
Metal
Aatimonv
Aneoic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
Total Allowable
Emission Rate0
SEF*
DMCL,
4. If any Safe Enrichment Factors are based on engineering judgement, a qualified,
registered professional engineer must describe the basis (attach additional sheet)
and certify the following:
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to be the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are «gnifi«-y«t penalties for submitting false information, including
• the possibility of fine and imprisonment for knowing violations.
Signature:
Date:
Title:
For furaacH •eatering metals concentration* in collected PM.
Meet ttrinftat PM standard for facility or more stringent self-uaposed standard. Muct natch PML on Form PC4.
Label as Tier 0 (II) or Tier in (ID) limit
Safe Enrichment Factor by default value (mercury SEF-100; other hazardous metals, SEF« 10) or engineering judgement.
Calculate •Conservative' Dust Metal Concentration Limit:
DMCL.
lb Dust Metal 1
Ib Dust J
Allowable Emission Rate
Ib Emitted Metal
hr
PML
lb PM
SEF
(lb 1
[Tb
Emitted Metal/lb PM
Dust Metal/lb Dust
NRJ/NW-048
1009-06.0TJ
-------
COMPLIANCE TEST NOTIFICATION FORM AM-2
TESTING PROCEDURES FOR FURNACES RECYCLING COLLECTED PARTICULATE
MATTER
Complete a separate form for each unit.
1. Unit # (see Form CTN-1, Block 3) is a furnace recycling collected PM.
2. Choose method of compliance testing by checking one method for complying
with interim status metals standards:
Option 1: Monitoring Metals Concentrations in Collected PM.
Follow special testing requirements prescribed in Section 10 of Appendix DC to the rule. Metal concentrations
in collected PM must remain within 'conservative" limits established during precompliance:
Constituent
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
DMCL,
Option 2: Daily Emissions Testing.
During compliance *******£,
operating limit* for the following:
1) Feed rate of total hazardous waste;
2) Total food rate of chlorine and chloride in total feed streams;
3) Total feed rate of ash in total feed streams (except for cement kilns and light-weight aggregate kilns);
4) Carbon monoxide, and if required, hydrocarbon concentration in stack gas;
5) Maximum production rate of the device when producing normal product
Option 3: Furnace Conditioning.
During compliance test, condition furnace to reach equilibrium with respect to metals fed into the system and
metals emissions. Establish limits for same parameters as for other BDFs.
-------
COMPLIANCE CERTIFICATION FORM AM-3
SPECIAL OPERATING PARAMETERS FOR FURNACES MONITORING METALS IN COLLECTED PM
Complete a separate form for each mode of operation for each unit.
1. Unit * (see Form CTN-1, Block 3): ; Mode (Mode ID on Fora CTN-3):
2. Enrichment factors measured during tests*:
METAL
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
RUN
1
RUN
2
RUN
3
RUN
4
RUN
5
RUN
6
RUN
7
RUN
8
RUN
9
RUN
10
3. From Worksheet AM-1, calculate EFwf, EFW%, and SEF for each metal. Then calculate the
"conservative" and "violation" Dust Metal Concentration Limits':
METAL
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
EFM,
EFW,
SEF
DMCL.
DMCL.
At least 10 runs are required of which 3 of the first 5 must be performed under compliance test conditions.
Use PML and Tier O or ffl limit from Form CC-3.
-------
WORKSHEET AM-1
STATISTICAL CALCULATIONS FOR FURNACES MONITORING METALS IN COLLECTED PM
Complete a separate worksheet for each metal.
1. Calculate 95% confidence level Enrichment Factor (EFe() based on number of runs (n) and t-distribution of
measured enrichment factors (EFJ.
a) Arithmetic mean of runs:
b) Standard deviation of runs:
' c) 95% confidence level enrichment factor (EFW,):
t„ from Table E-l:
i
i
(Enter into Section 3 of Form AM-3)
2. Calculate the 99% confidence level enrichment factor (EFW,):
t« from Table E-l:
(Enter into Section 3 of Form AM-3)
3. Calculate the "Safe* Enrichment Factor (SEF):
(Complete a, b, or c below and enter the SEF in Section 3 of Form AM-3)
a) If EFM > 2EFM>, use an SEF_> 2EF*,
SEF*
b) If EFW, <. 2EFB., use an SEF^. EFwt
SEF«
c) If the kiln dust metal concentration is undetectable SEF * 100.
4. Calculate "conservative" and "violation" Dust Metal Concentration Limits and enter in Section 3 of
Form AM-3.
-------
Table E-1. (-Distribution
0-1
or
n, + nj-2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
25
30
40
60
120
oo
t.«
631
192
135
113
102
1.94
1.90
1.86
1.83
1.81
1.80
1.78
1.77
1.76
1.75
1.75
1.74
1.73
1.73
1.72
1.71
1.70
1.68
1.67
1.66
1.645
t.»
31.82
6.%
434
3.75
336
3.14
3.00
190
182
2.76
172
168
2.65
162
160
2.58
2.57
235
154
153
148
146
142
239
236
133
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APPENDIX F
SAMPLE FORM TO REQUEST A TIME EXTENSION
TO COMPLY WITH THE HC STANDARD
-------
APPENDIX F
SAMPLE FORM TO REQUEST A TIME EXTENSION
TO COMPLY WITH THE HC STANDARD
Industrial furnaces (e.g, cement kilns) that
cannot meet the 20 ppmv HC limit due to organic
matter in raw material feedstocks may request an
extension of time to comply with the HC standard to
enable the Director to issue an operating permit with an
alternative (Le., higher) HC limit. An alternative HC
Emit may be established only under the permit process.
(Note that furnaces with a by-pass duct that diverts 10%
or more of the kiln off-gas are not eligible for the
alternative HC limit.) To be eligible for such a time
extension, the owner/operator must submit: (1) a
request for time extension, (2) a completed Part B
permit application that includes documentation of HC
and CO emissions testing used to support proposed
interim baseline HC and CO levels, and (3) a
certification of compliance with the other emissions
standards (Le., PM, metals, HO, and Clj). The first two
of the above items can be submitted to the Director
prior to certification of compliance with other emissions
standards. Based on review of these submittals, the
Director will make a preliminary determination that the
facility may meet the criteria specified in |266.104(f).
The facility should comply with the interim baseline HC
and CO levels proposed in the Part B application upon
submittal until they may be revised by the Director as a
condition of the time extension or until they may be
revised during the permit process. As required in
{266.104(0(1), the baseline HC and CO levels must be
established when the facility: (1) is operated to
tnimitiJTy HC emissions from all sources, (2) does not
burn hazardous waste, (3) processes normal
(nonhazardous waste) taw materials and fuels, aad (4)
produces normal
r -
on of C
To assist the Director in determining whether
the facility meets the criteria provided by §266.104(f)
and in reviewing the proposed interim HC and CO
limits, the owner/operator should submit the
information listed on Form TE-1 as part of the request
for time extension. The information listed on this form
is required; however the use of Form TE-1 is not
mandatory. Documentation supporting this information
must be submitted as part of the Part B application. If
different HC and CO levels are desired for more than
one mode of operation, separate documentation for each
mode of operation must be submitted.
F-l
-------
TIME EXTENSION REQUEST FORM 1 (TE-1)
DESCRIPTION OF OPERATING CONDITIONS DURING BASELINE HC TESTING1
(Submit separate information for each operating mode tested)
1. Highest 60-minute rolling averages of CO and HC from minimum of three test runs when
facility is not burning hazardous waste:
CO Run #1:
CO Run #2:
CO Run #3:
ppmv
.ppmv
.ppmv
HC Run #1:
HC Run #2:
HC Run #3:
ppmv
ppmv
ppmv
2. Baseline HC and CO levels determined as the average of the highest 60-minute rolling
average measured during each test run.
