EPA/540/2-89/025
     SUPERFUND TREATABILITY
           CLEARINGHOUSE
              Document Reference:
Ogden Environmental Services, Inc. "BOAT Treatability Data for Soils, Sludges and
 Debris From the Circulating Bed Combustion (CBC) Process." Technical report
            prepared for U.S. EPA. 31 pp. June 1987.
             EPA LIBRARY NUMBER:

          Super-fund Treatability Clearinghouse - EWHC
         PHASE DO NOT       FROM LIMY

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                SUPERFUND TREATABILITY CLEARINGHOUSE  ABSTRACT
Treatment  Process:       Thermal Treatment  - Circulating  Bed  Combustion
                         (CBC)

Media:                   Soil/Clayey

Document Reference:      Ogden Environmental Services,  Inc.   "BOAT Treat-
                         ability Data  for Soils,  Sludges  and  Debris  From  the
                         Circulating Bed Combustion  (CBC) Process."
                         Technical  report prepared for  U.S. EPA.  31  pp.
                         June 1987.

Document Type:           Memo and Conference Paper

Contact:                 Major Terry Stoddart
                         U.S. DOD/AFESC
                         Bldg 1117
                         Tyndall Air Force  Base,  FL  32403
                         904-283-2949

Site Name:               Circulating Bed Combustion  Demonstration Facility
                         (Non-NPL)

Location of Test:        California

BACKGROUND;  The  two papers provide a general overview of the Ogden
circulating bed combustion and summary data of both PCB  laden soils for
EPA-TSCA and a test on RCRA liquid organic wastes for  the California Air
Resources  Board (CARB).  This abstract will discuss the  results of  the PCB
test, which was planned, monitored and approved  by  the EPA.
OPERATIONAL INFORMATION;  The primary CBC  components are the combustion
chamber, hot cyclone collector, flue gas cooler, baghouse, and stack.
Auxiliary  systems include feeders  (solids, liquids, sludges), forced-draft
and induced-draft fans,  ash conveyer, compressed air,  cooling tower, and
building ventilation.  Operating parameters, schematic diagram and cost
estimates  are provided.
    Atmospheric primary  air is pumped into the lower portion of the
combustion chamber where the bed material  is fluidized by turbulent mixing
of the air and solids.   Larger solids gravitate downward to  form a more
dense fluidized bed in the lowest combustor zone.  The forced-draft primary
air carries smaller solids up to the top of the combustor.   Secondary air
is supplied to various locations in the combustion chamber to ensure
complete combustion and  minimize formation of nitrogen oxides (NO ).
    Auxiliary fuel and pressurized contaminated soil feed are individually
introduced into the lower combustion chamber.   Capability also exists to
feed liquid wastes.  Dry limestone sorbent is added to control gaseous
emissions of sulfur, phosphates, chlorines, or other halogens.
    Elutriated solids are separated from the flue gas  by a hot cyclone and
reinjected into the lower combustor using a proprietary non mechanical
seal.  Injection, burning and reaction of  fuel, contaminated soil feed,
3/89-46                                              Document Number:  EWHC

   NOTE:  Quality assurance of data may not be appropriate for all uses.

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sorbent, and ash  components are  the  inputs and outputs of a continuing
chemical process  which destroys  the  hazardous wastes.
    A  trial burn  of  PCB-contaminated soils was completed in GA Technologies
transportable Circulating Bed Combustor  (CBC).  Over 4000 pounds of soil
containing 1% PCB were treated in  three  identical 4-hour runs at 1800° F.
The sampling and  analysis and the  resulting data were obtained in
accordance with the  QA/QC protocol of EPA.  Third party sampling and
analysis contractors were used (along) with on-site and in-lab observation
by EPA.
PERFORMANCE!  Destruction and removal efficiencies (DREs) were greater than
99.9999% and PCB  levels  in combustor ash were less than 200ppb (see
Table  1).  No chlorinated dioxins  or furans were detected in the stack gas,
bed ash, or fly ash.  In addition, no significant concentrations of the
Products of Incomplete Combustion  (PICs) were detected. Combustion
efficiencies were greater than 99.9X, with CO concentrations less than 50
ppm and NO  concentrations less  than 75 ppm.  Particulate emissions were
generally Below 0.08 grain/dscf  and  HCL emissions were maintained below 4.0
Ib/hr  by introducing limestone directly into the combustor.  It is noted
that PCB test data led to the first  TSCA permit for transportable PCB
incinerator operation in all 10  EPA  regions.

