United States
                   Environmental Protection
                   Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park NC 27711
                   Research and Development
EPA/6007S8-89/063 May 1990
f/EPA         Project  Summary
                   Municipal Waste Combustion
                   Assessment:  Technical  Basis  for
                   Good  Combustion Practice
                   P.J. Schindler and L.P. Nelson
                     The EPA's  Office of Air Quality
                   Planning and  Standards (OAQPS) Is
                   developing emission standards and
                   guidelines for, respectively, new and
                   existing municipal waste combustors
                   (MWCs)  under the  authority of
                   Sections  111 (b) and  111 (d)  of  the
                   Clean Air Act (CAA). The EPA's Office
                   of Research and Development (ORD)
                   is providing support  in developing
                   the technical  basis for good com-
                   bustion practice (QCP), which  Is
                   Included In the regulatory  alterna-
                   tives  considered In selecting the
                   proposed standards and guidelines.
                   This report defines GCP and sum-
                   marizes  the  approach used to
                   Implement GCP Into  the proposed
                   MWC  standards and guidelines. The
                   report Identifies the minimum subset
                   of GCP operating parameters that can
                   be monitored  continuously to ensure
                   that the GCP goals are achieved.
                   Finally, the report provides a detailed
                   description of the data and rationale
                   used to establish quantitative operat-
                   ing limits for each of the continuous
                   operating parameters.
                      This  Pro/ect   Summary was
                   developed  by  EPA's Air and  Energy
                   Engineering Research Laboratory,  Re-
                   search Triangle Park, NC, to announce
                   key findings of the  research  pro/ect
                   that Is fully documented In a separate
                   report of the  same  title (see  Project
                   Report ordering Information at back).

                   Introduction
                     On July 7, 1987,  the U.S EPA
                   announced its intent to develop air
                   emission standards for  new municipal
                   waste  combustors (MWCs) and emission
guidelines for existing MWCs, under the
authority of Section 111 of the Clean Air
Act (CAA). The New Source Performance
Standards (NSPS) will apply to all MWCs
that commence  construction after the
proposal  date, and the  guidelines will
apply to  all MWCs not covered by the
NSPS.
   Concurrent with the  announcement
that it intended to further regulate MWCs,
EPA  published interim  operational
guidance for use by EPA  Regions and
States in making best available control
technology (BACT) determinations under
the Prevention of Significant Deterioration
(PSD)  provisions of the  Clean Air Act.
The operational guidance specified that
combustion controls are  a demonstrated
technology for controlling emissions of
carbon monoxide (CO) and organics from
MWCs. The technical  basis for the
operational guidance came from  EPA's
1987 Report to Congress on MWCs. The
Report to  Congress examined  two
emission  control strategies: combustion
controls and add-on flue gas cleaning
controls.

Performance Data/Rationale
   The combustion  control strategy
defined in  the  Report to Congress,
termed good combustion  practices
(GCP), identified three elements: design,
operation/control, and verification.   The
strategy  required that:  (1) MWCs be
designed to minimize organic  emissions,
(2) the systems be operated  within
established design  limits and that com-
bustion control measures be in place to
prevent operating outside of these limits,
and (3) verification measures be in place
(e.g., continuous monitors) to ensure that

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combustors continuously maintain good
operations. It  was judged  that  these
conditions would minimize trace organic
emissions. A group of components was
identified  for each of  the  three GCP
elements,  each  of  which  makes  a
necessary contribution to  the  GCP
control strategy.
   Following the July 7,  1987, announce-
ment, data gathering  was continued to
provide  additional  technical  support for
the proposed regulation. Consistent with
the approach laid  out in the  operational
guidance, data gathering addressed both
combustion and  add-on controls. The
new data  and information gathered on
destruction, formation, and  control of
trace organic  compounds  resulted in
revisions to the GCP  control strategy.
The  need  to develop a  practical
implementation strategy to  incorporate
GCP  into  the  standards and guidelines
also forced revisions to the format of the
recommendations. The revised GCP
include seven components, each related
to MWC design and operating conditions
needed  to  control emissions of organic
pollutants.  These components include
conditions  related to:  waste feeding,
combustion temperature, amount and
distribution of  combustion air, mixing,
paniculate matter  (PM)  carryover.
downstream temperature control, and
combustion monitoring and control.
   This  report  summarizes  the rationale
used  to identify  each component as  a
necessary requirement  of the GCP
control strategy. Some of the conditions
(e.g., mixing) cannot  be   measured
directly. Therefore, combustion paramet-
ers  are  specified as surrogates for
verifying  the  degree  to which each
condition is satisfied. For example, CO
concentrations in flue gases  are  indica-
tors of  the degree of mixing. Because
mixing cannot be quantified by itself, it is
necessary to use CO in flue  gases as a
surrogate  to verify mixing performance.
Some combustor  design and operating
conditions  (e.g., downstream flue  gas
temperature) can  be  measured directly.
Thus,  no need  exists  to specify
surrogates for  this condition.  This report
describes the  approach used to  identify
surrogates and numeric operating  ranges
and limits for each.

