5476
OOOD82004
                                                    c.l
                      Guidance manual for hazardous waste
                          incinerator permits:  draft

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               GUIDANCE  MANUAL FOR HAZARDOUS

                 WASTE INCINERATOR PERMITS
                      DRAFT
                     September, 1982
              Prepared by  the Office of Solid
                Waste and  MITRE Corporation
NOTE: This preliminary  guidance document is intended to
assist the owner  or  operator of a hazardous waste incin-
erator in developing a  RCRA Part B permit application
and the permit writer in  evaluating the permit applica-
tion.  It is being distributed for review,  comment and
possible use.  EPA is interested in receiving comments
on the usefulness of the  guide and suggestions on how it
may be improved.   It was  developed by a contractor in
concert with EPA  Headquarters personnel but has not yet
been reviewed by  applicants or other persons outside EPA.
       U.  S.  Environmental Protection Agency
                 401  M  St.,  S. W.
             Washington, D. C.  20460
                                  C1..V

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U,3. r.nvl.'crirr&rtcil rro!:cl;:.n  Agency

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                          TABLE OF CONTENTS

                                                                 Page

LIST OF ILLUSTRATIONS                                             v
LIST OF TABLES                                                    vi

1.0  INTRODUCTION                                                1-1

1.1  Hazardous Waste Incinerator Permits                         1-4
1.2  Content of the Permit Application                           1-8
1.3  Permit Application Procedures                               1-11

     1.3.1  New Incinerators                                     1-11
     1.3.2  Existing Incinerators                                1-13

1.4  Use of this Manual                                          1-15

2.0  EVALUATION OF THE PERMIT APPLICATION                        2-1

2.1  Evaluating the Waste Analysis Information                   2-2

     2.1.1  Analysis for POHC Selection                          2-3
     2.1.2  Analysis for Other Waste Characteristics             2-6
     2.1.3  Analysis Required to Support Exemption               2-8

2.2  Designating Principal Organic Hazardous Constituents        2-17
2.3  Review of the Trial Burn Plan                               2-32
2.4  Evaluating the Design of the Trial Burn                     2-33

     2.4.1  Selecting the Trial Burn Waste Feed                  2-37
     2.4.2  Operating Conditions                                 2-42
     2.4.3  Provisions for Stack Gas Sampling and Monitoring     2-48

3.0  EVALUATION OF INCINERATOR PERFORMANCE DATA                  3-1

3.1  Evaluation of Data Submitted in Lieu of Trial Burn          3-1
     Results

     3.1.1  Similarity of Wastes                                 3-2
     3.1.2  Similarity of Incinerator Units                      3-3

3.2  Interpretation of Engineering Data                          3-5
3.3  Calculation of Destruction and Removal Efficiency (ORE)     3-5
3.4  Hydrogen Chloride Emissions                                 3-12
3.5  Particulate Emissions                                       3-16
                                 iii

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                    TABLE OF CONTENTS  (Concluded)

                                                                 Page

4.0  SPECIFICATION OF PERMIT CONDITIONS                          4-1

4.1  Specification of Operating Requirements from                4-2
     Performance Data

     4.1.1  Carbon Monoxide Level in the Stack Gas               4-3
     4.1.2  Waste Feed Rate                                      4-5
     4.1.3  Combustion Temperature                               4-11
     4.1.4  Combustion Gas Flow Rate                             4-12
     4.1.5  The Emergency Waste Feed Cutoff System               4-15

4.2  Limitations on Waste Feed Composition                       4-17

     4.2.1  Allowable Waste Feed Constituents                    4-18
     4.2.2  Limitations on Chemical and Physical Waste Feed      4-21
            Characteristics

4.3  Specification of Inspection Requirements for the            4-25
     Emergency Waste Feed Cutoff System

5.0  EXAMPLES OF SPECIFICATION OF PERMIT CONDITIONS              5-1

5.1  Discussion of Example 1                                     5-2

     5.1.1  Case Description                                     5-2
     5.1.2  Development of Permit Conditions                     5-4

5.2  Discussion of Example 2                                     5-8

     5.2.1  Case Description                                     5-6
     5.2.2  Development of Permit Conditions                     5-11

5.3  Discussion of Example 3                                     5-13

     5.3.1  Case Description                                     5-13
     5.3.2  Development of Permit Conditions                     5-13

6.0  REFERENCES                                                  6-1

APPENDIX A - EVALUATION OF INCINERATOR DESIGN INFORMATION        A-l
                                 iv

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                        LIST OF ILLUSTRATIONS

Figure Number                                                    Page

     2-1         Water Vapor Content of Saturated Flue Gas       2-15

     2-2         Schematic Diagram Showing Trial Burn            2-50
                 Monitoring Locations for Rotary Kiln
                 Incinerator

     2-3         Schematic Diagram Showing Trial Burn            2-51
                 Monitoring Locations for a Liquid
                 Injection Incinerator

     4-1         Example of Multiple Waste Feeds to a            4-9
                 Rotary

     5-1         Samples of Continuously Recorded                5-6
                 Temperatures

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                           LIST OF TABLES

Table Number                                                     Page

    2-1          Rationale for Selection of Waste Analysis       2-7
                 Parameters

    2-2          Acceptable Analytical Methods for Waste         2-9
                 Analysis

    2-3          Heat of Combustion of Organic Hazardous         2-18
                 Constituents from Appendix VIII, Part 261

    2-4          Ranking of Incinerability of Organic            2-24
                 Hazardous Constituents from Appendix VIII,
                 Part 261 on the Basis of Heat of Combustion

    2-5          Checklist for Content of Trial Burn Plans       2-34

    2-6          Advantages and Disadvantages of Materials       2-43
                 to Increase Ash Content

    3-1          Criteria for Determination of Incierator        3-4
                 Similarity

    3-2          Calculation of ORE                              3-7
                   *
    3-3          Sample Calculation of DRE                       3-10
                          »
    3-4          Calculation of Scrubber Efficiency              3-14

    3-5          Sample Calculation of Scrubber Efficiency       3-15

    3-6          Calculation of Partriculate Emissions            3-18

    3-7          Sample Calculation of Particulate Emissions     3-19

    5-1          Sample Permit Application Data - Example 1      5-3

    5-2          Sample Permit Conditions - Example 1            5-5

    5-3          Sample Permit Application Data - Example 2      5-4

    5-4          Sample Permit Conditions - Example 2            5-12

    5-5          Sample Permit Application Data - Example 3      5-14

    5-6          Sample Permit Conditions - Example 3            5-16
                                 vi

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         GUIDANCE MANUAL FOR EVALUATING PERMIT APPLICATIONS
                  FOR HAZARDOUS WASTE INCINERATORS
1.0  INTRODUCTION

     The Solid Waste Disposal Act, as amended by the Resource

Conservation and Recovery Act of 1976, requires EPA to establish a

national regulatory program to ensure that  hazardous wastes  are

managed in a manner which does not endanger human health or  the

environment from the time they are generated until their eventual

destruction or final disposition.   The statute requires EPA  to:

     promulgate regulations establishing such performance standards,
     applicable to owners and operators of  facilities for the
     treatment, storage or disposal of hazardous waste identified
     or listed under this subtitle, as may  be necessary to protect
     human health or the environment.  (42  USC §6964)

Each such facility must apply for  and receive a permit which applies

the standards to its own particular circumstances and states its

particular compliance obligations.

     RCRA allows existing facilities to operate during the period

before a final permit descision is reached, provided that the owner

or operator has made a timely submission of the required permit

application.   A facility is legally eligible for operation during

this period,  called the period of  "interim  status",  only if  it was

in existence on November 19,  1980  and if the owner or operator

submits a RCRA permit application.

     Because of the Large number of RCRA permits that must be

issued, the permit application needed to qualify for interim status
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niay be due years before the facility's individual  permit  will  be




considered.  Requiring all of the information needed for  a  decision




concerning the facility permit at the time of qualification for




interim status would result in a requirement  that  owners  and opera-




tors provide a great deal of information to the Agency  long before




it is needed for regulatory purposes.  Furthermore,  because of the




lengthy period which ensues following qualification  for interim




status, information provided so far in advance might well be out-




dated by the time EPA begins to evaluate the  permit  application.




     To avoid this result, EPA has divided the permit application




into two parts.  Part A, which is relatively  brief,  is  filed by




owners and operators of existing facilities in order to qualify for




interim status.  Part 3 of the permit application  contains  the




balance of the information necessary to fully evaluate  the  facility's




performance and reach a decision concerning issuance of a permit.




SPA's standards for hazardous waste incinerators (40 CFR.  264.340 -




264.351 and 40 CFR 122.25 and 122.27(b)) specifically identify the  -



information necessary to complete the Part B  application  for a




hazardous waste incinerator.




     The standards specify three broad substantive requirements




regarding incinerator performance.  They are  that  the principal




organic hazardous constituents (POHCs) designated  in each waste feed




must be destroyed and/or removed to an efficiency  of 99.99Z, that




particulate emissions must not exceed 180 milligrams per  dry
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standard cubic meter, corrected to 7% oxygen in the stack gas,




and that gaseous hydrogen chloride (HC1) emissions must be reduced




either to 1.8 kg per hour or at a removal efficiency of 99 percent.




The regulations also specify a number of requirements for waste




analysis and incinerator operation, monitoring and inspections.




Finally, they establish the procedures by which permits to hazardous




waste incinerators will be granted.




     This manual provides guidance for review and evaluation of




the permit application information submitted to document compliance




with the RCRA standards for incineration.  Methods are suggested




for designating facility-specific operating conditions necessary




to ensure compliance with the standards, on the basis of the per-




formance data supplied by the applicant.  Each section of the




incineration regulation is addressed, including: waste analysis,




designation of principal organic hazardous constituents (POHCs)




in the waste, and requirements for operation, inspection and




monitoring.  Guidance is also provided for evaluating incinerator




performance data and the procedures used in an incinerator trial




burn, during which performance data are generated.




     In addition to the standards for incineration, owners and




operators of hazardous waste incinerators must comply with the




general facility standards and administrative requirements for




hazardous waste management facilities (40 CFR Part 264, Subparts




A through H).  These standards include requirements for: security,




facility inspections, personnel training, special requirements
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for ignitable, reactive and  incompatible wastes,  facility  location



with respect to floodplains  and areas of seismic  activity,  special



equipment for emergency preparedness and prevention, a  contingency




plan and procedures to be used in an emergency, use of  the  hazardous



waste manifest system, recordkeeping, reporting,  and facility




closure.  They apply to all  regulated hazardous waste treatment,



storage and disposal facilities and all Part B applications must



include detailed descriptions of the equipment, plans and procedures



required by these standards.  Guidance for review and evaluation



of the permit application information documenting compliance with



the general facility standards and administrative requirements  is



provided in other RCBA guidance manuals.






1.1  Hazardous. Waste Incinerator Permits



     Compliance with the standards for incineration of hazardous



waste (40 CFR 264.340 through 264.351) may be initially established



through performance of a trial burn.  During the  trial burn, the



applicant tests the incinerator's ability to destroy the hazardous



waste, or wastes to be treated at the facility, in compliance with



the performance standards.   Generally, the applicant's goal in  con-



ducting the trial burn should be to identify the most efficient con-



ditions, or range of conditions, under which the  incinerator can be



operated in compliance with  the performance standards.  Often,  this



will require that the applicant test a range of operating conditions



during the trial burn in order to identify the best conditions.
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     In order co establish compliance with the  performance standard




for 99.99% destruction and removal of organic waste  constituents,




the regulations provide for selection,  by the permitting official




(the "permit writer"), of principal organic hazardous  constituents




(POHCs) for each waste feed to be burned.  POHCs  are hazardous or-




ganic substances present in the waste feed representative of those




constituents which are most difficult to  burn and most abundant in




the waste.  The incinerator standards set out the criteria to be




used in selecting POHCs (i.e., ease of  incinerability  and concen-




tration).  The destruction and removal  efficiency is actually




measured only for the designated POHCs.   The incinerator's per-




formance in treating POHCs is considered  indicative  of overall




performance in treating other wastes.  This provision  acts to




simplify the sampling and analysis efforts which- are necessary to




determine whether the performance standard has  been  achieved,




thereby reducing the cost and complexity  of the trial burn.




     Compliance with the performance standard for control of




gaseous hydrogen chloride (HC1)  emissions is documented, during




the trial burn, by measuring HC1 in the stack gas.   Similarly,




compliance with the performance  standard  for control of particulate




emissions is documented by measuring the  particulate load in the




stack gas during the trial burn.




     Part B of the permit application for a hazardous waste incin-




erator may include a detailed plan describing th-e test procedures,
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sampling and analytical protocols and schedules for conducting  a

trial burn.  This plan should be reviewed by the permit  writer  and

approved if found sufficient to provide all necessary performance

data.  The trial burn plan is a required component  of a  permit

application for a new incinerator.^-  Owners and operators  of

incinerators currently in interim status are not obligated to draw

up a detailed trial burn plan for Agency approval prior  to conduc-

ting the burn.  Performance data may be collected in the course of

routine operation during interim status.  However,  prior approval

of a trial burn plan will provide the applicant with assurance

that the information collected will be sufficient for preparation

of the permit and that further data collection efforts are not

likely to be necessary.  Furthermore,  careful planning of  the

trial burn will allow the applicant and Regional or State  re-

presentative to design a permit that is well tailored to the

specific needs of the facility and provides the greatest possible

flexibility.

     The performance data collected during the trial burn  are

reviewed and evaluated by the permit writer and become the basis
  A "new" incinerator is one that  was  not in  existence on
  November 19,  1980 and therefore  does not qualify for interim
  status.  The  RCRA regulations  stipulate that owners or operators
  of new incinerators  must  apply  for  and receive a RCSA permit
  before beginning construction.

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for setting the conditions of the facility permit .   Generally,




the operating conditions, or range of conditions,  shown to  result




in acceptable incinerator performance (as defined  by the performance




standards) will be designated in the permit  as  allowable.   The




incinerator regulation requires that the permit  specify allowable




waste analysis procedures, allowable waste feed compositions  (in-




cluding acceptable variations in the physical or chemical properties




of the waste feed), acceptable operating limits for  carbon  monoxide




(CO) in the stack exhaust gas, waste feed rate,  combustion  tempera-




ture, combustion gas flow rate, and allowable variations in incin-




erator design and operating procedures (including  a  requirement




for cutoff of the waste feed during start-up, shut-down and at any




time when-the conditions of the permit are violated).   The  permit




must also specify actions necessary to control  fugitive emissions




from the incinerator,  methods for continuous monitoring of  operating




parameters, and requirements for periodic inspection of the facility.




Additionally, the incinerator regulation allows the  permit  writer




to specify any other permit conditions necessary for protection of




human healt h and t he envi ronment.




     In reviewing and  evalating the permit application,  it  is essen-




tial that the permit writer make all decisions  in  a  well-defined and




well-documented manner.  Once an initial decision is made to issue




or deny a permit, the  Subtitle C regulations (40 CFR 124.6, 124.7,




and 124.3) require that either a statement of basis  or  a fact sheet
                                1-7

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be prepared which discusses  the  reasons  for  the  decision.   The

statement of basis or  the fact sheet  then becomes  part  of  the

administrative record  (40 CM 124.9), which  is to  be made  available

for public review and  comment as part of the permit review process

(40 C7B. 124.6 through  124.20).



1.2  Content of the Permit Application

     The RCSA regulations allow  incinerator  owners and  operators  to

select one of several  options for completing a permit application.

First, applicants seeking permits to  burn wastes which  are hazardous

solely due to their ignitable, corrosive or  reactive properties are

eligible for exemption from most of the  technical  standards for

incineration.  These applicants are required to submit  only the

information required by the general and administrative  standards,

and a detailed waste analysis.  Applicants not eligible for the

exemption will be required to conduct a trial burn and  submit the

results of all stack sampling and analysis with the permit applica-

tion.  As an alternative to conducting a trial burn, applicants

may submit waste analysis data and data describing the  performance

of a similar incinerator burning a similar waste.  This information

will be evaluated to determine whether it can be used to predict

the performance of the applicant's incinerator.

     The information which must be submitted to show compliance
                                          \
with the standards for incineration consists of five components:

waste analysis information, the facility description, the  trial

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burn plan, performance data, and proposed operating conditions.




Waste analysis information includes all sampling and analytical




methods and plans for conducting both a detailed waste analysis




and periodic waste analysis to verify that the waste feed composi-




tion entering the incinerator does not violate the conditions of




the permit.  The results of a detailed waste analysis should also




be provided.  This information will allow the permit writer to




designate the principal organic hazardous constituents of the waste.




     The facility description includes, at a minimum, the linear




dimensions of the incinerator, capacity of the prime mover, descrip-




tion of the nozzle and burner design and the location and descrip-




tion of temperature, pressure and flow indicators and control




devices.  The applicant must also provide a description of the




auxiliary fuel system, the automatic waste feed cutoff system, the




air pollution control system and the stack gas monitoring system.




     The trial burn plan should include a description of all




sampling and monitoring procedures and equipment, a test schedule




and protocol, a description of the range of operating conditions




under which the incinerator will be operated, and a description of




emergency procedures for waste feed cutoff, shutdown of- the incin-




erator and control of emissions.  The trial burn plan should discuss




all methods planned for testing the components of the incinerator




(e.g., waste feed mechanisms, monitoring devices, air pollution




control devices).  In addition, the waste feed(s) to be used during
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 pending  on the  degree  of  flexibility needed in the permit conditions.






 1.3   Permit  Application Procedures




    .  1.3.1  New Incinerators.   Prior to  construction of  the  incin-




 erator,  owners  and  operators of  new  facilities who will  conduct  a




 trial burn are  required to  submit a  trial  burn plan with the permit




 application.  The application will be processed through  all  of the




 required administrative procedures (40 CYB. Part 124),  including




 preparation  of  a draft permit and opportunity  for  public comment




 and hearing.  After  completion of this process,  a  permit that




 establishes  all of  the conditions needed to  comply with  all  appli-




 cable  standards will be issued.  This permit will  be the "finally




 effective  RCRA  permit" required  (40  CFR  122.22)  for construction




 of the incinerator.




     The permit will be structured to provide  for  four phases of




 operation.   Operating conditions will be specified for each  phase.




 The initial  phase begins  immediately following completion of  con-




 struction.   During this phase, the facility  may  be operated  for




 "shake-down" purposes, in order  to identify  possible mechanical




 difficulties, and to ensure that the  facility  has  reached opera-




 tional readiness and has achieved steady-state  operating  conditions




 prior to conducting  the trial burn.    This phase  of  the permit is




 limited  in duration  to 720 hours of  operation  using  hazardous




waste feed (one additional period of  up to 720 hours may be allowed




for cause).
                                1-11

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the trial burn should be described in detail.  This  is particularly




important in cases where the applicant chooses to use a contrived




blend of wastes or chemicals instead of the waste that will normally




be treated at the facility.



     The performance data included in the permit application will




primarily consist of data collected during the trial burn.  The




applicant may supplement the trial burn data with data or informa-




tion collected previous to the trial burn or with data generated




by a similar incinerator.  In some cases, the applicant may have




extensive data from a trial burn conducted at a. similar or iden-



tical incinerator burning a similar waste.  This information, if




sufficient to write the permit conditions, may be used in lieu of




a trial burn.  At a minimum, the performance data should include:




results of the waste analysis, results of the analyses of the




scrubber solution, ash and other residues, computations of the




destruction and removal efficiency, particulate emissions and HC1



emissions, identification of any fugitive emissions, average,




maximum and minimum temperatures and combustion gas flow rates,




and results of any continuous monitoring.



     Finally, the permit application should include a description




of the conditions under which the applicant proposes to operate the




incinerator.   Each of the operating parameters identified in the




regulations (40 CFR 264.345) should be addressed.  This portion of




the permit application will vary in detail and complexity, de-
                                i-in

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     After  timely and  satisfactory  completion  of  all  shake-down




operations, the second phase of the permit begins.  This  phase con-




sists solely of the  period alotted  for  conducting the trial  burn.




Following completion of the trial burn, a period  of several  weeks




to several  months will be necessary for completion and submission




of the trial burn results and subsequent specification of operating




conditions  to reflect the results.  During this period, which re-




presents the third operational phase of the permit, the facility




may continue to operate under specified operating conditions.




     Detailed review of the trial burn  results will show either




that the incinerator is capable of complying with the performance




standards when operating within the trial burn conditions, or that




compliance was not attained during the  trial burn and a second




test is necessary.   If compliance was shown, the  permit may  be




modified to set, as  the final operating requirements,  those  demon-




strated during the trial burn.  (40 CFR 122.17 Minor  modifications




of permits).  If compliance has not been shown and an additional




trial burn  is necessary, the permit must be modified  to allow for




an additional trial  burn.  When all permit modifications are com-




plete, the facility  begins its fourth and final operating phase




which continues throughout the duration of the permit.




     Permit modification may be major or minor modification.  Minor




modlflcationsare changes in the waste feed composition, operating




conditions, or other permit stipulations that are within the range

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of allowable variations specified  in a permit.  Examples of minor




variations are an increase in the heating value of a waste and an




increase in combustion zone temperature.  Minor permit modifications




do not require review at a public hearing.  Major permit modifications




are changes that are outside the range of permitted values and




equipment modification that may affect incinerator performance.




Examples of major modifications are a decrease in the heating value




of a waste below the permitted value, a change in the monitoring




location of combustion zone temperature, and replacement of a combustion




chamber.  Major modifications require review at a public hearing.




     1.3.2  Existing Incinerators.  The application procedure for




existing facilities differs from new facilities because an existing




facility in interim status is authorized to burn hazardous wastes.




