x°/EPA
                                 United States
                                 Environmental Protection
                                 Agency
                                 Industrial Environmental Researc
                                 Laboratory
                                 Research Triangle Park NC 2771
                                 Research and Development-
                                 EPA-600/S7-81-108  Aug. 1981
Project Summary
                                 Assessment  of  Hazard
                                 Potential from  Combustion of
                                 Wastes  in  Industrial  Boilers

                                 James W. Harrison, James B. White, and William J. King
                                  The Resource Conservation and Re-
                                 covery Act of 1976 encourages the
                                 conservation of valuable resources,
                                 including energy, consonant with the
                                 protection of environmental quality.
                                 Recently promulgated hazardous
                                 waste regulations allow the onsite use
                                 of wastes as fuels with few restrictions.
                                 In response EPA's Office of Solid
                                 Waste has asked for comment and
                                 advice on this matter. The present
                                 study was undertaken to determine
                                 the extent of the present onsite use of
                                 waste fuel in industrial boilers and
                                 related process equipment, the nature
                                 and quantities of the materials so
                                 disposed, and the current regulations
                                 concerning such use.
                                  Based  upon contacts with Federal,
                                 State, and local environmental pro-
                                 tection officials as well as industry
                                 personnel and the open literature, this
                                 study concludes that: a wide variety of
                                 materials have been burned as fuel in
                                 standard or appropriately modified
                                 combustion equipment; the practice
                                 can be expected to expand  due to the
                                 economic pressures of hazardous
                                 waste disposal and rising fossil fuel
                                 costs; virtually no emission data on
                                 waste fuel combustion (except through
                                 incineration) is available; under condi-
                                 tions of inefficient combustion, signif-
                                 icant paniculate matter  and  high
                                 molecular weight (including polycyclic
                                 organic compounds) emission rates
                                 can be expected; and, finally, within
                                 the scope of this study, no current
                                 regulations were found to ba directed
                                 specifically at waste combustion.
                                   Recommendations for increased
                                 industry contacts, representative site
                                 selection, and a field program in con-
                                 junction with a coordinated regulatory
                                 program to ensure the environmentally
                                 safe use of wastes as fuel are made.
                                   This work, under Contract 68-02-
                                 3170, Work Assignment 21, was
                                 carried out  between June 5,  1980,
                                 and September 30, 1980.
                                   This Project Summary was devel-
                                 oped by EPA's Industrial Environ-
                                 mental Research Laboratory. Research
                                 Triangle Park. NC, to announce key
                                 findings of the research project that is
                                 fully documented in a separate report
                                 of the same title (see Project Report
                                 ordering information at back).

                                 Introduction and Summary
                                   The Resource Conservation and Re-
                                 covery Act of 1976 (RCRA) has among
                                 its objectives "to promote the protection
                                 of health and the environment and to
                                 conserve valuable material and energy
                                 resources." In formulating and promul-
                                 gating regulations for classifying and
                                 dealing with hazardous wastes, EPA's
                                 Office of Solid Waste has deemed the
                                 recovery of energy from waste combus-
                                 tion to be consonant with Congressional
                                 intent as expressed in the RCRA.
                                   Specifically, Part 261 of Title 40 of the
                                 Code of  Federal Regulations defines
                                 solid waste in a manner that excludes
                                 material burned as fuel for the purpose

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of energy recovery. The regulation also
includes criteria for determining whether
or not solid wastes are hazardous. The
effect of the exclusionary definition of
solid waste is to allow ignitable materials
which would otherwise be classified as
hazardous to be regarded  as nonhaz-
ardous if they are burned onsite as fuel
for energy recovery.
  The RCRA-based testing, classifying,
handling, transporting, and disposing of
hazardous waste will be complex,
troublesome, and  an additional cost
item for every generator of such wastes
in the nation. It is therefore anticipated
that a  significant change  in disposal
practice may occur. Many wastes which
were previously discarded may now be
burned  in an attempt to qualify under
the exclusionary definition. These wastes
could include synthesis process wastes,
solvents, lubricants, and other organics.
A further stimulus to such use  is  the
escalating prices of the conventional
fossil fuels that have heretofore been
used almost exclusively  for energy
production. Any materials which can
supplement fossil fuels, at  lower costs
per Btu, will be seriously considered for
use.
  The  Office  of Solid Waste (OSW) is
aware of the many possible consequences
of the  combustion allowed under the
present exclusion, and it plans to begin
consideration of the problems of spent
solvents and waste oil in the fall of 1980
ana of organic chemical process residues
in the fall of 1981. OSW  has  invited
comments on such further regulations
and has specifically solicitated informa-
tion dealing with combustion of wastes
in industrial boilers. It is in response to
this solicitation that the  work being
reported was undertaken.

  EPA's Office of Air Quality, Planning
and Standards (OAQPS), in conjunction
with the IERL-RTP and lERL-Cinn. of
EPA's Office of Research and Develop-
ment (ORD), has initiated a program to
collect information on the current prac-
tice of waste-burning in industrial
boilers and other process heating equip-
ment, the types and quantities of mate-
rials burned, the  state of the  art of
technology for waste combustion  and
waste/fossil fuel co-firing, and the
current environmental regulations and
policies of  State and Federal environ-
mental protection organizations. In
addition to the assessment of current
waste  combustion practices, there are
also plans to assess how  waste com-
bustion in industrial heating equipment
might be carried out in the future under
various regulatory scenarios that will
encourage the complete use of suitable
materials for energy recovery commen-
surate with adequate safeguards for
human health and environmental quality.
  The purpose of this initial work in the
OAQPS/ORD program is to scope the
problem and make recommendations as
to what should be done by EPA to meet
its responsibilities in respect to the
objectives of the RCRA.
  It must be emphasized that the in-
formation  reported  here in  no way
represents an exhaustive survey. The
intent was to collect enough data from
several Federal and  State sources as
well as from prior reports and the open
literature in order to obtain (1) an idea of
what kinds of materials might be used
for  fuel, (2) an  order of  magnitude
estimate of the quantities of these
materials used in industry, (3) some
indication of how these materialsare, or
might be, burned as a fuel in standard
industrial combustion equipment, and
(4) what air quality impacts might be
expected.
  An additional purpose was to find out
on the basis  of a  limited survey how
current environmental regulations are
being interpreted by Federal and State
enforcement officials with regard to
such  waste burning and how those
officials felt that they  might be, or
should be, regulated in the future.

Waste Materials  As Fuel
  Problems with waste  as fuel derive
mainly from the unknown, highly vari-
able nature of waste matter. In order to
determine the proper type of combustion
system for  use with a particular waste,
many properties are  of interest;, but in
an initial screening, the most important
of these are physical state, heat content,
and fuel-borne contaminants.
  Before a waste can be burned as a
fuel its physical state must be suitable
for a  particular burner  type. Physical
state  is normally classed as gaseous,
liquid,  or  solid.  When  dealing  with
waste, however, the difference between
solids and-liquids is frequently not clear
cut. As in the case of still bottoms from
solvent reclamation or  the chemical
industry, physical state is often depen-
dent  on the  process and how much
liquid the industrial processor chooses
to leave behind. The distinction between
liquids, semi-solids, and  solids is there-
fore made on the basis of  viscosity. To be
considered a liquid,  a waste  must be
pumpable  at ambient temperature or
should be capable of being pumped after
being treated to some reasonable tem-
perature (204°C -260°C). This normally
restricts the viscosity of the waste to
less than 10,000 ssu and solids content
to 70 percent by weight.
  Next, a waste must have a  high
enough heat content to develop and
sustain combustion reactions and
maintain required boiler temperatures.
The heat content of waste gases can be
grouped as  High Btu—>5.59 MJ/m3
(>150 Btu/ft3), Medium Btu—3.73-5.59
MJ/m3 (100-150 Btu/ft3), or Low Btu—
<3.73 MJ/m3 (<100 Btu/ft3). The heat
content of liquids and  solids can  be
grouped  as  High Btu—23.26 MJ/kg
(>10,000 Btu/lb), Medium Btu—11.63-
23.26 MJ/kg (5,000-10,000 Btu/lb),
and Low Btu—<11.63 MJ/kg «5,000
Btu/lb). This grouping is only an indica-
tor of a waste's fuel potential.  Some
liquids with thermal values as great as
23.26-25.59 MJ/kg (10,000-11,000
Btu/lb) are incapable of sustaining
combustion, while other wastes with
values as  low  as 10.47 MJ/kg (4,500
Btu/lb) have been burned unassisted.
  Lastly, a  waste must be  relatively
clean in order to burn properly.  After
physical state  and heat content, fuel-
borne contaminants have the greatest
effect on the quality and efficiency of
combustion. Contaminants in gaseous
organic waste include  particles, inor-
ganic gases, and water vapor. Panicu-
late  matter  can foul burner tips and
erode mechanical surfaces, while the
presence of  other gases can affect the
limits of flammability of the waste.
  Solids, metals, water, and inorganic
liquids are the most common contami-
nants of organic  liquid wastes. Not only
do water and  other liquids require
energy to vaporize, but the relative
differences in specific gravities can
cause the mixtures to stratify in holding
tanks and fuel lines. Chemical reactions
cause precipitates to form or can cause
polymerization  to occur which may
affect feed rates. Solids suspended in
the liquid waste can also erode or clog
burner tips and control  devices.

