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.
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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
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   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

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        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
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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

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(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
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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  
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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.

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        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

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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

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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

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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.

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       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

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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

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                                            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

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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.

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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

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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

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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

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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

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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

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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

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                                         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%

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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

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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

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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.

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                                       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

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•       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
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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.

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                                                    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).
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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.
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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.
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                                            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
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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))."


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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)).*
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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

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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

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•       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

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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

-------
       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

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                                                                   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.

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                                           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

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                                                   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.                                                "'

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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.
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                            5-20

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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
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                                                    5-23

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                                           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
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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
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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
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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.

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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).
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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.
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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
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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
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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).
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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).
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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.
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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.
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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.
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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

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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

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       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

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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.
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        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
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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
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                                                     8-7

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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.
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                                                     8-8

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                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
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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

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•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

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        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

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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

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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

-------
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));
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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
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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
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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
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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

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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

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I
     Figure 10-3. Potential Effects of Interpolating Between Test Results

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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

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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

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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
        
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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

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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

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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

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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

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                  APPENDIX A




DESCRIPTION OF DEVICES SUBJECT TO BIF REGULATIONS

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                                                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

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 f
 *
'I
                     •••V

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        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

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STEAM
OUTPUT'
                                                    COMUSIKM AM
             FlfutA-2. MmtedCwl-FlredWitBtBbeBaffcr

-------
flfare A3. FMr-Pan Flrctabe Bolter (7)
                 A-S

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 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

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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

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            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)

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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

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 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.
U.S. Environmental Protection Agency. Fossil Fuel-Fired Industrial Boilers - Ba
I, Draft Environmental Impact Statement EPA Publication No. EPA-600/7-78-100. June 1978.
                                                                                                 Volume
Fni
                    BVound Tnformadon
                                                           for the Develoment of Regulations to Control th
               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.
       September 1986.

       US. Government Printing Office. Federal Register. VoL 56, No. 35, pp. 7138-7141

       Devitt, Tn et al. The Population and  Characteristics of Industrial and Commercial Boilers."   PEDCo
       Environmental, Inc. May 1979. pp. 32-33.

       U.S. Government Printing Office. Federal Register. VoL 52, No. 87, pp. 16986-16988.
        Engineering-Science. Bykgrf""^ Infbrmatif"1 P? ^OT the Development of Regulations to Control the
        P'jmipy of Ht^rdous Wastes in Boilers and Industrial Furnaces. VoL n. January 1987. NTIS PB-87- 173837.
                                                                                                   » *
                                                                                                    »
        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
1977.
                                        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.
 U.S. Environmental Protection Agency.  Fossil Fuel Fired Industrial Boilers -
 1:  Chapter 1-9.  EPA Publication No. EPA-450/3-82-006a.  March 1982.
                                                                                      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

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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

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               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

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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

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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

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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.

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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]

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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-
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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.

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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

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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.

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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

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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

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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

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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

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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

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                                              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

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          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

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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

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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

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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

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                                              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

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        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

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       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

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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
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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]

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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.

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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
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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

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                  APPENDIX E

ALTERNATIVE METALS IMPLEMENTATION FOR FURNACES
  THAT RECYCLE COLLECTED PARTICIPATE MATTER

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                                              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

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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

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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

-------
              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

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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

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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

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                       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

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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.

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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

-------