Baseline CO:
Baseline HC:
3. Description of raw materials (prior to mixing and charging).
Raw Material or
Ingredient
Description
of Composition
4. Descriptions of fuels (wet cement
Fuel
Source
Source
Total Organic
Carbon Content (mg/1)
kilns should include slurry water).
Total Organic
Carbon Content (mg/1)
Firing Systems
and Location
»
5. Description of product(s) manufactured during testing and production rate (give appropriate
units):
6. For rotary kilns, the kiln speed during testing was:
*For furnaces unable to meet the 20 ppmv limit due to nw material organic* and requesting a tine extension for compliance while submitting a Part
B permit application. See |266.104(f). To qualify for the alternative hydrocarbon limit, a cement kiln cannot be equipped with a bypass duct.
-------
\
\
APPENDIX B
SAMPLE PRECOMPLIANCE CERTIFICATION FORMS
-------
WORKSHEET 1
This worksheet provides a step-by-step procedure for developing source information needed to use the Tier I
and Tier n lookup tables. It can also be used to document emission dispersion parameters as required in
|266.103(b)(2)(v).
Step 1: Stack and Site Data
Complete Tables 1 and 2 with stack and site data. Space is provided for three stacks. If the facility has
additional stacks, they should be included in the analysis.
Step 2; Determine the Applicability of the Screening
Fill in the following data to evaluate the acceptability of the screening procedure for the specific site.
Is the facility in a valley < 1 km in width? [ ] [ ]
Is the terrain rise within 1 km of the facility greater than the physical stack [ ] [ ]
height of the tallest stack? (Only applies to stacks j>20 meters in height.)
Is the distance to the nearest shoreline <5 km? (Only applies to facilities [ ] [ ]
with stacks >20 meters in height.)
Is the distance from the stack(s) to the closest property boundary
-------
CHECKLIST OF REQUIRED PRECOMPLIANCE CERTIFICATION FORMS
APPLICABILITY
Small Quantity Burners
AO Precompliance Facilities
Precompliance Facilities Using Tier I
rrecompuance faculties using Adjusted
Tier I Based on Screening Procedure
(Single Stack)
Precompliance Facilities Using Adjusted
Tier I Based on Screening Procedure
(Multiple Stacks)
Precompliance Facilities Using Adjusted
Tier I Based on Dispersion Modeling
Precompliance Facilities Using Tier II
REQUIRED FORMS
• SQB-1
• Worksheet 1 (Appendix H)
• PC-1
• PC-2
• PC-3
• PC-4
• PC-5
• PC-6
• Worksheet 1 (Appendix H)
• Chapter 5 Worksheets
(Appendix IX to the rule)
• PC-4B
• Chapter 5 Worksheets
(Appendix DC to the rule)
PC-4C
PC-7
PC-2
PC-3
PC-4
Worksheet 1 (Appendix H)
PC-5
RELEVANT PORTION OF REQUIRED FORM
• Entire Form
• Steps 1, 3, 4 and 5
• Entire Form
• Items 1, 2, 3, and 4;
Item 5 - Entire 'Feed Rate* Column;
Item 5 - Entire *Ash/PM* Line;
Item 6 - If engineering judgement is used.
• Item 1
Item 2 - Entire *PM* Line;
Item 3 - If engineering judgement is used.
• Entire "PM" Line
• Entire Total Feed Streams* Column;
Entire Total Hazardous Waste Feed Streams* Column.
• Entire Form
• Entire Worksheet
.
• Entire Form
• Steps 1-7
• Entire Form
• Entire Worksheet
Entire Form
Entire Form
Entire Form
Entire Form
Entire Form
Entire Worksheet
Entire Form
NW/NW-048
lONWIZnij
-------
Step 3: Select the Worst-Case Stack
If the facility has several stacks, the worst-case stack must be chosen to conservatively represent release
conditions at the facility. The term "conservative" in this procedure means that concentrations and risks tend to be
overestimated rather than underestimated. Follow the steps below to identify the worst-case stack.
1. Fill in the following data on each stack and calculate K:
K - HVT
where:
K - An arbitrary parameter accounting for the relative influence of the stack height and plume rise;
H - Physical stack height (m);
V « Flow rate (m'/sec); and
T - Exhaust temperature fK).
Stack
No.
1
2
3
Stack Height (m) x
X
X
X
Flow Rate
(m'/sec)
X
X
X
X
Exit Temp. (*K)
Select the stack with the lowest "K" value. This is the worst-case stack that will be used for Steps 4 through 6.
Worst-Case Stack is identified as Stack No. .
RPF\014
0221-02-rpf G-3
-------
aonpumpable. Toe firing system used with the feed
stream must also be noted. To estimate uncontrolled
feed rates for all TMlSfftTTCTtt
be listed The factor for partitioning to the combustion
gas and the basis for the factor (either supportable
engineering judgment or EPA-prescribed default values)
must be indicated for each constituent. The use of
y^mtff^ring judgment and the default assumptions for
dftcr"Mi""g partitioning factors are difniwifd in
Section 3.5 of *J"« document. If *«gi«
-------
Step 5; Determine the Effective Stack Height and the Teirain-AdJDsted Effective Stick Height
Follow the steps below to identify the effective stack height and the terrain-adjusted effective stack height.
1. In appendix VI to 40 CFR Pan 266, find the plume rise value corresponding to the stack temperature and exit
flow rate for the worst-case stack determined in Step 3.
Plume rise • (m)
2, Add the plume rise to the physical stack height of the worst-case stack (from Step 4) to determine the effective
stack height.
Stack Height ftt^ + Plume Rise (m) - Effective Stack Height (m)
3. Subtract the maximum terrain rise within 5 km of the facility from the effective stack height to determine terrain-
adjusted effective stack height. jr
Effective Stack - Terrain Rise * Terrain-Adjusted
Height (m) Within 5 km (m) Effective Stack Height (m)
RPF\014
0221-02.spf G-S
-------
the device to document compliance with the
requiremeats of 5266.103(i)(5)(i)(A), (B), and (Q. The
owner/operator must identify each location where
hazardous waste is fed to the device. The «"""mmn
temperature at each of these locations must be stated,
as well as the basis for determining tby temperatures.
The owner/operator must also identify oxygen
requirements for combustion and oxygen availability at
each such location. The basis for determining oxygen
requirements and availability must be described. For
cement kiln systems, the owner/operator must certify
that the waste is fed directly to the lorn (not the
precakiner or preheater).
B-6
-------
Table 3
Classification of Land Use Types
Type1
11
12
Cl
Rl
R2
R3
R4
Al
A2
A3
A4
A5
Description
Heavy Industrial
Light/Moderate Industrial
Commercial
Common Residential
(Normal Easements)
Compact Residential
(Single Family)
Compact Residential
(Multi-Family)
Estate Residential
(Multi-Acre Plots)
Metropolitan Natural
Agricultural
Undeveloped
(Grasses/Weeds)
Undeveloped
(Heavily Wooded)
Water Surfaces
Urban or Rorml Designation1
Urban
Urban
Urban
Rural
Urban
Urban
Rural
Rural
Rural
Rural
Rural
Rural
'EPA, Guideline on Air Quality Models (Revised), EPA-450/2-78-027, Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina, July 1986. 40 CFR Part 266, Appendix X.
'Auer, August H. Jr., "Correlation of Use and Cover with Meteorological Anomalies," Journal of Applied Meteorology.
pp. 636-643,1978.
WF\014
0221-02. rpf
G-7
-------
SMALL QUANTITY BURNER FORM 1 (SQB-1)
NOTIFICATION FOR SMALL QUANTITY BURNER EXEMPTION
1.