Therefore, an existing facility needs no prior approval to continue




operation or conduct a trial burn,  However, without the permit




writer's approval, the owner or operator cannot be certain that




the trial burn data will be sufficient to meet the permit writer's




needs.   Thus,  the applicant will find it advantageous to obtain




approval of a trial burn plan prior to conducting the test.  During




review of the trial burn plan,  the permit writer will designate




principal organic hazardous constituents to be monitored and will




specify other requirements.  However, the applicant may choose to




collect data during the course of normal operation under interim




status  or may acquire data from similar facilities burning similar
                                1-13

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wastes to be submitted with Part B of the permit application in lieu




of conducting a trial burn according to an approved trial burn plan.



     Because RCHA provides for existing incinerators to operate



under interim status while awaiting the Agency's decision concerning



permit issuance, these facilities do not experience the operating




restrictions which complicate the permitting process for new incin-



erators.  Owners and operators of existing incinerators who will




conduct a trial burn may submit a trial burn plan either before or



with Part B of the permit application.  The permit writer will



evaluate the plan and approve it after making all necessary deter-



minations (40 CFR 122.27).



     If a trial burn plan is submitted and approved before the



permit application has been submitted, the applicant should conduct



the trial burn, and submit the resulting data with the permit appli-




cation.  If completion of this process conflicts with the date set



for submission of the Part B application, the applicant should




contact the permit writer to extend the date for submission of the



Part B application, or submit the Part B without the trial burn



results and provide the data within 90 days following completion



of the trial burn.  If a trial burn plan is submitted with Part B



of the permit application, the permit writer, when approving the



plan,  will specify a time period for conducting the trial burn and



submitting the results.   Following submission of the trial burn



results and the Part B application, the permit writer will prepare
                                1-14

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a -draft penult specifying the proper operating requirements, based


on the results of the Jtrial burn, along with all other applicable


permit conditions.  This permit will then be processed through the


standard administrative procedures (40 CFR Part 124).



1.4  Use of this Manual


     The information and guidance presented in this manual consti-


tute suggestions for review and- evaluation, often based upon best


engineering judgment.  The guidance is intended to help resolve


technical issues on a:case by case basis, not provide rigid rules


to be applied in all circumstances.  This manual will assist the


permit writer in arriving at decisions in a logical, well-defined,


and well-documented manner.  Checklists are provided throughout the


manual to ensure that necessary factors are considered in the
                                              *

decision process.  Several options for developing specific permit


requirements are presented.  The permit writer is not limited to


adopting only one option and is encouraged to tailor permits to


each applicant's situation.  Technical data and numerical methods


are presented to assist the permit writer in evaluating an incin-


erator.  References are cited throughout this manual to aid the


permit writer in those dnsstances where further guidance is necessary.


     This guidance manual may be used in conjuction with the


"Engineering Handbook-fbr Hazardous Waste Incineration," EPA SW-889,


IERL, Cincinnati, OhioiX^  The:Engineering Handbook provides back-


ground information to familiarize the permit writer with current
                                1-15

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incineration technology.  Permit writers may also use  the hazardous



waste incineration data base.  This data base provides computer



and hard copy access to trial burn data, permit application data




and information from incinerator manufacturers.  The data base is




accessible at SPA regional offices and at SPA headquarters.



     The permit writer may also require technical assistance in




the evaluation of certain permit applications, especially those



for which there are no precedents.  To this end, the Agency has



formed a Permit Assistance Team (FAT).  The team consists of experts




in the field of hazardous waste incineration.  It has  two primary



functions:  (1) to provide the Regional Offices with direct access



to specialized expertise related to hazardous waste incineration,



and (2) to provide EPA with increased capability to respond quickly



when applications are received.  The members of the PAT augment



SPA staff capabilities concerning incineration hardware, facility




design, analytical measurements and protocols, site survey and



evaluation, and, environmental impact modeling and assessment.



     The permit writer should begin evaluating the application



with examination of the trial burn plan.  The elements and consid-



erations that should be included in the trial burn plan are iden-



tified and discussed in Chapter 2.  Guidance for evaluating the



waste analysis plan and waste analysis data is also presented in



Chapter 2.  This evaluation includes designation of the principal



organic hazardous constituents (POHCs) for each waste described in

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a permit application.  Guidance is presented in Section 2.1 for




making this designation.




     Methods for evaluating incinerator performance data are pre-




sented in Chapter 3.  Sample.calculations of destruction and removal




efficiency (DRE), scrubber efficiency, and correction of particular




emissions are provided in Chapter 3.  Guidance for the specification




of operating requirements is presented in Chapter 4 and examples of




the development of specific permit conditions from incinerator per-




formance data are included in Chapter 5.




     Incinerator design information may be evaluated using the




methods presented in Appendix A.  The purpose of this evaluation is




to ensure that the information is consistent with current engineering




practice and that the unit may be expected to achieve compliance with




the performance standards.  The methods of evaluation are based on




simple engineering assumptions and will assist the permit writer




in detecting major operational or design problems.
                                1-17

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2.0  EVALUATION OF THE PERMIT APPLICATION

     Evaluating the permit  application encompasses  four  major

activities:  Evaluating the waste analysis  procedures  and information,

designating principal organic hazardous constituents (POHCs) for

the waste feed, reviewing and approving the trial burn plan,^-

and evaluating the incinerator design.   This chapter provides

guidance for evaluating the waste analysis  plan  and data, designating

POHCs and evaluating the trial burn plan.   Guidance for  evaluating

incinerator design is provided in Appendix  A.

     The guidance presented in this chapter will assist  the permit

writer in reviewing the trial burn plan and determining  whether

the proposed trial burn will provide accurate data  of  sufficient

detail to determine whether the regulatory  requirements  are met.

This chapter discusses topics, related to chemical analysis of

wastes, stack gases and other incineration  residues, use of contrived

waste blends in the trial burn,  and alternatives for planning the

trial bum.  Section 2.2 presents a method  for selection of principal

organic hazardous constituents (POHCs)  on the basis of constituent

concentration and degree of incinerability.  The permit  writer

should recognize that this  method has been  selected as the best of

several alternatives, after careful consideration of the advantages
  Review and approval of  a trial  burn  plan prior to conducting the
  trial burn is not  required in every  case.  For incinerators
  operating in interim status, this activity will be conducted prior
  to the trial burn  at  the request of  the applicant.

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and disadvantages of each.  The POHC selection method presented

here should be used in all cases, although there may be instances

where the permit writer will select some additional POHCs using

other methods.

     Z.I  Evaluating The Waste Analysis Information

     The permit application should include procedures for sampling

and analyzing the waate feed^, the incinerator stack gas, and

incineration residues (e.g., bottom ash, scrubber solutions,

other residues from air pollution control devices).  The methods

used for sampling and analysis should be provided in detail.   All

sample preparation and storage techniques should be described.

Detection limits and standard deviations should be provided for

each analytical method used.

     The Agency has recommended sampling ttechniques and analytical

methods for waste analysis in its document: Test Methods for Eval-

uating Solid Waste:   Physical/Chemical Methods (SW-846).   Methods

for sampling and analysis of stack gases and other incineration

residues are provided in the EPA document Sampling and Analysis

Methods for Hazardous Waste Incineration, an Addendum to  SW-346.

The methods proposed in the trial burn plan should be taken from

these two documents.  The document specific to hazardous  waste

incineration provides general methods  for sampling and analysis,

and modifications to these methods may be made, as necessary,

to ensure that 99.992 ORE can be verified.   Such modifications
  The term "waste feed" is used here to indicate the waste stream
  as it enters the incinerator.  This feed  may  be a blend of  "wastes'
  received from several different  generators or production processes.

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would include, for example, increased sample collection times  or




modifications to the elements of the sampling train.




     Some applicants may propose the use of analytical methods




different from those recommended by EPA.  In all such cases, detailed




descriptions of the analytical protocols should be provided.   The




permit writer must evaluate the proposed analytical methods in




order to determine whether they are equivalent to those recommended




by EPA.  This evaluation should include consideration of factors




such as detection limits, precision, accuracy, and possible inter-




ferences.




     2.1.1  Analysis for POHC Selection




     In order to establish compliance with the performance standards




for 99.99% destruction and removal of organic waste constituents,




the regulations provide for selection, by the permit  writer, of




principal organic hazardous constituents (POHCs) for  each waste




feed to be burned.  POHCs are hazardous organic constituents of




the waste, selected from the list of hazardous constituents in 40




CFR Part 261, Appendix VIII, that are representative  of those  con-




stituents most difficult to burn and most abundant  in the




waste.  During the trial burn,  the destruction and  removal effic-




iency is actually measured only for the POHCa and the incinerator's




performance in treating these substances is used to indicate overall




performance in combusting organic waste.  This aspect  of the incin-




erator standards  simplifies the sampling and analysis  efforts  which
                                2-3

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are necessary to determine whether the performance standard has


been achieved, thereby reducing the cost and complexity of the


trial burn.

     To facilitate selection of POHCa and measurement of DRE,  the


applicant oust provide the permit writer with detailed waste analy-


sis information.  The regulation prescribes a 3-step procedure for

generating the necessary analytical information in an efficient


manner without requiring rigorous quantitative analysis for hun-


dreds of organic compounds.  This procedure, which employs a re-


verse search technique, reduces the complexity and cost of waste


feed analysis because the analysis is directed at  those specific


compounds that are expected to be present in the waste.


     In the first step of the procedure, the applicant  should


establish a list of hazardous constituents,  from among  those


listed in 40 CFR Part 261, Appendix Till, that are reasonably


expected to be present in the waste feed.  These selections should


be based on the applicant's knowledge of the waste normally fed

to the incinerator and the industrial processes from which the

wastes are generated.3  Once the list of "expected" hazardous  con-


stituents is completed, the applicant should generate a chromatogram
    t
from a sample of the waste feed using the mass spectrometer tech-

niques presented in SW-846.
  The trial burn plan must  also  identify  any constituents from
  Appendix Till that  are excluded from the  analysis  and provide
  the rationale for the exclusions.

-------
     In the second step of the procedure, the applicant  should




conduct a computerized reverse search of the chromatogram to  iden-




tify and quantify any of the "expected" constituents detected in




the chromatogram.  At this stage, quantification of each constituent




will not be highly accurate.   The concentration, generated, however,




will be sufficient for selection of POHCs by the permit  writer,  and




should be included in the trial burn plan.  Procedures for conducting




the reverse search are provided in SW-846.




     The third step in the data collection process takes place at




the time of the trial burn and should be addressed in the trial  burn




plan.  It is during this step that the data needed to accurately




calcuate the incinerator's destruction and removal efficiency are




generated.  Using the methods provided in SW-846,  the applicant




should analyze the waste feed and the stack gas in order to quantify




POHC levels present in each, to the prescribed detection limits.




     In order to maintain accuracy in the DRE calculation, the POHC




concentrations in the waste feed should be measured periodically



during the trial burn.  In general, waste feed samples should be




collected simultaneously with stack gas samples.   For example, the




trial burn plan may specify taking a 3-hour stack  sample for  each



set of operating conditions to be tested.  During  the 3-hour  stack




sampling period,  the waste feed could be sampled at  15-minute




intervals and the samples composited over the 3-hour period.   In




this manner,  accuracy is maintained without  requiring analysis of
                                2-5

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very large numbers of waste feed samples.



     2.1.2  Analysis .For Other Waste Characteristics



     In addition to identification and quantification of hazardous




constituents, the incinerator standards require the applicant to



measure the viscosity (where appropriate) and. heating value of the



waste feed.  Viscosity measurements provide the permit writer with




information necessary to Judge the adequacy of liquid waste delivery



systems.  The heating value of the waste feed is needed to deter-




mine and maintain adequate operating conditions and may be used




to establish permit conditions.



     The standards also allow the Regional Administrator to request




any information, in addition to that specifically required, that is




needed to evaluate incinerator performance and establish adequate



operating conditions.  Rationales for the selection of additional




waste parameters are summarized in Table 2-1.  The ash content of




the waste feed should be determined in order to specify permit



conditions for allowable variations in waste feed.  Measurement



of ash content also allows evaluation of potential for slag formation.




If the waste is solid or sludge, a Chermogravimetric analysis



(measurement  of weight loss as a function of temperature)  provides



valuable information.  Knowledge of flash point or eacplosivity




helps to ensure safe handling of the wastes.  Measurement  of carbon,



hydrogen,  sulfur,  nitrogen, phosphorous and oxygen concentrations



and the water content of the waste feed is needed to compute stoi-
                                2-6

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                             TABLE 2-1

        RATIONALE FOR SELECTION OF WASTE ANALYSIS PARAMETERS
Parameters
                     Rationale
PCS Content
Organically Bound
Chloride Content
Ash Content
Solids Content
Flash Point
Explosivity
Carbon, Hydrogen, Sulfur,
Nitrogen, Phosphorous,
Oxygen, Water Content
Thennograviniet ri c
Analysis
Cyanide and Sulfide
Incineration of wastes containing more
than 50 ppm PCS is regulated under
40 CFR 761.40.

The organically bound chloride content
is used to compute the hydrogen chloride
removal efficiency and to estimate uncon-
trolled hydrogen chloride emissions.

The ash content of a waste may be
determined to evaluate potential slag
formation, to assess particulate
removal requirements of an air pollu-
tion control system, and to determine
if the ash handling capability of the
system is sufficient.

Knowledge of these values helps to ensure
safe handling of a waste.  Explosive
wastes must be detonated in accordance
with the restrictions imposed under
40 CFR 264.

Knowledge of the concentrations of these
substances is necessary if stoichiometric
air requirements are computed to corre-
late oxygen concentrations in the stack
gas with excess air usage.

Thermogravimetric analysis helps to char-
acterize wastes by recording weight loss
as a. function of temperature.

Hazardous wastes exhibiting the reac-
tivity characteristic and containing
cyanides or sulfides are not exempt from
compliance with the Subpart 0 require-
ments.
                                2-7

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chiometric air requirements and evaluate proposed excess air usage.




Measurement of organically bound chloride content is necessary to




evaluate potential emissions of gaseous hydrogen chloride and




to establish permit conditions for allowable variations in waste



content.  Analytical methods for measurement of these parameters




are provided in Table 2-2.



     2.1.3  Analysis Required To Support Exemption




     Applicants proposing to burn hazardous wastes chat are ignic-




able, corrosive, or reactive may qualify for exemption from most of




the standards for incineration, including the performance standards



(40 CFR 264.343), requirements for continuous monitoring (40 GFR




264.347), inspection requirements (40 CFR 264.347),  and limitations




on incinerator operating conditions (40 CPR. 264.345).  Eligibility




for the exemption is determined on the basis of waste composition.




Therefore, after completion of the second step in the waste analysis



procedure, the applicant may decide to apply for the exemption.   If



so, the permit application will include the waste analysis plan and



data but will not include a trial burn plan.  The permit writer



must evaluate the waste analysis information and determine whether



an exemption should be granted.




     The exemption is available to incinerators burning wastes




that are ignitable, corrosive, or that have any or the reactivity




characteristics listed in 40 CTR 261.23(a)(l),  (2),  (3),  (6),  (7),




and (8).  The applicant must also demonstrate that the waste con-

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                                           TABLE 2-2

                        ACCEPTABLE ANALTTICAL METHODS FOR WASTE ANALYSIS
    Parameter
Mechod(s)*
                                                                        Comments
   Heating Value


   Chlorine
(Organically bound)

   Hazardous MataIs:

     Mercury
   Arsenic
   Selenium
   Barium
   Beryllium
   Cadmium
   Chromium
   Nickel
   Thallium
   Lead
   Silver
   Antimony

   Hazardous
   Constituents,
   including PCS

   Kinematic
   Viscosity
   Percent
   Solids
   Sulfur

   Ash



   Flash Point
   Carbon  and
   Hydrogen

   Moisture
  SA A006


  SA A004
  ASTM D2361,

  SA A021

  SW 3.57
  SW 3.51
  SW 3.59
SW 8.52, EPA 208.1
EPA 210.1
SW 8.53, EPA 213.1
SW 8.54, EPA 218.1
SW 3.58, EPA 249.1
EPA 279.1
SW 8.56, EPA 239.1
SW 8.60, EPA 272.1
SW 8.50, EPA 204.1

Sampling and
Analysis Manual
                    Methods 02015  and 03826 are  aplicable  Co  solid
                    wastes and 0240 is applilcable  to  liquid  wastes.

                    Combustion method, may be  combined with determination
                    of carbon, hydrogen and sulfur

                    Summary of atomic absorption and ICAP  methods

                    These methods  are based on detection of mercury vapor
                    by atomic absorption spectrophotometer, and  are sub-
                    ject to interferences.  Spiked  samples should  be
                    analyzed to establish recovery.  Methods  involving
                    strong oxidation, such as  ASTM  03223,  should be avoided
                    because of the possibility of explosions.  Alterna-
                    tively, atomic absorption  may be used  with a graphite
                    furnace.

                    Gaseous hydride generation coupled with atomic absorp-
                    tion detection is recommended.  This method  is subject
                    to interferences so spiked samples should be analyzed
                    to establish recovery.  Colorimetrlc methods,  such
                    as EPA 206.4 or ASTM 03081,  should not be used be-
                    cause of interferences.  Alternatively, atomic absorp-
                    tion may be used with a graphite furnace.

                    These methods are.for direct aspiration,  flame, atomic
                    absorption spectroscopy.   Sample preparation should
                    be performed in accordance with Section 200.1  of  the
                    EPA manual.  Generally, the  sensitivity achieved  with
                    the graphite furnace techniques is not required with
                    hazardous »aste samples, and Che furnace  methods  are
                    subject to interferences.
                      Hazardous constituents listed in Appendix VIII of Part
                      261 and chose in Table 1 of {261.24 may be analyzed
                      by methods in SW-346.


                      A variety of methods may be employed using various types
                      instruments, including rational, piston, float, vlbrat-
                      ing-probe or capillary types.

                      A distinction should be noted between water insoluble
                      solids and solids not soluble in organic solvents.
                      Any of a variety of separation techniques may be
                      employed; vacuum filtration, centrifugation, pressure
                      filtration, etc.

  ASTM D3177, E443    Combustion methods.

  SA A001-A002
  ASTM 03174 or 0482  03174 is for solid wastes and D482 is for liquid
                      wastes.
SA A005
ASTM 0445 or 088
ASTM 01888
  ASTM D93, D3278,
  or 01310
  ASTM 03178
  SA A001-A002
  ASTM D95, 03173
                    Methods D93 and 03278 are pursuant to the definition
                    of ignitable wastes in Section 261.21 of Che re-
                    gulations.  01310 provides comparable results.

                    Combustion method.
                    095 is a xylene co-distillation and is recommended
                    for most wastes.  03173 and A001-A002 are intended
                    for solid wastes, but the oven heating will drive
                    off volatile compounds in addition to water.  01796
                    is a centrifuge method intended for use with liquids.
   *  SA refers  to  Sampling and Analysis Manual for Hazardous Waste Incineration

-------
tains only insignificant concentracions of Appendix VIII constituents.




The regulation provides for automatic granting of the exemption to




facilities burning ignitable, corrosive or reactive wastes that



have been shown to contain none of the hazardous constituents




listed in Appendix Till of 40 C7S. Part 261 that would reasonably




be expected to be present'  In addition, ignitable, corrosive,  and




reactive wastes having low concentrations of some Appendix VIII




constituents may be exempted if the Regional Administrator finds



that the exemption will not result in a potential threat to human



health and the environment.  Wastes eligible for the exemption




include those that are hazardous solely due to any one of the




selected characteristics and those that are hazardous solely due



to any combination of those characteristics.  Wastes listed as




hazardous in 40 CFR Part 261 due to the presence of toxic constl -




tuents, wastes having the extraction procedure toxidty charac-



teristics (40 C7R. Part 261, Appendix II), and wastes containing



significant concentrations of Appendix Till constituents are not



eligible for exemption.



     The first step in determining whether exemption is appropriate



should be verification that the waste or wastes have only those




hazardous characteristics allowed by the regulation:   ignltability,



corrosivity,  or certain of the reactivity characteristics.   If



the waste has been specifically listed as a hazardous waste by  SPA
                                 -in

-------
 (40 CFR Part 261, Subpart D), the applicant should verify that

 the Agency's basis for listing the wast a as hazardous did not

 include toxicity or the reactivity characteristics of 40 CFR

 261.23(a)(4) or (5).  Physical/Chemcial Methods (SW-846) provides

 analytical methods for determining whether the waste has the

 reactivity characteristics of 40 CFR 261.23(a)(4) and (5).4

     The second step in the decision process requires review of

 the waste analysis information to verify that the waste contains

 only insignificant (if any) levels of Appendix VIII constituents.

 This step should involve examination of the sampling and analytical

 methods.  The methods required for collecting representative

 samples are listed in the regulations (40 CFR Part 261, Appendix

 I) and are discussed, in detail, in SW-846.  The permit writer

 should refer to SW-846 and determine whether the applicant  has

 used appropriate sampling techniques.

     Analysis of the waste for hazardous constituents should be

 conducted as described previously.  The applicant  should analyze

 only for those constituents reasonably expected to be present,  and

 should identify those Appendix VIII constituents not  reasonably
4  40 CFR 261.23(a)(4) describes  reactive  wastes  that, when mixed
   with water,  generate toxic gases,  vapors,  or fumes in  sufficient
   quantity to  present a danger to human health and the environ-
   ment.  40 CFR 26l.23(a)(5) describes sulfide or cyanide bearing
   wastes that  when exposed to pH conditions  between 2 and 12.5
   can generate toxic gases,  vapors,  or fumes in  sufficient quantity
   to present a danger to human health and the  environment.
                                2-11

-------
expected and provide a brief rationale for excluding them from che




analysis.  The analysis should be conducted using the methods pre-




sented in SW-846.  If the analysis shows that none of the expected




constituents were present in concentrations sufficient to be detected



by the SW-346-analytical methods, the exemption should be granted.




