United States
Environmental Protection
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United States
Environmental Protection
Agency
Office of Water &
Waste Management
Washington, D.C. 20460
SW - 908
January 1981
v/EPA
Solid Waste
Hazardous Waste Facilities
Standards for Incinerators
A Summary of the Regulations
Standards and
Permit Requirements
for Dwners
and Operators
of Hazardous Waste
Facilities
The Resource Conservation and Recovery Act of 1976 (RCRA) calls
for a national program to control hazardous waste. All wastes identified
as hazardous in the regulations issued under Subtitle C of RCRA are
tracked by manifests from where they originate to their final disposition
at a facility with authority from the U.S. Environmental Protection
Agency (EPA) or an authorized State to trjeat, store, or dispose of hazardous
waste. Regulations for carrying out Subtitle C of RCRA are set forth
in the Code of Federal Regulations (40 CFR Parts 260 to 266 and 122
to 124). The Federal hazardous waste program became effective November
19, 1980.
One portion of the EPA regulations covering owners and operators
of hazardous waste facilities sets standards for incinerators. These
facilities are covered by two types of standards:
• general requirements for all hazardous waste management facilities
• specific requirements for the various types of facilities
The regulations covering hazardous waste management facilities,
including incinerators, apply to two types of facilities operating under
the RCRA program for controlling hazardous waste:
• those with Interim Status. These facilities were in existence
on November 19, 1980 (the effective date of the regulations).
They have notified EPA of their hazardous waste activities and
have applied for a permit, though processing of their applications
has not been completed. During the processing period, they
must comply with Interim Status Standards set forth in Part 265
of Title 40 of the Code of Federal Regulations. These selected
minimum requirements will move their operations toward RCRA's
goal of protecting human health and the environment.
• those with a permit, either from EPA or a State authorized to
permit hazardous waste management facilities under RCRA.
These facilities must comply with the General (Permit) Standards
(Part 264), which are intended to ensure accomplishment of RCRA's
goal. All new facilities are covered by the General Standards.
In January 1981, EPA is establishing regulations covering several
aspects of incinerator operations:
U.S. Environmental Protection Agency
Region V, Library
230 Sou^i LX.,:K:rn S'.reet
Civcago, Illinois 60604
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Applicability
INTERIM STATUS
STANDARDS
Waste
Analysis
Operating
Requirements
Monitoring and
Inspection
• Interim Status Standards in final form. To allow the public to
comment, they were promulgated on an interim final basis on
May 19, 1980. They became effective on November 19, 1980.
Minor technical and reorganizational changes were made, and
the applicability provision was clarified to include exemptions
for ignitable wastes (Part 265).
• General Standards on an interim final basis. They will be effective
in July 1981 (Part 264).
• information required for Part B of a permit application for an
incinerator and criteria for trial burn permits, on an interim
final basis (Part 122)
• a regulatory proposal, on which public comment is sought, to
modify the General Standards to allow a variance in acceptable
incinerator emissions (Section 264.343)
This document summarizes the major features of the incinerator
regulations established in January 1981.
The Interim Status and General Standards apply to incinerators treating
hazardous waste, except those that are hazardous solely because of
ignitability. Also, combustion of wastes primarily for recovery of their
heat is not considered incineration and so is exempt from these standards.
The Interim Status Standards require the owner or operator of an
incinerator to analyze a new waste to establish normal (steady state)
operating conditions (including waste feed, auxiliary waste feed, and
air flow) and to determine the type of pollutants that might be emitted.
At a minimum, the analysis must determine:
• heating value
• content of halogens (chlorine, fluorine, bromine, iodine) and sulfur
• lead and mercury concentration (unless written, documented
data show that the element is not present)
Results of the analysis must be placed in the operating record.
When the incinerator is being started up or shut down, hazardous
waste cannot be fed unless the incinerator is at normal operating conditions.
The following monitoring and inspections are required:
• Instruments that relate combustion and emission control (for
example, those measuring waste feed, air flow, and temperature)
must be monitored at least every 15 minutes.
• Color and opacity of the stream (smokestack) plume must be
observed visually at least every hour.
• The complete incinerator and associated equipment (for example,
pumps, valves, conveyors, and pipes) must be inspected at least
daily for leaks, spills, and fugitive emissions, and all emergency
shutdown controls and system alarms must be checked to assure
proper operation.
U,S.
Protection Agencyf
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Corrections must be made immediately when problems are detected.
Closure
GENERAL (PERMIT)
STANDARDS
Waste
Analysis
Principal Organic
Hazardous
Constituents
Performance
Standards
When an incinerator is closing, all hazardous waste (including ignitable
waste) and hazardous waste residues (for example, ash and scrubber
sludges) must be removed from the incinerator site. At closure, as through-
out the operating period, any residues that are hazardous must be managed
within the RCRA system.
Under the General Standards, required analysis takes two forms.
• Each waste feed must be analyzed as part of each permit application
and whenever a permit is modified or a trial burn permit is sought.
(Waste feed, rather than waste as received, must be analyzed,
since wastes are often mixed before combustion.) Certain physical
properties of the waste feed must be described, and the analysis
must identify the presence of any hazardous organic constituents
listed in Appendix VIII of Part 261 of the RCRA regulations.
• Throughout normal operation, the owner or operator must ensure
that the waste feed does not deviate from that defined in his
permit.