2.
EPA facility ID Number:
Facility Name:
Contact Person:
Telephone Number
Facility Address:
3.
4.
5.
Number and Type (boiler or
industrial furnace) of Units
on-site. (If more than 3
units, list additional units at
bottom of page.)
Terrain-adjusted effective
stack height for each BIF
unit (list stack height of
additional units at bottom of
page).'
The maximum quantity of
hazardous waste that will be
burned per month for each
BIF unit (gallons/month)
#1:
#2:
#3:
#1: meters
#2: meters
#3: meters
#1: gal/month
#2: gal/month
#3: gal/month
•Supporting documentation for terrain-adjusted effective stack heights should be provided by completing and ttt»f*"pg
Worksheet 1 (Appendix G), Steps L, 3, 4, and 5 only. A separate worksheet should be filled out for each BIF meeting
the small quantity burner exemption requirements.
I certify under penalty of law that each boiler or industrial furnace unit listed in this notification is
operating as a small quantity burner of hazardous waste and is in compliance with all of the
requirements of 40 CFR §266.108.
I certify that this information was prepared under my direction or supervision in accordance with
a system designed to ensure that qualified personnel gathered and evaluated the information.
Signature:.
Title: _
Date-
NJU/NW-048
1016-03.ni]
-------
MODE:
WORKSHEET 2. CALCULATION OF CONTAINERIZED WASTE FEED RATE
Run No. /Date
Charge
Time
(Decimal)
Charge
Weight
Ob)
Ran No. /Date
Charge
Time
(Decimal)
Charge
Weight
-------
PRECOMPLIANCE CERTIFICATION FORM 2 (PC-2)
CALCULATION OF ESTIMATED UNCONTROLLED EMISSIONS FOR EACH FEED
STREAM FOR COMPLIANCE WITH THE PM, METALS, HO, AND Oj STANDARDS
Complete a separate form for each feed stream under each mode of operation for each unit
listed on Form PC-1.
1. Unit #: _ (see Form PC-1, Block 3); Mode (letter): _ ; Feed Stream #: _
2. Description of Feed Stream (Include Gross Feed Rate of Feed Stream (g/hr)):
I
3. Feed Stream Characteristics (check one):
Pumpable Nonpumpable Chlorine/Hydrogen Ratio
4. Firing System (check one): Suspension-fired Bed-fired
5. Estimated Uncontrolled Emissions.
Ash/PML
Chlorine and
Chloride
Antimony
Anenic
Barium
Bervflium
Cadmium
Lead
Mercury
Silver
Thallium
Feed
ffitV
JUte
HQi
P.:
Estimated
6. If any partitioning factors are based on engineering judgment, a qualified, registered
professional engineer must describe basis (attach additional sheets) and certify the following:
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person (or persons) who manage the system, or those persons directly responsible for gathering the information, the mformatioa submitted
K, to the beat of my knowledge and belief, true, accurate, and complete. I am aware that then are significant penalties for submitting fatee
information, mdudiag the possibility of fine and imprisonment for knowing violations.
Signature:
Title:
Date:
"Enter partitioning (to the combustion gas) factors based on default values or engineering judgment.
Indicate whether partitioning factor based on default values (D) or on engineering judgment (E).
•Calculated estimated uncontrolled emission* using the following equations:
Ash (in gr/dsef): (FR i PF) * Plow Rate (dacfm) x OJ57
AD other constituents (in g/hr): (FRxPF)
'Cement and light-weight aggregate kiln* are not required to monitor ash in feed streams.
-------
MODE:
DATE:
WORKSHEET 3. WASTE FEED CHARACTERISTICS
Feed Rate
Ob/hr)
%Asb
Heating Value
(Btn/lb)
% Total
Chlorine
Feed Stream #1:
Run No.
Run No.
Run No.
Feed Stream *2:
Run No.
Run No.
Run No.
Feed Stream #3:
Run No.
Run No.
Run No.
Feed Stream #4:
Run No.
Run No.
Run No.
Feed Stream *5:
Run No.
Run No.
Run No.
Feed Stream #6:
Run No.
Run No.
RPF\014
0221-02.rpf
G-ll
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4)
COMPARISON OF TOTAL ALLOWABLE EMISSION RATES TO TOTAL EMISSION RATES FOR COMPLIANCE WITH THE
PM STANDARD AND TIER II OR III METALS, HC1, AND CI, STANDARDS.
Complete a separate form for each mode of operation for each unit.
Unit #: ; Mode (letter): (use same identification codes as on Form PC-2)
Constituent
PM(gr/dscl)
HCl(g/hr)
Cl,(g/hf)
Antimony (g/hr)
Arsenic (g/hr)
Barium (g/hr)
Beryllium (g/iuj
Cadmium (g/hr)
Chromium (g/hr)
Lead (g/hr)
Mercury (g/hr)
Silver (g/hr)
Thallium (g/hr)
Total
Tottl AJhrttaM*
EmittkM Rate1
Basis'
1
Total Estimated
Controlled Emission Rate*
Ratio of Estimated to
Allowable Emission Rate4
•
s for Metafc, HO, Md O, ba*ed on Tier II or HI, or <• pet
_ ^ f , . PorPM.IndtaiteO.Oiir/ibcroramoreitringenlittmtanllftpplJMWe. (See
attached expanded imtractkMS.)
^iidk»le «kether total allowMe e«WM fM for e^ coMliMeM H1^
limit (r).
•From Pom PC-3. Cannot eweed total •ImnMe emWon rale
*IU»k> of total estimated emiscioM divided by total allowable emiviom.
•Sum of ratios (or individual metals. Must not exceed 1.0 to ensure that summed health risk doe* Ml exceed 1 m
NRJ/NW-048
1009-04.ni)
-------
MODE:
WORKSHEETS CALCULATION OF HEAT INPUT RATE
Heat Inputs
Feed Stream #1:
Feed rate (Ib/hr)
HV(Btu/Ib)
Heat input (Btu/hr)
Ron Number/Date
Line
No.
1
2
3
Feed Stream #2:
Feed rate Qb/br)
HV (Bru/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream #3:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream #4:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream #5:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream #6:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
Total Heat Input (Btu/hr)
1
2
3
4
R?F\014
0221-Ollpf
G-13
-------
PRECOMPL1ANCE CERTIFICATION FORM 4 (PC-4A)
CALCULATION OF ALLOWABLE EMISSION RATES FOR COMPLIANCE WITH THE TIER HI METALS, HCl, AND Cl,
STANDARDS USING THE HAZARDOUS WASTE COMBUSTION AIR QUALITY SCREENING PROCEDURE FOR SINGLE
STACKS.
Constituent
na
a,
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
RAC or RSD (ug/m1)
Dilution Factor
(ug/m'/g/s)'
Allowable
Emission Rate (g/hf )'
•Complete Steps 1-7 of Chapter 5 worksheets to Appendix IX to 40 CFR Part 266. Attach the worksheets from Chapter 5. The dilution factor is the highest maximum
annual dispersion coefficient recorded under Step 7(c).
^Calculate allowable emissions as follows:
Allowable Emissions (g/hr) - RAC or RSD (ug/m')/Dilutkra Factor ["ft/"*]] x 3,500
L ,..j, I 8/scc JJ
•Attach a USGS topographic map (or equivalent) showing faculty location and surrounding land within 5 km of the facility.
-------
MODE:
WORKSHEET 5. CALCULATION OF CHLORINE FEED INPUT RATE
Chlorine Inputs
Ron Number/Date
Line
No.