CONTAMINANTS;

Analytical data is provided in the treatability study report.  The
breakdown of the  contaminants by treatability group is:

Treatability Group             CAS Number        Contaminants

W02-Dioxins/Furans/PCBs        1336-36-3         Total PCBs
3/89-46                                              Document Number:  EWHC

   NOTE:  Quality assurance of data nay not be appropriate for all uses.

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                                       TABLE  1
PCB TRIAL
Parameter
Test Duration, hr
Operating Temperature, °F
Soil Feed Rate, Ib/hr
Total Soil Feed, Ib
PCB Concentration in Feed.
DRE X
PCB Concentration
- Bed Ash, ppm
- Fly Ash, ppm
Dioxin/Furan Concentration
- Stack Gas, ppm
- Bed Ash, ppm
- Fly Ash, ppm
Combustion Efficiency, %
Acid Gas Release, Ib/hr
Particulate Emissions,
grain/scf (dry)
Excess Oxygen, %
CO, ppm
co2, %
N0x, ppm
BURN OPERATIONAL
TSCA
Requirement
4
-
-
-
ppm
>99.9999

<2
<2

-
-
-
>99.9
<4.0

<0.08
>3.0
-
-
—
DATA AND

1
4
1800
328
1592
11,000
99.999995

0.0035
0.066

ND
ND
ND
99.94
0.16

0.095
7.9
35
6.2
26
TEST RESULTS
Test Number
2
4
1800
412
1321
12,000
99.999981 99

0.033
0.0099
i
1 ND
ND
ND
99.95
0.58

2 0.043
6.8
28
6.0
25


3
4
1800
324
1711
9,800
.999977

0.186
0.0032

ND
ND
ND
99.97
0.70

0.0024
6.8
22
7.5
76
2 ND - Not Detected
  Derived from 2-hour makeup test

Note:  This is a partial listing of data.
       information.
Refer to the document for more
3/89-46                                              Document Number:  EVHC

   NOTE:  Quality assurance of data may not be appropriate for all uses.

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OGDEN  ENVIRONMENTAL
SERVICES,  INC.
POST OFFICE BOX 85178            10955 JOHN JAY HOPKINS DRIVE
SAN DIEGO CALIFORNIA 92138-5178      SAN DIEGO, CALIFORNIA 92121
HAROLD R DIOT
DIRECTOR SALES AND MARKETING
i6'9l 455-2383
                                                  June 3, 1987
          Mr. James Antizzo
          U.S. EPA ( Mail Code WH-548E)
          401 M Street,  S.W.
          Washington, D.C. 20006

          Dear Mr. Antizzo:

          The enclosed abstract and package of information is sent to you in response
          to the Agency's  need for treatability data  for soils and debris to use in
          establishing BOAT standards under  the land  disposal restrictions program.
          We are pleased to respond to this  need as stated in a May 18, 1987 letter
          to Mr. Richard  Fortuna  of  the  Hazardous Waste Treatment Council from
          Mr. Bill Hanson, Acting  Chief, Site Policy and Guidance Branch.

          We think that  the attached Abstract and brief answers to  the "TREATABILITY
          STUDY ATTACHMENT" reflect the excellent performance of our Circulating Bed
          Combustion  technology and  the  responsible  and  precise  controls and
          standards of the Agencies involved in our test work.

          We look forward to supplying any additional  information.  Please call  me at
          (619) 455-2383 or  Derrell  Young  at  (619)  455-3045 if you have any
          questions.
                                                   Sincerely,
                                                   Harold R. Diot
         HRDrmat
         Enclosure
         cc:   Richard Fortuna,  Hazardous Waste Treatment Council

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                                 ABSTRACT
            BOAT  TREATABH.ITY DATA  FOR SOILS, SLUDGES AND DEBRIS
                                 FROM THE
                 CIRCULATING BED COMBUSTION (CBC) PROCESS
                               June 3,  1987
      The CBC has demonstrated its effective destruction of hazardous  and
toxic compounds in soils, sludges  and liquids.   These  demonstrations have
been done in tests  in commercial size equipment in a facility  recognized  as
one of the  leading  fluid bed research  centers in the world.   There  have
been over 5000 hours  of testing logged in this  facility.  The key tests
discussed below represent only a small sample  of the data available.

