EPA/540/2-89/015
SUPERFUNDTREATABILITY
CLEARINGHOUSE
Document Reference:
GA Technologies, Inc. "PCB Destruction Facility Circulating Bed Combustor.'
Technical report prepared for U.S. EPA. 24 pp. December 1985.
EPA LIBRARY NUMBER:
Super-fund Treatability Clearinghouse -EUXM
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SUPERFUND TREATABILITY CLEARINGHOUSE ABSTRACT
Treatment Process: Thermal Treatment - Circulating Bed Combustion
(CBC)
Media: Soil/generic
Document Reference: GA Technologies, Inc. "PCB Destruction Facility
Circulating Bed Combustor." Technical report
prepared for U.S. EPA. 24 pp. December 1985.
Document Type: Contractor/Vendor Treatability Study
Contact: Hiroshi Dodohara
Ogden Environmental Services, Inc.
P.O. Box 85178
San Diego, CA 92138-5178
619-455-2383
Site Name: Gulf Oil Corp., Berkley Heights, NJ (Non-NPL)
Location of Test: Berkley Heights, NJ
BACKGROUND: This treatability study reports on an evaluation of a
pilot-scale, transportable, circulating bed combustor (CBC) for the
incineration of PCB contaminated soils. This May 1985 test was for a
demonstration to support a permit application for operation in California.
OPERATIONAL INFORMATION; The CBC demonstration utilized a spiked soil
(10,000 ppm PCB concentration) at a feed rate of 400 pounds per hour and a
CBC operating temperature of 1800°F. No information was provided on the
soil. Three four-hour runs were completed; however, because problems
occurred in the sampling of particulates in the initial test, a fourth
abbreviated run of two hours was conducted solely for collecting a
particulates sample. Three supplementary runs were conducted to evaluate
low combustion temperatures (1625°F) and to incinerate PCB-contaminated
soil. Feed soil, fly ash, and bed ash were sampled and analyzed. Stack
emissions samples were collected for particulates, semi-volatile organics,
and volatile organics.
PERFORMANCE; Destruction Removal Efficiencies (DREs) ranged from 99.9999%
to 99.995% for PCB except for 1 run which resulted in a 99.82% efficiency.
No significant PCB stack emissions were indicated. Particulate stack
emissions during one test did not meet the standard for stationary air
point sources. High particulate emissions were attributed to a high
process air supply inadvertently applied to the air bag filtration unit.
Another significant test value was the residual dioxin and furan in the
treated soil. High values of 1.33 ppb for dioxins and furans were
indicated in the fly ash.
Several operational problems were reported. The damp, irregularly
shaped soil feed material used during the trials clogged the transfer ducts
in the unit. Agglomeration of the soil also occurred in the combustor bed,
affecting mixing efficiency with direct reduction in the combustion
efficiency.
3/89-9 Document Number: EUXM
NOTE: Quality assurance of data may not be appropriate for all uses.
-------
Other problems occurred with the stack sampling method. During one
stack sampling sequence, fly ash was inadvertently dispersed throughout the
operating bay, resulting in the evacuation of the entire office/pilot plant
building. Siloxanes were present in the stack gas stream and interfered in
the laboratory procedures to analyze the stack gas samples. However, the
siloxanes may have been from silicone sealant which was used to install an
in-line oxygen monitor, or from silicone rubber sealants in the sampling
trains or similar sources. The demonstration trial runs and the supple-
mentary tests indicated that the formation of agglomerates affected the
combustion efficiency of the CBC unit, and increased the emission of
products of incomplete combustion (PICs).
CONTAMINANTS:
Analytical data is provided in the treatability study report. The
breakdown of the contaminants by treatability group is:
Treatability Group CAS Number Contaminants
WOl-Halogenated Aromatic TOT-TCB Total Trichlorobenzenes
Compounds
W02-Dioxins/Furans/PCBs 11096-82-5 PCB 1260
12672-29-6 PCB-1248
3/89-9 Document Number: EUXM
NOTE: Quality assurance of data may not be appropriate for all uses.
-------
EVALUATION REPORT
GA TECHNOLOGIES, INC.
PCB DESTRUCTION FACILITY
CIRCULATING BED COMBUSTOR
DEMONSTRATION TRIALS FOR NATIONWIDE PERMIT
by
Hiroshi A. Dodohara
20 DECEMBER 1985
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- 1 -
GA TECHNOLOGIES INC. DEMONSTRATION TEST RESULTS
SUMMARY
Background; GA Technologies, Incorporated submitted an
application to obtain a PCB disposal operating permit for the
Circulating Bed Combustor (CBC), an incinerator using fuidized
bed technology. The CBC was demonstrated for approval May 20
through May 29, 1985. As a non-liquid PCB incinerator, the CBC
was demonstrated with spiked soil>of 10,000 ppm PCB concentration
at a feed rate of0*00 pounds per houFT The combustion
temperature was 1800° F^t/Three four-hour runs were completed,
however, because problems occurred in the sampling of
particulates in the initial test, a fourth abbreviated run of two
hours was conducted solely for collecting a particulates
sample. Split samples of feed soil, fly ash, and bed ash were
taken and analyzed. Stack emissions samples were collected using
the Modified Method 5 (MM5) for particulates and for semi-
volatile org-anics and th'e Volatile Organics Sampling Train (VOST)
for volatile organics. Quality assurance check samples were also
submitted to Analytical Technologies Incorporated during the
laboratory audit.
In addition to the four demonstration tests, three
supplementary runs were conducted to evaluate low combustion
temperatures and to incinerate PCB-contaminated site soil.
Test Results; Performance standards for non-liquid PCB
incinerators exclude the criteria for combustion temperatures,
residence time and excewss oxygen. All other PCB incinerator
standards are applicable. The quality assurance audit of the
laboratory indicated adequate performance. Test results are
summarized in Table A. One test run resulted in low combustion
efficiency (99.82% vs. 99.9% standard). The low combustion
efficency however, did not affect the destruction and removal
efficiency (ORE). All DREs were above the six 9s criteria for
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PCBs incinerators. No significant PCBs stack emissions were
indicated. Particulates stack emission during one test did not
meet the standards for stationary air point sources of 0.08
grains/dry standard cubic feet (gr/dscf). Test run 4 resulted in
a particulates emission of 0.095 gr/dscf. The high particulates
emission was attributed to a high process air supply
inadvertently applied to the air bag filtration unit. The other
test value of significance is the residual dioxin and furan in
the treated soil. High values of 1.33 ppb for dioxins and furans
were indicated in the fly ash. The Center for Disease Control
indicated a safe value in soil to be 1 ppb for 2,3,7,fl TCDD.