Feed Stream #1:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (Ib/hr)
1
2
3
Feed Stream *2:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (''
Feed Stream #3:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (Ib/hr)
Feed Stream #4:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (Ib/hr)
Feed Stream #5:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (Ib/hr)
1
2
3
1
2
3
1
2
3
1
2
3
Feed Stream #6:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (Ib/hr)
1
2
3
Feed Stream #7:
Feed rate (Ib/hr)
% Chlorine
Chlorine input (Ib/hr)
Total Chlorine Input (Ib/hr) =
Total Chlorine input (g/sec) *
1
2
3
4
5
RPF\OM
0221-Olrpf
G-15
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4B)
COMPARISON OF TOTAL ALLOWABLE AMBIENT CONCENTRATIONS TO TOTAL PREDICTED AMBIENT
CONCENTRATIONS FOR COMPLIANCE WITH TIER III METALS, Ha AND a, STANDARDS USING THE HAZARDOUS
WASTE COMBUSTION AIR QUALITY SCREENING PROCEDURE FOR MULTIPLE STACKS.
Constituent
HO
a,
Antimony
Barium
Lead
Mercury
Silver
Thallium
Arsenic
Beryllium
Cadmium
Chromium
Total
Maximum Annual
Average
Concentration
C. (ug/m1)'
RAC or RSD
(ug/m>)
Ratio of Estimated
to Allowable
(Q/RAC or RSD)
-
Ratio (from Previous
Column) If
More Than One
Carcinogenic Metal*
Note: Attach « USGS topographic map (or equivalent) showing facility location and surrounding land within 5 km of the facility.
•Complete Step* MO of Chapter 5 •orfaheeti I* Appendix IX to Part 266. Attack the oortaheett from Chapter 5. Eater the aujrimmi annual averafe concealratloa, C, (^m*) for each comtiluenl from
Step 10 (I).
TV feed me HmH for each metal when reeding more than one cardnafealc
not exceed 1.0.
-------
MODE:
WORKSHEET «. METAL CONCENTRATIONS IN FEEDS AND INPUT RATES
RUNNK
Date
Part Rife »/hr)
Star (Ac)
Cooceatnooo (ug/g)
Input rate (Ib/hi)
AlMBC(Al)
CoaccatntioB (ug/g)
Input rate (Ib/hr)
Rana«B (Be)
Concentntion (ug/g)
Input nte (Ib/hr)
CadmiM (Cd)
Concentntion (ug/g)
Input nte (Ib/hr)
Chroariav (Cr)
Concentntion (ug/g)
Input nte (Ib/hr)
MefTV7)
(g/iec)
LIB*
No,
1
2
3
4
3
4
3
4
3
4
3
4
3
4
3
4
3
4
3
4
3
4
RPF\014
0221-02. rpf
G-17
-------
PRECOMPLIANCE CERTIFICATION FORM 4 (PC-4D)
CALCULATION OF ALLOWABLE EMISSION RATES FOR COMPLIANCE WITH THE TIER HI METALS, HC1, AND Cl,
STANDARDS USING DISPERSION MODELING.
Constituent
HO
a,
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
RAC or RSD
(ug/m3)
Dilution Factor
(ug/mVg/s)'
Allowable
Emission Rate (g/hr)k
•Prom dispersion modeling. Complete and attach Form PC-4C.
'Calculate allowable emissions as follows:
Allowable Emissions (g/hr) - |RAC or RSD (ug/m^/Dilution Factor f1**/'"']] , 3,600
L I 8/«* J J
-------
MODE:
WORKSHEET 7. CALCULATION OF ASH INPUT RATE
Ash Inputs
Feed Stream #1:
Feed rate (\b/la)
%Ash
Ash input (Ib/hr)
Ron Nunber/Date
Line
No.
1
2
3
Feed Stream #2:
Feed rale (Ib/hr)
%Ash
Ash input (Ib/hr)
1
2
3
Feed Stream #3:
Feed rate (Ib/hr)
%Ash
Ash input (Ib/hr)
1
2
3
Feed Stream #4:
Feed rate (Ib/hr)
%Ash
Ash input (Ib/hr)
1
2
3
Feed Stream #5:
Feed rate (Ib/hr)
%Ash
Ash input (Ib/hr)
Feed Stream *6:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
Total Ash Input (Ib/hr) »
1
2
3
1
2
3
4
WF\014
0221-02. ipf
G-19
-------
PRECOMPLIANCE CERTIFICATION FORM 6 (PC-6)
CALCULATION AND DOCUMENTATION OF TIER I FEED RATE LIMITS FOR METALS AND CHLORINE DURING
PRECOMPLIANCE PERIOD
Complete a separate form for each mode of operation for each unit.
Unit #: ; Mode (letter): (use same identification codes as on Form PC-2)
rf"^*fc^fc^AlA^fc^— i
UDtMiroent
Chlorine (Ib/hr)
Antimony (g/hr)
Barium (g/hr)
Lead (g/hr)
Mercury (g/hr)
Silver (g/hr)
Thallium (g/hr)
Arsenic (g/hr)
Beryllium (g/hr)
Cadmium (g/hr)
Chromium (g/hr)
tod Rate Limit
froM Reference
Tabfcaf
Desired
Peed Rate
(8/kOk
Ratio of Desired
Feed Rate to
Reference Table
Peed Rate Limit*
(g/hr)
Peed Rate UmK
When Feeding More
Than One
Carcinogenic Metal*
(I/to)
•Attach Worioheet 1 (Appendix O).
fow caidMfmk inetA d
1»>
PC-Zfonm. OiloriiM«Mbecoirrertedto^>PropriMeMtoMroaoM: Chlorine (Ib/hr) . (OrioriM Peed RMe (|/tir)/4334|
^ tablet (A|»pei.dlce« I «ndn effort 266) mb««edo««1
-------
Line 38:
Joe 21 x Line 11 x I Une 18 *
J Line 20 x L
Line 28: 5129.4 x Line 21 x Line 11 x Line 18 * 460
Line 9
Line 29: 0.0945 x (Line 18 * 460) x Line 13
Line 9 x (Line 28 + 60) x A. Line 22 x (1 - Line 27)
Where A. » (Line 23)2 x T + 576
Line 30: Line 28 x Line 27
Line 31- Line 30 x 17.64 x Line 19
Line 18 * 460
Line 32: Line 31 x (1 - Line 17)
Line 34: 15.43 x (Line 33 + Line 13)
Line 35: (14 x Line 34 ) + (21 - Line 14)
Line 36: (Line 34 x 12) + Line 15
j. 37. 272.15 x Line 33 x Line 9
(Line 13 + (0.047 x Line 16)) x (Line 18 * 460)
Line 34 x Line 32 x 60
7,000
W»F\014
0221-Oltpf G-21
-------
APPENDIX C
SAMPLE COMPLIANCE TEST NOTIFICATION FORMS
-------
MODE:
TEST CONDITION:
RUN NO--
DATE:
WORKSHEET fc DATA REDUCTION FOR METHOD 5 SAMPLING TRAIN (ContiDoed)
Line
No.
27
28
29
30
31
32
33
34
35
36
37
38
Ffcraneter
Suck Area, square feet
Stack Velocity, actual feet/min
% Isoltinetic
Flow Rate, actual cubic feet/min
Flow Rate, std. cubic feet/min
Flow Rate, dry std. cubic
feet/min
Particulate Weight, grams
Particulate Loading, grains/dry
std. cubic feet
Corrected to 7% Oxygen
Corrected to 12% Carbon
Dioxide
Particulate Loading, grains/cubic
feet
Emission Rate, Ib/hr
Pwtkwlate
Sum>llnc Tnta
Multiple Metals
RPF\014
0221-02. rpf
G-23
-------
also be stated.1 Other key parameters, discussed in
|266.103(c)(l), for which operating limits will be
established during the compliance test, must also be
identified. Descriptions of the fuel, raw material, and
waste are required, including type, category, heating
value, and feeding method for each stream. Feed rates
, of ash, chlorine, and metals for each feed stream must
i also be listed.2 The information listed on Form CTN-3
must be consistent with the facility's written test
protocol. The written test protocol and Quality
j Assurance/Quality Control (QA/QC) Plan must be
L included with the notification of compliance testing.