  Metals create  problems in  both solid
and  liquid  waste fuels. If  a burner
operates at  temperatures greater than
the fusion point of the metal, oxides, or
carbonates, slagging and fouling can
occur. Metals can also form eutectic
mixtures on refractory surfaces and
promote corrosion at temperatures
much lower than would otherwise be
expected.

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   Hydrocarbons such as waste oil and
 waste solvent are likely candidates for
 combustion in industrial boilers. Waste
 oils, however, are apt to contain con-
 taminants which can pose environ-
 mental as well as combustion problems.
 Approximately two-thirds of the U.S.
 waste oil comes from the crank cases of
 automobiles and trucks and contains an
 estimated  1 percent by weight lead as
 well as other toxic materials. Pretreat-
 ment prior to use  is generally  required
 since waste oils  frequently  contain
 sludge,  grit, solvents, w^ater, heavy
 metals,  and additives added during
 processing. Usually, however, this
 involves  only the removal of water and
 solid particles by gravity settling and/or
 filtration.
   Waste solvents are generally contam-
 inated with suspended and dissolved
 solids, organic matter, organometallics,
 or other  solvents. Normally the contam-
 inants compose less than 10 percent of
 the solvent. Industries that produce
 waste solvent include the drug industry,
 solvent refineries, vegetable oil extrac-
 tion, polymerization processes, and
 cleaning operations. Fuels derived from
 these hydrocarbon solvents are markedly
 different from petroleum oil in chemical
' and physical properties. They  differ in
 flow characteristics, air/fuel  ratio,
 pumping requirements, and pressure
 requirements in general. Since they
 have a lower viscosity than fuel oils,
 liquid hydrocarbons require lower pres-
 sure for movement and atomization and
 this can therefore affect any preset feed
 rate. The heat content is also variable
 and often, in order to achieve the
 temperature and steam pressures re-
 quired for plant processes, more  of the
 hydrocarbon must be used than normally
 required.
   The single largest group  of  solvents
 used in  industry are halogenated sol-
 vents. Approximately 26 percent  of  the
 205,000 metric tons of dirty solvent
 reclaimed  in 1974 were either chlori-
 nated or fluorinated solvents. Physically
 these solvents tend to behave like their
 hydrocarbon counterparts;  however,
 marked differences are seen in the heat
 contents. The heating value of  these
 wastes decrease as the percent by
 weight of the halogen constituent  in-
 creases.  This has been attributed  to  the
 flame  retardant effects of the  halogen
 atom.  For example, chlorinated  com-
 pounds with a concentration greater
 than 70 percent by weight chlorine can
 require art auxiliary fuel source in order
 to sustain combustion.
  The use of halogenated waste as fuel
also presents problems with corrosion
in the boiler and in the heat recovery
devices. Care must be taken to maintain
the combustion products which are rich
in halogen acids above their respective
dewpoints in order to prevent conden-
sation and corrosion. This fixes the
minimum temperature in the heat re-
covery devices and thereby determines
the energy available for process streams.
In addition, sufficient hydrogen must be
provided usually  in  the  form of an
auxiliary fuel to permit the combustion
of free halogen gases (such as chlorine
gas) to their respective hydrogen acids.
Otherwise, stress corrosion problems
can occur in the heat recovery units.
  Many  solid  industrial wastes also
have potential for energy  recovery. In
industrial situations, the  solid waste
component can be varied, but generally
one class of constituents will  predomi-
nate. It can consist of semisolid sludges
and still bottoms  too viscous to be
handled as liquids or solid  discrete
objects such as rubber or plastic straps.
  Plastic wastes originate from both the
synthetic and fabrication processes.
These wastes  consist of tars and still
bottoms, off-spec product,  or  shavings
and trimmings. Plastics have heat con-
tents similar to high grade fuel  oils.
Burning characteristics vary from plastic
to plastic, and  due to their  density they
are normally fired as solids. Combustion
is accompanied by physical change
such as charring, melting, or vaporizing.
Polyolefins burn relatively easily and
give off  no toxic gases. They do tend to
melt and run off the grates resulting in
molten  pools of plastic which burn
under the grates. Polystyrene degrades
at 482°C with high heat release that can
lead to incomplete burning. Polyvinyl
chlorides (PVC) behave similarly to
halogenated solvents. Although high in
heat content, the presence of the halo-
gen atom retards flame and requires the
use of  an auxiliary  fuel to sustain
combustion. In addition, the high chlo-
rine content can generate large quanti-
ties of hydrochloric acid or chlorine gas.
It has been estimated that 50-lb of
hydrochloric acid is generated for every
100 Ib of PVC  consumed.
  The heat content, flammability limits,
flash point, and  ignition and auto-
ignition temperatures generally govern
the choice of  waste  as  a fuel and its
blend with other fuel in an  operating
combustion system. Once injected  into
the combustion zone, the thermal de-
struction of a  given material  is deter-
mined by the partial pressure of the
available oxygen, the combustion tem-
perature (Tc), and the time spent at Tc.
Another parameter that is difficult to
characterize, but essential for complete
combustion, is good mixing (turbulence)
of the fuel with the oxidant (air).
  Gases and volatile hydrocarbons can
be well mixed with air during injection
through a burner nozzle to give the most
favorable situation for thorough  com-
bustion—the premixed flame. Usually
additional air must be supplied to com-
plete combustion. With many liquids, all
semisolids, and solids, however, pre-
mixing is not achieved. Even though air
might be used (with or without steam) to
atomize or disperse the fuel, there is still
a region which is predominately fuel, an
external region that is oxidant-rich, and
a boundary region in which the combus-
tion reactions are occurring. This is the
situation of a diffusion flame, so-called
because the fuel and oxidant are trans-
ported by diffusion into the combustion
region.
  When sufficiently high temperatures
for destruction are not achieved or
maintained for a sufficient period of
time or if there is not sufficient oxygen
present locally, the thermal cracking of
organic compounds (pyrolysis) may be
accompanied  by synthesis of higher
molecular weight compounds. For ex-
ample, ethylene pyrolyzed between
480° and 588°C yields propene, butene,
butadiene, ethane, acetylene, and hy-
drogen. Higher olefins or diolefins may
form aromatic hydrocarbons. Even in
the presence of oxygen, pesticides have
been  observed to form pyrolysis pro-
ducts.  It is conceivable therefore that,
unless a uniformly high temperature is
maintained along with a plentiful supply
of air in the region where the waste is
being  injected, additional chemical
species can be created as air pollutants.

Inventories
  Over the  past several years, the
quantities of various organic materials
suitable for energy recovery have been
estimated in a series of Federal and
State studies. These efforts have in-
cluded surveys of production and  sales
data through extrapolations based on
the response to telephone surveys and
questionnaires of a relatively small
number of firms as well as in-depth
surveys and site visits. Although the
"error  bars" for more in-depth studies
should be much smaller, the.re is still
much uncertainty  about the ultimate
disposal fate of many of the organic