For each waste feed, the permit will specify Principal Organic Hazardous
Constituents (POHCs) that must be destroyed or removed as required
by the performance standards. POHCs are selected primarily on the
basis of how hard they are to incinerate, but their concentration in the
waste feed is also considered.
Three performance standards are at the heart of this regulation.
The most important is:
• An incinerator must achieve a destruction and removal efficiency
(DRE) of 99.99 percent for each POHC designated for each waste
feed.
This standard allows an incinerator facility credit for removal
of pollutants in air pollution control equipment as well as for
destruction in a combustion zone, and it avoids the technical
difficulties of precise measurements within the extreme conditions
of the combustion zone. The standard still protects the environment
because it covers all emissions before their release and because
the residues trapped by emission control equipment must still
be treated as hazardous wastes and managed properly within
the RCRA system.
There are limits to the DRE approach:
— It is difficult to apply to metals because they are not destroyed
by combustion.
— It fails to describe the actual amount of POHCs emitted.
— It does not account for products of incomplete combustion,
which may be equally or more hazardous than the POHCs
themselves.
To deal with these problems, EPA is proposing a set of procedures
(discussed later in this summary) for varying this performance
standard.
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New Wastes
Operating
Requirements
Monitoring and
Inspection
The two secondary performance standards are:
• An incinerator burning hazardous waste containing more than
0.5 percent chlorine must remove 99 percent of the hydrogen
chloride from the exhaust gas.
• An incinerator burning hazardous waste must not emit particulate
matter exceeding 180 milligrams per dry standard cubic meter.
The three performance standards would be difficult to monitor on
a continuous basis. For this reason, the regulation will be enforced
on the basis of compliance with operating conditions (specified in a
permit) that have been shown to achieve the performance standards.
EPA can modify, revoke, or reissue a permit if tests indicate that the
operating conditions fail to achieve the performance standards.
Each permit specifies the waste feeds it allows and the operating
conditions required for each. For all other waste feeds, the owner or
operator must:
• obtain a new permit or permit modification by demonstrating
the operating conditions needed to achieve the performance standards
• obtain a temporary trial burn permit
Each permit sets limits, on a case-by-case basis, for certain operating
conditions and may set any additional conditions needed to meet the
performance standards. The required conditions are:
• carbon monoxide (CO) level in the stack exhaust gas
• waste feed rate
• combustion temperature
• air feed rate to the combustion system
• allowable variations in incinerator system design or operating
procedures
Three other operating requirements will be applied uniformly:
• During start-up and shut-down of an incinerator, hazardous waste
(except ignitable waste) can be fed only if the incinerator is at
normal operating conditions.
• Fugitive emissions from the combustion zone must be controlled
by:
— totally sealing the combustion zone, or
— maintaining a combustion zone pressure lower than atmospheric
pressure.
• A system must be available for automatically shutting off waste
feed when operating requirements are violated.
The following variables must be monitored continuously when hazardous
waste is being incinerated:
• combustion temperature, waste feed rate, and air feed rate.
These variables most significantly affect the destruction and
removal efficiency and are readily controllable.
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Closure
INCINERATOR
FACILITY
PERMITS
PROPOSAL
OF ADDITIONAL
GENERAL
STANDARDS
• carbon monoxide downstream of the combustion zone and prior
to release to the atmosphere. This is the simplest procedure
for determining that combustion is adequate.
Daily inspection is required of the incinerator and associated equipment
(for example, pumps, valves, conveyors, and pipes).
At closure, the owner or operator must remove all hazardous waste
(including ignitable waste) and hazardous waste residues (for example,
ash and scrubber sludges) from the incinerator site. At closure, as
throughout the operating period, any residues that are hazardous must
be managed within the RCRA system.
The regulations covering the permitting process are being expanded:
• The contents of Part B of the permit application have been expanded
to specify the particular information needed for incinerator facilities.
• The title of the section on Emergency Permits has been changed
to Short-Term Permits, and a new subsection has been added.
The subsection describes procedures and standards for obtaining
a permit for a trial burn to gather data needed to apply for a
permit. Because trial burns are generally of limited duration,
the permitting process has been simplified, where the standards
ensure that the trial burn will be carried out in a manner that
protects human health and the environment.
EPA is proposing the following modifications to the performance
standards for permitted incinerators:
• Combustion by-products formed from POHCs must be destroyed
so that their total mass emission rate from the stack is no more
than 0.01 percent of the total mass feed rate of POHCs.
• The EPA Regional Administrator may, on a case-by-case basis,
set an emission rate of POHCs or hazardous combustion by-products.
This may be more or less restrictive than the normal performance
standard. The variance is to be based on an assessment of the
risk to human health or the environment.
• The Regional Administrator may, on a case-by-case basis, set
limits on mass emission rates of metals, hydrogen halides, and
elemental halogens, if needed to protect human health or the
environment.
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Major Features 40 CPE Parts 264/265, Subpart Q
Where to Find Them
in the Regulations
Applicability (Sections 264.340, 265.340)
Waste Analysis (Sections 264.341, 265.341)
Principal Organic Hazardous
Constituents (POHCs) (Section 264.342)
Performance Standards (Section 264.343)
New Wastes: Trial Burns or
Permit Modifications (Section 264.344)
Operating Requirements (Section 264.345)
General Operating Requirements (Section 265.345)
Monitoring and Inspections (Sections 264.347, 265.347)
Closure (Section 264.351)
Closure (Interim Final) (Section 265.351)
40 CFR Part 122
Contents of Part B (Section 122.25(b))
Short-Term Permits (Section 122.27)
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