Sections 523 and 52.7 provide guidance on the contents
r of the test protocol and QA/QC Plan.
Form CTN-4: Documentation of Planned Versus
Allowable Feed Rate Limits
I Form CTN-4 compares the planned feed rates
of ash, chlorine, and metals in total feed streams, total
(hazardous waste feed streams, and total pumpable
hazardous3 waste feed streams to the levels that were
certified as allowable on Form PC-5 of the
precompliance package. A separate Form CTN-4
should be completed for each test mode of operation for
each unit. Planned feed rates for each of the three feed
stream categories are based on the information on the
corresponding Form CTN-3. Feed rates for total feed
streams, total hazardous wastes, and total pumpable
hazardous wastes cannot exceed the certified
precompliance levels. If a facility would like to test at
feed rates greater than these previously certified rates,
a revised certification of precompliance must be
submitted with the compliance test notification to ensure
that the higher feed rates are not likely to result in an
exceedance of the emission standards.
I
I
i
'All facilities with dry PM control devices that operate at intet temperatures between 450»F and 750»F and industrial furnaces with HC emissions
greater than 20 ppmv because of high organic matter in raw materials must demonstrate that finmtnm of dknins and funns will not result in an
increased cancer risk to the ME! of greater than 1 in 100,000.
The feed rate of ash is not required for cement and light-weight aggregate kilns, and the feed rate of metals in nonhazardous waste feed streams
1(Le., raw materials, fossil fuels) is not required for industrial furnaces complying with the alternative metals implementation approach prescribed
in Section 10 of Appendix DC to the rute.
The BIF Rule (56 FR 7134) specifies that facilities complying with Tier I or adjusted Tier I metals feed rate screening limits must establish a
f compliance limit on the feed rate of each metal in total pumpable hazardous waste feed streams
J (I 266.10XcXl)(u)). EPA • considering rescinding this requirement by amending i 266.103(cXlXuXQ to "^ Total pumpable hazardous
' waste feed (unless complying with the Tier I or adjusted Tier I metals feed rate screening limits under i 266.106(b) or (e));*
i C-2
-------
MODE:
TEST CONDITION:
WORKSHEET 9. CHLORINE EMISSION RESULTS
Rn*
ud
Date
I»pt*ter
SotatteM
Condcnsatc
Caustk
Condensate
Caustk
Condensate
Caustk
(a)
•".'f
CUM**
f^A^r
<-I/M
(•>
V«l«Me
(L)
(c)
QwrtHjr
F«w>d
(«t)
(d)
Stack Gas
Sample
Value
(d«cf)
(e)
a
CMC.
(f/
-------
COMPLIANCE TEST NOTIFICATION FORM 2 (CTN-2):
UNIT DESCRIPTION Unit # (see Form CTN-1, Block 3)
Complete a separate form for each unit. Attach additional sheets if necessary.
1. Type and Size of Boiler or Industrial Furnace (e.g., 100 million Btu/hr natural gas-
fired boiler with four front-wall burners, 100 ton/hr wet process cement kiln):.
2. Attach (a) scaled plot plan showing entire facility and location of this unit and (b)
schematic drawing showing combustor; fuel, feedstock, and waste feed systems; air
pollution control devices; continuous emission monitoring systems; and stack.
Drawing should clearly indicate location and design capacities (kg/hr) of all feed
systems, and location of all continuously monitored parameter sampling points.
3. Description of air pollution control devices (e.g., 3-field ESP with design PM
emissions of 0.03 gr/dscf): __
Is APCD Shared with other device(s) or Unique (circle correct answer); if shared,
will other device(s) be in use during the test? Yes No
4. List of installed continuous emission monitors:
Carbon Monoxide; Oxygen; Hydrocarbons;
Description of hydrocarbon monitor:
Heated system; minimum CEM system temperature (*C):
Unheated system; minimum CEM system temperature (°C):
If not using a heated system, explain why and briefly describe sample gas
conditioning system:
5. Description of Stack:
Shared with other device(s) or Unique (circle correct answer); if shared, will other
device(s) be in use during the test? Yes No
6. Other information useful to understanding unit design or operation (Note: if it is
expected that a conflict between parameters will arise, such that more than one test
condition under a given mode is needed in order to determine a parameter, indicate
the parameter and the reason for conflict):
NRJ/NW-042
lOOO-OXorj
-------
MODE: TEST CONDITION:
WORKSHEET It ANALYSIS RESULTS TOR METALS SAMSUNG TRAIN
fi|^«l 1 A* 1 At
^^^^^^^^^^^^^^^^^^^^^^g^H^E^^_^^0^^B^^f^^^_^^^^^B^^^Q^^^_^^^^^^a^^E^^^f^i_
RnaN*. /Date
RM
Acetone Rime
Nitric Riiwe
Filter
Nitric Acid Imoincen
KMn04 Impinccn
Total. UK
Concentmtion. nt/d*cf
EmiaMom. t/*ec
N.. /Data
Acetone Rime
Nitric Rime
Filter
Nitric Acid Inwinien
KMnCM Impinten
Total, uc
Concentnlion. Ht/dacf
Ernksioiic. i/fee
N*. /DM*
Acetone Rime
Nitric Rime
Filler
Nitric Add Impincen
KMnCM Impiiuen
Total. UK
Concentnlion. ui/dacf
Emiaions. c/sec
NA
NA
NA
NA
NA
NA
.. 1 R. 1 «
NA
NA
NA
NA
NA
NA
Cr
NA
NA
NA
NA
NA
H«
1%
NA
NA
NA
NA
91
NA
NA
NA
1 Tl 1 L»»N«.
NA
NA
NA
1
2
3
4
5
6
7
8
1
2
3
4
3
6
7
8
1
2
3
4
5
6
7
a
RPP\014
022l4>2.rpf
-------
COMPLIANCE TEST NOTIFICATION FORM 4 (CTN-4)
DOCUMENTATION OF PLANNED VERSUS ALLOWABLE FEED RATE LIMITS
Complete a separate form for each mode of operation for each unit.
Unit*:
Mode (letter):
Constituent
Ash (g/hr)'
Chlorine and
Chloride (g/hr)
Antimony (g/hr)
Arsenic (g/hr)
Barium (g/hr)
Beryllium (g/hr)
Cadmium (g/hr)
Chromium (g/hr)
Lead (g/hr)
Mercury (g/hr)
Silver (g/hr)
Thallium (g/hr)
Planned Feed Rate*
Total Feed
Streams
Total
Hazardous
Waste Feed
Streams'
Total Piimpable
Hazardous Waste
Feed Streams
Allowable Feed Rates*
Total Feed
Streams
Total
Hazardous
Waste Feed
Streams
Total Piimpable
Hazardous
Waste
Feed Streams
•
• Sum of applicable reed strum* from all Bonn CTN-3'c.
' From Foim PC-S.
• Not applicable if complying with Tier I or adjusted Tier I metals feed rate screening limits.
' Not applicabk for cement kilns and light-weight aggregate kilns.