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materials used or generated by industry.
  A series of overview studies of indus-
trial waste disposal practices were
conducted by the Office of Solid Waste
in the mid-70's. The types of material
generated were specified and the quan-
tities estimated. Technology for treat-
ment and disposal  of waste streams
was also surveyed.
  Information developed in these as-
sessments has been subsequently used
in further EPA  studies of the issue of
energy recovery from waste burning. A
recent engineering study conducted for
OSW examined the energy conversion
potential of industrial waste streams.
Using the generation of low pressure
(125 psi) steam as the energy recovery
medium and defining a heat content of
18.4 MJ/kg (about 8,000 Btu/lb) as the
threshold for practical  recovery, the
study proceeded to identify five indus-
trial categories as having sufficient
waste heat  potential to justify more
detailed study on methods of implemen-
tation. These  industries and waste
quantities are:  organic  chemicals, 1.5
million metric tons; plastics, 0.445
million metric tons; petroleum refining,
0.110 million metric tons; drugs, 65,000
metric tons;  and  tires, 31,000 metric
tons.
   lERL-Cincinnati  has compiled an
inventory of  used  and byproduct hydro-
carbon streams which includes volatile
orcianic constituents (VOCs), waste oils,
and solvents. Semisolids, sludges, and
solids were not included. This study
concluded that petroleum refineries
were the only major  industry with
substantial recovery potential for VOCs,
with  an estimated 8.9 x  105 metric
tons/year recoverable. Using data from
previous reports,  the study estimated
that about  2.8 x 109  liters/year of
automotive lubricating oils and 5.4 x109
liters of industrial  oils (of various types)
were generated in  1977.  The  energy
content of these oils ranges from 31.5
MJ/kg to 44.7 MJ/kg (13,000 Btu/lb to
19,300 Btu/lb). The ultimate  fate of
most of this oil  is  not known.
   lERL-Cincinnati also estimated the
1978 demand for  solvents, to be 1.39 x
106 metric tons/year of halogenated
hydrocarbons, 1.45  x 106 metric tons/
year of ketones, and 1.53 x 106 metric
tons/year of alcohols, giving a  total of
about 4.37 x 106 metric tons/year. A
previous EPA source assessment of the
solvent reclaiming industry has esti-
mated that only a  little over 2 percent of
solvents are reclaimed.
  Many states have completed surveys
to determine the types, rates of genera-
tion, and disposition of hazardous wastes
within their jurisdiction. The data from
these surveys is useful in understanding
the patterns that recently existed. How-
ever, how these patterns might change
under the impetus of new hazardous
waste disposal regulations is moot. As
might be expected, the units used and
the degree of  detail vary considerably
from state to state. There are also
considerable differences in the reported
details of disposal practice. Some of
these surveys are sketched below.
  The State of New York has conducted
an extensive survey contacting some
1,170 generators out  of an estimated
4,000. More than 90 percent  of the
firms contacted responded. The total of
1.0 x 105 metric tons/year of  waste
accounted for in the survey was esti-
mated to represent 90 percent of that
actually generated in New  York. Six
groups of industries in the state account
for more than 75 percent of the annual
hazardous waste production: organic
and inorganic chemicals, primary metals,
plastics, petroleum refining, and phar-
maceuticals.  The New York survey
provides an in-depth view of the types of
waste generated by the various  indus-
tries in the stateand how these materials
are disposed of.
  The State of North Carolina conducted
a survey of hazardous waste generation
in the state in 1978 and collected data
by site visits to selected facilities  repre-
sentative of the major  industries of the
state.
  The State of Illinois has also conducted
a thorough survey of  industrial  waste
generation and disposal practices. Out
of 21,000 industrial establishments
queried, 7,900 responded. These  rep-
resented 62 percent of the industrial
employees in Illinois.
  The State of California  is in the
process of conducting an inventory of its
hazardous wastes and the State of
Maryland has also recently instituted
procedures to collect similar data.
  The State  of Massachusetts has for
some time maintained an inventory of
hazardous wastes collected by licensed
waste handlers which provides the
basis for understanding  the  pattern of
generation of waste in the state.

Current Disposal Practice
  Information on current disposal prac-
tices and trends was obtained from
three sources: Federal, State, and
private industry reports and contacts.
The main points from each of these
sources are surveyed in this section to
indicate the pattern of information
developed during this initial phase of
study.
  The Federal studies have been avail-
able for  some time and were briefly
discussed earlier. Further discussion is
not warranted in this brief summary.
  Published reports of state hazardous
waste inventories and disposal practices
were used, as well as telephone con-
tacts with state and local environmental
protection officials, in an effort to
develop more detail on the burning of
hazardous wastes for energy recovery.
Although the-quantitative detail was far
from what  is needed to accurately
assess the magnitude and the impacts
of the various disposal practices, the
information developed was useful in
highlighting the enormous variety of
such practices.
  In New York State, material "reclaimed
for fuel or material value," constitutes
about 26.5 percent of the waste disposal
onsite. Among these materials, it ap-
pears that the solvent mixtures and
nonemulsified waste oils along with
some portion  of the nonhalogenated
solvents are likely candidates for cofiring
for energy recovery. If so, some 90,000
m3 of supplementary fuel at a nominal
heat value of 28,000 MJ/m3 is available
to industry each year by burning this
waste onsite.
  Some plants in New York have applied
for permits to burn waste solvents, oils,
or both as fuels.
  As specific examples of use [1]:
  One plant operates a coal-fired, ce-
ment wet process  kiln with a nominal
firing rate of 5 tons per hour of 12,500
Btu/lb coal. Particulates are controlled
by an electrostatic precipitator. Since
1976, this company has been blending
in waste solvents such as ketones,
alcohols, acetates, and benzenes which
contain colloids (paint sludges). In 1978
some 1,600 m3 (422,000 gallons) of
such solvents with a heat content
ranging  27.9 MJ/kg to 41.8 MJ/kg
(12,000-18,000 Btu/lb) were burned at
a rate of 315 cm/3 second (5 gallons/
minute)—about 25 percent standard
fuel (coal) replacement.
  A  second plant operates two light-
weight  aggregate  kilns—each  with a
capacity of 16.8 metric tons/hour—
using solvents and oil as fuel on a 100
percent  replacement basis. The con-
sumption rate is about 2.18 mVhourfor

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each kiln. The actual fuel composition is
varied. Typical fuel composition is 96
percent solvents and 4 percent waste
lubricating oil;  35 percent aromatics
(benzene, xylene, toluene); 35 percent
aliphatics (mineral spirits, petroleum
oils, hexane, heptane); 15 percent
alcohols (methanol, ethanol, isopropyl);
5 percent  ketones (acetones, MEK,
MIBK); 5 percent esters (butyl or octyl
phthalates); and 5 percent polymeric
resins (alkyds, cellulose). When chlo-
rinated solvents are added, they are kept
to about 2 percent average because of
the corrosion problems they cause in
the scrubber and exhaust fan system.
Each kiln is equipped with an impinge-
ment type scrubber.
  In a third plant's lightweight aggregate
kiln, waste solvents are burned at a rate
of about 2.16 mVhour  (570 gallons/
hour). These have an average heat
content of  22,300 MJ/m3 (80,000
Btu/gallon). At  this plant, halogenated
solvents are also used at about 2 percent
composition. Other constituents and
their composition ranges are: MEK (20-
80  percent); MIBK (0-10 percent); ace-
tone (10-30 percent); toluene (20-80
percent); mineral spirits (5-20 percent);
isobutanol (0-5  percent); methanol  (0-
10  percent); ethanol (0-10 percent);
isopropanol (5-15 percent); acetates (5-
10  percent); sulfur (0.2 percent); and
ash (5 percent). Particles are controlled
by an impingement scrubber.
  The State of  Illinois EPA estimates
that almost 75 percent of  industrial
wastes are disposed of onsite; and 22
percent, offsite. Of the materials disposed
of onsite, Illinois environmental protec-
tion officials estimate that 33,000
metric tons  are  burned as fuel. These
materials include: oils, solvents, dye
and paint sludges, fats-and waxes, and
organic solids.
  In Illinois, a   permit  is required if
wastes are to be burned as fuel. Applica-
tion must be accompanied by an analysis
of the waste, but usually only sulfur and
trace  metals content are of concern to
the Illinois EPA air quality officials. Only
a few companies have applied for a
permit. One company planned to burn
solvents, and two were burning fatty
acids and oily residues from  vegetable
oil processing.
  In the State of Maryland, although
recycling is encouraged, the burning of
waste oils and solvents is not discour-
aged. The state  wants a typical sample
analysis along  with a sample  of the
material to be burned. This is checked
for PCBs and lead. If these are present,
the blend ratio is restricted to reduce
emissions. There are also operating
problems. PCBs corrode precipitators
and  lead fouls boiler heat transfer
surfaces. Although at least one firm
collects waste solvents and sells mix-
tures such as MEK and toluene as a fuel
(at reportedly less than 10 cents/gallon),
only one firm has applied to the state for
a permit to burn waste solvents. This is a
printing firm that burns ethyl alcohol
and toluene in a conventional boiler.
This is blended at about 10 percent with
either No. 2 oil or gas. The state suspects
that burning of oil and solvents, both on
and  offsite, for energy recovery is a
common practice and will become even
more prevalent, but at present the state
has little solid information on the prac-
tice.
  In the State of North Carolina, at least
two organic chemical firms burn process
wastes (DMT sludges) for heat recovery:
a pharmaceutical firm burns solvents,
and a furniture manufacturer has applied
for a permit to burn pretreatment sludge,
scrapings and  trash from a paint line,
and wood scrap with natural gas as the
primary fuel in a package boiler. Also,
one  resin  manufacturer uses fumes
from its process as its sole fuel.
  In the State of South Carolina, several
examples of industrial burning of wastes
for fuel were given. An analysis of the
waste, must be supplied to the state
before a permit is issued. One asphalt
plant has tried  burning phenols, but
problems occurred and the practice was
stopped by the state. An unspecified
firm received permission for a "one-
shot" burn of 55,000 gallons of tars
from a manufactured gas storage tank.
Another unspecified firm buys "all
burnable material" for energy recovery.
A small  secondary aluminum foundry
uses waste oil in  its smelting. State
environmental protection officials sus-
pect that a  lot of waste oil, solvent, and
other chemicals are being burned  in
small boilers, but they have no definite
information.
  In the State of Georgia, "two or three"
facilities process waste oil for fuel. Such
reprocessed oil  and some solvents are
used as fuel supplements in pulp mills.
This is also apparently common practice
in pulp mills in the State of Washington.
Blends of up to 20 percent reprocessed
lube oil and Bunker C are commonly
burned both in pulp mill boilers and in
cement  kilns. One oil reprocessor esti-
mates that  95  percent of the motor oil
reclaimed in the Northwest is burned in
boilers, and  most of the rest is used on
roads.
  In the State of Oregon, one firm was
reported to be burning shredded rubber
tires and wood waste for energy recovery,
and two tallow firms were  reported  to
use waste oil for their process heat
units.
  The heavy concentration of petro-
chemical and refining firms  in the State
of Texas and the needs for process heat
in such operations make this state a
prime target for a study to determine the
nature and extent of such practices. The
Texas Air Control  Board (TACB) has no
regulations concerning cofiring but
uses federal regulations which require
permits from appropriate state or local
agencies. Through these permits, in-
formation is available concerning pre-
sent practice.  For example: one  utility
has applied for permission to burn PCB-
contaminated mineral oil in a high
efficiency boiler;  a coal tar plant is
burning waste creosote for heat recovery;
several  chemical plants recover heat
from fuels obtained from the pyrolysis of
waste streams that were  previously
landfilled; another burns vinyl chloride
monomer and ethylene  dichloride
process wastes in a vapor/heavy liquid
incinerator equipped for energy recovery;
still another chemical plant  is installing
incinerators with waste heat  boilers to
recover energy from burning waste
chlorinated  and other  hydrocarbons; at
least three chemical plants are inciner-
ating PVC with heat recovery; and yet
another cof ires waste gases and organic
liquids in high efficiency boilers. Even
with these  examples, TACB believes
that the tempo of such waste burning
will not change much  in the future, but
that industry will try harder  to suppress
waste generation or will try to recycle as
many materials as possible  rather than
burning them for energy recovery.
  The State of Massachusetts, through
a manifest  system  which has been in
operation for several years, has compiled
an  inventory of the flows and disposal
methods for  hazardous wastes generated
in the state. This was mentioned pre-
viously. Currently, it is estimated that
much of the waste oil and  about one-
third of the  solvents collected by waste
handlers in  the state are used for fuel
either  in the  state, or in  one of the
surrounding states. Much of this  mate-
rial is burned in'small boilers supplying
heat to  greenhouses.  One  large brick
manufacturer was using large amounts