Two items remain incomplete. One is the PCBs analysis from
solvent extracts of the particulate filter media. The second
item is the calibration of the chloride in-line monitoring
instrument using a two-feet section tubing and also using a 25
feet tubing section. Values for the two tests will be compared
to determine whether or not significant differences exists
between the two method. t The comparison will be made in order to
resolve the departures from standard chloride sampling
techniaues.
CONCLUSION
Evaluation of test results for both the demonstration trial
runs and the supplementary tests indicate that the formation of
aaglomerates has some effect on the combustion efficiency of the
CBC unit. DREs were not affected significantly although
Combustion Efficiency standard of 99.9% was not met in one of the
demonstration test and in al of the supplementary runs.
Indications are that agglomerate formation also increases the
emissions of products of inclomplete combustion (PICs). In one
of the supplementary runs, significant concentrations of
phthlates were noted in the stack emissions.
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RECOMMENDATIONS
Approval for the GA Technologies, Inc. CBC unit to operate
does not impose unreasonable risk to health and environment when
operated as intended. Therefore, strict operating restrictions
must be imposed to assure proper operation of the CBC.
The following provisions in addition to the non-liquid PCB
incinerator performance standards should be included as
conditions of approval to ensure proper operation of the CBC:
1. Operating temperature: 1750 - 1850 °F.
2. Process air supply to Bag House: as recommended by
manufacturer.
3. Frequent inspection of the Bag House air supply.
4. Shutdown of the CBC when the Combustion Efficiency falls
below the 99.9% standard, when the Combustion Efficiency
cannot be brought up to standard after a speciied period of
*
time, say one hour.
5. Pneumatic transfer system for soil feed should be modified.
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1 e A
GA TECHNOLOGIES DEMONSTRATIU FEST RESULTS (TESTS 1 THRU 4)
TEST
PARAMETER
TEST
TEMPERATURE °F
COMBUSTION
EFFICIENCY, %
DESTRUCTION
REMOVAL EFF. %
RANGE
1,795-1,815°F
99.82 - 99.97
99.9999
0.000045 - 0.00023
<0.0092 - <0.029
<0.0027 - <0.015
Dioxin, ug/tn
Furans, ug/fa
Trichloro- .,
benzene, ug/m 0.28 - 0.29
Particulates,
gr/dscf
Carbon
Monoxide, ppm
Hydrogen
Chloride, ppm)
Nitrogen
Oxides, Ib/MBtu
Volatile
Org an ics
Semi-Volatile
Organics
Ash Residues
0.0024 -
0.0950
22 - 105
57 - 266
0.035 - 0.156
No significant
anissions
STANDARD (Reg)
2,191°F for PCB incinerator
99.9 MIN. (§761.70)
COMMENTS
standard not applicable for
non-liquid incinerator
99.82 C.E. caused by
formation of agglomerates
in combustion bed
low combustion efficency did
not affect ORE
99.9999 MIN. (§761.70)
0.001 gm outAg PCB introduced (§761.70)
No current emissions standards Not detected at detection limits
No current onissions standards Not detected at detection limits
0.08 gr/dscf
0.095 gr/dscf result attributed
to high process air pressure
200,000 ferroally production (§60.263)
500 petroleum refinery (§103)
min. of 1% HC1 entering system highest emission rate was
if over 4 Ib/hr HC1 discharged 0.7 Ib/hr
0.2 Ib/M Btu, steam generation
most stringent
Benzene S. vinyl chloride
controlled at NESHAP
Siloxanes, phthalates No current standards
significant emissions
PCDD3, PCDFs No current standards
<0.25 - <1.33
All V.O. emissions compared well
OSHA PELs, all under limits
Phthalates above OSHA PEL limit,
no PEL for siloxanes
Not detected at detection limits,
1 ppb dioxin considered safe by CDC
<
I
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- v -
TABLE OF CONTENTS
CONTENTS PAGE MO.
SUMMARY
Background i
Test Results i
CONCLUS ION i i
RECOMMENDATIONS Hi
BACKGROUND 1
Demonstration Trials 2
OPERATIONAL PROBLEMS 5
Combustion Bed Agglomerate 5
Negative Stack Pressure Sampling 5
Modified Method 5 Sampling 5
Siloxane Interference in Stack
Emission Analysis 5
Pneumatic Transfer Sys-tem 6
TEST RESULTS 6
Combustion Temperature, Residence Time,
and Excess Oxygen 7
Combustion Efficiencies 7
DREs 7
Carbon Monoxide, CO 9
Hydrogen Chlor ide, HC1 9
Nitrogen Oxides, NOX 9
Particulates 12
PCB Emissions 13
Dioxins and Furans 13
PICs 14
Ash Res idues 15
PERFORMANCE STANDARDS FIR NON-LIDQUID
PCB INCINERATORS 24
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- VI -
LIST OF FIGURES
FIGURES • PAGE NO.
FIG. 1. GA TECH CIRCULATING BED COMBUSTOR 3
FIG. 2. GA CBC TRANSPORTABLE CONCEPT 3
FIG. 3. GA CBC FLOW DIAGRAM 4
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- VI 1 -
LIST OF TABLES
TABLES
PAGE NO.
TABLE A GA TECH DEMONSTRATION TEST RESULTS iv
TABLE 1 COMB. EFF.,-DRE, AND STACK EMISSIONS.... 8
TABLE 2 POLLUTANTS IN STACK EMISSIONS 8
TABLE 3 VOLATILE ORGANICS. VOST RESULTS 11
TABLE 4 SEMI-VOLATILE ORGANICS: MM5 RESULTS 12
TABLE 5 GA TECH PCB DEMONSTRATION TEST RESULTS.. 17
TABLE 6 GA TECH DEMONSTRATION TEST RESULTS 18
TABLE 7 GA TECH PCB STUDY TEST RESULTS 19
TABLE 8 GA TECH PCB STUDY TEST RESULTS 20
TABLE 9 DREs ADJUSTED FOR PCB LOSS IN
SAMPLING TRAIN 21
TABLE 10 POLLUTANTS EMISSIONS VS. STANDARDS
OR CRITERIA, RUNS 1 THRU 3 22
TABLE 11 POLLUTANTS STANDARDS OR CRITERIA,
RUNS 5 THRU 7 23
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GA TECHNOLOGIES, INC.