NRJ/NW-042
-------
The University of Dayton
April 30, 1991
Mr. Shiva Garg
US-Environmental Protection Agency
WH 565A, 401 M Street
Washington, DC 20460
Dear Mr. Garg:
C. C. Lee called last week and noted that you would
like a copy of our latest thermal stability ranking. We
have enclosed a copy. This ranking includes experimental
studies through the end of the 1990 Fiscal Year.
Sincerely,
Philip H. Taylor
Environmental Sciences
PHT:dl
Encls.
RESEARCH INSTITUTE
300 Colkgt Pfcrk Dayton. Ohio 4546WH32
-------
APPENDIX D
SAMPLE CERTIFICATION OF COMPLIANCE FORMS
-------
THERMAL STABILITY-BASED MdNERABIUTY RANKING
PR1NCFAL ORGANIC HAZARDOUS CONSTTTUENT T M (2X*C) RANK
METHYL CHLOROCAABONATE {CAftBONOCHLORIDlC ACID. METHYL ESTER) 850 50-53
METHYL ISOCYANATE (METHYLCARBYLAMINE) B50 50-53
TETRACHLOROOIBENZO-P-OIOXIN (1,24,4.) 845 54
OIMETHYLPHENETHYLAMINE (alpha, a***) 840 55-58
MALONONtTRILE {PROPANEDINTTRILE) 840 55-58
NAPHTHYLAMINE (1-) 840 55-58
NAPHTHYLAMINE (2-) 840 55-58
DICHLOROETHENE (trtnt-1,2-) 835 59
FLUOROACETAMIDE (2-) 830 60
ACRYLAMIDE {2-PROPENAJUIIDE} 820 61-62
METHYL METHACRYLATE {2-PROPENOIC ACID. 2-METHYL-.M ETHYL ESTER} 820 61 -62
DICHLOROMETHANE (METHYLENE CHLORIDE) 815 63-64
METHACRYLONITRILE{2-METHYL-2-PROPENENrrRiLE) 815 63-64
CHLOROANIUNE (CHLOROBENZENAMINE) 810 65
METHYLCHOLANTHRENE (3-) 805 66
CHLORO-1,3-BUTADIENE(2-){CHLOROPRENE) 800 67-70
DIPHENYLAMINE {N-PHENYLBENZENAMINE} 800 67-70
PRONAMIDE(3.5-DICHLORO-N-{1,1.DIMETHYl.-2-PROPYNYL]BENZAMIDE] 800 67-70
ACETYLAMINOPLUORENE (2-) {ACETAMIDE,N-{9H-FLUOREN-2-YLH 800 67-70
CLASS 3'
AMINOBtPHENYL(4.){[1,1'-BIPHENYLH-AMINE} 796 71
DICHLOROBENZ1DINE (3,3'-) 795 72-73
CHLOROPHENOL (2-) 795 72-73
BENZlDINE{p,1'-BIPHENYLM.4'DlAMINE) 794 ;74
DIMETHYLBENZIDINE (3.31-) 793 75
PHENYLENEDIAMINE(1,3-){BENZENEDIAMINE} 792 76
PHENYLENEDIAMINE(1.2-){BEN2ENED!AMINE} 791 77
PHENYLENEDUkMINE(1,4){BENZENEDIAMINE) 790 78
rvPROPYLAMINE{1-PROPANAMINE) 789 79
PYR1DINE 785 80-81
CHLOROPHENOL (3-) 785 80-81
PICOUNE (2-) {PYRIDINE.2-METHYL-} 780 82-85
DICHLOROPROPENE(1,1-) 780 82-85
THIOACETAMIDE {ETHANETHIOAMIDE} 780 82-85
TRICHLORO(1^»TRIFLUOROETHANE(1,1»{FREON113)P] 780 82-85
PHENOL (HYDROXYBENZENE) 775 86-90
BENZIcJACRIDINE {3.4-BENZACRIDINE) 775 86-90
DICHLORODIFLUOROMETHANE {FREON12) 775 86-90
ACETOPHENONEtETHANONfeM^HENYL-) 775 86-90
TRICHLOROFLUOROMITHANE {FREON 11) 775 86-90
ETHYL CYANIDE {PROPIONTTRILE} 770 9193
BEN20QUINONE{1,4^YaOHEXADIENEDIONE) 770 91-93
VINYL CHLORIDE (CHtOHOfTHENE) 770 91-93
DIBENZla,hlACRIDINl {tA8,6.0IBEN2ACRIDINE) 765 94-99
DIBENZ(a.j]ACRIDINE {1 A7*^IBENZACRIDINE) 765 94-99
HEXACHLOROBUTADIENI(irwt-1,3) 765 94-99
NAPHTHOQUINONE (1.4-) {1,4-NAPHTHALENEDIONE) 765 94-99
DIMETHYL PHTHALATE 765 W-99
ACETYL CHLORIDE (ETHANOYL CHLORIDE) 765 94-99
ACETONYLBENZYL-*WDROXYCOUMARIN (3-a|pha-) (WARFARIN) 760 00-0
MALEIC ANHYDRIDE {2,5-FURANDIONE} 760 100-01
CHLOROPHENOL (4-) 755 02-03
DICHLORO.^BUTENE(1,2-) 755 102™*
DICHLOROPROPENE(2.3-) ;JJ 105.113
DICHLOROPROPENE(tran$-1.2-) Jg 105. 13
DIBENZO(c,olCARBAZOLE (7H-) {3.4.5.6-DIBENZCARBAZOLE) 750 105-113
H-2
-------
If the unit routinely blows toot or performs
some other activity that increases short-term emissions,
average emissions for PM, HO, Qj, and metals should
be determined using the equation for emission rate in
Section 523.9. If such activities were not incorporated,
calculation of average emission rates (Len average for
the entire test) is not required. Emission rates for PM,
HO, Qj, and metals for all runs conducted without soot
blowing (or other activities) and the average emission
rate (if soot blowing or other activities occurred), cannot
exceed allowable levels. The allowable emission rates
listed on this form must correspond to those listed in
Form PC-4. If the emission rate for any parameter
exceeds the allowable level, the facility must immediately
submit a revised certification of precompliance. Options
in the event of noncompliance are discussed in Section
5.4.
Form CC-4: Summary of Compliance Test Operating
Conditions
Form CC-4 can be used to summarize operating
conditions during each run of a given mode. A separate
form must be completed for each run at each test
condition for each mode of operation. As with the
information specified on Form CC-3, most of the
information on this form can be easily transferred from
monitoring system results or from the worksheets in
Appendix G (note that unit conversions may be
necessary when transferring information from the
worksheets):
• PM Control Device Inlet Temp f F): Provide
run average and highest 60-minute rolling
average values measured by data acquisition
system;
• Combustion Chamber Temperature (*F):
Provide run average, highest 60-minute rolling
average, and lowest 60-minute rolling average
values measured by data acquisition system;
• Production rate (Ib/hr of steam produced or
raw material fed, or Btu/Ib of thermal input):
Provide run average and highest 60-minute
rolling average values measured by data
acquisition system;
• APCS Operating Conditions: See list of
applicable APCS operating limits in
|266.103(c)(l)(ix-xiii). Provide run average
and, as appropriate, highest or lowest 60-minute
rolling average values measured by data
acquisition system.
Mass feed rates: Worksheet 3;
Thermal feed rates: Worksheet 4, Lines 3 and
4;
Ash feed rates: Worksheet 7, Lines 3 and 4;
Chlorine feed rates: Worksheet 5, Lines 3 and
4;
Metals feed rates: Worksheet 6, Line 4 for
each metal.