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of waste oil  in its kilns but recently
applied for a permit to switch from oil to
coal for its operations. Since the state
does not require permits for such waste
cofiring, there is no definite information
on the extent of the practice. However, it
is suspected to be widespread now and
should be even more so in th'e future.
  A survey of the open literature over
the past decade or  so did not yield a
large amount  of information that would
provide a definitive picture of current
industrial  practice.  There is enough,
however, to indicate that the technology
has been steadily developing under the
impetus of rising fuel prices and stricter
waste disposal regulations.
  The American Society of Mechanical
Engineers (ASME) has for  many years
charged a Research Committee on In-
dustrial and Municipal Wastes (RCIMW)
with the responsibility of identifying
important  research problems, sponsor-
ing surveys,  research  and prototype
installations and coordinating seminars,
and organizing conferences and similar
professional activities to exchange
information and stimulate professional
interest in the solution of the problems
associated with environmentally sound
waste  reduction. This committee  has,
among other activities, produced reports
on the thermodynamic properties of an
enormous variety of materials to aid the
design calculations of combustion en-
gineers [2,3],  produced reports on state
of the  art waste disposal installations
[4], and published the proceedings of a
conference on the status and research
needs  of energy recovery from wastes
[5]. This committee also coordinated the
ASME response  to OSW's proposed
hazardous waste regulations.
  A paper presented at the 66th meeting
of APCA (1973) [6] gave an overview of
burning wastes in industrial boilers. The
physical properties and heat content of
various industrial wastes were discussed
and several methods of burning with
heat recovery were described. A recent
paper [7] has described the use of crude
tars from the coking process in a steel
plant to routinely replace Bunker C as
the backup fuel for conventional boilers
generating steam at 400 psi and 600
psi.
  The  use of package boilers  to burn
gaseous,  liquid, and solid wastes as
fuels has been described [8]. The author
has cited the environmental advantages
of such combustion over landfilling—
assuming, of course, that complete
combustion occurs. However, this au-
thor also points  out that many of the
wastes will produce effects that require
proper design and maintenance to keep
under control. Some wastes will require
frequent sootblowing,  or hand lancing
and scrubdown to remove deposits, to
reduce corrosion, and  to maintain effi-
cient heat transfer. These maintenance
procedures will  produce solid/liquid
waste streams that must be tested with
respect to the hazardous waste criteria
to determine  classification and proper
disposal.
  Solid-waste fuels have been burned
in industry for  years [9].  The most
economical situation occurs when the
solid waste is burned as a supplemental
fuel in  an  existing boiler. The most
versatile design for such firing Is the
spreader stoker. Suspension firing is
also possible but requires that the waste
be finely divided to achieve total com-
bustion. These authors also discuss
new boiler  designs for waste  burning.
Considerations attendant to the retrofit-
ting of industrial boilers to accommodate
different fuels, including wastes, have
also been discussed [10].
  A final example of some of  the solid
wastes that could be expected to be
burned  in industrial boilers is seen in
the test firing of a variety of solid wastes
(and some liquids) from-the rubber
industry in a small (20,000 Ib steam/
hour at 150 psig) batch-fed reciprocating
grate stoker. The unit  was designed to
burn  reject linoleum  and roofing tar
paper from a  production plant with.a
secondary  fuel (oil) burner mounted
well above  the grate. For the test burn,
the various kinds of scrap were either
mixed or individually  injected in batch
fashion. The intermittent batch feed
caused sudden overload, resulting in
smoking that cleared toward the end of
the cycle:  shredding  and continuous
feeding reduced emissions. Test effi-
ciency was about 50 percent,  although
it was suggested that 60 percent effi-
ciency could be attained with continuous
feed [11].
  There .appears little doubt  from the
previous survey that the burning of
waste materials by industry for energy
recovery is a  viable growing  practice.
Large quantities of materials that have
been landfilled or collected and trans-
ported to another location for dumping,
with or without containment, will be-
come increasingly diverted to onsite
burning. The increasing cost of fuel and
the cost of offsite disposal  are both
"drivers" to this practice.
                                                                                                                  \
  The combustion technology—design,
construction, and operating technique—
for waste fuel burning, either as a
primary fuel, secondary fuel, or as a
more or  less constant blend, is well
established. There is sufficient operating
practice  base to encourage further
exploration and use. Boiler and burner
equipment manufacturers are aware of
most of the attendant operational prob-
lems as  well as the techniques  for
getting around or "living with" these
problems.


Emission Data
  Quantitative data  are required to
assess the potential pollutant emissions
and the effectiveness of various control
methods in reducing such emissions to
acceptable levels. This data should
relate pollutant species and emission
rates to waste feed composition, com-
bustion conditions, and control methods
employed. At present, information on
emissions from the combustion of
waste materials in industrial boilers is
very limited.
  There have been many studies of the
emissions from various kinds of waste
burned in incinerators. These combus-
tion conditions are  generally quite
different from those obtained in indus-
trial boilers,  so direct extrapolation is
not possible. However, such data on the
species evolved can be used as a guide
to some of the pollutants to be expected.
  Tests were run on the combustion of
waste oil and No. 2 distillate blends at
Aberdeen Proving Ground early in  the
1970's [12]. The waste oil was drained
crankcase oil from commercial-design
vehicles with traces of antifreeze,
hydraulic brake fluid, and transmission
fluid (in addition to water).  Upon com-
parison  of emissions obtained from
burning No. 2 fuel oil and blend of No. 2
with 27 percent waste oil in three low-
pressure, rotary-cup burners, it was
found that there was a fivefold increase
in particulate matter emissions. The
trace metal emissions increased from
44-fold to several hundredfold. A report
sponsored by EPA provided data from
seven different installations on lead
emissions from waste oil blended with
coal, No. 2 oil, No. 6  oil, or (as in  one
case) burned alone [13]. The fraction ol
lead emitted in the flue gas as a percent
of the lead feed rate was found to range
from about 25 percent to over 50 per-
cent.
   Tests  on blends of various fuels,
designed to assess the problems ol