DEMONSTRATION TRIALS FOR NATIONWIDE PERMIT
EVALUATION REPORT
BACKGROUND
The demonstration trials were conducted to obtain an EPA
nationwide permit to operate the PCB destruction facility, a
transportable 16" diameter unit located in La Jolla,
California. The data generated will be used to design a 36"
transportable commercial facility to treat PCB-contaminated soil
at a site in Berkeley Heights, New Jersey owned by Gulf Oil
Corporation, a subs id ivis ion of Chevron Corporation. Gulf Oil
has been working with the New Jersey Department of Environmental
Protection (DEP) to quantify the extent of contamination and to
determine the best method to clean the site. Some portions of
the Berkely Heights site were found to contain as much as 6000
*
ppm PCBs.
The New Jersey DEP has recently imposed extensive study
requirements in the form of a 50 feet by 50 feet sampling grid to
gather subsoil data. Consequently Chevron has shifted emphasis
to initiate the commercial use of the CBC from the New Jersey
location to a PCB-contaminated site in Alaska.
GA Technologies demonstrated the Circulating Bed Combustor
(CBC) shown in Figures 1 and 2 for disposal of PCB-contaminated
soil spiked to 10,000 ppm PCB concentration. The CBC uses high
turbulence, low temperatures and recircul ating solids to destroy
PCBs. GA claims high turbulence ensures good contact between the
waste and both incoming air and recirculating hot solids which
rapidly heats the waste to combustion temperature while in the
presence of excess air. Combustion takes place along the entire
height of the combustion chamber. Solids are separated from
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off-gases by an integral cyclone and returned to the combustor
through a nonmenchanical seal. Temperatures are uniform, within
_+50°F, throughout the loop. The'entire unit operates slightly
below atmospheric pressure to preclude fugitive emissions. As an
alternate to a wet scrubbing sytem, limestone is fed into the
combustor primarily to neutralize and to reduce HC1 and other
acidic gases in the stack gases. A flow diagram illustrates the
process in Figure 3.
Demonstration Trials; The demonstration trials were
conducted during the period from May 24 through May 29, 1985.
Three runs each of four-hour duration were reguired to fulfill
conditions of the demonstration permit. However, four test runs
were completed, the fourth run being of two-hour duration solely
to collect a particulates sample to satisfy all sampling
reguirements for Test 1. The particulates sampling filter paper
became dislodged during Test 1 nullifying the sample and
necessitating a fourth make-up test run.
*
Three additional test runs were completed after the
demonstration trials. One test (Test 5) was conducted at a lower
combustion temperature with the spiked soil and the other two
tests (Tests 6 & 7) were conducted feeding site soil from
Berkeley Heights. Although these last three tests were not part
of the PCB disposal demonstration, data from these tests are
included to provide additional information.
The demonstration tests were auditted by Team Leader Jared
Flood and Chemical Engineer Hiroshi Dodohara of the PCB Disposal
Section of Chemical Regulation Branch, Office of Toxic
Substances. Gary Kelso and Fred Bergman of Midwest Research
Institute coordinated the sampling of solids streams and the
sampling of stack emissions, respectively. The laboratory audit
was performed by John Smith of Design Development Branch, Office
of Toxic Substances.
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FLUE GAS
TO STACK
INDUCED
DRAFT FAN
FLUE-GAS COOLER
COOLING WATER
BAGHOUSE
FILTER
FIGURE 1.
GA TECHNOLOGIES
CIRCULATING
BED COMBUSTOR
CYCLONE
COMBUSTION
CHAMBER
FINE ASH REMOVAL I
SOLIDS-RETURN LEG
SOLID-
FEED
PORTS
AIR INLET
COARSE ASH REMOVAL /
FIGURE 2. GA CIRCULATING BED CUMBUSTOR TRANSPORTABLE CONCEPT
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STACK
STAC
ASH REMOVAL AND
COOLING SYSTEM
BED ASH OUTPUT
GRAB SAMPLE
BAG HOUSE FINES
THIEF SAMPLE
FIGURE 3
CIRCULATIONG 8ED COMBUSTOR FLOW DIAGRAM
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OPERATIONAL PROBLEMS
Combustion Bed Agglomerates; Agglomeration of soil in the
combustor bed affected mixing efficiency with direct reduction in
the combustion efficiency (CE). Cause of the agglomeration was
attributed to power failure from electrical circuit breakers
which resulted in flame-out (extinguishment of burner flame).
The process upset caused by the flame-out ultimately resulted in
hot spots along the combustor system which contributed to the
formation of agglomerates.
Negative Stack Pressure Sampling; The stack sampling contractor
had no experience in the sampling of stacks under small vacuum
pressures. Most stacks are under positive pressures or at
atmospheric pressures. In one sampling seguence as the sampling
instrument was being replaced, a pressure pulse directed back to
the baghouse filters caused fly ash to disperse throughout the
operating bay resulting -in the evacuation of the entire
office/pilot plant building. Wipe test analysis were performed
after clean-up and prior to resumption of operations.
Modified Method 5 Sampling; The sampling contractor had no prior
experience in the Modified Method 5 (MM5) sampling technigue.
They received much guidance from the EPA consultant (Fred Bergman
of MRI) during the course of operation. Their inexperience
caused much delay in start-up of the demonstration tests.
The MM5 sampling train is eguipped with an imp ing er to
collect chloride emissions. The impinger normally contains
caustic solution to absorb the chlorides. For the purpose of
this demonstration, mercuric chloride was substituted for the
caustic solution.
Siloxane Interference in Stack Emission Analysis; Use of silcone
sealant to install an in-line oxygen monitor at a more
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- 6 -
advanatageous location apparently caused siloxanes to enter the
stack gas stream and ultimately interfered in the laboratory
procedures and analysis of the stack gas samples. However, the
silicone sealant was not confirmed to be the source of the
siloxanes. Silicone rubber sealants in the sampling trains or
other similar sources may have been the problem.
Pneumatic Transfer System; The soil pneumatic feed transfer
system was designed for handling high density, uniform
radionuclear particles with right angle bends throughout the
unit. The damp, irregularly shaped soil fed during the trials
were not ideal for the pneumatic transfer system. Periodic
clogging of the transfer ducts caused difficulties during the
processing; however, the disposal operations were not affected.
Field CBC units to be constructed in the future will likely not
incorporate pneumatic feed systems.
TEST RESULTS
Test results were submitted to EPA on September 4, 1985.