     In the majority of cases, however, several hazardous consti-



tuents will be detected at low levels and the permit writer will




need to determine whether they can be considered "insignificant".




Since a waste feed concentration of 100 parts per million (ppm)



represents a practical lower limit below which detection in the




stack gas will be difficult, the permit writer may use 100 ppm as




a standard against which an initial determination of "significant"




or "insignificant" can be made.  The exemption should not be



allowed if any of the Appendix Till hazardous constituents are




present in concentrations of 100 ppm or greater.



     In some cases, the permit writer may find it necessary to deny



if hazardous constituents are- present in concentrations lower than




100 ppm.  This may occur, for example,  if the constituent is known



to be highly toxic.  In such cases,  provisions should be made



during the trial burn to- ensure that verification of 99.992 destruc-




tion and removal efficiency is possible.   The trial burn waste may



be spiked with pure chemical in order to  increase the concentration




of a POHC present at  less than 100 ppm.  Alternatively,  the volume




of the stack gas sample collected may be  increased to ensure that
                                2-12

-------
the POHC will be detected during analysis.

     The sample stack gas volume necessary to verify 99.99% destruction

and removal efficiency may be estimated according to the following

procedure.

     The quantity of waste (in pounds) needed to generated sufficient

quantity of POHC in the stack gas sample can be calculated from

the formula:
                                  Q x 104
                           W  = -
                                   454(C)

where:   W » Quantity of waste to generate Q x 10^ ^ug of POHC in stack
             gas sample (Ibs);

         C - Concentration of POHC in the waste feed (^ug/g » ppm); and

         Q - Quantity of POHC (;ig) needed in the stack gas sample
             to ensure detection.
                                                       »

     Assuming that 1 standard cubic foot (SCF) of combustion gas is

generated for every 100 Btu burned at st oi chi omet ri c conditions,

and given the heating value of the waste and the amount of air

fed to the combustion chamber in excess of st oi chi omet ri c require-

ments, the dry volume of the stack gas sample, at standard tempera-

ture and pressure, can be estimated from the formula:


                        Vg  -   (W)(HW)(A)
                                     100

where:  V3 - Dry volume of the stack gas sample at  standard tempera -
             ture and pressure (dscf);

        Hw » Heating value of the waste (Btu/lb); "and

        A  » Air feed to combustion chamber .
             S toi chi omet ric Air Requirement
                                2-13

-------
     This volume must be corrected to the corresponding volume  at

stack conditions and corrected to include the volume of gas  generated

by burning auxiliary fuel, as follows:


              VD  «   (460 + T)  x
                         492       \    LOO          /

Where:  VQ  *  Actual dry volume of stack gas sample (corrected
               to stack temperature and for contribution from
               auxiliary fuel);

         T  m  Stack gas temperature (*F);

        Hp  *  Heating value of fuel (Btu/lb);  and

         R  »  Fuel Feed Rate
               Waste Feed Rate


     The dry sample volume oust then be corrected to account  for

water vapor in the stack gas.  After passing through an air pollu

tion control system, the stack gas will likely be saturated with

water.  Figure 2-1 shows the water content of saturated stack gas

as a function of stack gas temperature.  The corrected  sample

volume is calculated from the formula;
where:  Vw  *  Volume of the stack gas sample including  for water
               vapor; and

         K  *  Concentration of water in the flue gas  (Z volume
               of water/100),

-------
                                FIGURE 2-1


                WATER VAPOR CONTENT OF SATURATED FLUE  GAS
  a


  8
  ^4
U -J
CJ -»
U -3
fl S
  4)
u u
S a
3 l-i
>-4 3
0 W
> a
 u  o
 u  a.
 93  4
 0-  >
                  60     30    100    120   140   160   ISO    200   220
                           Gas Temperature, °F


        Basis:  Volume  of  water vapor in saturated air at 1 atm.
                                   2-15

-------
     The utility of this calculation is illustrated by the following

example.  A. waste feed having the characteristics:

     C *  Concentration of hexachlorobenzene » 400 ppm
    Hw *  Waste heating value » 6500 Btu per pound,

will be burned under the following conditions:

     T - stack gas temperature - 160°?

     A - Air fed to the combustion chamber « 1.2
          Stoichiometric air requirement

     R » Fuel feed rate  » .20
         Waste feed rate

The auxiliary fuel used has a. heating value if 19,000 Btu per pound

(Hf) and the flue gas is saturated with water.  A. quantity of

10 ug of hexachlorobenzene is necessary in the stack gas sample

to ensure detection.  Therefore, the waste burned to generate 10 ug

of HCB in the stack gas, at 99.991 DUE, oust contain IslO5 ug of

HC3, and
          '  105
                     I.  (6500)  .  (1.2)
    Vs - \(454)(400)
                     100

        - 42.9  dscf

     Vfl - (460 + 160)/(19.QOO)(0.20)(0.55) + 42.9
             492               100

        - 80.4  dscf

     K - 0.32 from Figure 2-1, therefore:

     7W -   80.4
          1 • 0.32

        - 118  acf

Thus, a adniimim of 118 acf of stack gas should be collected to ensure

detection of hexachlorobenzene.

-------
2.2  Designating Principal Organic Hazardous Constituents

     In accordance with the incinerator regulation,  the  permit

writer must designate one or more of the organic hazardous con-

stituents identified in the waste feed as principal  organic hazard-

ous constituents (POHCs).  The regulation specifies  that POHC

selection be based on a consideration of two factors:  the degree

of incinerability and the concentration of each organic  hazardous

constituent in the waste feed.  EPA has therefore developed a

method, presented here for systematic consideration  of these two

factors in. selecting POHCs.

     The method presented uses the heat of combustion of one gram

of the hazardous constituent as an indication of incinerability.

Constituents having low heat of combustion values are assumed to

be less able to support combustion.   Table 2-3 lists the organic

hazardous constituents from 40 CFR Part 261,  Appendix VIII and

provides the heat of combustion (per gram) of each.  These same

constituents are ranked,  in Table 2-4,  according to  ease of incin-

erability (i.e., those most difficult to incinerate, as indicated

by their low heat of combustion values, are listed first).5

     To select  POHCs for  a. given waste feed,  the permit writer

should array the hazardous constituents and their concentrations
  The correlation between incinerability  and  heat  of  combustion is
  an approximation.   As EPA accumulates data  regarding incinerability,
  the hierarchy (Table 2-3) will  be  adjusted  to reflect actual observa-
  tions.
                                2-17

-------
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in order of increasing incinerability (i.e.,  the order in which




they appear on Table 2-4).  The least incinerable constituent




(i.e., that constituent having the lowest heat  of combustion value)




and the most abundant constituent should be designated as POHCs.




In theory, only one POHC need be designated on  the basis  of  incin-




erability.  The correlation between heat of combustion and incin-




erability, however, is approximate.  Therefore, more than one  POHC




should be designated on the basis of incinerability in most  cases,




particularly when the heat of combustion values indicate  only




small differences in incinerability.  Overall,  POHC selection




should be limited to no more than six constituents.




     The permit writer should also consider the limitations  of




stack gas sampling and analytical techniques  when selecting  POHCs.




Constituents present in the waste feed in concentrations  as  low as




1000 parts per million (ppm) should be routinely detected in the




stack gas.  A waste concentration of 100 ppm  represents a practical




lower limit below which determination of 99.99% destruction  and




removal efficiency will be difficult to document.




     Whenever possible, POHC selection should be confined to consti-




tuents present in concentrations greater than 100 ppm.  In cases




where this is not possible, modification of the stack sampling and




analytical methods may be necessary and the permit  writer should




determine that the methods described in the trial burn plan  will be




adequat e•
                                2-29

-------
not detected in the stack gas, despite careful fulfillment  of che




sampling, analysis and quality control procedures set  out in the




trial burn plan, attainment of DRE to the level of detectibility




should be assumed.




     When the trial burn plan proposes using a waste that contains




one or more of the POHCa in low concentrations, the permit  writer




should estimate the volume of the stack gas sample necessary to




detect the POHC present in low concentrations according to  the




method presented in Section 2.1.3.  Once this estimate is made,




the permit writer can evaluate the adequacy of the proposed sampling




and analytical methods and recommend modifications, as necessary.




     The following examples demonstrate application of the  POHC




selection criteria:




EXAMPLE 1




HAZARDOUS CONSTITUENT     Z CONCENTRATION     HEAT OF  COMBUSTION




   Chloroform                    3                   .75




   Dichloroethane               14                  3.00




   Dichlorobenzene               3                  4.57



   Chlorophenol                 12                  6.89




In this case, chloroform should be designated a POHC because of




its low heat or combustion.  The most abundant constituent,




dichloroethane, should also be designated a POHC.
                                2-30

-------
EXAMPLE 2




HAZARDOUS CONSTITUENT     % CONCENTRATION     HEAT OF COMBUSTION




   Chlorobenzene                 6                   6.60




   Phenol                        4                   7.78




   Benzene                       4                  10.03




   Toluene                      25                  10.14






Chlorobenzene, the least incinerable constituent,  should be desig-




nated a POHC in this case.  Toluene should also be designated a




POHC on the basis of its high concentration.   Phenol might  also be




designated a POHC, both to compensate for possible discrepancies




in the hierarchy and to compensate in the event that 99.99% DRE is




not achieved for chlorobenzene.




EXAMPLE 3




HAZARDOUS CONSTITUENT     % CONCENTRATION     HEAT OF COMBUSTION




   Tetrachloromethane           .001                 .24




   Chloromethane                  8                 3.25




   Dichloropropene                8                 3.44




In this case,  the least incinerable constituent, tetrachloromethane,




is present in such a low concentration that detection in the stack




gas would be difficult.  If,  to ease sampling and  analytical diffi-




culties, tetrachloromethane is not  designated a POHC,  both  chloro-




methane and dichloropropene should be designated POHCs because their




heat of combustion values show little difference in incinerability.
                                2-31

-------
If both are treated to 99.99% DRE during the trial burn,  the permit




could allow treatment of all hazardous constituents more  easily




incinerated than chloromethane.  The list,  however, would not include




tetrachloromethane.  The applicant might therefore wish to alter




the required sampling and analytical methods to lower detection




limits and measure the DRE for tetrachloromethane.  As an alternative,




the concentration of tetrachloromethane in the waste feed might be




increased for purposes of conducting the trial burn.  Ir  the alterna-




tive approach is used successfully, the permit could be written with




tetrachloromethane as the least incinerable POHC.




2.3  Review Of The Trial Burn Plan




     The trial burn is essentially a test to determine whether an




incinerator is capable of meeting the performance  standards  and,




if so, to identify the operating conditions necessary to  ensure




that the performance standards will be met  throughout the life-




time of the permit.  The results of the trial burn directly




influence the decision to issue a permit and the conditions  of



the permit.  Careful and detailed planning  of the  trial burn is




therefore necessary.




     In its final form,  the trial burn plan should represent  the




interests of both the applicant and the permit  writer.  The  data




and information generated during the trial  burn should be suf-




ficient to allow the permit  writer to establish permit  conditions




that provide enough latitude for the facility operator to  accomo-
                                2-32

-------
date some variations in waste composition.   The facility  operator




should use the trial burn to identify a range of operating  con-




ditions within which the incinerator can achieve the required




level of performance.




     Table 2-5 lists the information required to be  included in




the trial burn plan.  The table may be used as a checklist  for




purposes of determining whether the applicant has included  the




minimum amount of information in the trial  burn plan.  This com-




pleteness check should always be the first  step in reviewing




the trial burn plan.  Because the permit  application for  a  new




incinerator must be filed and a permit issued before construction




begins, some of the information, such as  waste composition  data,




may need to be updated before the trial burn is conducted.  Similarly,




specific analytical methods used in the trial burn may need to be




updated or dates and schedules for the trial burn may require




revision.  Permit conditions should provide sufficient flexibility




to allow such changes.




2.4  Evaluating The Design Of The Trial Burn




     In designing the trial burn, the primary goal of both the




applicant and the permit writer should be to identify the condi-




tions under which the incinerator must be operated in order to




successfully treat the designated principal organic  hazardous




constituents.  The waste fed to the incinerator and  the operating
                                2-33

-------
                              TABLE 2-5

              CHECKLIST FOR CONTENT OF TRIAL BURN PLANS
Waste Analysis Data

Heating value of the waste

Viscosity (if applicable)

Concentrations of hazardous constituents listed in 40 CFR 261,
Appendix VIII expected to be present in the waste

Organically bound chlorine content (recommended but not required)

Ash content (recommended but not required)


Incinerator Design Information

Manufacturer's name and model number of major incinerator components

Type of incinerator (rotary kiln, liquid injection, etc.)

Linear dimensions of major incinerator components and cross
sectional area of the combustion chamber(s)

Description of auxiliary fuel system

Capacities of prime movers

Description of automatic waste feed cutoff system(s)

Stack gas monitoring and pollution control monitoring systems

Nozzle and burner design

Construction materials

Location and description of temperature, pressure and flow
indicating and control devices
                                2-34

-------
                        TABLE 2-5 (Continued)
Provisions for Sampling and Monitoring of the Incineration Process

Description of process monitoring equipment, procedures, and
locations for:

        Combustion zone temperature
        Waste and fuel feed rates
        Combustion gas velocity
        Carbon monoxide in stack gas
        Oxygen in the stack gas

Computation of ORE, including methods for sampling and analysis of:

     •  POHCs in the stack gas,
     •  Stack gas volume flow rate and temperature
     •  Waste feed rate and POHC concentrations in waste feed

Determination of particulate emissions, including monitoring methods
of:

        Particulate collection
        Volume flow rate of stack gas
        Temperature of stack gas
        Water content of stack gas
        Oxygen concentration in stack gas

Determination of scrubber efficiency including sampling and
monitoring of stack gas for hydrochloric acid if emissions are
greater than 4 pounds per hour
Trial burn Schedule

Dates of trial burn

Duration of trial burn

Quantity of waste feed to be burned
                                2-35

-------
                        TABLE 2-5  (Concluded)
Trial Burn Protocol

Planned operating conditions for; each performance burn including:

     •  Combustion zone temperature
     •  Waste feed rate
     •  Combustion gas velocity
     •  Use of auxiliary fuel and feed rate
     •  Carbon monoxide level in the stack gas

Planned operating conditions for air pollution control devices

Procedures for stopping waste feed, shutting down the incinerator,
and controlling emissions in the event of an equipment malfunction
or other emergency
                                2-36

-------
conditions tested, therefore, are critical components of  the  trial




burn plan.  Because the results of the trial burn directly  influence




the conditions of the final operating permit and because  modifica-




tion of the final permit can be costly and time consuming,  the  waste




feed and operating conditions tested should be selected on  the  basis




of a careful consideration of many facility-specific factors.   The




most influential factors to consider are the number of  waste  streams




and the chemical constituents of the wastes normally fed  to the




incinerator.




     The applicant should attempt to account for any planned  or




possible changes in the waste feed when designing the trial burn.




By selecting additional POHCs (particularly those that  are  known to




be difficult to incinerate) or testing a wide range of  operating




conditions, the applicant may build sufficient flexibility  into the




final permit conditions to account for future changes in  waste  feed.




In this manner, careful planning of the trial burn can  reduce or




even eliminate the need for further permit  modifications  and trial




burns.




     2.4.1  Selecting The Trial Burn Waste Feed




     The specification of waste composition in a permit is  developed




primarily from the values of three parameters,  specifically, the




heating value of the waste, the organically bound chloride  content,




and the ash content.  Other parameters may  be used as agreed upon by




the permit writer and the applicant.   Relying on the  three  primary
                                2-37

-------
parameters, the applicant has several options to ensure that  the


permit covers most of the wastes that will be incinerated at  the


facility.

     The trial burn waste feed may take one of three forms:  (1)  the


applicant may choose to burn the actual waste, or a mixture  of


actual wastes, normally accepted for treatment at the incinerator,


(2) the applicant might choose to add hazardous constituents


to the actual waste feed or may increase the concentration of


constituents already present in the waste feed, (3) and the  applicant

may create an artificial waste feed by feeding a mixture of  chemicals


to the incinerator*  The chemicals included in such a "waste" feed


should be those that are selected as POHCs on the basis of waste


analysis data.
                                      *

     Burning actual waste during the trial burn has the advantages


of using materials that are readily available and providing  data


that are descriptive of normal operation.  One option is to  group


wastes with similar characteristics and to demonstrate that each

waste mix can be incinerated at specific operating conditions.   The

utility of this approach is best illustrated by a simplified  example.


An off-site liquid injection incinerator operator receives chlorinated


solvents from eight generators and non-chlorinated solvents from four

generators.  Rather than conduct trial burns on each of 12 different


wastes, the applicant may wish to group the chlorinated and the


non-chlorinated wastes separately, and conduct a trial burn using
                                2-38

-------
the two waste mixes.  In order to achieve the greatest  benefit  from




waste grouping, the applicant should conduct  a trial  burn at the




least incinerable composition, specifically,  at the lowest heating




value and the highest ash and chloride contents of  each waste mix.




     Using actual waste in the trial burn also has  several dis-




advantages.  Chemical analysis of both the waste and  the stack




gas may be complicated due to interference by waste constituents




other than the POHCs.  More importantly,  when actual  waste is




used, the applicant is restricted to testing  only the hazardous




constituents present in the waste.  The permit,  therefore, will




allow burning of only those constituents more easily  incinerated




than the most difficult to incinerate constituent in  the waste.




After the permit is issued, if the operator receives  a  waste contain-




ing a less incinerable constituent,  an additional trial burn and




major modification of the permit  will be necessary.




     Spiking the waste with less  incinerable  hazardous  constituents




provides the advantage of increasing the number of  hazardous con-




stituents that can be allowed by  the permit.   The permit writer




should assume that if an incinerator can achieve a  99.99% DRE of




a hazardous constituent,  then it  is  also  capable of achieving a




99.99% DRE of more easily incinerated constituents, if  the same




operating conditions are maintained.   For example, if the




applicant spikes the waste with chloroform or tribromomethane and




99.99% DRE is achieved,  the permit may be written to  allow burning
                                2-39

-------
of nearly all of the Appendix VIII hazardous constituents.   Spiking




the waste to increase the concentration of constituents  already




present will increase stack gas concentrations and reduce sampling




and analytical difficulties.  Generally, spiking the actual waste




for use in. the trial burn allows the applicant to compensate for




the disadvantages of using actual waste and can be done  without




causing significant changes in characteristics such as physical




state of the waste and particulate load.




     Alternatively, the applicant may propose to incinerate a blend




of chemicals and fossil fuel during the trial burn instead  of actual




waste.  This approach is useful for new incinerators, particularly




when waste will not be available at the time of the trial burn.




When an artificial waste feed is used, the feed should be blended




to contain the POHCs in concentrations equal to or greater  than



those expected during routine operation.




     Using an artificial waste feed has the advantage- of simplifying




the analytical procedures because interference by organ!cs  other



than the POHCs is greatly reduced.   This approach also allows the




applicant to create a waste feed that is very difficult  to  burn.




A successful trial burn conducted with such a waste feed results



in permit conditions allowing the operator to accept  a wide variety




of wastes for treatment, perhaps eliminating any future  need for




permit modifications and additional trial burns.   Operators of




off-site commercial incinerators will generally need  such latitude
                                2-40

-------
in Che permit in order that they not be restricted in their  ability




to accept new clients.  Use of wholly artificial waste feeds for the




trial burn, need not be restricted to new incinerators or  cases




where actual waste will not be available.




     Conducting the trial burn with an artificial waste feed




adds complexity to the trial burn plan.  The artificial feed may




not be similar to actual waste feed in physical state,  chloride




content, or ash content.  Consequently, specific provisions  are




necessary for testing the performance of the air pollution control




devices and evaluating incinerator design.   When evaluating  the




trial burn plan, the permit writer should determine that each




component of the incinerator will be tested and that  the data




generated will be sufficient to demonstrate that each component




will function properly during routine operation.




     When an artificial waste feed is used,  the trial burn plan




should include specific provisions for testing  the performance of




the air pollution control system.  Data must  be generated  to docu-




ment compliance with both the hydrogen chloride removal standard




and the standard for control of particulate emissions.  This may




be accomplished by testing each air pollution control device




separately or by testing the effectiveness  of the entire system.




The test should be conducted during the trial burn.




     A variety of materials may be used to  test  the performance of




the particulate removal device.  The advantages  and disadvantages
                                2-41

-------
of the use of a limited number of materials are listed in Table  2-6.




If available, incinerator fly ash should be used.   Sand should not




be used as a substitute for ash because it  forms  a slag layer in




the combustion zone and contributes very little to particulate




load.  Ash from combustion of coal acts similarly because if its




high silica content (40-60%).  Diatomaceous earth and  powdered




gypsum or limestone will be entrained in the flue gas  easily because




of their small particle sizes.  These materials will not  form a




slag in the combustion chamber, but are very different in chemical




composition from incinerator fly ash.




     Materials containing organically bound chloride may be added




to an artificial waste feed in order to test the  efficiency of the




gas scrubbing equipment.  Hydrogen chloride removal efficiencies




generally increase as the hydrogen chloride content of the influent




gas stream increases, until the scrubber capacity is exceeded.




When testing the device, the applicant  should attempt  to  establish




the maximum organically bound chloride concentration in the waste




that the device can effectively control.



     2.4.2  Operating Conditions




     The results of the trial burn are the  permit  writers' princi-



pal basis for setting the conditions of the operating  permit.  It




is therefore necessary that the data and information collected




during the trial burn provide an accurate description  of  incinera-




tor performance.  The trial burn data should identify  a range of
                                 2-42

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values for each operating parameter (carbon monoxide level in the

stack gas, waste feed rate, total thermal input  rate,  combustion

temperature, and combustion gas flow rate) within which the incinera-

tor achieves the performance standards.   The trial burn data

should provide an indication of the effect on performance,  particularly

the destruction and removal efficiency,  that results from a change

in one or more of the operating parameters.  For facilities that

burn numerous waste streams, the trial burn results should also

provide some indication of how operating conditions can be altered

to maintain compliance when changes in the waste feed  composition

occur.