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burning industrial wastes in conven-
tional boilers [14], have produced data
on the relationship between particulate
emissions and volume percent 02 in the
stack gas from the combustion of four
fuels: naphtha, a heavy oil with a high
pour  point (>150°C) denoted  HPP, a
blend of naphtha and HPP, and a residual
oil.
  The results generally agree with
those reported by several authors that,
with the burner designs and oil fuels
typically used in industrial boilers, the
particulate  matter emissions generally
decrease as the excess  air is increased.
  An  incineration  system for  atactic
polypropylene combined with a waste
heat boiler for energy recovery has been
described [15]. The system hearthburns
the  polymer to pyrolyze the solid. Typi-
cally,  the system operates at 922 K-1,
144 K, although a maximum of 1,367 K
could be achieved. The  pyrolysis gases
are  mixed with air at about 25 percent
excess of stoichiometric requirements.
The plastics may produce HCI and P205
as combustion products. Ash content
varies, but could be  as high as  10
percent. The temperatures in  the pyrol-
ysis zone and entering the heat recovery
boiler are kept below  the ash fusion
point  to avoid surface fouling.
  In a study performed  many years ago
on  coal, oil, and gas-fired combustion
units, as well as incinerators,  Hange-
brauck and coworkers found that under
certain firing conditions significant
amounts of polynuclear hydrocarbons
could be generated [16], It was found
that polynuclear emission rates were
generally large when CO and total
gaseous hydrocarbon emissions rates
were  large, indicating incomplete com-
bustion. When benzo(a)pyrene (BaP)
was used as an indicator, a consistent
increase was demonstrated in polynu-
clear  emissions proceeding  from the
high efficiency pulverized coal units to
the low efficiency hand-stoked home
heating units. BaP from oil-fired units
was generally much lower than from
coal-fired units, but significant amounts
of polynuclear materials were generated
m an oil-fired unit that used  a  low-
pressure air atomizing burner.
  This brief survey indicates that,
although particle emission  data and
some trace metal emission data exist,
they are insufficient to prepare a proper
guidelines  document  and not nearly
adequate enough to form a  basis  for
setting standards. There are little or no
data available on hydrocarbon emis-
sions, particularly fhe higher molecular
weight species that are suspected of
posing potential health risks. It is well-
known that a sequence of pyrolytic and
synthetic reactions can occur in flames
to produce polycyclic molecules [17],
particularly where the hydrocarbon fuel
is not well mixed with air; i.e., in
diffusion flames that are typical of liquid
combustion.
  In the ASME response [18] to EPA's
proposed regulation on incineration, an
example was cited of sampling for
hydrocarbon emissions from a  190
million Btu/hr industrial boiler cofiring
coal and chemical process wastes.
Practically no volatiles (Ci to C6 hydro-
carbons) were observed, and the gas
chromatographable (C7 to  Ci6 hydro-
carbons) fraction amounted to only
about 5 percent of the organics. It was
noted that most of the heavy hydrocarbon
emissions condensed  in the sampling
lines rather than passing through to be
deposited on a cartridge of XAD-2 resin
for  subsequent GC analysis. There is a
serious need for careful sample acquisi-
tion and analysis procedures to be used
to ensure that representative hydro-
carbon emission measurements are
obtained.
  Most importantly, data on particulates,
organic species, and trace metal emis-
sion rates should  be correlated with an
analysis of the feedstock and combustion
conditions. The effects  of the variation
in feedstock composition, boiler loading,
and excess air (or equivalently, stack
gas Oz) on emissions of particles, SO2,
NO,, PNA, and trace metals should be
determined to provide guidance on
permissible  waste/fossil  fuel  ratios
under given conditions. The performance
of standard control devices under these
same variable conditions should also be
ascertained to determine if any pollutants
are not being adequately controlled and
to provide the basis for efforts to improve
performance where needed.
Source Testing
  A large variety  of materials used or
generated by industry can be burned for
energy recovery. These materials can be
and, in many cases, are burned in a
large variety of combustion equipment.
In view of this multiplicity of combina-
tions, it is difficult to select "representa-
tive sites" for the collection of emission
data to guide the development of regula-
tions. It is also difficult to  determine
whether existing regulations can be
adequately applied for air quality protec-
tion.
  Because of the meager amount of
emission data available on waste burn-
ing, it appears that the first requirement
for source characterization is a Level 1
assessment of several sources which
span the spectrum of waste utilization.
  Once these sources have been char-
acterized and the actual nature of the
environmental problem is assessed, a
30-day (or other appropriate period)
continuous emission testing backed up
by appropriate reference  methods and
quality assurance procedures can be
used to obtain legally defensible data for
standards setting.
  The "spectrum of  utilization" can be
conceptually portrayed by Figure 1. For
a given energy content of waste, the
achievement of high combustion effi-
ciency becomes more difficult as the
physical  state of the waste proceeds
from a vapor or a nonviscous liquid up
through a semisolid or viscous liquid.
Similarly,  the combustion  type will
influence how well the waste is burned.
As seen in Figure 1, suspension firing
gives the best mixing of fuel and air, and
hearth burning, the  poorest.
  Physical state of the  waste is, of
course, only one consideration. Another
is the chemical composition—including
both chemically  bound and physically
included species. Another consideration
is how well the source  is controlled.
Large coal-fired units are  most likely to
have ESP or fabric filtration units to
provide efficient particle collection
whereas small units may  have none at
all. A further consideration is how much
waste material is being burned or, more
properly, what the total pollutant emis-
sions are over a given period.
  A tentative priority listing that would
lead to site selection is:
  1. Sources burning off-spec resins or
     plastics or rubber industry wastes
     in a batch-fed  mode.
  2. Sources burning semisolid or vis-
     cous chemical  processing wastes
     on a continuous or piecewise
     continuous basis.
  3. Sources burning waste lubricating
     and/or cutting oils on a continuous
     or piecewise continuous basis.
  4. Sources burning waste solvents
     from metal or semiconductor
     processing operations on a con-
     tinuous or piecewise continuous
     basis.

The presumption made in this listing is
that incomplete combustion presents
the most severe environmental hazard
through polycyclic organics. Also the

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          Organic Waste State
        Combustor Type
             Semisolids and
             Viscous Liquids
              Shreddable or
              Friable Solids
              Oily Liquids
           Nonviscous Liquids
                 Vapor
        Hearth Burning
     Batch Mode Underfed
            Stoker
       Overfeed, Chain or
      Moving Grate Stoker
        Spreader Stoker
        Suspension Fired
Figure 1. ,    Qualitative comparison of organic waste state and combustor
             type in achieving high combustion efficiency.
burning of products (plastics and rubber
goods) that contain a variety of fillers
and additives offers more possibility of
inorganic emissions than those expected
from, say, settled or filtered lube oils or
solvents.

Control Technology
  When waste materials are burned for
energy, the basis for sound environ-
mental control is to ensure that:
  1.  Complete combustion occurs.
  2.  Fly ash, particles, pollutant gases,
     and hazardous vapors emitted to
     the atmosphere are reduced to a
     predetermined safe level.
  3.  Air emission control device residue
     is properly classified and disposed
     of.
  4.  Solid residue (bottom ash) is prop-
     erly classified and disposed of.

  Additional fuel handling steps prior to
combustion must also be considered
when planning an overall control strat-
egy.  If the waste  contains VOC, the
processing steps  must occur  under
conditions where the volatiles are not
allowed to escape  to the atmosphere.
This  has three advantages: (1) air quality
is preserved, (2) material with significant
heat content is reserved for burning,
and  (3) the safe operation of the plant
(prevention of fire or explosion) is
maintained. In addition, if the waste is
treated prior to combustion to filter out
or chemically complex and settle out
sludge, the bottom waste from these
processes must be adequately handled.
  For complete combustion there must
be adequate air, the fuel and air must be
thoroughly mixed (turbulence),  the
exothe.rmic reactions of combustion
must provide  enough heat to raise the
burning mixture to a high enough tem-
perature  to destroy every organic con-
stituent,  and  transport  of the burning
mixture through  the high temperature
region must occur over a sufficient time
duration to ensure that even the slowest
combustion reaction has gone to com-
pletion.
  Burner designs for liquid wastes must
ensure the  adequate vaporization, mix-
ing, and initial combustion of the partic-
ular materials being burned. The waste/
fuel mixture is injected with pressurized
air at a sufficient velocity into a geometry
that promotes turbulence and circulates
some of  the  high temperature gases
back into the incoming  stream to raise
the injected  material rapidly toward
combustion temperature. The burning
mixture  is then  injected into a flame
zone where additional air is supplied to
fully develop the combustion.
  The comminution of solid wastes
must be fine enough to promote rapid
charring and facilitate the distribution of
fuel into the combustion zone;  e.g., by
overfeed from a spreader stoker or
crossfeed onto a traveling grate. Com-
bustion air must be fed through the char
bed and into the resulting volatiles to
promote temperatures and mixing suffi-
cient to achieve complete combustion.
  As with many environmental control
technologies, the proper  design to
achieve as complete combustion as
possible also provides operational bene-
fits through:
  1.  Better fuel use.
  2.  Less deposit buildup on the cooler
     surfaces downstream from the
     combustion zone.
  The needs of and procedures for the
design  and maintenance of proper
combustion process controls are well-
documented. The control system must
provide the proper fuel/air feed ratios
and ensure safe operation. Included in
the safety considerations are flame
failure detection, protective interlocks
for burner ignition, fan operation, fuel
valves, and fuel/air  ratio limits. With
regard to the fuel/air ratio, the control
system  must limit  the fuel feed to
prevent air deficiency:  it must phase
down fuel feed ahead of air feed with a
decrease in load, and must phase up air
feed ahead of fuel feed with an increase
in load.
  If the  waste fuel is not blended in a
constant ratio with the regular fossil
fuel or if the average heat content of the
waste fuel varies significantly, the
fuel/air ratio required for proper com-
bustion will also vary. This can be taken
into account by using an oxygen analyzer
(of appropriate response time) to set the
feed ratio.
  Any guidelines document to promote
the environmentally  safe use of waste
materials as fuels must also include a
discussion of and recommended design
practices for state of the art combustion
controls  and interlocks. As with other
facets of good environmental design
practice there is also a benefit in this
case. A well-designed  and well-main-
tained combustion control'and safety
interlock system can save fuel and
prevent unscheduled shutdowns.
  Section 261.4(b)(4) of the Hazardous
Waste Regulations  declares that  the
following are not hazardous waste (by
definition):
   "Fly ash waste, bottom ash waste,
   slag waste and flue gas emission
                                  8