Quality assurance (QA) results for the laboratory were not
available until December 2, 1985. The QA audit indicated
adequate performance by Advanced Technologies, Incorporated of
National City, California. These results demonstrated that the
GA Technologies CBC incinerator is capable of destroying non-
liguid PCB as required by 40 CFR 761.70(b)(l) and (2). Results
from triplicate tests indicated less than one part per million
(ppm) PCBs in both the bottom ash and the fly ash. Stack gas
samples revealed less than the emission standard of 0.001 gram of
PCB emitted per kilogram of PCB introduced into non-liquid PCB
incinerators.
Tables 1 through 4 summarize results of the seven tests runs
including DREs, combustion efficiencies, and stack emissions.
Tables 5 through 8 tabulates available results from all test
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runs. A discussion of per formance parameters by item follows.
Combustion Temperature, Residence Time, and Fxcess Oxvnen: PCB
incinerator performance standards pursuant to 40 CFP 761.70(a)(l)
for combustion temperatures, residence time, and excess oxyqen do
not apply to non-liauid PCB incinerator.
Combustion Efficiencies; PCB rules require a combustion
efficiency of 99.9% for non-liauid PCB incinerators. Tests 1, 2
and 3 meet this standard. However, Tests 4 through 7 fell short
of the 99.9% requirement.
Test Nos.
Combustion 1234
Efficiency 99.94 99.95 99.97 99.82 99.67 99.80 99.85
According to GA Technology representatives the lower
combustion efficiencies obtained in Tests 4 through 7 resulted
from the formation of agglomerates in the combustor bed. The
agg lone rates reduced the mixing efficiency of the combustor bed
resulting in higher carbon monoxide levels than usual and lower
combustion efficiencies. Agglomerates were formed initially
during Test 3 when power failures resulted from a faulty circuit
breaker. Temperature excursions as high as 1900°F and above
occured which potentially causing the agglomerate formation. On
completion of Test 3 the CBC was shutdown for the long Veterans
Day weekend. The following short work week imposed some time
constraints, because four tests were scheduled during the
folowing four days. With a tight schedule to complete, the CBC
was not cleaned out properly and the formation of agglomerates
seemingly worsened thoughout Tests 4 through 7 with accompanying
low combustion efficincies.
_DREs_: Except for Test 7, DREs for all tests were within the PCB
incinerator criteria of 99.9999% (six 9s). Tests 6 and 7
initially indicated DREs of 99.999% and 99.995 respectively.
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PCS DESTRUCTION TEST 'RESULTS
TABLE 1
COMBUSTION EFFICIENCY, DESTRUCTION
AND REMOVAL EFFICIENCY (DRE), AND STACK EMISSIONS
TEST
NO.
1
2
3
4
5
6
7
TEST
NO.
1
2
3
4
5
6
7
TEST
TEMPERATURE, °F
1,805
1,805
1,795
1,815
1,625
1,795
1,805
ug/m
0.087
0.49
0.40
(b)
0.038
0.031
0.31
COMB.
EFF. %
99.94
99.95
99.97
99.82(a)
99.67(a)
99.80(a)
(
99.85
(
POLLUTANTS
DIOXIN 3
ug/m
(d)
< 0.0092
< 0.029
(b)
< 0.0049
< 0.0093
< 0.0019
DRE %
> 99.9999
> 99.9999
> 99.9999
(b)
> 99.9999
CO HC1
PE*n PPn
35 57
28 202
22 255
105 266
119 266
99.999 124 55
> 99.9999) (c)
99.995(a) 72 29
> 99.9995) (c)
NO
ppft
25.7
24.8
76.1
22.3
22.9
55.4
18.1
TABLE 2
IN STACK EMISSIONS
FURANS.,
ug/hi
(d)
< 0.0027
< 0.015
(b)
< 0.0032
< 0.0029
< 0.0016
TCB 3 PARTICULATES
ug/m gr/dscf
< 0.28
< 0.28
< 0.29
(b)
l,500(f)
3,890
l,160(f)
See Test 4
0.0425
0.0024
0.0950(e
0.0171
0.0219
0.0053
(a) Did no meet PCB incinerator standard of 99.9 %
(b) Data not requested, test for particulates only
(c) Based on calculated W . derived from chloride mass balance
(d) Data not obtained, interference from silicones in analysis
(e) Did not meet particulates standard for RCRA and CAA incinerators
uof 0.08 gr/dscf
^ i
!f) 3 is roughly equivalent
m
24.8
, can convert by multiplying by —r——
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- 9 -
However, when back-calculated for ORE usina mass balance for
chlorides, the DREs were 99.9999% and 99.9995%.
DRRs for Test Nps.
4 5
99.9999 99.9999 99.9999 * 99.9999 [99.9999] [99.9995]
* Test was conducted for particulates samolinq only, ORE was
not required.
[ # 1 Calculated by use of chloride mass balance.
The apparent low DREs for Tests 6 and 7 were caused by cross-
contamination of PCBs from spiked soil having the high PCB level
of 10,000 ppm. Feed material for Tests 6 and 7 were site soil
from Berkely Heights with low PCB levels of 20 ppm and 47 ppm
respectively. Residual soil high in PCB in the feed system from
previous tests cross-fed into CBC with soil of low PCB levels in
Tests 6 and 7. The higher DP.Fs of 99.9999% and 99.9995% were
calculated by summing UD inorganic and organic chlorides in the
feedstock and in discharges, and then compensating for the
additional chlorides introduced into the CBC combustor by the
residual soil from previous runs.
Carbon Monoxide, CO; Although standards for carbon monoxide
emissions do not exist for incinerators, limits are promuloated
for ferroalloy production facilities (40 CFR 60.263) of 20% or by
volume or 200,000 ppm of carbon monoxide and for petroleum
refineries (40 CFR 103) of 0.05% by volume or 500 ppm carbon
monoxide. The highest concentration of carbon monoxide
discharged during the CBC demonstration was 124 ppm CO in Test fi.
Test No.
1 2 3 4 5 6 7
CO, ppm 35 28 22 105 119 124 72
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Hydrogen Chloride, HCjj Performance standard for RCRA (40 CFR
340) and CAA (40 CFR 61) incinerators is the larqer value of
hydroqen chloride discharqed at rates of four (4) pounds per hour
or at rates of one per cent of the chorides entering the
pollution control eauipment. The hiqhest HC1 emission rate was
for Test 4 with a stack rate of 550 dscf/min of qas containinq
266 ppm HC1. This rate is equivalent to an emission rate of
about 0.7 Ib/hr of hydrogen chloride, well below the standard for
discharges of HC1.
