United States Environmental Protection Agency Hazardous Waste Engineering Research Laboratory Cincinnati OH 45268 Research and Development EPA/600/S2-86/050 July 1986 Project Summary Practical Guide - Trial Burns for Hazardous Waste Incinerators P. Gorman, R. Hathaway, D. Wallace, and A. Trenholm This Guide concentrates on those as- pects of a trial burn that are the most im- portant and those that are potentially troublesome. It contains practical explan- ations based on experience of Midwest Re- search Institute (MRI) and others in con- ducting trial burns and related tests for EPA. Comments of several industrial plant owners and operators are included in the Guide. It is directed mainly to incinerator operators, those who may conduct the ac- tual sampling and analysis and those who must interpret trial burn results, but it will also be useful for regulatory personnel and others that need to understand trial bums. Potential trouble spots that have been en- countered are: (1) trial burns frequently take more time and effort than an operator anticipates and (2) failure to meet the trial burn requirements. This Project Summary was developed by EPA's Hazardous Waste Engineering Research Laboratory, Cincinnati, OH, to announce key findings of the research pro- ject that is fully documented in a separate report of the same title (see Project Report ordering information at back). Introduction On May 19,1980, the U.S. Environmen- tal Protection Agency (EPA) published regulations under the authority of the Resource Conservation and Recovery Act (RCRA) for hazardous waste incinerators. These regulations require that new and ex- isting incinerators adequately destroy haz- ardous organic compounds and maintain acceptable levels of paniculate and chlor- ide emissions. Owners and operators of incinerators are required to demonstrate the performance of the facility by means of a trial burn. Consequently, industry and control agency personnel have become in- volved in planning for, conducting, and in- terpreting the results from trial burns. A guide has been written to assist those individuals in their efforts. The Guide addresses multiple compon- ents of the trial burn process including planning and preparation, sampling and analysis for the trial burn, process monitor- ing during the trial burn, and data reduc- tion and reporting. It does not directly ad- dress the preparation of the Trial Burn Plan, but it does address some planning aspects that affect Trial Burn Plan preparation and subsequent interpretation of the trial burn results. Summary of Results The probability for success of a trial burn is enhanced by good planning. The major objectives of the planning process are: (a) to select trial burn conditions that provide the plant adequate operating flex- ibility; (b) to assure that the trial burn will be conducted in a manner acceptable to regulatory agencies; and (c) to make the trial burn cost effective. The operating conditions selected for the trial burn must represent the worst case conditions under which the inciner- ator may expect to operate, and therefore needs to be permitted to operata The con- ditions selected may include any or all of the following: Waste containing hardest-to-burn POHC (lowest HHV). Highest concentrations of all POHCs selected. Maximum waste feed rates. Maximum combustion airflow rate (min- imum residence time). Maximum CO level in stack gas. Minimum combustion temperature. Minimum HHV of wasta Maximum thermal input (Btu/hr). Minimum 02 level in stack gas. ------- Maximum Cl content of waste feed. Maximum ash content of waste feed. Minimums or maximums on other oper- ating conditions (e.g., venturi scrubber, AP scrubber water flow rate and pH). POHCs for the trial burn should be selec- ted during development of the trial burn plan. The selection reflects the regulatory approach. In addition to the regulatory criteria, the following two considerations should be taken into account: (1) max- imum flexibility of operating conditions under the permit and (2) ease of sampl- ing and analysis during the trial burn. Currently the regulation requires that a ORE of 99.99% be demonstrated for the selected POHCs. The quantity of waste required is depen- dent on the waste feedrate to be used dur- ing each run, the number of runs, and the duration of each run. Waste feedrate and number of runs are selected by the inciner- ator operator and are specified in the Trial Burn Plan. The sampling time required in each run is usually 3 to 4 hours plus 1 hour to line out the unit before testing starts, and 1- to 2-hour contingencies (plant oper- ating problems or sampling problems). Considering these, a quantity of waste sufficient for 8 hours of operation should be available for each run. If the trial burn involved only three runs, at one set of operating conditions, then waste sufficient for 24 hours of operation should be available. Preparations for the test are numerous; several of the most important items are scheduling, sampling crew activities, equip- ment preparation and calibration, facility readiness, process data, data sheets and labels, and safety precautions. One poten- tial problem that should be addressed dur- ing preparation is how to coordinate with observers during the trial burn. Samples taken during a trial burn are usually brought to the analytical laboratory for transfer to an analytical task leader. At that point, when the samples are check- ed in and transferred, the project leader needs to cross-check that each sample taken in the field has arrived and is intact. Any missing samples can in this way be immediately identified and hopefully lo- cated. Also, any extra samples that have been taken can be identified. Conclusion Always design the sampling and analy- sis so that passage/failure of the 99.99% criterion is determinable. This can best be done by preliminary estimates of POHC concentrations in the stack (assuming 99.99% ORE) and with selection of sampl- ing and analysis methods having appropri- ate upper and lower limits of detection. Ex- perience in using these methods to avoid contamination is also a key factor. P. Gorman, R. Hathaway. D. Wallace, and A. Trenholmare with Midwest Research Institute, Kansas City, MO 64110. Donald A. Oberacker is the EPA Project Officer (see below). The complete report, entitled "Practical Guide— Trial Burns for Hazardous Waste Incinerators," (Order No. PB 86-190 246/AS; Cost: $11.95, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Hazardous Waste Engineering Research Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 45268 BULK RATE POSTAGE & FEES PA EPA PERMIT No. G-35 Official Business Penalty for Private Use $300 EPA/600/S2-86/050 ------- |