     Measurement of the residence time of the waste in the combus-

tion zone is not specifically required by the incinerator standards.

Instead, control over residence time is  established indirectly

through the requirement for monitoring and controlling combustion

gas flow rate.  When the incinerator design includes multiple waste

feed locations and multiple combustion chambers,  sufficient

residence time can be ensured by specifying an allowable feed

location for each waste feed.  In such cases,  the trial burn plan

should address feed locations and might  propose  to test  the effect

on DRE of feeding the same waste at different  locations.

     At a minimum, the trial burn plan should prescribe operation

at one set of steady state" operating conditions.   The plan  should
  Steady state occurs when the value  of  a measures parameter does
  not steadily increase,  decrease,  or fluctuate  greatly from a
  mean value.
                                2-45

-------
specify a steady state value for each operating parameter:  carbon




monoxide level in the stack gas, waste feed rate,  combustion temperature




and combustion gas flow rate.  The applicant is encouraged  to operate




the incinerator at the maximum thermal input and waste feed rates




during a trial burn in order to ensure the greatest  flexibility in




permitted operation.




     If the applicant proposes to continuously incinerate one waste




stream that does not vary significantly in composition (i.e.,  the




organic hazardous constituents remain the same, although  concentrations




may vary slightly), such a simple trial burn may provide  all of the




information necessary.  If compliance with the performance  standards




is not achieved, however, the applicant will be required  to conduct




an additional trial burn.  Furthermore, if compliance  is  shown at




only one steady state, the resulting permit  conditions will restrict




operation to those conditions regardless of  changes  in waste composition




or decreases in waste feed rate.  Therefore, the applicant  should




consider testing performance at the most severe and  most  lenient




operating conditions, and possibly intermediate conditions  as  well.



Such operation will allow identification of  the greatest  range of




incinerator capabilities.



     Testing a range of operating conditions will  be particularly




important when the incinerator is new and has not  been previously




evaluated.  In cases where the Incinerator has been  in operation




under interim status and the operator is reasonably  certain that
                                2-46

-------
99.99% destruction and removal efficiency will be achieved,  the


trial burn plan may propose to test only those conditions  under


which the incinerator is normally operated.   The applicant,  how-


ever, should view the trial burn as an opportunity to  test  various


operating conditions and determine whether operating costs  can be


reduced (e.g., by reducing combustion temperature, increasing


waste feed rate, or reducing use of auxilliary fuel) without


decreasing the level of performance.


     At facilities where wastes from many sources are  blended  to


make up the incinerator feed, the applicant  might propose to burn


several different waste feeds during the trial burn and establish


permit conditions for burning each feed.  The may should be


blended on the basis of composition.  For example, those wastes
                           *

that contain hazardous constituents from the upper third of the


inrinerability hierarchy (Table 2-3) might constitute  one blend,


the most difficult to incinerate.  Wastes of moderate  incinerability


may be blended into a second waste feed, and wastes that are rela-


tively easy to incinerate could make up a third blend.   Presumably,


the applicant could use the trial burn to identify a set of


operating conditions for each blend, to be established as permit


conditions.  The operator would therefore be required  to operate


at the most stringent conditions only when burning the least incin-


erable blend.  Temperature and auxiliary fuel could then be cut


back when more easily incinerated blends are fed.
                                2-47

-------
     Conducting this type of trial burn is advantageous to the




applicant because the resulting permit conditions can be sufficiently




flexible so as not to disrupt normal operating practices or sig-




nificantly increase operating costs.  The cost of conducting the




trial burn, however, increases as the plan becomes more complex.




Therefore, decisions regarding the range of operating conditions




to be tested and the number of waste blends to be burned during




the trial burn should be left to the applicant.  The permit writer's




evaluation of the trial burn plan should focus on determining whether




the applicant has provided all of the necessary information,  whether




the methods used for sampling and analysis are equivalent  to those  of




SW-846, and whether the data generated are likely to establish that




the incinerator is capable of achieving the performance standards.




     2.4.3 Provisions For Stack Gas Sampling And Monitoring




     Comprehensive sampling and monitoring during the trial burn




is essential for documenting compliance with the performance  standards




and for developing the conditions of the permit.  At  a. minimum,




sampling and monitoring data from the trial burn oust  be sufficient



to provide for:  a quantitative analysis of the POHCs  in the




waste feed to the incinerator;  a quantitative analysis of  the exhaust




gas for the concentration and mass emissions of the POHCs,  oxygen (02)>




and hydrogen chloride (HC1);  a quantitative analysis of the scrubber




water (if any), ash residues, and other residues for the POHCs;  a




computation of destruction and removal efficiency (DUE); a  computation
                                 2-48

-------
of HC1 removal efficiency (if emissions exceed 1.8 kilograms per hour);




a. computation of particulate emissions; an identification of sources




of fugitive emissions; a measurement of average,  maximum, and minimum




combustion temperature and gas velocity;  and a continuous measurement




of carbon monoxide in the exhaust gas.  When evaluating the trial




burn plan, the permit writer should ensure that provisions for all




required sampling and monitoring are included.




     In addition to the sampling and monitoring specifically re-




quired, the permit writer should consider requesting that other




parameters be measured.  Combustion gas temperature at  the point




of e,ntry to the air pollution control system may be routinely




monitored by the applicant to ensure proper operation of the system.




Flow rates for auxiliary fuel and scrubber liquid  might also be




monitored to further ensure that proper operating conditions are




mg-j nt ai ned •




     The trial burn plan should include descriptions of process




monitoring equipment, sampling frequencies,  and procedures.   The




location of each sampling and monitoring  point should be indicated




on the facility diagram.   Typical sampling and monitoring locations




are indicated in Figures 2-2 and 2-3,  diagrams of a liquid injec-




tion incinerator and a rotary/kiln afterburner incinerator,  respec-




tively.  Section 5.6 of the Engineering Handbook  for Hazardous




Waste Incineration (1) provides information concerning  the use and




capabilities of available monitoring devices.
                                2-49

-------
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3.0  EVALUATION OF INCINERATOR PERFORMANCE DATA




     Compliance with the regulatory performance standards may be




demonstrated using data obtained from trial burns,  from incineration




conducted during Interim Status, or from incineration conducted at a




facility similar to the applicant's (see Chapter 1).  Prior to




evaluating data submitted in lieu of performing a trial burn, the




permit writer must determine whether such data are  applicable and




similar to the incineration proposed in a permit application.




Methods to determine the similarity of the previous and proposed




incineration are presented in Section 3.1.




     Permit applicants may provide many types of incineration




performance data.  There is no standard format for  the submittal.




Because permit conditions will be established from  the data,  the




permit writer must be able to accurately interpret  the information




as provided by the applicant.  Guidance for determination of  the




sufficiency of engineering data is provided in Section 3.2.




     This chapter contains sample calculations for  computation of




destruction and removal efficiencies (ORE), particulate




concentrations in the stack gas, and scrubber efficiencies to check




compliance with the regulatory performance standards.  Various




factors affecting the calculations are identified in Sections 3.3,




3.4 and 3.5.




3.1  Evaluation of Data Submitted in Lieu of Trial  Burn Results




     When evaluating performance data submitted in  lieu of trial




burn results, the permit writer should make the following




determinations:
                                 3-1

-------
     •  Similarity of previous and proposed wastes

     •  Similarity of previous and proposed incinerator units

     These determinations should be made prior to checking the

calculations of the incinerator performance results.

     3.1.1  Similarity of Wastes

     Prior to evaluating the waste analysis data submitted from

previous incineration, the permit writer should ascertain that the

waste previously incinerated is similar to the waste described in

the permit application.  If incomplete data are available so as to

preclude comparison between the previous and proposed wastes, then

the wastes should be considered dissimilar and performance data from

the applicant's incinerator should be requested.

     Suggested criteria for determination of waste similarity have

been developed to ensure that the applicant's waste or mixture of

wastes, is as easily or more easily incinerated than the waste

previously destroyed.  In order for the proposed waste and the

previously incinerated wastes to be considered similar, all of the

criteria listed below should be met.

     •  Heating Value - The heating value of the proposed waste must
        be equal to or higher than that of the previously
        incinerated waste.

     •  Hazardous Constituents - The proposed waste must not contain
        any hazardous constituents considered more difficult to
        incinerate than those in the previously incinerated waste on
        the basis of the heat of combustion hierarchy.  The use of
        other incinerability hierarchies is discussed elsewhere in
        this manual.
                                 3-2

-------
     •  Organic Chlorine Content - The organically bound chlorine
        content of the proposed waste must be equal to or lower than
        that of the previously incinerated waste.

     •  Ash Content - The ash content of the proposed waste must be
        equal to or lower than that of the previously incinerated
        waste.

If all of these criteria are not satisfied, the wastes are not

similar and there is no basis for comparing the proposed and

previous incineration.  In cases of non-similarity, the permit

writer should request the applicant to submit performance data from

the incinerator for which a permit is sought.

     3.1.2  Similarity of Incinerator Units

     The incinerator unit design and operating data should enable

the permit writer to compare the unit previously used to obtain

operating data, with the incinerator unit described in a permit

application.  It is, therefore, necessary that the data for the

previous unit be as detailed as the data submitted for the proposed

unit in order to determine similarity.

     Criteria are presented in Table 3-1 for determining the

similarity between the applicant's incinerator unit and the unit

previously used for the incineration of a similar waste.  If the

previous incineration was conducted at the applicant's facility, and

if the incinerator unit has not been modified, then this evaluation

is not necessary.  For the cases in which this evaluation is

necessary, all the criteria in Table 3-1 must be satisfied for the

units to be considered similar.  The criteria are designed so that
                                 3-3

-------



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-------
similarity means that the capabilities of an applicant's incinerator



to destroy a hazardous waste are nearly identical or superior to the



capabilities of the incinerator previously used.  If only some of



the requirements are met, the units must be considered dissimilar



and the permit writer should request the applicant to conduct a


                                  ~-JF
trial burn.



3.2  Interpretation of Engineering Data



     The permit writer has two major purposes for interpreting



engineering data, specifically to ensure that steady state



conditions were achieved during the incinerator performance test and



to determine the range of normal operating conditions.  The permit



writer must have the records of continuously monitored parameters in



order to make these determinations.  If an applicant specifies only



average or median values of parameters monitored during a



performance test, the permit writer should request the data from



which the values were derived.  Instead of presenting detailed



methods for data evaluation in this manual, the permit writer may



refer to the example of data interpretation presented in Chapter 5


and may seek technical assistance from available resources.



3.3  Calculation of Destruction and Removal Efficiency (ORE)



     Incinerators burning hazardous waste must achieve a DEE of



99.99 percent for each principal organic hazardous constituent



(POHC) in the waste feed as required under 40 CFB. 264.343(a).   The



ORE is determined from the following equation:
                                 3-5

-------
        DEE - W1n " Wr
                     win

Where:  W^  =»     Mass feed race of the principal organic hazardous
                  constituent (POHC) in the waste stream feeding the
                  incinerator

        WQut »    Mass emission rate of the principal organic
                  hazardous constituent (POHC) present in exhaust
                  emissions prior to release to the atmosphere.

The waste feed rate is expressed in mass per unit time and must be

consistent with the units used to express W   .  If a waste is

co— fired with auxiliary fuel, the auxiliary fuel feed rate does not

affect the calculation of Wifl, unless the fuel contains the POHC,

     W    is calculated from stack sampling data and involves

three steps :

     •  Computation of stack gas sample volume

     •  Computation of POHC concentration in stack sample

     •  Computation of stack gas volume flow rate

Stack gas sample volume and stack gas volume flow rate may be

determined either by EPA Methods 2 and 5 in 40 CFR 60, or ASTM
             ( ?}
Method D2928.  '  Monitoring stack emissions for POHCs includes

sampling and analysis of particulate matter, gas phase organics, and

water present in the stack gas.  Methods of stack sampling and

laboratory analysis for POHCs are presented in the Sampling and

Analysis Manual   .  Ideally, all sampling and analytical data

should be included with a permit application.  Table 3-2 identifies

the necessary data and provides a method of computation allowing the

permit writer to check the ORE calculated by an applicant.  A sample

calculation of DBE is presented in Table 3-3.

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     In the example presented in Table 3-3, if Che DRE was 99.9880

percent, it could riot be rounded off to 99. -99 percent.  If the DRE

was rounded off, it would allow a 25 percent increase in W   ,

corresponding to a 25 percent increase in stack emissions.  If a DRE

of 99.99 percent is not demonstrated , the permit writer must notify

the applicant that incinerator performance is not in compliance with

the regulatory standards.  The applicant may submit additional

performance data for evaluation or the permit writer may recommend

rejection of the permit application.

3.4  Hydrogen Chloride Emissions

     An incinerator destroying hazardous waste and emitting more

than 4 pounds per hour (1.3 kilograms per hour) of hydrogen chloride

must be equipped with emission control equipment capable of removing

99 percent of hydrogen chloride from the exhaust gases or of

limiting hydrogen chloride emissions to 4 pounds per hour, as

required under 40 CFR 264.343(b).  Waste and stack gas sample

analyses usually are conducted for the chloride (d~) ions.  The

scrubber efficiency (SB) used to determine hydrogen chloride removal

may be defined as follows, based on chloride analyses:
                                    100
Where:  Clin  *    mass feed rate of organically bound chlorides
                   entering the incinerator

        dout *    mass emission rate of hydrogen chloride in the
                   scrubber exhaust gas prior to emission to the
                   atmosphere
                                3-12

-------
     Where the term  "scrubber efficiency" is used, the acid gas




 removal efficiency of  the entire scrubber systam, including the




 quench, particulate  removal device, and gas absorber, is the




 parameter being considered.  The efficiency of indivudal scrubber




 units can be determined, but a high efficiency for the total




 scrubber system is the fundamental desired parameter.




     Since the gases exiting the scrubber are generally cool




 (180°F), sampling and  anlaysis of this gas is comparatively easy




 and safe.  Sampling  of the hot incinerator exhaust gases is not




 simple and is generally avoided.  To avoid hot sampling, Gl.  may




 be calculated from the waste feed rate and the organically bound




 chlorine content of  the feed.  A method to compute scrubber




 efficiency is presented in Table 3-4 and a sample calculation of




 scrubber efficiency  is presented in Table 3-5.




     Cl    is computed from stack monitoring data.  Necessary data




 include:




     •  Volume of the  stack gas sample at standard conditions




     •  Total chlorides (Cl ) collected during sampling




     •  Stack gas volume flow rate at standard conditions




 The method for computing the volume of the stack gas sample




( V ("stdn  amP^°yec* f°r tne DEE calculation may be used to compute




 the scrubber efficiency.




     The percentage  of hydrogen chloride emitted in the stack gas,




 or scrubber efficiency, may not be rounded off.  In the example
                                 3-13

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-------
                                 TABLE 3-5

                 SAMPLE CALCULATION OF SCRUBBER EFFICIENCY
          Data
                                        Computation
I.



II.

III.
IV.



V.

VI.



VII.
[Cl~] =• 25%
feed rate - 2000 Ib/hr
See Table 3-3

A  =• 3.12 ml
N  - .01
Vj = 40 ml
Vs - 10 ml
                     "6
Cl  =• 9.74 x 10 D Ib

Sample Volume • 33.17 dscf

See Table 3-3

Q * 86,960 scf/min
[from Step IV in Table 3-1]
Ccl - 2.94 x 10"7 Ib/scf

Clin - 8.33 Ib/min
 [Step I]
Clout =• 0.0255 Ib/min
 [Step VI]
                               Clin = (.25) (2000 Ibs/hr)
                                      =• 500 Ibs/hr
                                      - 8.33 Ib/min

                               33.17 dscf

                               mg C
 - 35.45(3.12)(.01)(40)
              10
   - 4.43
   =• 9.74 x 10~6 Ib

9.74 x 10"6 Ib
  33.17 dscf
- 2.94 x 10~7 Ib/scf
                               86,980 scf/min

                               Clout - (86,980 scf/min) x
                                         (2.94 x 10~7 Ib/scf)
                                       - 0.0255 Ib/min

                               SE =• 8.33 Ib/min - 0.0255 Ib/min x 100
                                                  8.33 Ib/min
                                          99.69%
                                3-15

-------
presented in Table 3-5, if the scrubber efficiency was 98.81




percent, the value of Cl    would be four times greater.   The




value of 98.81 percent may not be rounded off to 99 percent and is



not in compliance with the regulatory performance standard.




     If the scrubber efficiency is less than 99 percent when




hydrogen chloride emissions are greater than 4 Ib HCl/hr, the permit




writer must notify the applicant that the hydrogen chloride




emissions exceed the regulatory performance standard.  The applicant




may provide additional performance data demonstrating compliance




with the standard.




3.5  Particulate Emissions




     Incinerators destroying hazardous wastes must not emit




particulate matter at concentrations greater than 180 milligrams of




participates per dry standard cubic meter of stack gas (0.08 grains




per dry standard cubic foot) when the stack gas is corrected to a




7 percent oxygen concentration, using the following formula for the



correction factor specified in 40 GTB. 264.343(c):




                                14
           Correction Factor «
     Where:  7 - measured oxygen concentration in the stack gas on a



                 dry basis.



The measured particulate concentration is multiplied by the



correction factor to obtain the corrected particulate emissions.  A



sample calculation of particulate matter concentration in the stack



gas using the method referenced in the Sampling and Analysis
                                3-16

-------
      (3")
Manual    is presented in Table 3-6.   The calculation involves the




following steps:




     •  Determination of the stack gas sample volume




     •  Determination of weight of collected particulate matter




     •  Calculation of particulate concentration in the stack gas




     •  Determination of the oxygen concentration in the stack gas




     •  Correction of the measured particulate concentration




     Particulate emission calculations are sensitive to the values




of oxygen concentrations, and the permit writer may check that these




values are obtained properly.  If the oxygen concentration was found




to be 10.0 percent instead of 8.0 percent in the sample calculation




presented in Table 3-7, the particulate emissions would increase to




0.096 grains per dry standard cubic foot.  Thus, the particulate




emissions at 8.0 percent oxygen concentration are in compliance with




the performance standard and the emissions at 10.0 percent oxygen




concentration are not.  Orsat analysis for the oxygen content of the




flue gas is satisfactory and should be reported on a dry basis.




     Rather than follow the procedure presented in Table 3-6, an




applicant may submit particulate emission monitoring data from an




in-stack instrument in order to demonstrate compliance with the




performance requirements.  The permit writer should determine that




such instruments are properly calibrated and are functioning




properly.  Instrument calibration data should be submitted by the




applicant for this purpose.  The permit writer should be aware that




continuous particle emission monitoring equipment must operate near






                                3-17

-------





























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-------
                             TABLE 3-7

             SAMPLE CALCULATION OF PARTICULATE EMISSIONS
           Date
        Computation
l>    Vm(std) = 33-17 dscf

II.   Particulate weight *
        137 milligrams
        (2.113 grains)

III.  Particulate weight »
        2.113 grains
      Stack gas volume »
        33.17 dscf

IV.   [02] » 8.0%, dry basis
V.    P » 0.0637 gr/dscf
See Table 3-3

Gravimetric determination
P - 2.113 grains
    33.17 dscf
  = 0.0637 gr/dscf
       14
     21-8
     1.077

     (0.0637)(1.077)
     0.0686 gr/dscf
                                3-19

-------
its sensitivity limit in order to detect 180 mg/dson.  Equipment




response is dependent upon particle size distribution and particle




color and requires calibration for each different waste fed to an




incinerator.




     If the corrected particulate emissions are greater than 180




mg/dscm (0.08 gr/dscf), the permit writer must notify the applicant




that particulate emissions exceed the regulatory performance




standard.  The applicant may provide additional performance data




demonstrating compliance with the standard.
                                3-20

-------
4.0  SPECIFICATION OF PERMIT CONDITIONS




     The permit writer must designate a set  of operating require-




ments specific to each waste feed which the  applicant  indicates




will be burned.  These requirements must reflect  the set of  con-




ditions which have been shown to achieve the performance standards




of 40 CFR 264.343, either during a trial burn conducted in the unit




for which the permit is sought, or by data submitted in lieu of




conducting a trial burn.  At a minimum., .the  permit  must specify




requirements for the carbon monoxide level in the stack gas,  thermal




input rate,, combustion temperature, combustion gas  flow rate, and




acceptable variations in the waste feed composition.  In addition,




the permit writer may Include other operating requirements,  as




necessary to ensure compliance with the performance standards.




These may include, for example, conditions which  may derive  from




trial burn results for specific combinations of wastes or alternate




operating conditions to be used under specifically  defined circum-




stances.  Guidance for specifying each of these requirements  is




provided in Sections 4.1 and 4.2.




     The permit must also include a schedule for  conducting  periodic




facility inspections. 'Two types of inspections are required.  The




first, a visual inspection of the incinerator,  must be conducted




daily.  The second type of inspection, testing of the  emergency




waste feed cut off system, should occur at either weekly or monthly




intervals.  Guidance for determining the best  means of testing the
                                 4-1

-------
system and the frequency at which testing should occur is  presented



in Section 4.3.



     Initially, the operating requirements for new incinerators



will be established on the basis of the incinerator's anticipated



performance capabilities.  The requirements will be designated



primarily on the basis of the design specifications provided with



the permit application and experience or information gained from



trial burns at other facilities.  These requirements will  then be



modified when data from the trial burn is complete and evaluation



of actual incinerator performance can occur.   Further guidance



regarding the specification of operating requirements from design



data is presented in Section 4.4.