Form CC-S; Summary of Operating and Feed Rate
Limits for a Specific Mode
Form CC-5 can be used to combine information
from each run to define the operating limits
corresponding to a specific mode of operation. The
mode tested and the runs that comprised the mode must
be labeled. Indicate if more than one set of conditions
was tested under the mode (e.g., Mode: A; Test
Conditions: 1 and 2; Run Nos.: 1-3,4-6). Also, place an
asterisk by any parameter limits that were determined
under the second set of conditions (Section 523.8
disrumr* which limits should be set from the second set
of conditions).
Operating limits, maximum feed rate limits, and
CO, HC, and PM limits must be listed. Much of the
information needed to calculate limits is presented on
Forms CC-3 and CC-4. Procedures for determining
compliance limits, and where the information can be
found, are presented below:
• Maximum PM Control Device Inlet
Temperature (*F): Average over all runs of the
highest 60-minute rolling average for each run
conducted at a given set of test conditions (all
Forms CC-4 for each mode); or if complying on
an instantaneous basis under
|266.103(c)(4)(iv)(A), the time-weighted
average temperature for each mode;
D-2
-------
THERMAL STABILITY-BASED MQNERABIUTY RANKING
PRtNOPAL ORGANIC HAZARDOUS CONSTITUENT T W (2X*C)
NITROANIUNE {4-NITROeENZENAMlNE}
PENTACHLOROPHENOL
PENTACHLOROCTHANl
DINITROBENZENE(1,4-)
DINITROBENZENE{1.2-)
TRICHLOROETHANE (1,1,2-)
ISODRIN
OIELORIN
ALORIN
DICHLOROPROPANE (1,3-)
DIBROMOETHANE (1,2.) {ETHYLENE DIBROMIDE]
NITROTOLUIDINE (S-) {BEN2EJ4AMINE*METHYL-5-NrTRO-}
CHLOROACETALDEHYDE
BENZAL CHLORIDE {ALPHAJUPHA-OICHLOROTOLUENE}
TRICHLOROMETHANE (CHLOROFORM)
DICHLOROPROPENE (tfv».1»
TRICHLOROPROPANE (1,2»
DINITROTOLUENE (2,4-)
DINITROTOLUENE (2,6-)
MEXACHLOROCYCLOPENTAOIENE
DICHLORO-1-PROPANOL (2,3-)
ETHYLENS OXIDE (OXIRANE}
OICHLOROPROPENE (d»-1,3-)
DIMETHYLCARBAMOYLCHLORIOE
GLYCIDYALDEHYDE (1-PROPANOL-2.3-EPOXY)
JOT (OICHLOROOIPHENYLTRICHLOROETHANE)
DICHLOROPROPANE (1J-) (PROPYLEHE BICHLORIDE}
AURAMINE
HEPTACHLOR
DICHLOROPROPANE (1,1-)
CHLORO-ZS-EPOXYPROPANE (1-) {OXIRANE.2-CHLOROMETHYL-}
DINITROPHENOL (2,4-)
bU(2-CHLORO€THYL)ETHER
TRINI7ROBENZENE {U^-TRMrTROBENZENE}
BUTYL-4.6-DINrmOPHENOL (2-MC-) (ONBP)
CYCLOHEXYL^.e-OtNITROPHENOL (2-)
DICHLOROETHANE (1,1-) (ETHYUOEME DICHLORIDE}
bi$(2-CHLOROETHOXY)METHANE
CHLORAL {TRICHLOROACETALOEHYDE}
TRICHLOROM ETHAN ETHIOL
OINITROCRESOL (4» {PHENOU2,4-OINITRO^METHYL-}
HEPTACHLOR EPOXJDE
DIEPOXYBUTANE (1 A3.4-) (W-BIOXIRANE)
BENZOTRICHLORIOE {TmCHLOROMETHYLBENZENE}
METHAPYRILENE
RANK
-""• CLASS S
PHENACETJN {N^ETHOXYPHENYLIACETAMIDE)
METHYL HYDRAZ1NE
AFLATOX1NS
HEXACHLOROETHANE
BROMOFORM (TRIBROMOMETHANE)
CHLOROBENZILATE
ETHYL CARBAMATE {URETHAN} {CARBAMIC ACID, ETHYL ESTER)
ETHYL METHACRYLATE {2-PROPENOIC ACID. 2-METHYL-, ETHYL ESTER}
LASIOCARPINE
640
640
640
635
635
635
632
632
632
630
630
630
630
630
625
625
625
625
625
625
625
625
625
620
620
620
620
618
618
615
615
615
615
615
613
613
610
610
610
610
610
609
604
600
600
158-163
158-163
158-163
164-166
164-166
184-166
167-169
167-169
167-169
170-174
170-174
170-174
170-174
170-174
175-183
175-183
175-183
175-183
175-183
175-183
175-183
175-183
175-183
184-187
184-T87
184-167
184-187
188-189
188-189
190-194
190-194
190-194
190-194
190-194
195-196
195-196
197-201
197-201
197-201
197-201
197-201
202
203
204-205
204-205
593
593
590
565
585
564
584
564
584
206-207
206-207
208
209-210
209-210
211-214
211-214
211-214
211-214
H-4
-------
COMPLIANCE CERTIFICATION FORM 1 (CC-1)
GENERAL FACILITY AND TESTING INFORMATION
[ Jlnitial Certification [ ]Revised Certification [ ]Recertification
1. EPA facility ID Number
2. Facility Name:
Contact Person:
Telephone Number:
Facility Address:
3. Type of boiler /industrial furnace.
4. Person responsible for conducting
compliance test: (Attach statement of
qualifications)
Telephone Number:
Company Name:
Address:
5. Date(s) of compliance test:
6. Person responsible for QA/QC:
Title:
Telephone Number.
•
Attach a statement certifying that procedures prescribed in QA/QC plan submitted with Compliance Test
Notification Form 3 (CTN-3) have been followed, or a description of any changes and an explanation of why
changes were neceuary.
I certify under penalty of taw that this information was prepared under my direction or supervision in accordance with a system designed to ensure
that qualified personnel piopcrty pthered and evaluated the information and supporting documentation. Copies of all emissions tests, dispersion
modeling results, and other information used to determine conformance with the requirements of |266.103(c) are available at the facility, and can be
obtained from the facility contact person listed above. Based on my inquiry of the person or persons who manafes the system, or those persons
directly responsible for fathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, ud complete.
I am aware that there are npifieMt penalties for submitting fabe information, mriudhif the possibility of fine and imprisonment for knowing
violations.
I also acknowledge that the operating conditions established in this certification pursuant to |266.103(cX4X'v) are enforceable limits at which the
facility can legally operate during interim status until (1) a revised certification of compliance is submitted or (2) an operating permit is issued.
Signature:.