Test No.
12345
HC1 , ppm 57 202 225 266 266 55 29
Nitrogen Oxide, NOy; No nitronen dioxide emission standards
exists for incinerators; however, standards do exist for steam
and electric utility steam qenerating units.The hiqhest NOX
emission was 0.156 Ib NC> /MBtu (based on a molecular of 38
x»
grams/qram molecular weiqht, as an averaqe of predominant species
N02 and NO), as seen below:
TEST NO. 1 2 3 4 5 6 7
NOV, ppm 25.7 24.8 76.1 2?.3 22.9 55.4 1R.1
X
NO , In/MBtu 0.037 0.036 0.156 0.035 0.036 0.086 0.028
X
The most strinqent standards are those for gaseous fuel at 86
nanograms N0v/Joule or 0.2 pounds NO /million Btu of heat
X **
input. These standards are based on quantity of nitroqen dioxidp
per power rating or heat input rating and are presented at 40CFR
60.40 and 40a as:
§60.40 Steam Generating Units of 73 Megawatts or 250 million
Btu/hour input or more
N0y Emission Standard
FUEL TYPE nq/Joule 1 b/M Btu
Gaseous fuel with or without 86 0.20
wood residue
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- 11 -
PTCs(a)
TABLE 3 VOLATILE ORGANICS:(C*UT6T RESULTS(b)
ORGWICS
Benzene
Bromonrethane
2-butanone
Chloroethane
Chorofom
Chlorcrethane
Ethylbenzene
Tetrahydrof uran
Toluene
Total Xylenes
1,1,1 Trichloroethane
Trichlorothene
Vinyl Chloride
Alkanes
Alkenes
Alkyl furans
Aldehydes
Sil.anes
ORGAN TCS CPM:EOTRATIONS, uo/m
3 (c)
TEST 1
>293.68
-
-
27.65
>262.8 >
17.14
-
-
7.20
0.96
-
0.43
-
0.43
20.04
12.55
0.49
224.37
TEST 2 TEST 3
>389.8
-
-
30.10
1,506.
31.74>1
-
-
3.58
-
0.42
-
5.17
-
9.53
3.36
-
217.9
>214.6
9.02
-
4.47
>719.9
,221.
35.62
2.13
1.86
-
11.2
0.39
-
90.96
57.78
3.23
29.66
232.57
TEST 5
38.72
-
-
-
0.43
4.92
-
2.20
5.02
1.82
-
0.26
-
0.21
6.42
-
0.24
192.4
TEST 6
49.84
-
-
-
>82.54
29.14
0.43
-
6.87
7.31
6.31
-
-
1.77
12.22
-
0.23
129.9
TEST 7
39.3
-
6.48
-
2.93
2.28
1.31
0.71
7.53
8.18
-
0.82
-
-
8.40
-
0.49
667.9
(a) PICs = Products of Incomplete Combustion
(b) Volatile Oroanic Sanplinq Train
(c) Each result is an averaqe of 6 sample analyses taken during the test.
-------
- 12 -
PTCs(a) .
TABLE 4 SEMI- VOLATILE OPGWTCS: MM5 RESULTS(b)
ORGAN ICS mNPENTRATIONS, ug/m3
ORGAN ICS TEST 1 TEST 2 TEST 3 TEST 5 TEST 6 TEST ~>
Acyclic Hydrocarbons - 9,165 23,571 24,645
Aldehvde/ketone 30.24 1.87 38,257 1,887
Carbon acids/bases 58.25 79.57 11,065 - 14,246 11,618
1,2,4-Tr ichlorobenzene - - 1,536 3,885 1,162
Chlorinated hydrocarbon 19.21 -
Phenol - 19.21 52.71 - 6,994 2,817
Phthalates 63.8 24.70 - - 56,986 10,738
Siloxanes 99.86 85.06 56,200 2,156 36,264 4,577
(a) PICs = Products of Incomplete Combustion
(b) EPA Modified Method 5, a sanoling train for particulates with an addition
of an XAD resin cartridge for semi-volatile organic sampling
cont'd
NDX Emission Standard
FUEL TYPE ' no/Joule Ib/M Btu
Liauid fossil fuel with or 130 0.30
without wood residue
Solid fossil fuel with or 300 0.70
without wood residue
§60.40a Electric Utility Steam Generating Units of 73 Megawatts
or 250 Btu/hour input or nr>re
NZ> Emission Standard
FUEL TYPE ng/Joule Ib/M Btu
Gaseous fuel (Coal derived) 210 0.50
All others 86 0.20
Liquid fuel (Coal derived) 210 0.50
Shale oil 210 0.50
All others 130 0.30
Solid Fuel 210 0.50
-------
- 13 -
Particulates: Emission standards for RCRA and CAA incinerators (40 CFR
264.340 and 40 CFR 60) limit the discharge of particulates to 0.08 or/dscf.
Test 4 discharged particulates above the standards (0.095 qr/dscf). This
condition was attributed to process air pressure to the haqhouse filter above
that recommended by the manufacturer. The high rressure apparently stretched
the filter media allowing higher than normal particulates to pass through the
media.
Test No.
Particulates, * 0.0425 0.0024 0.0950 0.0171 0.0219 0.0053
gr/dscf
* See Test 4 results
PCB Emissions; For non-liguid PCB incinerators, the emission standard is
0.001 g PCB/kg PCB introduced into the incinerator. All tests except for Test
7, complied with this critical standard. PCB stack emissions for the CA CBC
unit were:
PCB Emissions
TEST NO. grans PCBs out/kg PCRs Introduced
1 0.000045
2 0.00019
3 0.00023
4 sanple not reguired
5 0.000017
6 0.00022*
7 0.0046*
* Calculated fran chloride mass balance
Tn the laboratory analysis of PCBs, rinseate fron the cleaning of the MM5
probe v**s not analyzed for PCBs. Likewise, the particulates collection
samples were not extracted for residual PCBs. Fred Bergman of MRI indicates
that up to 80 percent of the total guantity of PCBs may reside in the nrobe
and in the particulates and particulates filter media. Assuming two values,
50% and 8H%, of the total PCBs to be remaining in the probe and particulates
-------
- 14 -
system, the D3Es were recalculated. Table 9 indicates that at the 50% level,
all but Run 7 met the six 9s criteria (using the chloride mass balance"
results). At the 80% level, all tests treating spiked soil (10,000 ppm PCBs)
met the six 9s criteria. One run with the site soil feed passed the six 9s
criteria and the second failed (usinq the chloride mass balance results).