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  control waste generated primarily
  from the combustion of coal or other
  fossil fuels."
The meaning of the word "primarily"
must be determined in order to specify
the limits of the feed ratios of waste/
fossil  fuel under which  the exclusion
applies.
  These same wastes derived from the
combustion of wood as the primary fuel
could  conceivably be hazardous if they
do not pass the EPA toxicity test. Unless
the exclusion is broadened, the solid
wastes from the combustion of wood, or
wood and shredded tires, etc., could
conceivably require handling and dis-
posal as a hazardous waste.
  It is doubtful that the combustion of
waste oils and solvents under properly
control led conditions will constitute any
more  of a hazard than the burning of
coal or heavy oil. Crankcase oil, cutting
oils, and many solvents are apt to
contain appreciable quantities of metals,
but much of this detritus can be settled
or filtered out prior to combustion. This
not only has environmental advantages,
it has practical operational advantages.
Adequate pretreatment, along with the
state of the art particle controls, would
probably provide effective regulation
where wastes are cofired with coal or
wood. When  cofired with oil, however,
there may be more  of  a problem in
achieving adequate stack gas cleanup.
The lead and other toxic metal  content
of the feedstock  would need to be
limited to limit emissions.

Current Regulatory Approaches
  On May 19,1980, OSW published its
Phase 1  interim final regulations for a
hazardous waste management system.
As discussed previously, the current
definition of  solid wastes specifically
excludes material "burned as a fuel for
the purpose of recovering'usable energy."
In commenting on energy recovery,
OSW  states:
  "The Agency  has decided  that the
  burning of hazardous waste for energy
  recovery will not now be covered
  under the hazardous waste provisions
  of RCRA. (However, storage or trans-
  portation of listed hazardous waste
  prior to energy recovery is covered by
  these regulations.) Accordingly, if
  waste oils and solvents are burned as
  a fuel in a boiler primarily to produce
  steam or usable energy, this action is
  not now covered by these regulations."
Whereas the  regulation on incineration
requires the achievement of steadystate
combustion by the use of an auxiliary
fuel before wastes are introduced, OSW
comments in another part:
  "For example, air emissions generated
  by the burning of waste oil for energy
  recovery can probably be effectively
  controlled without requiring boilers
  to meet hazardous waste incinerator
  requirements."
The implication appears to be that air
quality regulations should govern the
use of wastes as fuel.
  This implication, if true, apparently
contradicts a previous comment:
  "The procedures of the Clean Air Act
  would be a less efficient  way to
  control a large number of hazardous
  air pollutants than RCRA,  under
  which design, operation, or perform-
  ance criteria (such as incinerator
  destruction efficiencies) can be set
  more easily for many pollutants emit-
  ted  by the facilities. Therefore the
  Agency has chosen RCRA as the
  primary vehicle for controlling air
  emissions from hazardous  waste
  facilities."
In view of this contention and the
previous  statement, the burning of
wastes for energy recovery appears to
be an area in which careful coordination
between  OSW and OAQPS will be
required.
  OSW has specifically listed a number
of solvents as "hazardous waste from
nonspecific sources." Under 40CFR
Part  262  of  the new regulations, a
generator who treats, stores, or disposes
of these materials on site must obtain
an EPA identification number and sub-
mit an annual report, unless the total
amount generated is less than 1 metric
ton (100 kg) per month. A generator who
wants to have these substances trans-
ported for disposal elsewhere must
have first obtained an EPA identification
number that is used on a manifest to
identify the generator, type material,
and quantity.
  The consequence of the regulations
as currently written is to enable tracking
of a portion of the materials that is apt to
be burned for  energy  (i.e., those listed
solvents) but to specify nothing about
the conditions under which these mate-
rials will be burned.
  OSW is presently studying the problem
of waste oil disposal. Spent solvents are
also under study but lag behind the
waste oil effort. Residues from the
production of organic chemicals will be
subsequently addressed.
  At present  most states  have filed
State Implementation Plans (SIPs) that
specify plans for implementation and
enforcement of regulations to protect
and enhance air quality. None of these
deal specifically with the problem at
hand.
  The State of New York requires a
permit to construct and a certificate to
operate sources emitting to ambient air.
The materials to be emitted are classified
with respect to their potential for adverse
health effects and/or environmental
degradation. After classification, a pre-
determined percentage  reduction is
imposed based on  the uncontrolled
emission rate for the particular pollu-
tants involved. New York's Department
of Environmental'Conservation is cur-
rently considering a change in regula-
tions to specify that anyone who burns
other than  fossil fuels must first get a
permit, for which an environmental
impact analysis would be  made.
  The State of Massachusetts currently
does not require a permit to burn waste
organics such as oils and  solvents,
except for  mineral oils containing less
than 50 ppm PCBs. A process weight
table is used to specify allowable emis-
sion rates of particles. With respect to
fuels, the state's regulations deal with
fossil fuels  except for 301  CMR 7.05 (b)
which deals with fuel additives. These
are defined as "any substance which is
not a natural component  of the fuel to
which it may be added or in conjunction
with which it may be used." This part of
the regulations calls for specific written
approval by the Department of Environ-
mental  Quality Engineering (DEQE)
prior to  use. Apparently this section is
not being construed broadly enough to
include  cofiring of wastes. The  State
Hazardous Waste Division permits waste
haulers and keeps track  of materials,
quantities, where generated, and where
delivered.
  The State of Maryland has a specific
regulation dealing with waste oils and
other combustible fluids. Maryland has
been concerned with the burning of PCB
contaminated oil. Their Air Quality
people want to ensure that these are
burned under carefully controlled con-
ditions. The state has a big problem with
liquid organic waste disposal and would
not mind if  much of it is burned, as long
as it is  done in an environmentally
sound manner.
  Except for those sources burning less
than 2.93 x107W (100 million Btu/hr)
of No. 2 fuel oil or less than 7.3 x 107 W
(250 million Btu/hr) of natural gas, the

