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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