4.1  Specification of Operating Requirements  From Performance Data



     An incinerator permit must specify a set of operating require-



ments for the following parameters:



     •   Carbon monoxide level in the stack exhaust gas
                           •                                   —


     •   Waste feed rate



     •   Combustion temperature



     •   Combustion gas flow rate.



The degree of flexibility inherent  to each of these requirements



will be governed by the performance data reported by the applicant.



The trial burn (or alternative) data should include values for



these operating parameters which correspond to the performance



level achieved in the trial burn.  Therefore,  at  a minimum, a set
                                4-2

-------
of values for carbon monoxide in the stack gas,  waste  feed  rate  or




thermal input rate,  combustion temperature and  combustion gas  flow




rate should be reported for a corresponding destruction and removal




efficiency, mass emissions of HC1 and/or scrubber removal efficiency,




and emissions of particulata material.




     The applicant should report values for each operating  parameter




which include information regarding normal fluctuations. The permit




requirements can be written to incorporate the  range identified.




This may be accomplished in several ways-   For  example,  the operating




parameter values may be reported as a range (e.g.,  1800  +_ 50°F),




or the applicant may provide the actual readout  from the monitoring




instrument which shows fluctuations over time.   Submission  of  readouts




from continuously monitoring instrumentation is  recommended.




     The maximum amount of information can be generated  by  testing




each of the operating parameters at several levels  during the  trial




burn.   If each level is reported along  with a description of the




fluctuation that occurred, the applicant will have  established a




wide range of conditions over which adequate performance is achieved.




Permit conditions for each parameter may be expressed  as the ranges




tested successfully  during the trial burn.   This approach provides




the operator with a high degree of flexibility  during  routine  operation.






     4.1.1  Carbon Monoxide Level In The Stack Gas




     The amount of CO present in combustion exhaust gas  is  a function




of many factors, including combustion temperatures, residence  time
                                4-3

-------
of the combustion gases at Che combustion temperature,  degree  of




mixing of fuel(s) and air, and the amount of air used in excess of




stoichiometric requirements.  Thesie factors are interdependent to




some extent; however, residence time and the degree of  adzing  of




air and fuel(s) are primarily determined by by combustion chamber




and burner design.  Therefore, changes of CO concentration will




reflect changes in excess air usage and in combustion temperatures.




     The continuous measurement of carbon monoxide (CO) in the




stack gas is useful for several reasons.  CO concentration is  a




reliable indicator of combustion upset and remains a good indicator




as excess air is lowered toward stoichiometric conditions and  as




combustion temperature is lowered.  Additionally,  carbon monoxide




and carbon dioxide concentrations can be used to determine combustion




efficiency.




     Monitoring CO in the exhaust gas is most conveniently done in




the exhaust stack, where temperatures are low.   However,  measure-




ment of CO at other points in the system is acceptable.  For example,



CO may be measured in the take-off ducting immediately  after the



combustion chamber or after-burner.




     The permit writer should specify, as the maximum allowable CO



concentration, the maximum CO -concentration reported from the trial




burn demonstrating compliance with the performance standards.




However, some allowance for normal variation may be specified in




the permit in order to protect against unnecessary activation of
                                4-4

-------
the waste feed cutoff system.   Following  the  trial burn, the appli-




cant should submit the actual  readout  from the CO monitoring device.




This chart will provide data describing the average CO concentration




and the frequency, magnitude and duration of  any downward or upward




spikes.  Permit conditions that  accomodate some degree of fluctua-




tion in the stack gas CO concentration can then be selected on the




basis of this information.






     4.1.2  Waste Feed Rate




     The waste feed rate may be effectively controlled by stipulating




the maximum total thermal input  rate to the incinerator.  The permit




writer is encouraged to specify the maximum total thermal input rate




(e.g., Btu per hour) including the heating values contributed by




hazardous waste, non-hazardous waste and  auxiliary fuel, in all




permits.  In conjunction with  specifying  the  minimum heating value




of the waste feed, control of  the thermal input rate will ensure




that the incinerator is not overloaded with difficult to incinerate




hazardous constituents and that  compliance with the performance




standards is maintained.   Because the  total thermal input is derived




from trial burn data, the applicant  gains greater flexibility in a




permit by operating at the maximum thermal input than at a lesser




thermal input during a trial burn.  Turndown, or reduced thermal in-




put to an incinerator, from the  maximum permitted value is allowable




if compliance with the other permitted operating conditions is main-




tained.
                                4-5

-------
     Additional restrictions on the waste feed  rate may be imposed by.




specifying a mass or volume feed rate of the waste (e.g., pounds per




hour, gallons per hour) and the total thermal residence times are




maintained in incinerator equipped with multiple  feed  location and




to limit the amount of waste containing very toxic constituents that




may be fed to an incinerator.




     The following example illustrates specification of both the




total thermal input and a mass feed rate.




     Tetrachloroethylene is the most difficult  POHC to incinerate




present in Waste A.  Waste A is successfully incinerated during a




trial burn at a feed rate of 100 Ib/hr,  using 100 Ib/hr of auxiliary




fuel.  If the heating value of Waste A is 5000  Btu/lb and that of




the auxiliary fuel is 18,000 Btu/lb, the total  thermal input is 2.3




million Btu/hr.  The permit may be written specifying the maximum




feed rate and minimum heating value of Waste A, and the maximum




allowable total thermal input, 2.3 million Btu/hr for more easily




incinerated wastes.  Thus, Waste 3, having heating value of 10,000




Btu/lb and all hazardous constituents easier to incinerate than



tetrachloroethylene, may be fed to the incinerator at rates up to




230 Ib/hr if no auxilliary fuel is burned.  Alternatively, the incin-




erator can be operated co-burning 100 Ib/hr of  Waste A and 180 Ib/hr




of Waste B to achieve the maximum thermal input of 2.3 million Btu/hr.




The net effect of specifying the total thermal  input is to permit




the substitution of easily incinerated waste for auxilliary fuel if
                                4-6

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specified operating conditions,  such as combustion zone  temperature




and air feed rate, are maintained.   Additional examples  of  specifying




the total thermal input are provided in Chapter 5.




     Specification of waste feed as mass feed rate of  the POHCs will




generally not be necessary.  Such a permit  condition would  require




frequent analysis of incoming wastes and feed tank blends in  order to




ensure permit compliance.   The permit limitations  on other  operating




parameters fix the temperature,  residence time and heating  value of




the waste, reducing the need for feed rate  stipulations  based on




mass input of the POHCs.




     Waste compositions are specified in a  permit  for  each  waste




or waste mix having a different  physical state.  The permit writer




has the option of developing permit conditions for wastes with the




same physical state, entering the incinerator at the same location,




as separate wastes or as a single waste mix.   The  physical  states of




wastes in the form they enter the incinerator are  classified  as




pumpable liquids, non-pumpable or solid materials, and containerized




wastes.  Pumpable liquids  include pumpable  slurries and  highly aqueous




wastes.  Non-pumpable wastes include sludges,  tars,  and  solid materials




having high ash contents.   The definition of  wastes having  different




physical states as separate wastes  in a permit is  necessary to ensure




adequate volatilization of the hazardous constituents  from  a  waste




prior to flame oxidation.   For example,  the volatilization  of hexa-




chlorobenzene from a liquid solvent atomized  in a  burner is much
                                 4-7

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faster than the volatilization of hexachlorobenzene  from  a still




bottom tar.  Accordingly, the maximum mass  loading rate that may




be incinerated in compliance with the performance standards of




the liquid waste is likely to be much greater than that of the




sludge and the permit must take these factors into account.




     Waste feed locations are specified in  a permit  in order to




ensure adequate retention time in the combustion chamber.  Waste




feed locations upstream of those used during a satisfactory per-




formance test provide additional residence  time in the combustion




chamber and are permitted.  Downstream feed locations decrease




residence time and should not be permitted  because the DRE may be




lowered out of compliance.




     Wastes having the same physical state  fed to the incinerator




at the same location may be regarded as one waste in a permit.  The




permit writer has the option to consider such wastes a waste mix




and specify the mixed waste composition in  a permit.  Alternatively,




the composition of each waste stream may be specified in the permit.



The applicant may prefer one of the options and the  permit writer




should prepare the draft permit accordingly.




     The specification of wastes of different  physical form and mul-



tiple feed locations is illustrated using the example in Figure 4-1.




Assuming that all the performance test  results are in compliance,




wastes C and D must be defined in the permit  separately because the




physical states are not the same.   The incinerator charging rate may
                                4-8

-------
 C  U

 o   Ca

00-^
C 3
•H U
•U S3
C8 *~f
CU


o
0
o
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o
H










-------
be specified on the basis of total  thermal input,  or the combination




of thermal input and mass input  rates.   If mass  loading rate is used,




the permit would specify that 600 Ib/hr  of waste C having a minimum




heating value of 7000 Btu/lb and a  maximum organically bound chlorine




content of 6 percent may be fed  to  the kiln.  600  Ib/hr of waste D




having a minimum heating valued  of  8000  Btu/lb and a maximum organically




bound chlorine content of 10 percent  may be fed  to the kiln.  Speci-




fying the total thermal input, no more than 4.2  million Btu/hr of




waste C and no more than 4.3 million  Btu/hr or waste D may be fed to




the incinerator.  Wastes C and D must be fed to  the kiln and may not




be fed to the afterburner in order  to ensure sufficient residence




time.




      Wastes A. and B have the same  physical state  and both are fed to




the kiln.  Only Waste A is fed to the afterburner.  The waste compo-




sition may be specified in a number of ways.  Wastes A and B may




be considered a waste mix entering  the kiln (see the example above)




and the total allowable waste fed to  the kiln includes the amount of



waste A fed to the afterburner.  Waste B may not be fed to the after-




burner.  The permit would specify that 1500 Ib/hr  of liquid waste




having a minimum heating value of 7400 Btu/lb, and for no more than




11.1 million Btu/hr of liquid waste,  having a maximum organically




bound chloride content of 11 percent  may be fed  to the kiln.  Another




option is that Wastes A and B may be  considered  a  waste mix to the




kiln and may include Waste A to  the afterburner, if operating conditions
                                4-10

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for the afterburner are stipulated separately.   Weighted  averages




may be used to establish the heating value and  chloride content.




The permit would also specify that 400 Ib/hr of waste A may be  fed




to the afterburner with a minimum heating value of 10,000 Btu/lb and




a maximum organically bound chloride content of 15 percent.




     The other method to develop the permit is  to  define  wastes A




and B separately at each feed location,  using mass feed rate or total




thermal input.  Using the mass feed rate for example, 400 Ib/hr or




waste A can be fed to the afterburner, 600 Ib/hr or waste A can be




fed to the kiln, and 500 Ib/hr of waste  B can be fed only to the




kiln.  Waste A must have a minimum heating value of 10,000 Btu/lb




and a maximum organically bound chloride content of 15 percent.




Waste B must have a minimum heating value of 2000  Btu/lb  and a maximum




organically bound chloride content of 3  percent.






     ^•1*3  Combustion Temperature




     The permit needs to specify a minimum allowable combustion




temperature.  This value should be the minimum  temperature shown,




during the trial burn or by alternative  data, to correspond with




achievement of the required performance  standards.   Specification of




a maximum allowable combustion temperature is not  necessary because




increased temperatures presumably increase destruction efficiency.




Furthermore,, the maximum temperature at  which the  incinerator will




be operated is limited by refractory capabilities  and other design
                                 4-11

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considerations.



      In setcing the requirement  for minimum allowable  combustion




temperature, the permit writer should consider temperature fluctua-




tions encountered during the performance test.   The  heated refractory




will act to maintain thermal stability and temperature  fluctuations




should not be great•  However, some allowance for normal variations




is needed in order to protect against unnecessary activation of the




waste feed cutoff system as a result of temperature  "spiking" (see




Section 4.1.5).  Examples of the  specification of minimum permitted




operating temperature are provided in Chapter 5.




     Consideration must also be given to the location of the tem-




perature sensing device.  In many instances,  temperature sensors




will be located at several points in the system.   The reported




temperature should be measured at the point  where the data will be




most representative of the gas temperature as it  exits the hottest




part of the combustion chamber.  Although the exact  location of the




temperature sensor will vary in each case, a location should be




specified in the permit in order  to ensure that temperature is always




monitored at the same point  in the system during  routine operation.






      4.1.4.  Combustion Gas Flow Rate




     Combustion gas velocity is an indicator of the  flue gas volume




flow rate, which is a function of thermal input to the incinerator,




gas temperature, and excess  air usage.   Measurement  of combustion
                                 4-12

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gas flow rate provides a good indication of  residence  time in the




combustion zone.




     The maximum combustion gas velocity (or exit  gas  velocity)




shown during the trial burn (or by alternative data) as  corresponding




to achievement of the required level of performance  should be desig-




nated as the maximum allowable velocity.   Specification  of a minimum




velocity is not necessary since the required performance should be




maintained at turndown provided that all other operating parameters




are maintained.  The permit writer should recognize  that incinerators




burning containerized wastes may exhibit  sharp momentary increases




in combustion gas velocity ("puffing")  upon  charging.  Such varia-




tions should be incorporated into the permit conditions  if sufficient




performance data are supplied.




     Combustion gas flow rate may be measured by many  different




means.  Combustion gas velocities may be measured  using  orifice




plates or veturis, pitot tubes, or by indirect  means.  Orifice




plates and Venturis are impractical for combustion gas velocity




measurements because of the large pressure drops caused  by these




devices.  Pitot tubes may be used to measure combustion  gas velocity




in the hot zone of an incinerator immediately downstream of the




combustion chamber or in cooler areas,  such  as the stack.  Pitot




tube measurements can be converted to combustion gas velocity and




volume flow rate using the procedure in EPA  Method 2 presented in




the Appendix of 40 CFR 60.  Changes in the molecular weight and
                                4-13

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the water content of the combustion gas will affect the correlation




of pitot tube measurements and combustion gas velocity.




     Indirect measurements of combustion gas velocity may include




blower rotational speed and current draw.  Many blowers operate in




the region of the blower curve where static pressure and current




draw (horsepower) do not change radically with a change in capacity.




Therefore, blower static pressure and current measurements are




generally not suitable indicators of combustion gas velocity unless




the applicant can demonstrate a noticeable correlation.  Blower




rpm is indicative of combustion gas velocity and volume flow rate




only if static pressure in the blower remains constant.  Measure-




ment of combustion gas velocities using blower characteristics on




incinerators equipped with more than one blower may become very com-




plex, and the problems may be alleviated by use of a pitot tube.




     Measurement of pressure differentials across incinerator




components, such as combustion chambers and air pollution control




devices, is not a suitable indicator of combustion gas velocities.




Pressure differentials may be affected by leakage, changes in



liquid flow rates, and clogging phenomena as well as gas flow rates.




It is not possible to distinguish the factors affecting changes in




pressure measurements using conventional equipment.  Therefore,




pressure differential measurements should not be used as gas velocity




indicators; however, they are useful monitors for upset conditions.




     Continuous monitoring of the oxygen concentration in the stack
                                4-14

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gas is an acceptable substitute for combustion gas  velocity measure-




ment.  The oxygen concentration is indicative  of  excess  air usage




and, if waste feed composition and feed rate remain constant, it




is an indirect measurement of the combustion gas  volume  flow rate.




The most common method of continous oxygen measurement is an electro-




catalytic device, and paramagnetic and polarographic instruments




are used.  The monitors are either in-situ or  extractive.  Addi-




tional information about instrument capabilities  is presented in




the Engineering Handbook.






      4.1.5  The Emergency Waste Feed Cutoff System




     The purpose of the automatic waste feed cutoff system is to




shut off waste feed to the incinerator whenever the operating




parameters deviate from the limits set in the  permit.  For this




reason, the cutoff valve should be interlocked to all of the re-




quired continuous monitoring devices.   These devices include moni-




tors of temperature, combustion gas velocity,  and carbon monoxide




level in the stack gas.  For each of these parameters, the permit




should include a provision that establishes both  a  range for opera-




tion and a level, somewhat beyond that range,  at  which the emergency




waste feed cutoff system must  be activated.  The  following discussion




provides an example for proper integration of  the waste feed cutoff




system with the combustion temperature monitor.   Similar approaches




may be taken for integration with other operating parameters as well.
                                4-15

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     Following the trial burn,  the applicant  should submit the




actual readout from the temperature recording device.   This  chart




will provide the permit writer  with data describing the average




operating temperature and the frequency, magnitude and  duration of




any downward or upward spikes*   Effective permit  conditions  can be




selected on the basis of these  data.   Generally,  the permit  will




specLry that the incinerator be operated at  or above the average




temperature tested during the trial burn.  Additionally,  the permit




should sperify that the automatic waste feed cutoff be  activated




at a lower temperature than the range of normal fluctuation  indicated




by the results of the trial burn.




     This cutoff temperature may be selected in several ways, each




of which requires some degree of judgment.   The automatic cutoff




temperature may be selected by  calculating a time-weight'ed average




of the temperatures recorded below the target operating temperature.




Alternatively, the permit writer may select  the temperature  of the




lowest spike as the automatic cutoff temperature.   In this case,




however, a rarely occurring, very large downward  spike  should be




considered unrepresentative of  normal temperature fluctuation and




should be disregarded.  The permit condition, might  also be written




to establish an automatic cutoff which allows for momentary  excur-




sions by specification of allowable excursion magnitude,  frequency




and duration.  Conceptually, this type of  control could best be




accomplished using a system which would limit the total number
                                4-16

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of degree-minutes below a prescribed level before activation  of




the waste feed cutoff mechanism.   Such a system,  however,  will not




always be available for use by the operator.   The necessary limits




for such a system would vary from case to case.   The permit writer




should require that detailed information regarding temperature




fluctuations be provided.  When selecting the actual limit  on




degree-minutes of deviation, the permit writer should generally




allow deviations to occur for only a small fraction of the total




operating time.  This approach is advantageous because it  allows




for the possibility of a very large, but rare, downward spike




without activation of the automatic waste feed cutoff.






4.2  Limitations On Waste Feed Composition




     Permit limitations on waste feed composition should address




two aspects of the waste:  allowable waste constituents and chemical




and physical waste characteristics.  The actual  limitations selected




for these parameters depends on the results of the trial burn.  Per-




mit conditions regarding allowable waste constituents are  restricted




to limitations on those substances listed as  hazardous constituents




in Appendix VIII of 40 CFR Part 261.




     Limitations on the physical and chemical characteristics of the




waste feed may be used, rather than stipulations  on allowable POHC




concentrations.  Theoretically, incinerator DRE performance is inde-




pendent of POHC concentration, provided that  limitations are  placed
                                4-17

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on the other physical and chemical  characteristics of the waste and




on the incinerator operating parameters.   However, in practice, this




approach will be most reliable  if the  trial burn is conducted using




the largest POHC concent rat ions anticipated during normal operation.




Guidance for selecting limitations  on  chemical and physical charac-




teristics is presented in this  section.




     The method described for restricting  waste feed composition




has been designed to minimize the burden of time consuming and




complex chemical analysis.  This is accomplished by using operating




requirements and restrictions on physical  and chemical character-




istics of the waste to ensure adequate performance.






4.2.1  Allowable Waste Feed  Constituents




     The number and identity of allowable  hazardous waste con-




stituents specLfed in the permit will  depend primarily on the waste




constituents burned during the  trial burn  and on their placement




on the hierarchy of incinerability  (presented in Chapter 2).  The




principle which should govern writing  the  permit is that allowable




hazardous constituents are those which exhibit higher heat of



combustion values (i.e.,  those  which are easier to burn) than the




POHCs for which the required performance was shown either in a




trial burn or by alternative data.   In this way, the determination




of allowable hazardous constituents is derived directly from the




hierarchy of incinerability.
                                4-18

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     In practice, this approach allows the applicant  to control




the number of hazardous constituents which Che permit will allow




him to burn (and hence, the range of wastes which can be accepted




for treatment at the facility) through careful design of the trial




burn.  If a wide range of flexibility is needed,  the  trial burn




should be conducted using a waste containing significant levels  of




POHCs having very low heat of combustion values.   The permit would




allow burning of wastes containing constituents which are easier




to incinerate if complianced with the performance standards is




demonstrated.




     After successful completion of a trial burn, it  is not necessary




that the permit writer automatically allow burning of all constitu-




ents, without regard to their concentration in the waste, which




fall below the trial POHCs on the hierarchy.   The permit writer  may




deem certain exclusions or restrictions on concentration necessary.




Such restrictions should be considered in cases where a substance




known or suspect ed t o be a hi g'hly pot ent human t oxL cant (e.g.,




2,3,7,8-TCDD) falls below the trial POHC on the hierarchy.




     In order to maximize flexibility of the permit conditions re-




garding allowable waste feeds, the applicant  may  burn a contrived




waste during the trial burn which has been spiked with one or




several POHCs known to be difficult to destroy.   In such a case,




the applicant will gain flexibility in terms  of allowable hazard-




ous constituents (and, therefore, waste feeds).   However,  since
                                4-19

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compliance is established at  conditions  sufficient  to  destroy the

most difficult POHC to incinerate,  the permit  will  require that

all wastes be treated under these same conditions.^

     In cases where a contrived waste is used  during the trial

burn, the permit writer should also consider concentration of the

POHCs in the trial waste.  The contrived waste should  contain

POHCs in concentrations which are representative  of concentrations

expected to be found in the actual  wastes managed at the facility.