Implementing
Recommendations
   The  final step  in  GCP development
was  to implement the  GCP recom-
mendations into the proposed standards
and guidelines by identifying  a minimum
set of operating parameters that could be
monitored continuously to ensure that the
GCP goals are achieved. Three operating
parameters were selected which meet
this criterion: CO in flue gases, maximum
operating load, and  PM  control device
inlet temperature. This report describes
the rationale for selecting each parameter
for inclusion  in  the standards and
guidelines,  and provides  a  detailed
discussion of the data used to  establish
quantitative operating limits. The  CO
emission levels  are  established on  a
technology  specific basis because inher-
ent design  and operating  characteristics
of various combustor technologies enable
some design types to achieve lower CO
emission levels than other technologies.
Thus,  the CO emission  levels that
correspond to the use of GCP vary based
on the combustor technology employed.
The population  of existing  MWCs was
categorized based on: conventional mass
burn waterwall, mass burn  refractory wall,
mass burn  rotary  waterwall,  modular
starved  air, modular excess  air, refuse-
derived-fuel  (RDF)  combustors, and
fluidized bed combustors (FBC).

CO in Flue Gases
   Long term continuous  CO data were
gathered from existing MWCs for use  in
establishing an achievable emission limit.
Data were acquired from two mass burn
waterwall MWCs, one modular starved air
MWC, and two RDF-fired MWCs. The
data were statistically analyzed to deter-
mine exceedance frequencies for various
averaging  times, and recommended
emission limits  were established based
on a 1-in-10-year exceedance of a 4-hour
block average. Where no  longterm data
were available to characterize  the per-
formance of an MWC technology, long-
term emissions were extrapolated from a
review of  shortterm  data.  Sometimes,
when longterm data  appeared  not  to
adequately represent emission levels that
correspond to the use of GCP, shortterm
parametric test data were used   to
establish the achievable emission levels.
The CO emission levels were established
ranging from 50 to 150 ppm, corrected to
7%  02, 4-hour  block   average. The
emission levels selected were judged  to
reflect the  use  of GCP for each MWC
technology.

Maximum Operating  Load
   The  maximum operating load level
was selected as a continuous operating
parameter to serve as a surrogate for PM
carryover. The rationale for selecting this
parameter  was that  high  load operation
results in  increased  flue gas flow rates,
which  can lead  to increased  PM
entrainment and  carryover.  Data are
presented showing a relationship be-
tween PM carryover and polychlorinateq
dibenzo-p-dioxin (CDD) and dibenzofurar
(CDF) emissions. The GCP recommenda-
tion  is for each  MWC that  produces
steam not  to exceed  a  maximurr
operating load of  100% steam flow,  4
hour  average.  This recommendatior
cannot be implemented for MWCs tha
do not generate steam.

PM  Control Device Inlet
Temperature
   The  third  continuous operatin;
requirement  addresses  the potential fo
CDD/CDF formation to occur in lov
temperature portions  of the  MW(
system.  Low temperature  CDD/CDI
formation  has been  observed  am
quantified in  several full  scale MWCs
and  bench scale laboratory experiment
have examined the parameters control
ling  these reactions. The  recommendei
control strategy in full scale MWCs is t
minimize the flue  gas  residence time i
the temperature window where the rate <
the formation reactions is  highest (25C
400 °C). Data are presented showing th
relationship between electrostati
precipitator (ESP)  operating temperatur
and  CDD/CDF removal. These data ar
used to establish the  GCP  recorr
mendation that  all MWCs  maintain  PI
control device  temperatures  belo
232 "C. The  data indicate that  thes
conditions  will  minimize  CDD/CD
concentrations in  stack flue gases t
preventing formation and, in some case
enhancing removal of CDD/CDF in th
flue gas cleaning device.

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  P.J. Schindler and LP. Nelson are with Energy and Environmental Research
       Corp.. Durham, NC 27707.
  James D. Kilgroe is the EPA Project Officer (see below).
  The complete report,  entitled  "Municipal Waste  Combustion Assessment:
       Technical Basis  for  Good Combustion Practice," (Order No. PB 90-154
       949IAS; Cost: $23.00, 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:
          Air and Energy Engineering Research Laboratory
          U.S. Environmental Protection Agency
          Research Triangle Park, NC 27711
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
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