'*,
Dioxins and Flirans; No dioxins or furans were detected at the detectable
levels indicated, the hiqhest detectable concentrations of dioxins and furans
in the stack emission was 0.029 ua/nr (see Table 2). Althouqh emission
standards do not exist for dioxins and furans, a ERE of six 9s for the
destruction of PCBs Arochlor 1260 meets with conditions for incinerators
burninq desiqnated dioxin-containinq waste under PCRA rule 40 CFR 264.343.
The incinerator must meet the six 9s DRE for the principal POHCs, in this case
Arochlor 1260, which are more difficult to burn than tetra- , penta-, and
hexachorodibenzodioxins and furans. The measure of cumbustion difficulty is
the heat of combustion, the lower heat of combustion indicating a hiqher
degree of combustion difficulty. A comparison is presented below.
Dioxins
Tetra
Ttenta
Hex a
Heat of
Combustion
Kcal/qm
3.46
3.10
2.81
»
Furans
Tetra
tenta
Hexa
Heat of
Combustion
Kcal/qm
3.65
3.40
3.07
Arochlor
1260
(Composition)
Benta (12%]
Hexa (38%)
Hepta (41%)
Octa (8%)
Heat of
Combustion
Kcal/qm
3.65
3.25
2.98
2.72
Althouqh the PCR-spiked soil is not one of the RCRA desionated dioxin-
containinq waste, the capability to meet the performance standards has
certainly been demonstrated.
The concentrations of dioxin and furan residues in the fly ash and the bed
ash did not exceed 1.33 ppb (hiqhest detectable levels) for Tests 1, 2 and 3
(see Tables 6 and 8). Dioxin and furan concentrations were no hiqher than 3.8
ppb for Tests 5, 6, and 7, (hiqhest dectable levels) indicatinq that the lower
Combustion Efficiency in these tests had a noticeable effect on ash content
for these orqanics. Soil contaminants lower than 1 pnb dioxins** is
considered by the Center for Disease Control to be environmentally safe.
** Conversation with D. Keehner, Chief, Req. Sect. CRB/EED/OTS 12-12-85.
-------
- 15 -'
PICs; Products of incomplete combustion (PICs) are listed in Tables 3 and 4
as \folatile and Semi-volatile organics. Dioxins and furans were previously
discussed. Tables 10 and 11 tabulates the high emission values for the
volatile and semi-volatile organics detected in the stack emissions samples.
All but two of the orqanics are currently not renulated under the Clean Air
Act. Benzene and vinyl chloride are controlled via the National Emissions
Standard for Hazardous Air Pollutanta (NESHAP). Renzene is regulated under
the Equipment Leak provisions of NESFAP which controls fugitive emissions.
Equipment is reguired to operate at a 500 ppm above background level. Leaks
are defined as detections of 10,000 ppm or greater of vapors at the equipment,
and are required to be repaired within five days. Vinyl chloride has an
emission standard of 10 ppm under NESH?U?.
With the need for a benchmark to compare the emission levels of stack
gases and vapors, the OStft. standards for worker exposure level to each organic
chemical was used. The standards listed in Tables 10 and 11 represent time-
weiqhted averages (TWA) of permissible exposure level (PEL) to the organic
vapors for a worker during an eight-hour work shift. Comparison of the
Volatile Organics emissions to PEL values reveal that they are generally well
below the C6HA standards. The Semi-\folatile Organic emissions for Tests 1, 2,
and 3 are again generally below the PEL levels; however, emissions for Tests
5, 6, and 7 indicate a tendency for higher levels of Semi-UDlatile Organics.
Carbon acids and bases with an emission value of 14.25 mg/nr is greater than
•3 -5
the PEL value of 12 mq/m . Pht-.halates emissions were 57 mq/irr and compares
poorly with a PEL of 5 mg/nv3. Low combustion efficiencies attained during
Tests 5, 6, and 7 may have resulted in higher values of Semi-^latile
Organics.
k. Ash Residues; The ashes fron the CBC incinerator were predominantly
treated soil. Bed ash is discharged from the CBC combustion chamber and fly
ash results from treatment of the flue gas by the bagnouse filters. In all
cases, the PCB levels were below the concentration necessary for designating
the treated soil as non-regulated for PCBs (2ppm or 2,000 ppb per congener).
Dioxins and furans were not detected at those detectable limits designated.
-------
- 16 -
Ash residues containing dioxins and furans in the range from 0.27 to 1.28 ppb
fron a RCRA incinerator were proposed for delisting as a hazardous waste (FR
50 23721-23728, Jine 5, 1985).
Test No.
1 2 3 4 5 6 7
Bed Ash
PCBs, ppb 3.49 33.27 185.9 * 5.3 71.75 314.8
Dioxins, ppb <0.37 <1.22 <1.23 * <3.8 <1.83 <1.89
Furans, ppb <0.25 <0.85 <1.33 * <1.88 <1.21 <1.50
Fly Ash
PCBs, ppb 66.45 9.90 32.12 * 26.81 106.0 55.2
nioxins, ppb <0.58 <0.25 <1.33 * <1.24 <0.84 <3.1
Furans," ppb <0.72 <0.54 <0.84 * <1.12 <0.58 <2.8
-------
- 17 -
TABLE 5 •
GA TECHNOLOGIES, INC.
PCB DEMONSTRATIQN TEST RESULTS
TEST 1
Soil Feed Rate, Ib/hr 327.5
Total Soil Feed, Ib 1,310
PCB Feed Concentration, ppn\ 11,000
(MRI results, GC/ECD) (9,600)
(MRI results, GC/ttS) (8,500)
PCB Feed Rate, Ib/hr (W. ) 3.65
in
CO, ppm 35
C02, % 6.2
NO , ppm 25.7
X
Combustion Eff. % 99.94
Superficial Velocity, ft/sec 18.