Spiking the trial waste with  POHCs  in concentrations which are

somewhat higher or in the upper range of concentrations expected

to be encountered during routine operation will provide greater

assurance that the operating  requirements will be sufficient to

achieve compliance with the performance  standards.  In all such

cases, very large differences between the trial POHC concentra-

tions and the expected waste  concentrations  should  be  avoided, and

the concentration of POHCs in the trial  burn waste  should always

be greater than or equal to the POHC concentrations expected during

routine operation.
  As described in Chapter 2,  this  situation may be avoided if
  the applicant groups the wastes  according to inrinerability
  and establishes a. set of operating  conditions for each group
  of wastes.  In such a case, a trial burn would be necessary
  to show the required performance for the most difficult to
  destroy POHC(s) from each waste  group.
                                4-20

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4.2.2  Limitations On Chemical And Physical  Waste  Feed Characteristics




     In addition to specification of  allowable waste  constituents,




the permit should set appropriate limits  on  the  chemical and physical




properties of the permitted waste(s).   The parameters for which




limits should be set include,  at  a minimum:




     •    Heating value




     •    Ash content




     •    Organically bound chloride  content




     •    Physical characteristics (e.g., physical state).




These limitations, together with  the  operating requirements dis-




cussed in previous sections (in particular,  stipulations on waste




feed rate), limit operations to such  an extent that the performance




level demonstrated during the  trial burn  should  be achieved and




maintained during routine operation.






4.2.2.1   Heating Value




     Knowledge of the waste feed  heating  value is  necessary to main-




tain a relatively constant  thermal load to the incinerator thereby




resulting in stable combustion zone conditions.  Gross decreases in




heating value may indicate changes such as increased  water content




or major changes in the concentration of  hazardous constituents,




which would make the waste more difficult to incinerate.  Addi-




tionally, the permit condition for waste  heating value may be used




to convert the waste feed rate from units of mass  per unit time
                                4-21

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co Btus per unit time.  Stipulation of waste feed rate in this




manner will be advantageous in cases where the operator normally




controls heat content of the waste feed in order to maintain




stable combustion conditions.




     The lowest heating value shown to correspond with the required




performance level, either during a trial burn or by alternative




data, should be designated in the permit as the lowest allowable




heating value.  An upper limit on heating value is not necessary




because wastes with higher heating values are presumably more




easily burned.






4.2.2.2   Ash Content
     Specification of the maximum allowable ash content  will, to




some extent, ensure that the paniculate removal capability of the




air pollution control system is not  exceeded during  normal opera-




tion.  Only a maximum allowable level need be specified.  Because




ash content and exhaust gas particulate load do not  correlate




directly, this permit condition is not  intended as a direct means



of controlling particulate emissions.  Rather,  it is intended to




provide an indication that, with respect to ash content, the waste



feed to the incinerator remains similar to that  tested during the



trial burn.




     Specification of an effective permit condition  for  ash content




will be particularly difficult  when  the trial burn waste is contrived
                                4-22

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by blending wastes or chemicals.   In  such  cases, the contrived blend




should contain a material (such as available  fly ash) suitable for




simulating a particulate load that is equal to  or  greater than that




expected during routine operation. Several factors should be considered




when selecting an appropriate material for this purpose.  They include




particle size distribution,  mean particle  diameter, the resistivity




of the material, the degree  to which  it may react  with the stack gas




(and influence the ORE), and the design of the  particulate collection




device.  The waste feed selected for  use in the trial burn should




contain ash at levels similar to or higher than those expected




during normal operation.






4.2.2.3   Organically Bound  Chloride  Content




     The organically bound chloride content of a waste may be corre-




lated with scrubber performance.   In  order to avoid overloading




the scrubber and possibly exceeding the hydrogen chloride emission




standard, the maximum allowable organically bound  chloride concen-




tration should be that for which compliance with the performance




standard has been demonstrated.   Lower organically bound chloride




concentrations in the waste  are allowable  variations.






4.2.2.4   Physical Characteristics




     Changes in the physical state of the  waste feed can result in




changes in incinerator performance.   The permit should therefore




limit the physical state of  the waste to that of the trial burn
                               4-23

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waste.  Precise guidance for establishing limits  on physical charac-




teristics is not provided because determinations  will  be highly




case-specific and will require application of  engineering  judgement.




The following discussion provides a specific example which might




be used for comparative purposes.




     An incinerator having both liquid injection  and rotary kiln




capabilities may effectively treat liquid,  solid  and sludge wastes.




Furthermore, any of these wastes might be fed  to  the incinerator in




containers.  The trial burn should be conducted such that  the POHCs




are introduced in the physical form in which they are  likely to be




received during routine operation.  The permit should  then restrict




the allowable physical form to that used during the trial  burn.




     If containerized hazardous wastes are to  be  burned, the permit




writer should consider the need to limit the condition or  construc-




tion of the drums as they enter the combustion zone.   For  example,




when closed steel drums are fed to a rotary kiln  incinerator,




explosion of the drums inside the kiln may result  in "puffing",



or release of highly concentrated emissions from  the kiln.  The




permit, therefore, might specify that  drums be opened  or punctured




immediately prior to charging in order to minimize puffing.  However,



if the trial burn demonstrates that introduction  of closed drums




does not result in puffing, the requirement that  drums be  opened




may not be necessary.
                                4-24

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4.3  Specification Of Inspection Requirements  For  The Emergency
     Waste Feed Cutoff System

     The incinerator regulations require weekly testing of the

automatic waste feed cutoff system.   Monthly testing may be allowed

in cases where the applicant  has shown that  weekly testing will be

highly disruptive and that  monthly inspection  is sufficient.  This

test is intended only to verify operability  of the emergency waste

feed cutoff system and should not  require dismantling of equipment

or unscheduled calibration of sensors.

     Complete shutdown of the incinerator is not necessary for

testing the feed cutoff valves and the associated  safety system.

The valves may be checked while waste is input  to  the incinerator

and the potential for creating upset  conditions are at a minimum.

The valve needs to be activated only  once during an inspection;

a check of every input to the safety  system  does not have to

activate the valve.   Additionally, if the valve is "fail safe"

(i.e., it fails in the closed position),  only  the  control panel

circuits and associated alarms need weekly testing; the valve need

not be activated.   Since cut  off valves are  designed to operate

for over one million cycles,  testing  should  not  be considered

to contribute significantly to wear.   Detectors  and sensors are

generally connected to the  cut off valve through relays, which

are often equipped with an  integrated test circuit.

     The permit writer should specify the inspection requirements

on a case-by-case basis.  Although safety system design is fairly
                               4-25

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standard due to insurance requirements,  the following factors

should be taken into account before specifications  of a  schedule

for testing:

     •    Extent of integration of the incinerator  with  other
          on-site processes.  If the incinerator is closely
          integrated, testing is likely  to be complex and
          time consuming.

     •    Installation of multiple burners.  Incinerators with
          more than one liquid waste burner will be better able
          to maintain thermal input to an incinerator as the
          cutoff valves to each burner are tested.

     •    Presence of a solid waste loading system.   Momentary
          cut off during inspection of a conveyor belt,  screw
          feeder, or hydraulic ram should not  upset  incinerator
          conditions because such feed systems are  not likely
          to be the only source of thermal input.

     •    Availability of test circuits.   Checks and inspections
          of safety systems equipped with test circuits, test
          jacks-, and signal simulators are easily performed and
          may not require the presence of an instrument  mechanic.

     •    Safety system design.  The more complex a safety system
          is, the longer it will take to check.   Also, if accessa-
          bility to system components is a problem,  a system check
          is further complicated.

     When evaluation of these factors indicates  that  weekly inspec-

tion may be impractical, alternatives may be considered.  For

example, weekly inspection might be limited to testing the feed

cutoff valve and more comprehensive testing of the  system (e.g.,

verifying operability of alarms, sensors  and associated  control

circuitry) could be conducted at longer  intervals.   Such a minimum

weekly inspection could involve triggering of  the valve  by a simu-

lated low firebox temperature.  This test  should be  conducted by
                                4-26

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properly trained personnel,  e.g.,  an instrument mechanic.  Should




the test reveal that  the system is not  functioning properly, the




permit should require that  the waste feed  be  cutoff immediately




and the necessary repairs made.




     A second approach to inspection of the waste feed cutoff




system might involve  weekly testing of  the valve and rotational




testing of the control circuitry which  interlocks the valve with




the various control parameter monitors.  For  example, during




Week 1, the valve might be activated by inducing a low temperature




condition.  During Week 2,  a high  carbon monoxide level might be




used to activate the  valve.   This  would be followed, in Weeks 3




and 4, by activation  of the circuitry interlocked to the gas flow




velocity monitor and  any other continuous  monitoring devices.




This inspection method incorporates weekly testing of the cutoff




valve(s) with rotational (monthly,  or bimonthly) testing of the




system components.




     Daily incinerator inspection  may be limited to visual examina-




tion for leakage, spills, corrosion,  hot spots and malfunctions.




The inspection should reveal whether gauges,  recorders, and moni-




tors are functioning  and if  there  are any  signs of tampering with




incinerator equipment.   Visual inspection  should also identify




needs for repair.
                                4-27

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5.0  EXAMPLES OF SPECIFICATION OF PERMIT CONDITIONS

     The examples of the specification of permit  conditions provided

in this chapter are intended to illustrate some of the approaches to

permitting discussed in this manual.

     Example 1;  The first example demonstrates the development of
     permit conditions for an on—site  incinerator dedicated to
     burning one hazardous waste under one set of operating
     conditions.  This permitting situation is straightforward and
     is used to illustrate the development of permit conditions from
     performance results and the interpretation of engineering data.

     Example 2;  The second example illustrates the permitting of a
     hearth incinerator burning a solid waste mixture and a liquid
     waste mixture at one set of operating conditions.  The purpose
     of this example is to demonstrate how a permit is written to
     allow the incineration of more than one hazardous waste and how
     the maximum thermal input is used to limit waste feed rates.

     Example 3;  In the third example, two hazardous liquid waste
     mixtures are co-incinerated with  a solid waste mixture and the
     incinerator operating conditions  depend on which liquid waste
     blends are being co-incinerated.   The third  example illustrates
     the permitting of incineration of specific hazardous wastes at
     specific operating conditions and the use of the waste grouping
     concept.

     The examples in this chapter address the specification of waste

composition and incinerator operating  conditions  from selected data

appearing in a Part B application and  do not include the

specification of other provisions that must be included in a permit,

such as monitoring, safety, and inspection requirements.  Each

example in this chapter is summarized  in two tables; one table

contains the trial burn data that comprise part of the permit

application and the other table lists  the permit  conditions

developed from these data.  The combustion zone temperature is used
                                5-1

-------
as a surrogate for all continuously monitored operating parameters


such as combustion gas velocity and carbon monoxide  concentration in


the stack gas.  It is assumed that all numerical values have  been


checked and found acceptable.


5.1  Discussion of Example 1


     5.1.1  Case Description


     Sample permit application data are listed in Table 5-1.   The


incinerator is a single chamber liquid injection unit integrated


with a production process.  The waste stream to be incinerated is


fairly consistent in terms of waste quantity and composition.   The


heating value ranges from 8QOO to 10,000 Btu/lb, and the applicant


used a waste sample with 8000 Btu/lb for the trial burn.  Of  roughly


a dozen Appendix VIII constituents that were present based on waste


analysis data submitted with the penult application, three POHCs
                                            s       •

were selected for the trial burn:  dioxane (heat of  combustion 6.41


kcal/gm); ethylene oxide (heat of combustion 6.86 kcal/gm); and


phenol (heat of combustion 7.78 kcal/gm).  The concentrations  of


these POHCs in the waste were the following:  dioxane 32;  ethylene


oxide 52; phenol 202.  The applicant indicated that  concentrations


of each constituent varied not more than +252 from these values.


The waste analysis showed chloride content and ash content of   0.52


and  0.82 respectively.  For the trial burns the applicant proposed

                                              Q
two operating conditions, one targeted at 2100 F, the other at


2300°F.
                                5-2

-------
                           -   TABLE  5-1

             SAMPLE PERMIT APPLICATION DATA - EXAMPLE 1


Incinerator:  Single Chamber Liquid Injection

Waste Characterization Data

                                               Waste 1

Physical State                                 Liquid

Heating Value                             8,000-10,000 Btu/lb

Organically-Bound Chloride                      >0.5%
  Content

Ash Content                                     >0.8%

POHCs                                          Dioxane
                                               Ethylene oxide
                                               Phenol

Two trial burns were conducted generating the following data:

Incinerator Operating Conditions
                                              Test1        Test 2

Waste Feed Rate - Waste 1                    600 Ib/hr     600 Ib/hr

Combustion Chamber Temperature

   Primary                                   See Figure 5-1
   Secondary                                    	

Waste Feed Location                          Primary       Primary

Trial Burn Results

   ORE - Dioxane                             99.97%        99.99%
         Ethylene oxide                      99.984%       99.992%
         Phenol                              99.991%       99.995%

   Particulate Emissions                 0.075 gr/dscf  0.068 gr/dscf
   HC1 Emissions                            <4 Ib/hr      <4 Ib/hr
                                 5-3

-------
     The applicant could have built additional flexibility into his


permit by continuing his trial burn waste to have lower heating


value, higher ash or chlorine content, or additional POHC's more


difficult to incinerate than dioxane.


     5.1.2  Development of Permit Conditions


     The results of the trial burn are shown in Table 5-1.  The


trial burn at 2100°F achieved 99.99Z DRE only for phenol.   The


trial burn at 2300°F achieved 99.992 DRE for all three POHCs.  The


particulate and HC1 emissions were in compliance in both trial


burns.  The resulting permit conditions are shown in Table 5-2.


(Note:  Limits on air feed rate and CO in the stack gas are not


shown in this example,  but they would be derived similarly from


trial burn conditions.)


     The derivation of the permitting operating temperatures from


the continuously recorded combustion zone temperature is very


important in this example.  Samples of the recorded temperatures


from each performance test are presented in Figure 5-1.  The mean


temperature during Test 1 was 2160 F based on temperatures


measured at 15-minute intervals.  Because there were three


temperature spikes which lasted over 45 minutes of this 7-hour


performance test, a mean value obtained at less frequent intervals


might be skewed.  Ideally, the mean temperature should be  obtained


from measurements at more frequent intervals.  Although the

                                       
-------
                             TABLE 5-2

                SAMPLE PERMIT CONDITIONS - EXAMPLE 1


•  The permittee is allowed to burn liquid hazardous wastes with the
   following composition:

     - Minimum heating value is 8,000 Btu/lb

     - Maximum organically bound chloride content is 0.5%

     - Maximum ash content is 0.8%

     - No hazardous constituents more difficult to incinerate  than
       dioxane using the heat of combustion hierarchy may be
       incinerated at Condition 1 defined below

     - No hazardous constituents more difficult to incinerate  than
       phenol using the heat of combustion heirarchy may be
       incinerated at Condition 2 defined below
•  The following incinerator operating conditions must be maintained
   subject to the previous stipulations:

   Condition 1;  - The waste feed rate must be no more than 600 Ib/hr

                 - The minimum allowable  combustion zone temperature
                   is 2150°F measured at  (specify location of
                   temperature sensing device used during the
                   performance test); at  lower temperatures, the
                   waste feed cut off system must be activated

   Condition 2:  - The waste feed rate must be no more than 600 Ib/hr

                 - The minimum allowable  combustion zone temperature
                   is 1950°F measured at  (specify location); at
                   lower temperatures, the waste feed cut off  system
                   must be activated
                                5-5

-------
                 Test 1
                                                Temperature
                Time
                  Test 2
?   -\~\.-\
                                                Temperature
                                                   °F
                  Time
                                 30 minutes
                        F1GUBZ 5-1

        SAMPLES OF CONTINUOUSLY RECORDED TZ^PERAITOES
                           5-6

-------
the amount represents an increase of less than 10 percent.  The


temperature spikes account for approximately 10 percent of the time


of the performance test.  Considering both of these values,  the


incinerator is probably operating at steady state conditions.   If


the values were considerably less than 10 percent deviations,  steady


state conditions would definitely exist.  If the deviations were


greater than 15 percent, the incinerator would probably not be


operating at steady state.


     Specification of the allowable temperature range for Test 1 is


difficult.  The standard deviation of the Test 1 temperatures  at 15

                       o
minute intervals is 121 F.  The standard deviation might be used


to establish the allowable temperature range; however, the deviation


increases as the incinerator approaches non-steady state conditions,


which should not be permitted.  If the incinerator operates at ideal


steady state conditions, the use of the standard deviation might be


overly restrictive.  The purpose of allowing variations in operating


conditions is to allow adjustments to maintain steady state


conditions without activating the waste feed cut-off system.  The


potential problems of permitting unsteady state operation and


confining operation too strictly may be avoided by allowing


variations that are a fixed percentage of the mean or median


temperature.  In this example, a 10 percent variation from the mean


temperature was allowed, permitting a minimum operating temperature


of 1950 F.  The permit writer should not specify the minimum
                                 5-7

-------
operating temperature attained during a performance test as the


minimum permitted temperature.  The minimum temperature in this


example was 1550°F and it is highly improbable that the same


performance would be obtained at a mean temperature of 1550 F as


at a mean temperature of 2160 F.


     Steady state conditions were definitely achieved during Test 2;


the temperature chart does not continually increase or decrease and


there are no temperature spikes.  The mean temperature measured at


15-minute intervals is 2350°F.  The standard deviation is 45 F


and if this value was used to specify the permit condition, it would


be overly restrictive.  As in the previous example, a deviation of


approximately 10 percent is allowed, giving a minimum operating

                   o
temperature of 2150 F.  The records of other continuously


monitored parameters may be evaluated similarly.


5.2  Discussion of Example 2


     5.2.1  Case Description


     Sample permit application data for the second example are


presented in Table 5-3.  The purpose of this example is to


illustrate the permitting of mixed wastes and spiked wastes, and


permitting on the basis of total thermal input.  The incinerator in


this example is a multiple chamber hearth burning a mixture of solid


hazardous wastes and a mixture of liquid hazardous wastes.


     The waste characterization data in this example are the results


from the analysis of waste mixes comprised of several different
                                 5-8

-------
                               TABLE 5-3

              SAMPLE PERMIT APPLICATION DATA - EXAMPLE 2


 Incinerator:  Multiple Chamber Hearth

 Waste Characterization Data
                                  Waste Blend 1         Waste Blend 2

 Physical State                    Solid                 Liquid

 Heating Value                     5000 Btu/lb           80,000 Btu/gal

 Organically-Bound Chloride        4-6%                  <0.7%
   Content

 Ash  Content                       10-25%                0.5%

 POECs                             Phthalic anhydride    Pyridine
                                  Paraldehyde           Toluene diamine
                                  Phenol                Aniline

 One  trial burn was conducted generating the following data:

•Incinerator Operating Conditions
                                              Test 1
Waste Feed Rate - Waste  1                    200 Ib/hr
                  Waste  2                    15 gal/hr

Combustion Chamber  Temp.

    Primary                                   1400-1600°F
    Secondary                                 1750-1900°F

Waste Feed Location -  Waste  1                Primary
                       Waste  2                Primary

Performance Results

DRE - all POHCs                                99.99%

Particulate Emissions                        0.072 gr/dscf

HC1 Emissions                                >4 Ib/hr
                                             99.2% removal efficiency
                                 5-9

-------
hazardous wastes.  Analytical data are provided on the two mixed




wastes in the form each enters the incinerator.  The data indicate




that all solid wastes received at the facility are blended so that




the heating value is greater than 5000 Btu/lb, the organically bound




chloride content ranges from 4 to 6 percent, and the ash content is




between 10 and 25 percent.  Similarly, all non-halogenated liquid




wastes are blended to achieve the stated values.




     The FOHCs present in the wastes are not considered very




difficult to incinerate if the heat of combustion heirarchy is




used.  The applicant may spike these wastes with hazardous



constituents more difficult to incinerate than phthalic anhydride



and pyridene, particularly if the incinerator feeds are blended and




such constituents may be present in future shipments of wastes.  If




the wastes are spiked using less incinerable compounds such as




maleic anhydride or nitroaniline, and satisfactory performance is




achieved, the permit could be written to allow the incineration of




wastes containing a greater number of hazardous constituents.



Spiking wastes reduces the number of trial burns that might be



necessary if wastes are received containing hazardous constituents




that are more difficult to incinerate than those specified in the



permit.




     One trial burn was conducted with both hazardous waste mixes




being fed to the incinerator simultaneously.  The range of




combustion chamber temperatures was determined using the method
                                5-10

-------
presented in Example 1.   The trial burn performance results were in




compliance with the regulatory requirements.




     5.2.2  Development of Permit Conditions




     The permit conditions developed from the trial burn data are




presented in Table 5-4.  Because the physical states of the waste




mixtures are different, the permit must specify the compositions of




two separate incinerator feeds.  The permit conditions can be




written directly from the waste characterization data and the




incinerator operating information because the results of all the




incinerator performance tests comply with the regulatory




requirements.  The permitted composition limits of waste blends are




specified in the same manner as wastes from one specific source.




The waste feed" rates and other permit conditions may be specified in




the units most conveniently monitored by the  applicant.




     Waste feed is restricted to the primary  chamber.  If the wastes




were fed to the secondary chamber, the residence time would be




decreased and satisfactory performance might  not be achieved.  The




permit is written so that up to 200 Ib/hr of  Waste Blend 1 or




15 gal/hr of Waste Blend 2 may be fed to the  primary chamber




individually, or these amounts of the wastes  may be incinerated




simultaneously.  Hazardous wastes containing  more readily




incinerated hazardous constituents than phthalic anhydride and




pyridene may be fed in greater amounts, providing that the total




thermal input is less than 2.2 million Btu/hr and the other permit




restrictions on waste composition are satisfied.