      The two key tests discussed here and in  the attached brief answers  to
the "TREATABILITY STUDY ATTACHMENT" include a  test  on PCB for  EPA-TSCA and
a test on RCRA  compounds for the  California Air Resources  Board (CARB).
Both of these tests were  planned,  monitored and  approved by the  respective
agencies.   The sampling and analysis and the   resulting data obtained was
gained under the QA/QC protocols of these agencies. Third party sampling
and  analysis contractors  were  used  under with on-site  and  in-lab
observation by these  agencies.   The PCB test  data  led to  the first  TSCA
permit for  transportable  PCB incinerator operation  in  all  10  EPA regions.
The CARB data  (along  with the PCB and  other  test data) have  formed the
basis of the "operating  boundary" permit  conditions for the  RCRA  RD&D
permit given by EPA Region IX for the facility.

      Some major points regarding the data:

      o  The FCB tests  were done on actual site soils (clay-like,  rocky
         material).

      o  Greater than  99.9999X DRE was  obtained on PCB and no dioxin or
         furan was  detected and ash was well below TSCA requirements.

      o  PICs were studied  to  the extent that all  peaks in the National
         Bureau of  Standards Mass Spectral library were quantitated.

                                     1

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o  PICs have  been  related  to continuously  monitored CO  and  HC
   emissions.

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                             TREATABILITY STUDY
                                ATTACHMENT '
1.  Facility identification, description,  and waste characteristics.

1.1.  Identification

      Ogden Environmental Services, Inc. (OES)
      Circulating Bed Combustion (CBC) Demonstration Facility
      10955 John J. Hopkins Drive
      San Diego, CA 92121

      EPA Permit Number:  CAD 981613789

1.2.  Description

      A CBC thermal  destruction facility  including all auxiliary hardware
for solids, liquids or sludge waste treatment are instrumented specifically
for rigorous data collection.   A  schematic and  photographs  of  the  facility
are shown in Figures 1.2-1, 1.2-2, and 1.2-3.

      This CBC is a  transportable  treatment  unit with a 2 million  Btu/hour
thermal rating*.   The  transportable CBC has  a  TSCA permit  for PCB soils
treatment in all  10  EPA regions.   This CBC facility  also has  an EPA-RCRA
Research, Development and Demonstration (RDD) permit  for test  work on RCRA
waste.  The waste characteristics  tested  already  and allowed to be tested
by the EPA RDD permit are described in Section 1.3 below.
      OES  provides  full  waste  thermal  destruction services  with
      transportable CBCs up to  10 million Btu/hour and with fixed CBCs up
      to over 50 million Btu/hour.

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                  840311-3C
   Fig.  1.2-2.    OES 16-in. pilot-scale circulating bed combustor
                 •80238-19C
Fig. 1.2-3.    Pilot-scale CBC control console and data acquisition

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1.3.  Waste Characteristics

1.3.1.  Hazardous  Wastes  Already  Tested*  in CBC

      o  Soil containing  up  to:
         -  12,000 ppm PCS  (arochlor  1260)
            2,100  ppm 1,2,4  trichlorobenzene
         -  350  ppb total furans  (estimated)
            7 ppb  total dioxins (estimated)

      o  Liquids containing:
         -  Freon  113
            Carbon tetrachloride
            Hexachlorobenzene
            Ethylbenzene
         -  Xylene
            Trichlorobenzene
         -  Toluene
            Sulfur hexafluoride

1.3.2.  Hazardous  Wastes  Allowed  for  CBC  Tests by EPA  RDD  Permit

      All RCRA wastes listed in 40 CFR, number 261,  except:

      1)   F020,  F021, F022,  F023, F026, F027, F028 wastes (specific dioxin
          and furan compounds) with a concentration  of 1 ppm or higher.

      2)   Wastes with a concentration of  greater than  1000 ppm mercury (Hg,
          lead  (Pb),  arsenic  (AS),  barium (Ba),  cadmium  (Cd), chromium
          (Cr),  selenium  (Se), or silver  (Ag).
      Successful  test  demonstration work on many other materials not listed
      as  hazardous has been  done  including:  aluminum smelter  potliners,
      refuse  derived fuels,  high sulfur coals,  etc.
                                     6

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       3)  Wastes  with a PCB content of 50 ppm  or  greater,  (only if the
          Permittee's  TCCA  permit  to burn PCB's is no longer valid .  . .
          note this permit  allows up to 9,800 ppm PCB soils).