Residence Time, sec 1.18
Destruction Temp. °F 1,805
Excess 02, % 7.9
Stack HC1, ppn , 57
Stack Gas Flow Rate, dscf/friin 504
TEST 2
411.5
1,646
12,000
(9,500 & 7,900)
(9,140 & 7,950)
4.94
28
6.0
24.8
99.95
7 18.7
1.18
1,805
6.8
202
509
PCB Output Rate, Ib/hr (W ) 1.65E-7 9.45E-7
DRE, % > 99.9999 > 99.9999
Participates Concentrations
Dry, gr/dscf see Test 4
Wet, gr/acf see Test 4
N/H = not required, Test 4 only for
CO
Destruction Renoval Efficiency (DRE)
0.0425
0.0227
particulates
X 100
W. - W .
_ in out 1QQ
X 100
in
TEST 3
323.8
1,295
9,800
(8,900)
(8,050)
3.17
22
7.5
76.1
99.97
18.1
1.22
1,795
6.8
255
486
7.22E-7
> 99.9999
0.0024
0.0013
TEST 4
428.0
856
10,000
-
4.28
105
5.9
22.3
99.82
17.6
1.25
1,815
6.2
266
550
N/R
N/R
0.0950
0.0551
-------
- 18 -
TABLE 6
GA TECHNOLOGIES, INC.
DEMONSTRATION TEST RESULTS
PCBs CONCENTRATIONS
1,800 12,000 33.27 9.90 >
1,800 9,800 185.9 32.12 >
1,800 10,000 N/R N/fc
DIOXIN CONCENTRATIONS
FEED BED ASH FLY ASH
ppb ppb ppb
< 1.55 < 0.37 < 0.58
< 1.82 < 1.22 < 0.25
< 12.8 < 1.23 < 1.33
N/R
*
(c)
FURAN CONCENTRATIONS '
< 33.8 < 0.25 < 0.72
< 2.62 < 0.25 0.0092
< 12.8 < 1.23 < 1.33
N/R
TRICHLOROBENZEN CONCENTRATIONS
1,800 < 0.33 < 0.33
1,500 < 0.33 < 0.33
2,100 < 0.33 < 0.33
ORE STACK GAS
% CONC.(ug/in )
99.9999 0.087
99.9999 0.49
99.9999 0.40
N/R N/R
STACK GAS
CONC.(ug/fo3)
-
0.0092
0.029
-
0.029
< 0.28
< 0.28
< 0.28
(a) = MRI results for bed ash and fly ash are all < 2 ppm by GC/MS method
(b) = PCB 1260
(c) = conservative estimate since no standards were available for
hex a-, hepta-, or octabenzofuran
-------
- 19 -
TABLE 7
GA TECHNOLOGIES, INC.
FOB STUDY TEST RESULTS
PCB Feed Rate, Ib/hr (W. )
in
_ TEST 5
Soil Feed Rate, Ib/hr
Total Soil Feed, Ib
PCB Feed Concentration, ppm 12,000
PCB Fee
CO, ppm
C02, ppm
NO , ppm
Combustion Eff. %
Superficial Velocity, ft/sec
Residence Time, sec
Destruction Tenp. °F
Excess 0_, %
Stack HC1, ppm
Stack Gas Flow Rate, dscf/min
(a)
TEST 6
(a)
TEST 7
(a)
PCB Output Rate, Ib/hr (W
Qut
ORE, %
Particulates Concentrations
Dry, gr/dscf
Wet, gr/acf
398.0
1,592
12,000
4.78
119
3.6
22.9
99.67
: 16.6
1.32
1,625
9.7
266
n 540
0 8.02E-8
> 99.9999
0.0171
0.0100
330.3
1,321 1
20
0.0066
124
6.1
55.4
99.80
19.3
1.14
1,795 1
8.6
55
540
6.01E-8
> 99.999
(> 99. 9999) (b)
0.0219
0.0122
285.2
,711
47
0.00131
72
4.9
18.1
99.85
18.6
1.18
,805
8.1
29
543
6.45E-7
> 99.996
(> 99. 9995) (b)
0.0053
0.0031
(a)
(b)
Tests 5 and 6 were 4-hour duration; Test 7 was 6-hour duration
Based on calculated W. derived from chloride mass balance
in
-------
- 20 -
TABLE 8
GA TECHNOLOGIES, INC.
PCS STUDY TEST RESULTS
PCBs CONCENTRATIONS
TEST
NO.
5
6
7
TEMP FEED(b) BED ASH
°F ppm ppb
1,625 12,
1,800
1,800
000 5.3
20(c) 71.75
47(e) 314.8
FLY ASH
PPb
26.81 >
106.0 >
(>
55.2 >
(>
ORE STACK GAS
% CONC.(ug/m )
99.9999 0.038
99.999 ... 0.031
I fi t
99.9999Ta;
99.995 ,H. 0.31
99.9995T
DIOXIN CONCENTRATIONS
TEST
NO.
5
6
7
FEED
PPb
< 7.42
< 1.97
< 2.13
BED ASH
ppb
< 3.8
< 1.83
< 1.89
FLY ASH
PPb
< 1.24
< 0.84
< 3.1
STACK GAS
CONC.(ug/n3)
< 0.0049
< 0.0093
< 0.0019
FURAN CONCENTRATIONS
5
6
7
< 390 ( a)
< 1.27
< 1.53
< 1.88
(a) < 1.21
(a) < 1.50
TRICHLOROBENZ ENE
5
6
7
(a) =
(b) =
(c) =
(d) =
(e) =
1,300
< 0.17
< 0.17
MRI results
PCB 1260
PCB 1248
Values based
Mixture of 6
< 0.33
< 0.33
< 0.33
for bed ash and
< 1.12
< 0.58
< 2.8
CONCENTRATIONS
< 0.33
< 0.33
< 0.33
0.0032
0.0029
0.0016
1,540
3,890
1,160
fly ash are all < 2 ppm by GC/MS met!
on chloride mass balance
ppm 1248 and 41 ppm PCB 1260
-------
- 21 -
TABLE 9
ORES ADJUSTED FOR PCB LOSS IN SAMPLING TRAIN
Win
TEST
1
2
3
4
5
6
7
Ib/hr
3.
4.
3.
4.
4.
0.
[0
0.
[0
60
94
17
28
78
0066
.28]
0131
.14]
1
9
7
8
6
6
Wbut
Ib/hr
.65X10~7
.45X10"7
. 22X10~7
PCBs
.02X10"8
.oixio"8
.45X10"7
DREs
99.
99.
99.
samples
99.
99.
[99.
99.
[99.