                                5-11

-------
                              TABLE  5-4

                SAMPLE PERMIT CONDITIONS - EXAMPLE 2


•  The permittee is allowed to incinerate the following hazardous
   wastes:

   Waste Blend 1:  - The physical state of the hazardous waste must
                     be solid

                   - Minimum heating value is 5000 Btu/lb

                   - Mmr-tmum organically hound chloride content is 6Z

                   - Maximum ash content is 25Z

                   - No hazardous constituent more difficult to
                     incinerate than phthalic anhydride may be
                     present in the waste

   Waste Blend 2:  - The physical state of .the waste must be a liquid

                   - Minimum heating value is 80,000 Btu/gal

                   - Maximum organically bound chloride content is 0.7%

                   - Maximum ash content is 0.5Z

                   - No hazardous constituent more difficult to incin-
                     erate than pyridine may be present in the waste

•  Waste Blends 1 and 2 may be incinerated only if the following
   conditions are maintained:

     - The maximum feed rate of Waste Blend 1 is 200 Ib/hr to the
       primary chamber at (specify location)

     - The maximum feed rate of Waste Blend 2 is 15 gal/hr to the
       primary chamber at (specify location)

     - The maximum thermal input to the incinerator is
       2.2 million Btu/hr

     - The minimum combustion zone temperature in the primary chamber
       is 1400°? measured at (specify location)
     - The nin-tninm combustion zone temperature in the secondary
       chamber is 1750°? measured at (specify location)

                                5-12

-------
5.3  Discussion of Example 3




     5.3.1  Case Description




     The third example of developing permit conditions is a more




complex variation of the second example,  illustrating the




correlation of incinerator operating conditions with waste




composition in a permit.  The sample application information is




summarized in Table 5-5.  The incinerator is a multiple chamber




hearth unit burning solid waste and non-halogenated liquid waste




mixtures as in the second example.  A mixture of halogenated liquid




wastes is also incinerated at different operating conditions and




non-halogenated waste is fed to the afterburner to" maintain high




temperatures.




     Two trial burns were conducted.  The first trial burn was the




same as the trial burn conducted in Example 2, where only the solid




waste and the non-halogenated waste blends were incinerated.  During




the second trial burn, all three waste blends were fed to the




primary chamber of the incinerator and the non-halogenated waste




mixture was fed to the secondary chamber.  Higher combustion zone




temperatures were maintained during the second trial burn than




during the first trial burn in order to ensure adequate destruction




of the chlorinated materials.  The results of both trial burns were




in compliance with the regulatory performance standards.




     5.3.2  Development of Permit Conditions




     The permit conditions developed from the trial burn data are




summarized in Table 5-6.  The permit is similar to the one developed




                                5-13

-------
                                TABLE 5-5

               SAMPLE PERMIT APPLICATION DATA - EXAMPLE 3
Incinerator:  Multiple Chamber Hearth Equipped with Liquid Injection

Waste Characterization Data

                     Waste Blend 1    Waste Blend 2    Waste Blend 3
Physical State

Heating Value

Organically-Bound
 Chloride Content

Ash Content

POHCs
Solid

5000 Btu/lb

4-6Z


10-25Z

Phthalic
 anhydride
Paraldehyde
Liquid       .    Liquid

80,000 Btu/gal   40,000 Btu/gal

<0.7Z            15-2 5%
<0.5Z

Pyridene

Toluene
 diamine
Aniline
                     Phenol

Two trial burns were conducted generating the following data:

Incinerator Operating Conditions
 <0.5%

Tetrachloroethane

Hexachlo robenz ene

Hexachlorobutadiene

Waste Feed Rate

- Waste Blend 1
Waste Blend 2
Waste Blend 3
Test 1
200 Ib/hr
15 gal/hr
0
Test 2
150 Ib/hr
15 gal/hr
10 gal/hr
Combustion Chamber Temperature

   Primary
   Secondary

Waste Feed Location - Waste Blend 1
                      Waste Blend 2
                      Waste Blend 3
                  1400-1600°F
                  1750-1900°F

                  Primary
                  Primary
                 1400-1600°F
                 1850-2000°F

                Primary
                Primary & Secondary
                Primary
                                5-14

-------
                        TABLE  5-5  (Concluded)


Performance Results

                                       Test 1          Test 2

DRE - all POHCs                        99.99%          99.99%

Particulate Emissions                 0.069 gr/dscf   0.076 gr/dscf

HC1 Emissions                          4 Ib/hr         4 Ib/hr
                                     >99.4% removal  >99.8% removal
                                      efficiency      efficiency
                                5-15

-------
                             TABLE 5-6

                SAMPLE PERMIT CONDITIONS - EXAMPLE 3


•  The permittee is allowed to incinerate the following hazardous
   wastes:

   Waste Blend 1:  - The physical state of the hazardous waste must
                     be solid

                   - Minimum heating  value is 5000 Btu/lb

                   - Maximum organically bound chloride content is 6Z

                   - Maximum ash content is 25Z

                   - No hazardous constituent more difficult to
                     incinerate than phthalic anhydride may be
                     present in the waste

   Waste Blend 2:  - The physical state of the waste must be a liquid

                   - Minimum heating value is 80,000 Btu/gal

                   - Maximum organically bound chloride content
                     is 0.7Z

                   - Maximum ash content is 0.5Z

                   - No hazardous constituent more difficult to
                     incinerate than pyridine, may be present in the
                     waste

   Waste Blend 3:  - The physical state of the waste must be a liquid

                   - Minimum heating value is 40,000 Btu/gal

                   - Maximum organically bound chloride content
                     is 25Z

                   - Maximum ash content is 0.5Z

                   - No hazardous constituent more difficult to
                     incinerate than tetrachlorethane may be present
                     in the waste
                                5-16

-------
                       TABLE 5-6 (Concluded)

•  Waste Blends 1 and 2 may be  incinerated  only  if  the  following
   conditions are maintained:

     - The maximum feed rate of Waste  Blend 1  is 200  Ib/hr  to  the
       primary chamber at (specify  location used during performance
       test).  Up to 750,000 Btu/hr of wastes  containing more  easily
       incinerated hazardous constituents,  and satisfying the  other
       permit conditions, may be fed at this location.

     - The maximum feed rate of Waste  Blend 2  is 15 gal/hr  to  the
       primary chamber at (specify  location used during performance
       test).  Up to 1.2  x 10^  Btu/hr  of wastes  containing  more
       easily incinerated hazardous constituents, and satisfying the
       other permit conditions, may be fed  at  this  location.

     - The minimum combustion zone  temperature in the primary
       chamber is 1400°F  measured at (specify  location).

     - The minimum combustion zone  temperature in the secondary
       chamber is 1750°F  measured at (specify  location).

•  Waste Blend 3 may be incinerated only if the  following conditions
   are maintained:

     - The maximum feed rate of Waste  Blend 1  is 150  Ib/hr  to  the
       primary chamber at (specify  location used during performance
       test).  Up to 750,000 Btu/hr of wastes  containing more  easily
       incinerated hazardous constituents,  and satisfying the  other
       permit conditions, may be fed at this location.

     - The maximum feed rate of Waste  Blend 2  is 15 gal/hr, no more
       than 5 gal/hr of which may be fed to the  secondary chamber  at
       (specify location  used during performance test). Up to
       1.2 x 10° Btu/hr of wastes containing more easily
       incinerated hazardous constituents,  and satisfying the  other
       permit conditions, may be fed at this location.

     - The maximum feed rate of Waste  Blend 3  is 10 gal/hr  to  the
       primary chamber at (specify  location used during performance
       test).  Up to 400,000 Btu/hr of wastes  containing more  easily
       incinerated hazardous constituents,  and satisfying the  other
       permit conditions, may be fed at this location.

     - The minimum combustion zone  temperature in the primary
       chamber is 1400°F  measured at (specify  location)

     - The minimum combustion zone  temperature in the secondary
       chamber is 1850°F  measured at (specify  location)

                                5-17

-------
in Example 2 but includes additional operating requirements  for the



incineration of the halogenated waste blend.



     One of the operating requirements is the restriction on waste




feed location.  Wastes may only be fed to the incinerator at the



locations used during a satisfactory performance test.  During



Test 2 of this example, 10 gal/hr of Waste Blend 2 were fed  to the




primary chamber and 5 gal/hr were fed to the secondary chamber, or




afterburner.  Therefore, the permit conditions stipulate that no



more than 5 gal/hr of Waste Blend 2 can be fed to the afterburner at



the same location used during the performance test and Waste Blend 3




cannot be fed to the afterburner.  If Waste Blend 3 was fed  to the




afterburner, the residence time in the incinerator would be  less




than if it was fed to the primary chamber, and a 99.99 percent DRE.



might not be attained.  In the absence of performance data,  it must



be assumed that a 99.99 percent DRE will not be achieved and the



permit is developed accordingly.  Up to 15 gal/hr of Waste Blend 2



may be fed to the primary chamber because the residence time is



increased if the waste is fed to the primary chamber instead of the



afterburner.  The increase in residence time will increase the DRE,



and such operation is permitted.




     Because of the restrictions on waste feed locations, the permit



cannot be written on the basis of total thermal input to the



incinerator.  Maximum thermal inputs may be specified at each feed
                                5-18

-------
location,  but unless significant  amounts  of  auxiliary fuel were used




during the performance test,  the  allowable feed  rates of easily




incinerated wastes will not be much  greater  than the feed rates used




for the performance test.   Table  5-6 demonstrates how the thermal




input at each feed location may be specified in  a permit.
                                5-19

-------
6.0  REFERENCES

1.   U.S. Environmental Protection Agency.  Engineering Handbook for
    Hazardous Waste Incineration, SW-889 IERL, Cincinnati, Ohio,
    September 1981.

2.   American Society for Testing Materials.  Standards for Analysis,
    American Society for Testing Materials, Philadelphia, PA, 1980.

3.   U.S. Environmental Protection Agency.  Sampling and Analysis
    Methods for Hazardous Waste Incineration, OWWM, Washington, DC,
    February 1982.

4.   Kiang, Yen-Hsiung.  Total Hazardous Waste Disposal Through
    Combustion, Industrial Heating, December 1977.

5.   North American Combustion Handbook, North American Manufacturing
    Company, Cleveland, OH, 2nd Edition (1978).
                                6-1

-------
APPENDIX A - EVALUATION OF INCINERATOR DESIGN INFORMATION




     The permit writer should evaluate incinerator design




information in order to ensure that the unit is capable of attaining




the operating conditions stated in the permit application and that




the waste chaxacteristics, incinerator design specifications, and




incinerator operating conditions are in agreement.  The evaluation




is particularly important for new incinerators because draft permit




conditions are established on the expectation that the operating




conditions will be sufficient to comply with the performance




standards.  The methods for evaluation presented in this chapter are




engineering estimates developed from simplifying assumptions.  More




precise methods of analysis are presented in the Engineering




Handbook   .  Typical operating conditions for hazardous waste




incinerators axe summarized in Table A-l for reference and general




guidance.




     The permit application must contain a detailed engineering




description of the incinerator unit.  Although an applicant may




submit engineering blueprints, they are too detailed to be used




effectively by the permit writer.  Evaluations of structural




integrity are not necessary in order to approve an application.




Schematic drawings or process and instrumentation diagrams may




assist the permit writer in evaluating incinerator design.




     The design characteristics evaluated in this chapter include




the combustion zone temperature, the gas volume flow rate and
                                A-l

-------

































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residence time at the combustion temperature, combustion chamber

mixing, air pollution control equipment, and instrumentation and

safety system design.  These characteristics are capable of

significantly affecting incinerator performance.

     English units of measure are used throughout this guidance

manual because of their widespread use in incineration technology

and practice in the United States.  Conversion factors to metric

units are provided in Appendix B.

A.I  Combustion Zone Temperature

     Combustion zone temperatures may be estimated using the

relationship between the gross thermal input to the incinerator

(higher heating value), excess air usage, and adiabatic temperature

of the combustion gases shown in Figure A-l.  The figure is

applicable to liquid and solid wastes.  The curves are derived from

theoretical computations of the combustion gas temperatures attained

under adiabatic (no heat loss) conditions.  Thus, the temperatures

are the maximum that would be encountered in actual practice.  The

use of these figures is demonstrated by the following example:

     The heating value of the incinerator feed is 11,750 Btu/lb and
     the excess air is 30 percent.  Locating these values on
     Figure A-l, the corresponding adiabatic temperature is about
     2900°F.

     If total thermal input to the incinerator is specified on a

moisture free basis (the energy required to heat and vaporize the

free water present in the waste is not subtracted from the total

thermal input), the adiabatic combustion zone temperature (T) may be
                                 A-3

-------
             PARAMETERS:  X EXCESS AIR
        2000   6000    10000   14000   13000

         HIGHER HEATING VALUE, BTU/LB.
               FIGURE A-l

ADIABATIC TEMPERATURE OF COMBUSTION GASES
       FROM WASTE INCINERATION <4'
                   A-4

-------
estimated using the following formula derived from a simplified

energy balance:

               HV + 0.0525 (EA)(HV) - 845 W
               2.3 x ICT4 (EA)(HV) + 0.612 W
                                                       Equation A-l

     Where:  HV = Heating value of moisture free waste (Btu/lb)
             EA = Excess air usage (1 + % Excess Air/100)
              W = Amount of water entering the incinerator (Ib/hr)
              T - Combustion zone temperature (°F)

     If the combustion zone temperature specified in a permit

application is different from the theoretical adiabatic temperature,

the excess air value should be checked using the method in A.2.1.

A.2  Combustion Gas Velocity

     The combustion gas velocity measurement required by the

regulations is affected by excess air use and auxiliary fuel use,

and is indicative of residence time and turbulence.   Methods of

estimating values of each of these parameters to ensure that they

correlate with the measured combustion gas velocity are presented in

the following subsections.

     A.2.1  Excess Air Usage

     Excess air is defined as that air supplied in addition to the

quantity required for stoichiometric (perfect) combustion and may be

expressed as:

  % Excess Air = Actual air feed rate - stoich. air feed rate
                            Stoich. air feed rate

                                                       Equation A-2

Excess air acts as a diluent in the combustion process and reduces

the temperature in the incinerator (i.e., maximum theoretical
                                A-5

-------
temperatures are achieved at zero percent excess air) .   This

temperature reduction is desirable to limit refractory degradation

when readily combustible, high heating value wastes are burned.

When aqueous or other low heating value wastes are burned, excess

air is usually minimized to keep the system temperature as high as

possible.

     The percentage of excess air used during incineration can be

computed from stack monitoring data by EPA Method 2, Appendix A,

40 CFB. 60.  The permit writer can check the computed excess air

value using the following equation:
     1 ****** *** ' o.26«o&                     * 10°
                                                        Equation A-3

     where:  02 " Percent oxygen in the stack gas by volume,
                    dry basis
             N2 * Percent nitrogen by volume, dry basis
             CO * Percent carbon monoxide by volume, dry basis

     If stack monitoring data are not available, the permit writer

can check whether the thermal input, combustion gas velocity, and

excess air usage correlate using the following engineering

approximations.  The combustion gas volume may be estimated from the

engineering approximation that 1 standard cubic foot (scf) of

combustion gas is generated for each 100 Btu/lb of incinerator feed

material.  This estimate is true only for stoichiometric combustion

(zero excess air).  This relation may be expressed as:
                                 A-6

-------
     scf of gas = Higher heating value of feed (Btu/lb)
     Ib of feed                    TTTD

                                                        Equation A -4

     If auxiliary fuel is co-fired with the waste, the heating value

(HV) of the feed may be expressed as:

     HV(feed) - HV(waste) x (fraction of waste in feed) + HV(fuel)
                x (fraction of fuel in feed)

                                                        Equation A-5

Because the volumes of combustion gas and air feed required for

combustion are nearly equal under standard conditions, this same

approximation is also valid to estimate the volume of air required

for combustion.

     The volume of combustion gas under standard conditions,

expressed as standard cubic feet (scf), may be converted to the

volume under operating conditions expressed as actual cubic feet

(acf), by use of the ideal gas law.  A standard temperature of

32 F is used in this manual, although a standard temperature  of

60°F or of 70°F is used by the fan and blower industry.  Because

most incinerators operate at atmospheric pressure, this law

simplifies to:

          acf = Stack gas temperature (460 + °F)
          scf
                                                        Equation A-6

Another useful and approximate relationship converts the volume of

combustion gas obtained with stoichiometric air to the total volume
                                 A-7

-------
of gas generated with a known percentage of excess air.   The

calculation, is as. follows:

     (Stoi. gas vol.) x (1 + % excess air/100) « total gas volume

                                                        Equation A-7

This approximation is adequate for most fuels or vaste/fuel mixtures

and for excess air values to 200 percent.

     If the incinerator is equipped with a quench or a wet air

pollution control device, the approximate total gas volume must

include the water vapor contributed by the equipment.  The gas

streams are usually saturated with water and the water content of

the saturated gas is a function of the gas temperature,  as

illustrated in Figure A-2.  The saturated total gas volume may be

estimated using the following formula:

  Saturated total   	total gas volume	
    gas volume    * 1-concentration of water in flue gas (2/100)

                                                        Equation A-8

     The total gas volume flow rate or saturated total gas volume

flow rate can be converted to the combustion gas velocity if the

cross sectional area of the gas duct at the point of the velocity

measurement is known.  The volume flow rate divided by the cross

sectional area is the gas velocity.  Typical stack gas velocities

range from 50 to 60 feet per second.  The utility of these

approximations is presented in the following sample calculation:

     An applicant states that the stack gas velocity is  3000
     ft/min downstream of a wet scrubber when using 22 percent
     excess air.  The permit writer uses the following data to
     check these values:


                                A-8

-------
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70




60




50




40




30




20




10
                                     I	I
                 60     80   100    120   140   160   180   200   220




                              Gas Temperature,  °F



           Basis:  Volume of water vapor In saturated  air at 1 atm.






                             FIGDBE A-2


            WATER VAPOR CONTENT OF SATURATED FLUE GAS
                                 A-9

-------
   Waste feed rate:  17 Ib/min
   Heating value of waste:  5000 Btu/lb
   Auxiliary fuel feed rate (#6 Residual Oil):  17 Ib/min
   Heating value of fuel:  18,000 Btu/lb

   Note:              Gross heating Values of Several Fuels

                         Btu/lb       Btu/scf      Btu/gal

   Natural Gas           21,800        1020
   #2 Distillate Oil     19,000         —         137,000
   #6 Residual Oil       18,100         —         153,000

   Stack gas temperature:  160°F
   Stack diameter:  2 feet

   Substituting into Equations A-4 and A-5, the calculation of
   combustion gas volume flow rate for stoichiometric air is:

17 Ib/min. (5000 Btu/lb) + 17 Ib/min (18100 Btu/lb) - 3930 scf/min
                      100 Btu/scf

   Substituting into Equation A-7, the calculation of combustion
   volume gas flow rate including excess air is:

      (3930 srcf/min)(l + 22/100) - 4790 scf/min

   Calculation of combustion gas volume flow rate at 160°F using
   Equation A-6 is:

      4790 scf/min (460 + 160)°R - 6040 scf/min
             492 RO

   Using Equation A-8 and Figure A-2,  the calculation of saturated
   flue gas volume flow rate at 160°F is:

      6040 acf/min - 8880 acf/min
      (1 - 32/100)

   Calculation of saturated combustion gas velocity:

      8880 acf/min
       Tr(2ft)2/4
                   - 2830 ft/min - 47 ft/sec
   The estimated gas velocity agrees within six percent of the
   velocity stated in the permit application.  If the difference
   were greater than ten percent, the application could be
   referred to the Permit Assistance Team for a more detailed
   evaluation.
                              A-10

-------
     A.2.2  Auxiliary Fuel Use

     The correlation of the combustion zone temperature,  total

thermal input, and excess air use may be checked using an elementary

heat balance.  The sum of the heat lost to combustion gas and the

associated water vapor and the heat lost to radiation should equal

the heat input from the waste and auxiliary fuel.  Combustion gas

enthalpy (or heat content) and water vapor enthalpy are a function

of combustion zone temperature as illustrated in Figures  A-3

and A-4.  Radiation losses may be estimated at five percent of the

total heat input as a rule of thumb.  If the heat loss is greater

than the heat input from the waste, auxiliary fuel must be added to

make up the difference.  If the heat input is greater than the heat

loss, the excess air usage is generally increased to maintain the

desired combustion zone temperature.  The utility of these

approximations is presented in the following example:

     The permit writer may wish to estimate the auxiliary fuel use
     and compare the value with actual fuel consumption for an
     incinerator operating under the following conditions:

        Waste feed rate:  5000 Ib/hr
        Heat content of waste:  6000 Btu/lb
        Water content of waste:  20%
        Combustion zone temperature:  2200°F
        Excess air usage:  150% (2.5 times stoichiometric)

     Heat Input = (6000 Btu/lb)(5000 Ib/hr)
                =• 30 x 106 Btu/hr

     In order to calculate the heat output the flue gas volume must
     be estimated and multiplied by the enthalpy obtained from
     Figure A-3 (44 Btu/scf).
                               A-H

-------
Enthalpy
Btu/scf
80
70
60
50

40

30
           20
           10
            3000                 2000                 1000

                  Combustion Zone Temperature, *?
                       FIGTJBE A-3
            FLDZ GAS ENTHALPY AS A FUNCTION
            OF COMBUSTION ZONE TEMPE3ATUBZ
                            A-12

-------
                                                        C3
                                                        U
                                                       TS
                                                       
-------
     Calculation of flue gas enthalpy:

     30 x 106 Btu/hr (2.5)(44 Btu/scf) = 33.0 x 106 Btu/hr
               100 Btu/scf

     Calculation of water vapor enthalpy using the enthalpy at
     2200°F obtained from Figure A-4 (2200 Btu/lb):

(20 Ib water/lb waste)(500 Ib waste/hr)(2200 Btu/lb) - 0.2 x 106 Btu/lb

     Heat Output » 33.0 x 106 Btu/hr flue gas enthalpy
                   +0.2 x 10^ Btu/hr water vapor enthalpy
                   +1.5 x 106 Btu/hr radiation loss
                              (0.05 x 30 x 106 Btu/hr)
                 - 34.7 x 106 Btu/hr

     The heat output is approximately 4.7 x 10^ Btu/hr greater
     than the heat input, so auxiliary fuel must be used to maintain
     the combustion conditions.