       A)  Chemical warfare  agents.

       5)  Radioactive materials.

       6)  Forbidden and Class A  explosives as defined  in 40  CFR  173.51 and
          173.53.

       7)  Waste with a total organic sulfur content greater than 5 wt.Z.

2.     Treatment Technology  Selected for Treatability Testing

2.1.   Treatment  Category (i.e., Thermal Destruction. Physical  Chemical'r
Biological.  Solidification/Stabilization)

      Thermal destruction

2.2.  Criteria for Technology Selection

      In-house technology or technology provided by a vendor.  Vendor  name.
Reason for selection.

      The CBC is  in-house technology.  The  CBC technology for hazardous
waste  was developed  by GA  Technologies,  Inc.  (GA).   GA and Ahlstrom  of
Finland formed Pyropower  Corporation in 1980 to supply CBCs for the  U.S.
boiler market.   Pyropower and Ahlstrom have many  CBC  units  installed  and
operating worldwide burning a variety of fossil fuels, biomass and wastes.
OES has a licensing agreement to use the same CBC  technology to  develop and
build hazardous waste  incinerators.   Also,  the 2 million Btu per hour CBC
facility  and  the key  CBC  program  personnel were transferred  to Ogden
Corporation as OES in  December  1986, and OES continues to develop  the CBC
technology for hazardous waste destruction.

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2.3.  Process Description, Requirements and Limitations

      The process description is given below.

Requirements

      Requirements for operations vary depending upon the CBC  size  and  feed
type.  An example is  given below for the 36-inch diameter CBC, the largest
transportable version.   Note:   ~10 MM  Btu/hr  .  .  .  hazardous waste
treatment CBCs are available  in  sizes  from ~16-inch diameter  (2 MM Btu/hr)
to ~120-inch diameter (50 MM Btu/hr).

                     36-inch CBC  Operating Requirements
     o   Temperatures

     o   Thermal Rating
     o   Auxiliary Fuel Required (if no
          heat value of feed)
     o   Electricity (connected)
     o   Water

     o   CBC Area
1AOO°F to 1800°F (normal
 range)*
10 MM Btu/hr
10 therms/hr
250 kva
None (closed loop cooling
 system)
50 x 50 feet
Limitations

     Feed limits  for solids are  ~l-inch ring size on  the largest feed
input.    Liquids/sludges  must  be  pumpable.    Ash melting  limits
(glass-formers) in feed materials vary depending upon application.
     Higher than 1800 F  temperatures  can be accommodated  in the CBC but
     have not been necessary to achieve the desired waste destruction.

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 Typically, several wtJ of low-temperature «1600 F) melting material can be
 handled without special procedures.  We have developed procedures to handle
 >30 wt% glass-formers.

 Process Description

     The CBC is a complete, self-contained thermal process plant capable of
 destroying, through combustion, hazardous components of various contami-
 nated  solid  feedstocks.   It will produce inert  by-products  that satisfy
 federal, state, and local regulatory requirements.

     Commercial units  in  Europe and the U.S.  are designed to burn  a wide
variety of fuels  such as  coal, peat, wood  wastes,  municipal wastes,  and
oil, primarily for the purpose  of  raising steam or generated electricity.
Application of  this  process  to the treatment  of hazardous wastes was
developed in the US since 1980 (Ogden Environmental Services, Inc. acquired
this technology in December 1987 from GA Technologies, Inc.).

     The CBCs process  advantages are derived  principally from   (1) the
extremely high fluidizing velocities and the resulting intrinsic turbulence
and  (2) the recirculation of solids to the  combustion chamber.

     The ability of  the  CBC to efficiently destroy organic waste at low
combustion temperatures and low excess  air levels without  an afterburner
results in very high waste processing rates for given-sized hardware.  With
typical operating  conditions, the  CBC  system  can handle a  maximum soil
                               2
waste  throughput  of  1100 Ib/ft  of combustor  cross section and  requires
only  850  Ib/h/ft   of  combustion  air.   This  specific  throughput is
significantly higher than  can  be obtained using other  incineration
technologies.  Thus, CBC  units  do  more  work than other equivalently sized
incinerator types.