Date:
Title:
NRJ/NW-OSO
-------
THERMAL STABILITY-BASED WdNERABldTY RANKING
PRINCIPAL ORGANIC HAZARDOUS CONSTITUENT T 99 (2X°C)
CITRUS RED No. 2 (2-NAPHTHOL.H(2,5-OIMETHOXYPHENYL)AZOD
TRYPAN BLUE
ETHYL METHANESULFONATE (METHANESULFONIC ACID, ETHYL ESTER}
DISULFOTON
DIISOPROPYLFLUOROPHOSPHATE {DFP}
0,0,0-TRIETHYL PHOSPHOROTHIOATE
D»-*vBUTYL PHTHALATE
PARALDEHYDE (2,4,6-TRlMETHYL- 1,3,9-TRIOXANE}
DI-0-OCTYL PHTHALATE
OCTAMETHYLPYROPHOSPHORAMIDE {OCTAMETHYLOIPHOSPHORAMIDE)
bis(2-ETHYLHEXYL)PHTHALATE
METHYLTHIOURACIL
PROPYLTHIOURACIL
STRYCHNINE (STRYCHNIOIN-10-ONE)
CYCLOPHOSPHAMIDE
NICOTINE {{S)*H14*ETHYL-2-PYRROUDlNYLJPYRIDINE}
RESERPINE
TOLUIOINE HYDROCHLORIDE {2-METHYL-BENZENAMINE HYOROCHLORIDE}
CLASS 7
TOLYLENE OIISOCYANATE {1,3-DHSOCYANATOMETHYLBENZENE}
ENDRIN
BUTANONE PEROXIDE (2-) {METHYL ETHYL KETONE. PEROXIDE)
TETRAETHYLPYROPHOSPHATE
NITROGLYCERINE [{TRINirRATE'lAS-PROPANETRIOL}
TETRAETHYLOrrHIOPYROPHOSPHATE
ETHYLENEbisDiTHIOCARBAMIC ACID
TETRANITROMETHANE
URACIL MUSTARD {5-{bis(2-CHLOROETHYL)AMINO]URACIL}
ACETYL-2-THIOUREA (1-) {ACETAMIDE.N-fAMINOTHlOXOMETHYLH
CHLOROPHENYLTHIOUREA (1-) {THIOUREA,(2-CHLOROPHENYLH
N-PHENYLTHIOUREA
NAPHTHYL-2-THIOUREA (1-) {THIOUREA,1-NAPHTHALENYL-}
THIOUREA {THIOCARBAMIDE}
DAUNOMYCIN
ETHYLENE THIOUREA {2-IMIDAZOLIDINETHIONE}
THIOSEMICARBAZIDE (HYDRAZINECARBOTHIOAMIDE)
MELPHALAN {ALANINE,3Kp-bis(2-CHLOROETHYL)AMIN01 PHENYL-.L-)
DITHIOeiURET (2.4-) (THIOIMIDODICARBONIC 01 AM IDE)
THIURAM (bi$(OIMETHYLTHKXARBAMOYL]OlSULFlDE}
AZASERINE (L-SERINE.D1A20ACETATE [ESTERS
HEXAETHYL TETRAPHOSPHATE
NITROGEN MUSTARD N-OXIDE
NITROQUlNOLINE-1-OXCf (4-)
CYCASIN {Nta-DXSLUCOPYRANOSIDE, {METHYL-ONN-A20XYJMETHYL-}
STREPT020TOCIN
N-METHYL-N'-NrrRO-N-NrrROSOGUANIDlNE
N-NITROSO-DI-ETHANOLAMINE fl2^-NITROSOIMIN01bi$ETHANOL}
N-NITROSO-DI-N-BUTYLAMINE {N-BUTYL-N-NrTROSO-l -BUTANAMINE)
N-NITROSO-N-ETHYLUREA {N-ETHYL-N-NITROSOCARBAMIDE}
N-NITROSO-N-METHYLUREA {N-METHYL-N-NITROSOCARBAMIDE)
N-NITROSO-fWylETHYLURETHANE
N-NITROSODIETHYLAMINE {N-ETHYL-N-NITROSOETHANAMINE}
N-NITROSODIMETHYLAMINE {DIMETHYLNITROSAMINE}
N-NITROSOMETHYLETHYLAMINE {N44ETHYL-N-NITROSOETHANAMINE}
N-NrTROSOMETHYLVINYLAMINE {N-METHYL-N^ITROSOETHENAMINE}
395
392
390
390
390
390
390
380
380
374
370
370
360
320
300
300
300
300
RANK
267-268
269
270-274
270-274
270-274
270-274
270-274
275
276
277
278-279
278-279
280
281
282-285
282-285
282-285
282-285
290
285
260
255
255
250
250
245
246
240
240
240
240
240
230
230
225
225
220
220
200
190
170
170
170
155
130
130
130
130
130
130
130
130
130
130
286
287
288
289
290
291-292
291-292
293
294
295-299
295-299
295-299
295-299
295-299
300-301
300-301
302-303
302-303
304-305
304-305
306
307
308-310
308-310
308-310
311
312-327
312-327
312-327
312-327
312-327
312-327
312-327
312-327
312-327
312-327
H-6
-------
COMPLIANCE CERTIFICATION FORM 3 (CC-3)
SUMMARY OF COMPLIANCE TEST EMISSIONS
Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit.
1. Use the same identification codes as on Form CTN-3 for the following:
Unit # _ ; Mode (letter) _ ; Test Condition (1, 2 or N/A)* _
Brief Description of Mode and Test Condition: _ _
2. Purpose of Test (e.g., Demonstrate compliance with PM, metals, HC1, and
sludges at maximum feed rate and flue gas flow):
emission limits when firing
3. Attach a complete copy of QA/QC results for each test
SoOtfalQW Time fmint")*
CO foomv ® 7% O,1
Hifhett 60-min rolliai
PM emissioiu (cr/dicfl
If facility conducted tects it only on* set of test conditions for the Rated node, eater N/A. If two aets of tea condition* were mo for the
mode, nu out a aepante fora for each aet of ten condition*, identifying the teat condition (1 or 2) as 00 Form CTN-1
rate wat iacorporated into the testing, calculate avenfe using
If toot blowing or other daily activity that inoeaae* the PM
equation provided in instructions.
Allowable levels are the same at indicated 00 Form PC-4.
Check if each noa-cootblowia| run and avenge are less than or equal to allowable.
Indicate soottolowing time or time of other activity that wm* incorporated into the testing.
-------
COMPLIANCE CERTIFICATION FORM 5 (CC-5)
SUMMARY OF OPERATING AND FEED RATE LIMITS FOR A SPECIFIC MODE
1. Unit #: ; Mode: ; Run Nos.: ; Test Date:
2. Operating Condition limits'
Max. PM Control Device Inlet Temp. f'F)^
Max. Combustion Chamber Temp. (*F)*
APCS Operating Conditions (list applicable parameters, tee f 266.103(eXlX«-
»i)):
Max. Production Rate (specify units)
Max. Total HW Feed Rate (t/hr)
Max. Total Pumpable HW Feed Rate (c/hr)b
Max. Total Chlorine and Chloride Feed Rate ft/hrt
Max. Total Ash Feed Rate (g/hr)d
3. Maximum Metals Feed Rates
Antimony (t/hr)
Arsenic fe/hrt
Barium ft/hrt
Beryllium fr/hr)
Cadmium fe/hr)
Chromium (c/hrl
Lead (i/hr)
Mercury (£/hr)
Silver ( e/hrl
Thallium (g/hr)
Total Feed Streams*
Total HW
Feed Streams*
Total Pumpable
HW Feed Streamsr
4. CO, HC, and PM Limits
CO (ppmv @ 7% O./*
HC (ppmv as propane A 7% O>)e<*
PM («r/dscf @ 7% O,l'
'Asterisk any parameter not determined under the primary test conditions.
Not applicable if complying with Tier I or adjusted Tier I metals feed rate tcreenin| limits.
*If applicable, attach documentation that the urr***-* cancer risk to the MEI from emisnons of dicoins and furans is not greater than 1 in
100,000.
Slot required for cement and Ufht-wetfht aggregate kilns.
*Not required for furnaces monitoring metals concentrations in collected PM.
If under Tier I, CO limit is 100 ppmv. If under Tier II, limit is the average over all runs of the HHA CO level for each run.
*If under Tier I HC limit is not applicable. If under Tier D, limit is 20 ppmv.
Tf a furnace cannot meet the Tier D 20 ppmv HC limit because of organic matter in raw material feedstocks, the interim HC and CO limits are
the baseline limits proposed in the Part B pennit application or the limits established by the Director as a condition of a time extension for
certification of compliance.
*0.08 gr/dscf or easting permit, whichever is more stringent
NRJ/NW-050
------- |