     The entire heat content of auxiliary fuel is not available to

compensate for thermal input deficiencies because of associated flue

gas losses.   As the combustion zone temperature is increased,  the

available heat from fuels decreases.  The fraction of heat avail-
                                                             -4
able, F, may be estimated using the formula F » 1 - (2.6 x 10  T),

where T is the combustion zone temperature in Fahrenheit degrees.

This formula is derived from the available heat values.of several

fuels presented in the North American Combustion Handbook   .

Continuing the previous examples using #2 fuel oil as the auxiliary

fuel,    F - 1 - (2.6 x 10~4T)

          F - 1 - [2.6 x 10"4 (2200°*)]
            - 0.43
                                                        Equation A-9

       4.72 * 106 Btu/hr     - 580 gal/hr
     (0.43)(19,000 Btu/gal)
                                A-14

-------
Therefore, the auxiliary fuel consumption in the example would be

approximately 580 gallons per hour of #2 fuel oil.

     A.2.3  Residence Time

     The gas residence time in the combustion ^one  may be estimated

if the volume of the combustion gas is known.  The  residence time

can be approximated by dividing the volume of the combustion chamber

by the combustion gas volume flow rate under actual conditions.  A

sample calculation is provided below.

     The combustion zone is cylindrical with a diameter of 5 feet
     and a length of 26 feet.


     Volume of combustion zone = u^_^
                                   4

                                                        Equation A-10

                               " 3.14 (52)(26)
                                      4

                               - 5iO ft3

     The combustion gas flow rate is 4800 scf/min.

     This volume flow rate must be corrected to combustion zone
     conditions using the ideal gas law, Vj/Tj_ » ^2^2-  If
     the combustion zone is 2200°F:

         acf flue gas  m  4800 scf
        (460 + 2200)°R    (460 + 32)°R

     Volume flow rate of flue gas - 25,900 acf/min.

     Residence Time - (510 ft3)(60 sec/min)
                         25,900 acf/min

                    - 1.18 sec

     In rotary kiln/afterburner incinerators, residence time of the

solids in the kiln is dependent on the physical state of the waste.
                                 A-15

-------
Finely divided solids may incinerate within a fraction of a second;

dense, bulky materials may require up to an hour.  Waste liquids

with high heating value may be co-incinerated with solids, slurries,

or tarry materials.  Residence times for liquids are generally much

shorter than for the other materials.  Generally, gas and solid

residence times in rotary kilns are not included in residence time

computations because lover temperatures are maintained in the kiln

than in the afterburner.

     The overall residence time (t) for movement of solids through a

kiln may be estimated by:

                          t *  0.19L
                              (rpm) DS
                                                        Equation A-ll
     where:    t * the mean residence time
               L » the length of the kiln
             rpm * the kiln rotational velocity
               D * the kiln inside diameter
               S » the kiln slope

In kiln operation, solids or sludges are fed to the higher end of

the kiln and then pass down through the kiln where they are

progressively heated and ignited.  Just prior to discharge near the

lower end, the ash may enter a cooling zone.  As gases rise from the

ignited solids, they may be further oxidized, but conversion to the

ultimate oxidation products will usually occur in the afterburner.

     The permit writer should not attempt to specify residence time

requirements in a permit because of the difficulties encountered

when trying to measure or estimate values.  The permit writer may

check the residence time stated by the applicant if such information

is included.
                                 A-16

-------
     A.2.4  Combustion Zone Turbulence

     The permit writer may use combustion gas velocity neasurements

to evaluate turbulence in the combustion chamber.  Temperature,

oxygen, and residence time requirements for waste destruction all

depend to some extent on the degree of mixing achieved in the

combustion chamber.  However, this parameter is not measureable  and

the permit writer must rely on sufficient combustion gas velocity to

ensure turbulence.  Many of the problems involved in interpreting

incineration data relate to the difficulty involved in quantifying

the degree of mixing achieved in incinerators of different design,

which is one reason for recommending trial burns.

     In liquid waste incinerators, the degree of mixing is

determined by the specific burner design (i.e., how the primary  air

and waste fuels are mixed), combustion product gas and secondary air

flow patterns in the combustion chamber, and turbulence.

     In conventional liquid injection incinerators or afterburners,

adequate turbulence is usually achieved at superficial gas

velocities of 10 to 15 ft/sec.  Superficial gas velocities (v) may

be estimated using the following formula:

                          v - 3.
                              A

                                                        Equation A-12

     where:  q • gas flow rate at operating temperature, acf/sec
             A « cross-sectional area of the incinerator chamber,
                 ft2
                                A-17

-------
     When primary combustion air is introduced tangentially to the

burner (e.g., vortex burners), or secondary air is introduced

tangentially, or burner alignment is such that cyclonic flow

prevails in the incinerator, actual gas velocities exceed the

superficial velocity.  Thus, adequate turbulence may be achieved at

superficial velocities less than 10 ft/sec in cyclonic flow

systems.  Turbulence is increased by installing baffles in the

secondary combustion zone of the incinerator, which abruptly change

the direction of gas flow.  However, baffles also increase pressure

drop across the system and are not a common practice in liquid

injection incinerator design.  Steam jets can also be used to

promote turbulence.  '

     Turbulence may also be characterized by the Reynolds Number

(Re) achieved in the combustion zone.  The Reynolds Number is

defined as:

                        Re -5ZP
                             H

                                                        Equation A-13

     where:   D » diameter of circular cross section or equivalent
                  diameter of other cross sections (ft)
              7 * average linear velocity of gas through a
                  combustion chamber (ft/sec)
              p - density of gas (lb/ft3)
              HL - viscosity of gas (Ib/ft-sec)

     The density and viscosity of the gases in the combustion zone

may be approximated by those of nitrogen at the combustion zone
                                A-13

-------
temperature (T in  F).  The density of nitrogen is a linear

function of temperature, specifically:

                        P-    38.4
                            460 + T
                                                       Equation A-14
The viscosity of nitrogen is temperature dependent, although

non-linearly, and may be estimated from Figure A-5.  For a

combustion chamber with a circular cross section, Equation A-13

becomes:

                   Re =»    72,000 Q
                         fiD (460 + T)
                                                       Equation A-15
     where:   Q * volume flow rate at T (acf/sec)
              |JL « viscosity of gas at T (from Figure A-5)
              D =• diameter of combustion chamber (ft)
              T » temperature of combustion zone gas (°F)

     Reynolds Numbers greater than 3000 indicate turbulent flow

conditions:  the higher the number, the greater the turbulence.  If

the permit writer obtains Reynolds Numbers less than 3000, adequate

mixing in the combustion zone cannot be ensured and incinerator

performance may be unacceptable unless methods to promote turbulence

are included in the combustion chamber design.

     A sample calculation of the Reynolds Number is presented below:

     Re ,  72.700 Q
          (j.D(460 + T)

     V - 432 acf/sec <§ 2200°F
     M. » 0.057 cp (from Figure A-5)
     T =• 2200°F
     D - 5 ft

     Re	(72,700) (432)	
            (0.057)  (5)  (460 + 2200)

     Re - 41,400


                                 A-19

-------
    0.064
    0.062
a.  0.060
o
    0.058
    0.056
o

£   0.054
tn
o

.3   0.052
    0.050
   0.043
             1600      1800       2000      2200

                                Temperature *7
2400
2600
                             FIGURE A-5
           VISCOSITY OF NITROGEN AT ELEVATED TEMPERATURES
                                 A-20

-------
     Turbulent flow is ensured because the Reynolds Number is  well

over 3000.

A.3  Air Pollution Control Equipment

     Air .pollutants from hazardous waste incinerators may be

classified in two groups, particulate matter and gaseous emissions,

and the air pollution control (APC) equipment is similarly

classified.  However, several items of AFC equipment are capable of

removing both types of pollutants.  Particulate matter is defined as

any material that exists as a solid or liquid at ambient temperature

and pressure, for example, smoke, dust, fumes, mists, and sprays.

     APC devices are either wet or dry, and each type has-its

relative advantages and limitations.  Dry devices have the advantage

of direct dust collection without sludge generation or the need for

subsequent wastewater treatment, but these devices cannot remove

gaseous pollutants (although injection of gas-sorbent materials in

baghouses has been suggested).  Caution must be exercised during

disposal of dry dust because of explosion hazards; such dust is

often wetted to prevent secondary emission problems.

     The efficiencies of APC devices are affected by factors such as:

     •  Particulate and/or gaseous concentrations in the combustion
        chamber exit stream

     •  Particle size distribution

     *  Adequacy of gas prime movers

     Table A-2 is a list of the six commonly used types of APC

devices used to control emissions from hazardous waste
                                 A-21

-------
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-------
incinerators.  This table also lists operating pressures and

relative particulate and gaseous collection efficiencies.   All six

types of APC devices remove particulate matter to some level of

efficiency.  However, only three devices control gaseous pollutants

to any degree.  The packed, spray, or plate scrubber is the most

efficient device for removal of pollutant gases.  Mechanical ash

collectors or cyclones are sometimes used for primary dust

collection with solid waste fired combustion units.   Secondary dust

collection equipment could be an electrostatic precipitator, venturi

scrubber, or baghouse.

     The ash content of wastes burned in liquid injection

incinerators may be used to estimate the maximum concentration of

particulate emissions.  The maximum particulate emissions are

estimated from values of the waste feed rate, the stack gas volume

flow rate, oxygen content of the stack gas and the waste ash

content.  An example of this calculation is provided below:

     Waste feed rate:  1000 Ibs per hour, no auxiliary fuel is used.
     Stack gas volume flow rate:  120,000 scf per hour @ 7  percent
     oxygen (this value may be verified or corrected to dry
     conditions, if necessary, by the method presented in
     Section 3.2).
     Ash content of waste:  0.5 percent

     The effective ash feed rate may be calculated:

       (1000 Ib of waste/hr) (5 x 10~3 Ib ash/lb feed) =«
        5.0 Ib of ash/hr

     The maximum particulate emissions from the liquid injection
     incinerator may be estimated at a stack gas oxygen
     concentration of 7 percent:
                                A-23

-------
     (5.0 Ib of a3h/hr)(7000 gralns/lb) . 0.29 gr of ash
            (120,000 scf/hr)                   dscf

Because the particulate emission in this example is greater than the

allowable limit of 0.08 gr/dscf, this liquid injection incinerator

unit will probably be equipped with a. particulate removal device.

     Maximum uncontrolled hydrogen chloride emissions may be

estimated in a similar manner.  Hydrogen chloride emissions greater

than 1.8 kilograms per hour (4 pounds per hour) must be removed from

the combustion gas at an efficiency greater than 99 percent or be

reduced to less than 1.3 kilograms per hour, whichever Is greater.

The following example illustrates estimation of maximum hydrogen

chloride emissions.

     Waste feed rate:  1000 Ibs/hr

     Organically bound chloride content: 12%

Estimation of uncontrolled hydrogen chloride emissions:

     0.12 Ib Cl     1000 Ib waste     36.5 Ib HO.               ,
      Ib waste   *  	to	  *  35.5 Ib Cl     123 lb HC1/hr

Because uncontrolled Hd emissions are greater than 4 Ib/hr, a

scrubber will probably be installed.  Allowable controlled emissions

at 99 percent removal efficiency may be estimated;

     123 lb HdL/hr x (0.01) - 1.23 lb HCl/hr

Because the Hd emissions controlled to 99 percent removal are less

than 4 Ib/hr, the scrubber may operate at less than 99 percent

efficiency (as long as Hd emissions remain lower than 4 Ib/hr).
                                A-24

-------
A.4  Monitoring Instrumentation and Waste Feed Cut Off System

     The minimum required process monitoring includes the combustion

zone temperature, waste and fuel feed rates, combustion gas

velocity, and carbon monoxide concentration of the stack gas.  It is

recommended that thermocouples be used in conjection with automated

recorders to continuously record temperatures.  Maximum operating

temperaures of some of the more common thermocouples are presented

below:

     Copper/constantan                  700°F (371°C)
     Chromel/constantan                1800°F (982°C)
     Iron/constantan                   2000°F (1093°C)
     Chromel/alumel                    2200°F (1204°C)
     W/W2& and W5/W26                  3000°F (1649°C)
     Platinum (Pt/Pt, Pt 6/Pt 30)      3000°F (1649°C)

Optical pyrometers are not acceptable combustion zone temperature

monitoring devices because of potential interferences present in the

combustion area.  The pyrometers could respond to sources of light

in the combustion chamber other than the flame and give erroneous

readings.

     The combustion zone operating temperature may be monitored at

more than one location in the chamber in order to minimize the

effects of local disturbances on temperature measurements.

Temperatures in the combustion chamber are not uniform; the hottest

temperatures are in the vicinity of the flame and the coolest

temperatures are at the refractory wall and air inlets.  Ideally, a

shielded thermocouple should be used to measure the gas temperature

at the combustion chamber exit.  Specification of the location of
                                A-25

-------
temperature measurement is as important as the specification of




allowable temperature ranges in a permit.




     Liquid waste and fuel feed rates may be measured using




conventional instruments such as flow tubes, magnetic or acoustic




meters, paddle wheel meters, and orifice meters.  These instruments




are installed downstream of liquid pumps and regulators and upstream



of the burners.  Gaseous fuel flow rates are measured by orifice or




venturi devices.  Solid waste loading systems may include scales to




weigh wastes as they are charged to the incinerator, or the loading




rate may be measured from the charging rate and capacity of waste



containers, such as carts, ram loaders, or 55 gallon drums.  Solid




waste feed rates to manually loaded incinerators may be determined




in the same manner as with automated loading systems.




     Combustion gas velocities may be measured using orifice plates




or Venturis, pitot tubes, or by indirect means.  Orifice plates and




Venturis are impractical for combustion gas velocity measurements




because of the large pressure drops caused by these devices.  Fitot




tubes may be used to measure combustion gas velocity in the hot zone



of an incinerator immediately downstream of the combustion chamber



or in cooler areas, such as the stack.  Fltot tube measurements can




be converted to combustion gas velocity and volumetric flow rate




using the procedure in EPA Method 2 presented in the Appendix of



40 C?R 60.  Changes in the molecular weight and the water content of




the combustion gas will affect the correlation of pitot tube




measurements and combustion gas velocity.






                                A-26

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     Indirect measurements of combustion gas velocity may include




blower rotational speed and current use.  Many blowers operate in




the region of the blower curve where static pressure and current use




(horsepower) do not change radically with a change in capacity.




Therefore, blower static pressure and current measurements are often




not suitable indicators of combustion gas velocity unless the




applicant can demonstrate a noticeable correlation.  Blower rpm is




indicative of combustion gas velocity and volumetric flow rate only




if static pressure in the blower remains constant.  Measurement of




combustion gas velocities using blower characteristics on




incinerators equipped with more than one blower may become very




complex, particularly if ambient air is being fed to the combustion




chamber while hot combustion gas is drawn from the chamber.




Correlation of the volumetric flow rate and blower characteristics




depends on the densities of the gases.  Density measurements of the




two gases may be avoided by use of a pitot tube installed downstream




of the combustion chamber.




     Measurement of pressure differentials across incinerator




components, such as combustion chambers and air pollution control




devices, is not a suitable indicator of combustion gas velocities.




Pressure differentials may be affected by leakage, changes in liquid




flow rates, and clogging phenomena as well as gas flow rates.  It is




not possible to distinguish the factors affecting changes in




pressure measurements using conventional equipment such as velocity
                                A-27

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head meters.  Therefore, pressure differential measurements should
not be used as gas velocity indicators; however, they are useful
monitors for upset conditions.  Rapid changes in pressure
differentials may indicate stoppage of water flows to air pollution
control devices, failure of blowers, or incorrect positioning of a
damper.
     Continuous monitoring of the oxygen concentration in the stack
gas is an acceptable substitute for combustion gas velocity
measurement.  The oxygen concentration is indicative of excess air
usage and, if waste feed composition and feed rate remain constant,
it is-an indirect measurement of the combustion gas volumetric flow
rate.  The most common method of continuous oxygen measurement is an
electrocatalytic device using zirconium oxide to promote an
electrolytic reaction, and paramagnetic and polarographic
instruments are also used.  The monitors are relatively durable and
accurate instruments.  Additional information about instrument
capabilities is presented in the Engineering Handbook^  .
     Continuous carbon monoxide monitors are typically infrared
devices, although ultra-violet or polarographic devices may be
used.  The devices may be in-situ or extractive.  Additional
information about carbon monoxide monitoring instruments is
presented in the Engineering Handbook^  .  Carbon monoxide
monitoring by Orsat analysis is not acceptable because it is not
continuous and it is not sensitive enough to detect ppm
concentrations in the stack gas.
                                A-28

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     An applicant may monitor parameters in addition to those




required by the regulations.   Supplementary process monitoring may




include such parameters as pressure differentials,  current use of




blower motors and additional stack gas monitoring.   Pressure drops




across major incinerator components are frequently  monitored to




detect changes in the gas or liquid flow rates,  and clogging in the




system.  Monitoring the pressure differential provides a continuous




check on the normal operation of many air pollution control




devices.  A change in the pressure drop or gage  pressure is an




indication that other measured parameters in the system need to be




observed immediately to find the cause of any malfunction in order




to take corrective action.




     Many kinds of pressure measurement devices  are commercially




available; however, a differential pressure gage calibrated in




inches of water is usually used.  In selecting a pressure measuring




device, the following items are considered:




     •  Pressure range




     •  Temperature sensitivity




     •  Corrosivity of the fluid




     •  Durability and ease of maintenance




A guide to pressure sensing device selection is  summarized in the




Engineering Handbook   .




     Another parameter that may be monitored is  the current use of




blower motors.  Rapid fluctuations in the current use indicate upset
                                A-29

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operating conditions of the incinerator unit.  Pressure drop and

current monitoring instruments may be integrated with the waste feed

cut off system.

     Stack gases may be continuously monitored for a variety of

parameters including sulfur dioxide, nitrogen oxides, nitrogen

dioxide, unburned hydrocarbons, carbon dioxide, and oxygen.

Capabilities of instruments available for monitoring of these

parameters are discussed in the Engineering Handbook^ '.

     The objective of a waste feed cut-off system is to stop waste

feed when incinerator operating conditions are not in compliance

with permit conditions.  If an incinerator is not equipped with a

cut-off system, hazardous waste could be emitted to the environment

and the combustion chamber could become filled with an explosive

mixture.  Every hazardous waste incinerator must be equipped with a

waste feed shut-off system under 40 CFS 264.345(e).

     A pilot flame does not offer sufficient protection and may not

be considered a substitute for a waste cut-off system because it may

be extinguished or may be unable to relight the main flame.

Automatic waste feed shut-off valves are necessary and may close

upon signals from:

     •  Combustion or atomizing air blower

     •  Elements of input control systems, such as fuel feed rate
        indicators and scrubber water flow rate indicators

     •  The flame detector
                                A-30

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     •  Safety devices such as pressure relief valves and emergency
        venting systems

     •  Failure of electrical power to the facility

     •  Failure of maintenance of permitted operating conditions
        (e.g., temperature, gas velocity)

Often, two shut-off valves are placed in series as a precaution

against the leak, or failure of only one valve.  Shut-off valves are

often connected to flame detectors, several types of which are

available.  Only ultraviolet flame detectors are suitable for use in

hazardous waste incinerators.  Unacceptable types include:

     •  Thermopiles and bimetal warping devices which are used in
        low input heating applications

     •  Photocells (cadmium sulfide and lead sulfide) which respond
        to light sources in addition to the flame

     •  Flame electrodes which are suitable only for clean natural
        gas flames

     Several other monitoring devices may be integrated with the

waste feed cut off system.  The system should be evaluated on a case

by case basis to ensure that any malfunction that might cause

non-compliance with the performance standards activates the waste

cut-off valve.
                                 A-31

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                           APPENDIX  3

         METRIC EQUIVALENTS OF BRITISH ENGINEERING UNITS
Quantity
Length
Area
Volume
British Engineering
1 ft.
1 in.
1 ft2
1 in2
1 ft3
1 in3
Metric
3.0480 x 10"1 m
2.5400 x 10~2 m
9.2903 x 10" 2 m2
6.4516 x 10~4 m2
2.8317 x lO-2 m3
1.6387 x 10-5 m3
Mass

Density


Pressure
Heat Content

Energy, Work
Velocity

Viscosity


Flow
  1 grain/scf

  1 lbf/in2
  1 in.  of water
                      1 in. of mercury
                        (32°?)
  1 Btu
(Internt'l Table)
  1 Btu
(Internt'l Table)

  1 ft /sec

  1 centipoise
  1 ft2/sec

  1 ft3 /sec
  1 U.S.  gal/min
4.5359 x 10'1 kg

1.6018 x 101 kg/m3
2.2884 gram/scsi

6.8948 x 103 pascal (Pa)
2.4884 x 102 Pa

3.3864 x 103 Pa
2,3244 Joules/gram

1.0551 x 103 joule (J)

2.9307 x 10"4 kWh


3,0480 x 10"1 m/sec

1.0000 x 10"3 Pa sec
9.2903 x ID"2 m2/sec

2.8317 x 10-2 m3/sec
6.3090 x 10~5 m3/sec
                               B-l

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APPEHDIX B (Couciudad)
 Quantity
British Engineering
                           Metric
 Heat
Conductivity

Temperature
1 BtuClntnt'l Table) •in
   " sec - ft 2 - "F

degree Fahrenheit (tp)
degree Fahrenheit (t?)
degree Rankine (t-g.)
                     5.192 2 x 102 W/m-ak
                             -  (ty -f- 459. 67) /1. 8
                     tcalsius-  (t? - 32) /I. 8
                                t^/1.8
         B-2

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