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State of North  Carolina requires a
permit which includes a description of
the fuel to be burned. This also covers
fuel changes such as the burning of
wastes.
  The State of South  Carolina also
requires such notification along with a
sample of the fuel to be burned, which
must be submitted  to the state for
analysis. This analysis includes: Btu
content, sulfur, ash, halogens, Pb, Hg,
Cr,  V, Cu, Co, Ni, T,  Sb,  cyanide, and
nitrogen.
  The State of Texas requires permit
application for cofiring to  be submitted
to the appropriate state or local air
protection agency. Permit data, including
stack tests where performed, are on file.
  Ohio has no specific regulations on
cofiring. Standard combustion regula-
tions are used. This has led to enforce-
ment problems. As an  example, the
state is in litigation with a firm that has
been cofiring wastes on a No. 2 fuel oil
permit.
  The State of Illinois has no regulation
that specifically applies to cofiring. In
contrast with recycling, the practice of
cofiring is not officially encouraged. The
only known permit application has come
from a chemical plant that wants to burn
solvents  in a boiler. This is still under
consideration. The state EPA recognizes
that tighter  landfill controls will force
cofiring  for energy recovery into a
possibly viable option and plans to move
into this area of regulation.
  The State  of Oregon has no specific
regulations  for cofiring.  Standard air
quality permit procedures are followed
with variances issued to those applicants
requesting cofiring. To date the state
has encouraged the cofiring of RDF with
other fuels, and will probably do so with
other materials if the practice can be
shown  not to degrade air quality.
Wherever feasible, recycling is encour-
aged. The Oregon Department  of Air
Quality is closely following a 1 -year trial
in which Georgia Pacific is cofiring
shredded automobile tires and wood
waste at a paper mill in Toledo, Oregon,
in a 7.3  x 107 W (250 million Btu/hr)
stoker-fired boiler. The variance provides
that the tires provide no more than 10
percent  of  the  total heat input; 40
percent opacity cannot be exceeded for
any period greater than 3 minutes and
particle  emissions cannot exceed 2
gr/scf.
  The current regulatory status con-
cerning waste combustion in boilers
could be fairly summarized as a state of
limbo. Heretofore, the combustion of
waste materials as fired represented
only a very small fraction of the total
material burned, both  as fuel  and by
incineration. As such, the problem was
minute. Now that there is a strong trend
toward more such combustion, there is
a question as to whether current regula-
tions are sufficient to provide adequate
control to ensure air quality.
  This question cannot be answered
until substantially more is known (i.e.,
quantitative data is obtained) about the
waste fuel composition, the conditions
of combustion, the species emitted, and
their  dependence on feed and firing
conditions. In addition, there is much to
be learned about the operating practices
and maintenance required to  ensure
essentially  complete  combustion if
guidelines are  to be prepared.
  In the interim, it appears that enforce-
ment of existing paniculate emission
and opacity regulations are the first line
of air quality  defense. Collection of
particles, especially at  low enough
temperatures  to  effect adsorption of
higher molecular weight organics, may
serve to greatly reduce  the emission of
metals and  polycyclic organic com-
pounds.


Conclusions
  The brief survey of existing data and
current industrial waste combustion
practice supports the following  conclu-
sions:
1.  Waste Inventory Data. Federal sur-
veys have, of necessity, been relatively
aggregated to provide overall estimates
of wastes generated by SIC industrial
categories. Many states have conducted
hazardous waste surveys which provide
more definition  of waste types and
quantities, thus giving  a  better under-
standing of the diversity of materials
that can be burned for energy recovery.
Notable in the  survey reported here are
the data available from  the States of
Illinois, Massachusetts, New York, and
North Carolina.
  In particular, the inventory  data of
New  York and Illinois offer the best
bases for an in-depth study of current
disposal practice and  a  projection of
future trends.  Both states are heavily
and diversely  industrialized, thus pro-
viding a convenient cross-section to
include many of the waste materials
and combustion  equipments that are
used.
  Using these  two states  as examples,
the present extent of waste combustion
and a future projection can be compared
In New York, as much a 90,000-100,OOC
m3 of wastes with an energy content o1
28,000 MJ/m3 may be burned annually
onsite as fuel. The rate of organic waste
generation is such that this figure coulc
double. Based on an industry survey ir
Illinois, only 20 percent (8,100 m3 out o'
40,500 m3) of waste oil isacknowledgec
to be annually burned onsite as fuel, as
is only 9.7 percent (2,605 m3 out ol
26,900 m3) of solvents. The other alter
natives for disposal is listed as "recycle/
reclaim."  As the  price of  fossil  fue
increases, these percentages will prob-
ably escalate.
2. Combustion Technology and Practice.
A wide variety of waste materials have
been burned in either standard combus-
tion  equipment or  equipment modifiec
to accept wastes with  or without fossi
fuel. The combustion  technology base
for  increased  utilization is available.
Costs of the  RCRA manifest system for
tracking hazardous wastes and the
increasing price of fossil fuel can be
expected to  push the technology and
practice to make waste use as a fuel an
accepted feature of industrial energy
supply.
3. Emission Data. Virtually no emission
data on waste combustion in industrial
combustion  equipment (except incin-
erators) is available. Field tests are
needed to fully characterize sources
burning wastes  and provide the basis
for formulating and implementing ade-
quate air quality controls, if needed.
4. Potential Air Quality Problems. Some
organic wastes contain relatively large
amounts of metals or  metal-containing
compounds that can volatilize as meta
vapor or oxides, to produce fly ash in
much larger amounts than usual with
fossil fuels. This is supported by the
limited  existing  emissions  data.  Ir
addition, many wastes  differ appreciably
from fossil fuels in their physical prop-
erties. This can  lead to inefficient
combustion with the production of
carbonaceous particles and polycyclic
organic compounds. The  latter has not
yet been verified by emissions measure-
ments—as far as could be determined in
the present study— but can be inferred
from the behavior observed when firing
fossil fuels inefficiently in conventional
combustion equipment.
5. Current Regulations. The current
regulatory status concerning waste
combustion in  boilers can  be fairly
summarized as being in a state of limbo.
Heretofore,  the combustion  of waste

-------
materials as fuel represented only a
very small fraction of the total material
burned.  As such, the problem was
minute. Now that there is a strong trend
toward more'such combustion, there is
a question as to whether current regula-
tions are sufficient to provide adequate
control to ensure air quality.
  This question cannot be answered
until much more is known; i.e., quanti-
tative  data are obtained on waste fuel
composition, the conditions of combus-
tion, and the species emitted and their
dependence on feed and firing conditions.
In addition, there is much to be learned
about the operating practices and main-
tenance required to  ensure essentially
complete combustion if guidelines are
to be prepared.
  Many states  now have  regulations
that require a fuel analysis and notifica-
tion of the state agency before a permit
holder is allowed to burn a significantly
different fuel. There is abundant evi-
dence that requirement  is not, and
perhaps cannot, be enforced.
  In cases where notification and a fuel
analysis are provided,  the  states have
generally done  some dispersion mod-
eling,  looking at SO2 and perhaps lead.
PCB-contaminated oil is a special case:
there has been sufficient publicity,
public arousal, and EPA and state guide-
lines for compliance  to be effected.
  It is incumbent upon EPA to ensure
that field measurement methods that
develop representative data are  made.
The presence of pollutant species must
be proved and quantitated, then  health
risk assessments must be made in order
to provide the basis for regulation.
  In the interim, it appears that enforce-
ment  of existing particulate emission
and opacity regulations is the first line of
air quality defense. Collection of particles,
especially at low enough temperatures
to effect adsorption of higher molecular
weight organics, can serve to greatly
reduce the emission of metals and
polycyclic organic compounds. Whether
or not this is adequate must be decided
on the basis of field  measurements.
  The regulatory problem is to balance
air, water, and land  environmental
quality with resource recovery.


Recommendations
  Under the RCRA mandate, EPA has
the responsibility to promote resource
recovery commensurate  with the pro-
tection of environmental quality. In or-
der to carry out this  responsibility with
regard to the use of waste as fuel, EPA
must provide guidelines to industry to
promote environmentally sound usage
and  must formulate regulations,  if
needed, to ensure environmental pro-
tection. Fundamental to the preparation
of guidelines and regulations is an
understanding of the technology and
practice, both current and anticipated,
of waste/fossil fuel cofiring, the pollu-
tant emissions resulting from this
practice, and effective methods of
control.
1. Workshop. To promote communica-
tion between industry and EPA, a work-
shop on the environmentally safe use of
waste materials as fuel should be held
as soon as  practicable. A proposed
agenda for such a workshop is shown in
Table  1. This event  should  be well
publicized through industry association
organizations, professional groups such
as NSPE, ASME, and the AlChE, and
state environmental protection officials.
It should be repeated  periodically,
perhaps with a symposium format.
2. Disposal Practice Survey. A detailed
study should be carried out with the
cooperation of state environmental
protection officials using air emissions
permit information and hazardous waste
inventory information to develop a list of
specific sources, burning known waste
materials, that are representative of
those SIC classes which can reasonably
be expected to burn significant (with
respect to air quality) amounts of waste.
This study should be confined to two or
three States (e.g.. New York, Illinois, and
                            Massachusetts). The objective would be
                            to develop a list of potential test sites to
                            which selection criteria could be applied
                            to choose sites for field measurements
                            that would provide the basis for identify-
                            ing those waste materials, combustion
                            conditions, pollutants, andemission
                            rates that would cause air quality prob-
                            lems  unless adequately controlled.
                            3. Site Selection.  Criteria for selection
                            of field test  sites should be formulated
                            and applied to the candidate source list.
                            4. Site Test Plan. Test plans  specific to
                            each  selected source should be devel-
                            oped. These should include  screening
                            type measurements (Level 1) plus any
                            additional sampling and analysis  re-
                            quired to characterize the source by
                            relating waste feed composition, com-
                            bustion conditions, and emissions. In
                            those cases where the source is known
                            to be  representative of a large group of
                            similar sources, it may be desirable to
                            combine the screening measurements
                            with standard reference method mea-
                            surements, backed by suitable quality
                            assurance audits, to expedite future
                            regulations development.
                            5. Field Measurements. Actual  mea-
                            surements should be performed accord-
                            ing to'the test plans atthe selected sites.
                            6. Environmental Analysis. Measure-
                            ment data from the field program should
                            be used to estimate potential health and
                            environmental impacts due to the ag-
                            gregate emissions from  sources using
                            wastes as fuel. This aggregate emission
                            data should  be obtained by extending
Table 1.    Proposed Agenda for Joint Industry/EPA Workshop on the Environmentally
           Safe Use of Waste Materials as Fuel