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Major Equipment Components and Function

     The  primary  CBC components are the combustion  chamber,  hot  cyclone
collector, flue gas cooler, baghouse, and stack.  Auxiliary systems include
feeders  (solids,  liquids,  sludges),  forced-draft and induced-draft fans,
ash  conveyor,  compressed air, cooling  tower,  and building ventilation.
Figure 2-1.1 is a schematic representation of the process.

     Atmospheric  primary air is  pumped into the  lower  portion of the
combustion chamber where the  bed  material  is fluidized by  turbulent mixing
of the air  and solids.  Larger solids  gravitate downward  to  form a more
dense fluidized bed in the lowest combustor zone.  The forced-draft primary
air carries smaller solids up to the top of the combustor.

     Secondary  air  is supplied to  various locations in the  combustion
chamber to  ensure complete combustion and minimize  formation of  nitrogen_
oxides (NO ).
       v  x'

     Auxiliary fuel and  pressurized contaminated soil feed are individually
introduced into the  lower  combustion chamber.    Capability also exists  to
feed liquid  wastes.   Dry  limestone  sorbent  is added to control  gaseous
emissions of sulfur, phosphates, chlorines, or other halogens.

     Elutriated solids are separated from the flue gas by  a hot cyclone  and
reinjected into the lower combustor using a proprietary nonmeehanical seal.
Ignition, burning,  and  reaction  of the  fuel,  contaminated soil  feed,
sorbent,   and ash components  are a  continuing  chemical process  which
destroys th« hazardous wastes.

     The loop design is  such  that essentially  all of the pollution control
occurs  in the combustion loop itself.   Efficient mixing of the fuel, soil
feed, and combustion  air assures  that  all hazardous organic  constituents
are oxidized with minimum emissions  of both CO and  NO  .   Flue gas wet
scrubbers are not required.
                                     10

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                                                                 CO

                                                                 0)
                                                                f.
                                                                 u
                                                                 (fl

                                                                CJ
                                                                ea
                                                                 i
                                                                CM
                                                                 00
                                                                -^
                                                                fa.
11

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     The  high velocity  of  combustion-air  and  circulating  solids  creates  a
uniform temperature  (^50 F)  around  the  combustion  loop which  is  controlled
at  a  value  between 1400 F and 1800 F.  Residence  times  in the combustor
range  from  about  2 seconds  for gases to  about  30  minutes  for solid feed
material  (less than 1.0-inch ring size).

     During operation, ash is periodically removed from the CBC by means  of
a water-cooled  ash removal system.   The  hot  gas  leaving the cyclone is
cooled  in a  flue gas  cooler;  the  fly ash  escaping  the cyclone  is
continuously  collected  by baghouse  filters.   These filters  reduce the
particulate loading in  the  flue  gas from  as high as  130  to 0.01  grains/scf
(the EPA  RCRA particulate  emission  limit  is  0.08  grains/scf).  The fabric
filters are  acid-resistant  and  normally  operate   at temperatures  up to
350 F.  No post-treatment of the dry, inert ash is necessary.
CBC Advantage

     The  extreme  turbulence and high  recirculation rates of  the  solids
within the combustor make the CBC combustion process relatively insensitive
to feed properties.  The 100-to-l ratio of hot-inert-solids-to-feed and the
high internal  combustor heat transfer ensures that moisture  in  the waste
feed rapidly evaporates with little (if  any)  depression in local combustor
temperature.   The  only significant  effect  of  feed  moisture  on the
incineration process  is on the combustor energy  overall heat balance.
Energy that would otherwise  go to processing contaminated soil must be used
to evaporate water (as with  any thermal system).

     The CBC is insensitive to  large amounts  of fines in the  feed stream.
Feed fines  benefit the  solid circulation that  produces the  isothermal
combustor conditions.

     The  turbulence  in  the CBC atomizes liquid  waste feeds,  thereby
eliminating the need for troublesome spray nozzles which could  clog.  The
bed effectively disperses viscous sludges.
                                     12

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      The  acid  gases formed by chemical reactions are rapidly absorbed by
 the  large surface area of fine circulating sorbent (such as limestone or
 other inexpensive local sorbent).   The  intermediate  reactions form the
 final ash products  of benign salts  such as  CaCl   and CaSO,.  The rapid
 combustion  of  the flue gas  and  quick neutralization of the acid gases
 within  the  combustion chamber are in contrast to other incinerator types
 that  rely on afterburners  to complete combustion and add-on scrubbers to
 complete  acid gas capture.