WITH % LOSS
0%
9999954
9999809
9999772
99
99
99
IN SAMPLING TRAIN
50%
.9999908
.9999617
.9999545
99
99
99
80%
.9999771
.9999044
.9998861
not required
9999983
9990894
9999785]
9950763
9995393]
99
99
[99
99
[99
.9999966
.998178
.9999571]
.9901527
.9990786]
99
99
[99
99
[99
.9999916
.9954468
.999893]
.9753817
.9976964
Win = PCBs fed into CBC with contaminated soil
Wout = PCBs stack emissions
[##] = PCB feed rates and DREs based on chloride mass balance
noc- Win - Vfout/[l - wt. fraction PCB loss] inn
ORE X 100
-------
- 22 -
TABLE 10 POLLUTANT EMISSIONS VS. STANDARDS OR CRITERIA
RUNS 1 THRU 3
VOLATILE ORGANICS
ORGANICS
Benzene
Brononethane
2-Butanone
Chloro ethane
Chloroform
Chloromethane
1,1 Dichloroethene
Ethylbenzene
Tetrahyd rofur an
Toluene
Total Xylenes
1,1,1 Trichloroethane
Trichlorothene
Vinyl Chloride
Alkanes
Alkenes
Alkyl furans
Aldehydes
Silanes
SEMI-VOLATILE ORGAN ICS
Acyclic Hydrocarbons
Aid ehyd eA etone
Carbon acids/bases
1,2,4-Tr ichlorobenzene
Chlorinated hydrocarbon
Phenol
Phthalates
Siloxanes
(a)
HIGH EMISSION .,
CONCENTRATION mg/m"
0.761
0.033
0.122
5.500
4.135
0.0031
0.132
0.0066
0.014
0.027
0.0023
0.0064
0.246
0,656
0.027
0.083
0.660
38.26
11.07
0.019
1.854
0.064
56.21
PEL mg/fri
32
20
590
2600
240
200
(d)
435
590
740
435
1900
(e)
1,800
2,200
590
2.6
(f)
(h)
3.6
(i)
2,350
290
12
40
10
19
(j)
(k)
(1)
(o)
(m)
(c)
(n)
.(a) NESHAP(b) _ -
STANDARD ug/m
Equipment Leaks (fugitive
emissions); 10,000 ppm
defines leaks for pump
and valves, must be
repaired 500 ppm above
background limit fort
compressors and closed
vent systan
10 ppm (26 mg/ta )
PEL = Permissible Exposure Limit, 8-hr time-weighted average, CSHA
Standards, 29 CFR 1910.1000.
(b) NESHAP = National Emission Standards for Hazardous Pollutants
(c) Skin exposure; (d) Ceiling nunber
PELs for: (e) xylene; (f) propane, hexar.e; (g) butadiene;
(h) tetrahyrdrofuran; ( i) methyl- and iscbutylamine; (j) octane;
(k) diisobutyl ketone; (1) methy- and isopropylamine;
(1) hexachloroethane; (n) dimethyl- and dibutylphthalate
(o) Threshold Limit Value (TLV) established 1975, An. Conference of Gov't.
Industrial Hygienists (ACGIH)
-------
- 23 -
VOLATILE ORGAN ICS
ORGANICS
Benzene
Bronanethar.e
2-Butanone
Chloroethare
Choroform
Chloronet h are
Ethylbenzene
Tet r ahyd rof ur an
Toluene
Total Xylenes
1,1,1 Trichloroethane
Trichlorothene
Vinyl Chloride
Alkanes
Alkenes
Alkyl furans
Aldehydes
Silanes
SEMI-VOLATILE ORGANICS
Acyclic Hydrocarbons
Aid ehyd eA et on e
Carbon acids/bases
1,2,4-Trichlorcbenzene
Chlorinated hydrocarbon
Phenol
Phthalates
Siloxar.es
(a)
TABLE 11
HIGH EMISSION
POLLUTANT STANDARDS OR CRITERIA
RUNS 5 THRU 7
CONCENTRATION mg/fa
0.093
0.039
4.69
0.080
0.0079
0.006
0.019
0.033
0.027
0.0019
0.071
0.027
t
0.023
3.380
24.65
3.58
14.25
3.89
0.019
7.00
57.00
36.27
3
,(a) NESHAP
(b)
PEL mg/m
32
2Q(c)(d)
590
2600
240(d)
200
435
590
740
435(e>
1900
2.6
l,800(f)
2,200
STANDARD ug/fa
Equipment Leaks (Fugitive
anissions); 10,000 ppn\
defines leaks for punp:
and valves, must be
repaired; 500 ppm abovi
background limit for
compressors and closed
vent systems
590
(h)
3.6
(i)
2,350
290
12
40
10
19
(j)
(k)
(1)
(o)
(m)
(c)
(n)
10 ppm (26 mg/m )
PEL = Permissible Exposure Limit, 8-hr time-weighted average, OSHA
Standards, 29 CFR1910.1000.
(b) NESHAP = National Emission Standards for Hazardous Pollutants, 40 CFR 61
(c) Skin exposure; (d) Ceiling number
PELs for: (e) xylene; (f) propane, hexane; (g) butadiene;
(h) tetrahyrdrofuran; ( i) methyl- and iscbutylanine; (j) octane;
(k) diisobutyl ketone; (1) methy- and isopropylanine;
(1) hexachloroethane; (n) dimethyl- and dibutylphthalate
(o) Threshold Limit Value (TLV) established 1975, Am. Conference of Gov't
Industrial Hygienists (ACGIH)
-------
- 24 -
PERFORMANCE STANDARDS FOR
NON-LIQUID PCB INCINERATORS
1. 40 CFR 761.70(b)(l) Mass air emissions from the incinerator
shall be no greater than 0.001 g PCBAg of the PCB introduced
into the incinerator.
2. 40 CFR 761.70(b)(2) Incinerator shall comply with the
following performance standards:
- Incinerator performance standards for temperature and
residence time do not apply to non-liquid PCB incinerators
- Combustion efficiency of 99.9%
- Rate and quantity of PCBs fed to the incinerator shall be
measured and recorded every 15 minutes
- Incineration temperature measured and recorded continuously
- Stack monitoring shall be conducted when:
- Incinerator is first used for PCB disposal
- Incinerator is first used after modification which may
alter stack emissions
t
- Monitor as a minimum the following:
o2 co
C02 NOX
HC1 Total Organic Chlorides
PCBs Total Particulates
- Continuous monitoring of CO and 02 and periodic monitoring
of CO2
- Shutdown of PCB feed when:
- CO, O2, and C02 monitoring system fails
- PCB feed monitoring systen fails
- Use of water scrubber or alternate to control HC1
------- |