	(All Plenary Sessions)	

  First Day
             Introduction and Welcome (Invited)
             Waste Materials as Fuel (Invited)
             Combustion Equipment Design and Operation for Cofiring (Invited)
             Emissions Measurement (Invited)
             Environmental Controls (Invited)
             Environmental Regulatory Concerns (Invited)
  Second Day
  Third Day
Charge to Panels - Plenary Session
Parallel Sessions of Panels on:
    1.  Combustion Equipment Design and Operation
    2.  Emissions Measurements
   '3.  Environmental Controls
Morning Session: Statement of Issues
Afternoon Session: Recommendations on Resolution of Issues

Panel Reports - Plenary Session
Discussion of Reports
Recommendations to EPA
                                                                                11

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 the in-depth waste inventory and com-
 bustion practice survey to all states in
 which waste combustion as a fuel can
•degrade air quality measurably. Control
 technology to reduce  emissions to
 acceptable levels should be identified. If
 the necessary control technology is not
 available, the needs should be specified
 to facilitate  necessary  research  and
 development.
 7. Combustion Technology Research.
 In parallel with the field program, a
 research program should be carried out
 to elucidate how various equipment
 designs and operation parameters will
 affect the combustibn efficiency of
 various waste materials used as fuel.
 This research should take into.account
 recent and planned parallel research
 efforts by private industry and profes-
 sional organizations. The objective
 should be a set of designs and operating
 practice guidelines to promote the
 efficient combustion of organic waste in
 industrial boilers and related equipment.
 8. Regulatory Analysis. Field data, the
 results of the environmental analysis
 and combustion technology research,
 will provide a series of inputs for EPA's
 regulatory offices for air, water,  and
 land quality.  These  inputs will enable
 those  offices to mutually assess the
 environmental tradeoffs involved in the
 exercise of regulation through their
 respective legal mandates. These trade-
 off:; should be explicitly comparable in
 terms  of quantities of pollutants gener-
 ated, dispersion mechanisms, and health
 and environmental risk analyses.
 9. Regulation Preparation. Necessary
 regulations would be prepared on a
 schedule commensurate with existing
 program office workloads and priorities.
  The rationale  for  the  recommended
 program follows. It  is desirable to get
 industrial input  in an advisory, rather
 than an adversary, capacity. Establish-
 ment and maintenance of a dialog will
 enhance EPA's understanding of the
 practice of waste fuel usage as well as
 promote industrial efforts to do so in an
 environmentally sound manner.  The
 initial focus on the industrial experience
 in two states, the early selection of sites,
 and the acquisition of screening  data
 will provide a better understanding of
 the differences between emissions
 from wastes and those from fossil fuels.
 At the same time, this would generate a
 more  defensible set of  data should a
 decision be made early in the program to
 press  for  regulations specific to waste
 burning.
  In parallel  with these elements to
define current practice and its environ-
mental consequences, a program of
waste combustion technology research
would provide the basis for specifying
recommended designs and operational
procedures that would aid industry in
using waste fuels. There has already
been a great deal of research on refuse-
derived fuels (RDF).  It should not be
repeated. The materials considered
should be those liquids, semisolids, and
solids that are apt to be generated and
used by industry.
  Also, in parallel, the regulatory anal-
ysis element of the program considers
the environmental consequences of
various regulatory approaches. The
view taken is that effective regulation
will most probably take a coordinated
approach between the program offices,
with mutually supportive policies and, if
necessary, regulations.
  The regulation preparation portion of
the program could start as early as mid-
1981 if justified by the severity of the
perceived environmental problems. If
not urgent, the regulation  countdown
could start late in 1982, allowing the
accumulation of sufficient prior research
and development outputs and the output
of the regulatory analysis phase to set
the stage for the actual preparation and
promulgation.

References
   1. Private communication. J. Lauber,
       Toxic Unit, NYDEC to J. W.
       Harrison, RTI,  August 4, 1980.
   2. ASME Research Committee on
       Industrial and  Municipal Waste.
       Combustion Fundamentalsfor
       Waste Incineration. ASME, New
       York, 1974.
   3.	Thermody-
       namic Data for Waste Incinera-
       tion. ASME, New York, 1979.
   4.	Disposal of In-
       dustrial Wastes by Combustion.
       ASME, New York,  Three Vol-
       umes.
   5. R. A. Matula, editor.  Proceedings
       of the 1976 ASME  Conference
       on the Present Status  and Re-
       search Needs in Energy Recov-
       ery from Waste, Hueston Woods
       State Park, Oxford, OH,  Sep-
       tember 19-24, 1976. ASME,
       New York, 1976.
   6. J. H. Fernandes and L. J. Cohen.
       Burning of Waste  as Fuels in
       Industrial Boilers. 66th Annual
       Meeting of APCA, June 24-28,
       1973.
 7. C. C. Ferguson. Tar Burning on
      Boilers at Algoma. Iron and
      Steel Engineer, July 1980, pp.
      29-32.
 8. E. M. Mockridge. Utilization of
      Package Boilers for the Com-
      bustion of Waste Fuels, pp. 649-
      656 in Proceedings of the Am-
      erican Power Conference, Vol-
      ume  36, Illinois Institute of
      Technology, Chicago, 1974.
 9. J. H. Fernandes and R. C. Shenk.
      Solid-Waste Fuel Burning in In-
      dustry, pp. 663-670 in Proceed-
      ings of the American Power
      Conference, Volume 36, Illinois
      Institute of Technology, Chica-
      go, 1974.                . "
10. W. J. Matthys. Retrofitting Indus-
      trial Boilers to Meet the  Fuels
      Market, pp. 735-741 in Pro-
      ceedings of the American Power
      Conference, Volume 37, Illinois
      Institute of Technology, Chica-
      go, 1975.
11. C. A. Hescheles. Industrial Waste
      Analysis and  Boiler Perform-
      ance Test Burning Wastes,
      ASME Paper 66-WA/PID-11,
      July 1966.
12. M. E. LePera and G. DeBono.
      Investigating Waste Oil Disposed
      by Direct Incineration. Report
      2127, U.S. Army Mobility Equip-
      ment Research  and Develop-
      ment Center,  Ft. Belvior, VA,
      February 1975.
13. S. Chansky, et. al. Waste Auto-
      mative Lubricating Oil Reuse
      as a Fuel. EPA-600/5-74-032
      (NTIS PB 241357). U.S. EPA Of-
      fice of Research and Develop-
      ment, Washington, DC, Septem-
      ber 1974.
14. H. Ikebe, et al. Some  Examples
      of Combustion Tests for Putting
      New Fuels to Practical Use. IHI
      Engineering  Review 3(4), 1
      (1976).
15. W.  Hart. Combustion and Heat
      Recovery from Polymeric Ma-
      terials, pp. 371-379 in  proc.
      Conf. on Present Status and Re-
      search Needs  in Energy Recov-
      ery from Waste, Houston, 1976.
      New York: American Society of
      Mechanical Engineers, 1976.
16. R. P. Hangebrauck, D. J. Von
      Lehmden, and  J. E. Meeker.
      Emissions of  Polynuclear Hy-
      drocarbons and Other Pollut-
      ants from Heat-Generation and
      Incineration Processes. JAPCA
      14. 267(1964).  -
                                 72

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 17.  B. T. Commins. Formation of Poly-
       cyclic Aromatic Hydrocarbons
       During Pyrolysis and Combus-
       tion of Hydrocarbons. Atmos.
       Environ. 3, 565(1969).
 18.  Task Force on Hazardous Waste,
       American Society of Mechanical
       Engineers. Comparison of Full-
       Scale Incinerator Performance
       with the EPA Proposed Hazard-
       ous Waste Guidelines. January
       21, 1980. Submitted to OSW.
J. W. Harrison, J. B. White, and W. J. King are with Research Triangle Institute,
  P.O. Box 12194. Research Triangle Park, NC 27709.
Wade H. Ponder is the EPA Project Officer (see below).
The complete report, entitled "Assessment of Hazard Potential from Combustion
  of Wastes in Industrial Boilers," (Order No. PB 81-221 889, Cost: $11.00.
  subject to change) will be available only from:
        National Technical Information Service
        5285 Port Royal Road
        Springfield, VA 22161
        Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
        Industrial Environmental Research Laboratory
        U.S. Environmental Protection Agency
        Research Triangle Park, NC 27711
it US GOVERNMENT PRINTING OFFICE. 1981 —757-012/7311
                                                                               13

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