      Avoiding  the requirement for  a wet scrubber  not  only simplifies
 operation of the incinerator  and avoids acid gas  attack  of internals
 between the  combustor and  the scrubber,  but also completely eliminates
 aqueous waste streams.

     Two  features of  the CBC make it much more energy-conserving in soil
 decontamination applications.  The  first derives  from the  CBCs  ability co-
 destroy contaminants  in a  temperature range of 1400  to  1800 F  -  several
 hundred degrees lower  than required  in other types  of incinerators.   This
 ability to clean up soil without heating it to highly elevated temperatures
 greatly reduces the  amount  of auxiliary fuel required  in  the CBC versus
 other types of incinerators.

     The  second feature of  the CBC that  conserves energy is the  very  low
 excess air  required  in the destruction of  contaminants.   Because of the
 highly turbulent  bed  and intimate contact  between the contaminated solids
 and air,  the CBC  operates  in the  range  of 201 to 40Z excess air.   This
 compares  to several hundred  percent excess air  in  a rotary kiln,  for
 example, where most of the  air bypasses  the soil  without reacting with it.
Although much of the air bypasses the soil,  it still picks up heat from the
 rotary kiln  and makes  necessary  additional auxiliary fuel  to replace  this
 lost heat and additional water flow  to cool  the bypass air.

     When an upset occurs  in a CBC (e.g.,  fan failure,  power outage, etc.)
the bed material  slumps into the lower combustion chamber,  thus  retaining
pollutants  in  the limestone  and ash.   In  contrast,  the  conventional
                                     13

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bubbling  bed  is not easily  slumped  because  lower velocities invite bed
agglomeration.   When a  scrubber  is  involved,  as for kilns  and  grate
incinerators, scrubber bypass is required in an upset.  Scrubber bypass can
release large amounts of untreated pollutants.

     The  key  CBC  components,  the combustor,  provides these  benefits
inherently  and  automatically,  without  complicated   controls.   Other
components  (pumps, fans, etc.)  are standard  hardware.  Scrubbers  or other
chemical  treatment equipment are  unnecessary.   The innovation represented
by the CBC  is  in the total system, i.e.,  in  the arrangement  and particular
function  that  has  been designed into the incinerator using  this standard
hardware.

2.4.  Rate of Process and Length of Treatment Time.

     The  largest  transportable 36-inch CBC  will process  soils at  up  to _
12,000 Ib/hr on  a  24-hour  per  day,  7-day per week basis.   The system will
also process  contaminated  sludges and  liquids  concurrent with soils  or
separately.

     Length of treatment time is interpreted as residence time of materials
at temperature  in  the  CBC  combustion loop.   There  is a minimum  "gas"
residence time and longer residence for solids as described below:

Gas Residence Time

     The gas residence  time is controlled by the  superficial  velocity in
                                                                       Q
the combustion chamber,  and is approximately 2.5  to  3 seconds  at  1600 F.
Exact operating  conditions  are  selected based  on test and  trial  burn
results to meet  or exceed  all  requirements.   Upon leaving the combustor
loop, the  gas  flows  through the  flue gas cooler  where it  is cooled  to
350 F,  over  * 6  second time  interval.   The gas temperature  remains
essentially constant throughout  the rest  of  the  system,  with  about
                                                      /
3  seconds passing before discharge to the atmosphere.
                                     14

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     The  gas  residence time  (at  1600 F)  calculation is  summarized as
follows:
Component
Combustion chamber
Chamber to cyclone
Cyclone
Cyclone to FGC
Length
(ft.)
35
12
20
24
Velocity
(ft./s)
20
50
50
50
Time at
1600°F
(seconds)
1.75
0.24
0.40
0.48
                                                               2.87
Solids Residence Time
      Due to extensive backmixing and solids recirculation in the CBC, the
solids residence time at operating temperature  is much greater than for the
gas.   While this residence time is dependent on particle size and attrition
rates, on  average  the bed  is  replaced  about twice per  hour.   Thus, a
typical  solid  residence time  is  about  30  minutes.   Solids  leave  the
combustor  through  either  the bed ash discharge or the gas  exit  in the
cyclone.    Solids in  the gas stream  are  cooled  along with the gas, and are
separated  in the baghouse.   Bed ash is  transferred by a water-cooled  screw
conveyor, taking about 30 minutes to cool from operating temperature to the
cool ash temperature.

      Not* that  even very  finely divided  solids have a reasonably  long
system residence time due to the solids  recirculation.

2.5.   Material  Handling Equipment Requirements  (i.e.. Material  Transport
and Excavation)
      Solids material  transport  to  the  36-inch  diameter CBC  on  a
remediation site typically involves  loading  a  solids  feed hopper once per
                                     15

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 day  from  a  large  storage pile or  excavation  area using a front-end loader.
 From the  solids feed hopper, the solids are activated and fed automatically
 by mechanical feeders.

      Sludge/liquid material transport involves pumping out of a surge tank
 and  feeding  directly  into the CBC.   The  surge  tank may be  sized to receive
 daily, weekly or other periodic loads from the site.

      Excavation  equipment requirements vary  depending  upon  the  site.
 Standard  loader/excavators may be used on  soils  sites with digs up to 40'
 deep.  Special equipment (and/or  shoring,  etc.) may  be required for deeper
 excavations.

 2.6.   Pretreatment  Requirements  (i.e.,  Oversize  Material.  Removal,
 Disaggregation, Sorting,  Dewatering,  Chemical/Physical Treatment,  Control
 of Volatile  Release,  Control  of  Particulate  Release) Description Criteria
 for Application

      A solids size maximum of 1-inch ring size.  Pumpable liquids/sludges
 need no  pretreatment (filtering, etc.)  because there are no atomizers
 required on the CBC.  Dewatering of liquids stream is not necessary for the
 process (dewatering may be an economic benefit).  Some oversized impervious
materials such as  metal parts may  be washed and the surfaces  certified
 clean of  contamination.   The  contaminated wash material  would  then be
 incinerated in the CBC.

      Volatile and particulate release in  pretreatment is  minimized  due to
 the  minimal  pretreatment  required  for  CBC  feeds.   Fugitive dust/vapor
 control  for  screening/shredding/crushing  and  solids handling  typically
 requires  simple  dust enclosures.   Negative pressure systems or  spray
wetting systems may be  added  in   some cases  as necessary.  Volatile  vapor
 control is required  usually only if  thermal pretreatment  (dewatering)  is
 used.  This volatile  vapor control  would involve drawing  hazardous vapors
 through the inlet fans of the combustor  or alternatively absorbing vapors
                                     16

-------
 on  activated carbon  or condensing  the  vapors and  then burning  the
 contaminated residues.

      Criteria  for  application  of these  pretreatment requirements may be
 summarized as:

      o  Oversize Solids >1" - Screen, Crush - Dirt,  rock,  etc.,  1" to A"
                               Screen, Shred - Metal, wood,  paper,  fibre,
                                etc., 1"  to 4"+
                               Screen, Wash - Metal,  rock,  selected others
                                A"
      o  Dewater - If economics show favorable
      o  Volatile and To meet local, state and Federal standards
         Particle Control -(may include insitu monitoring)

 2.7.  Post-Treatment Requirements.  Description.  Criteria for Application

      Residuals  from  the CBC include dry cementitious  (pozzulanic) ash.
 This ash in site soils cleanups would include inert soils and limestone and
 lime salts  of  chlorine, sulfur and  other solid lime-absorbed materials.
 Tests on RCRA and TSCA materials  indicate such low organics levels in the
 ash  residue  that the ash  residue may be either delisted  (RCRA) or
 non-regulated (TSCA).

 2.8.   Byproducts and  Other Process  Effluent.   Type.  Quantities, and
 Concentrations.  Environmental Controls

      Th« off-gas is primarily  CO.,  0.,  N  and H.O vapor.  CO and NO  are
 typically <150 ppm and HC1  and  unburned HC (total) are  typically <100 ppm.
 Offgas particulate is «0.08 grains per acf as controlled by a baghouse.

      The baghouse  flyash and bedash are dry solids.  These  solids  are
primarily silica sand  and lime and lime  salts  (CaCl. or CaSO^)  since dry
 limestone is injected into the combustor  to capture  acid gas formers before
they leave the  combustor.   The resultant ash  is  a very  low leachable
cementitious (pozzularius) dry powder.  No wet scrubber sludge is  produced.
                                     17

-------
2.9.  Monitoring and Data Collection Requirements (i.e., QA/QC Protocols)

      Modified Method 5, VOST, (SW846 methods) solids sampling and analysis
procedures  (methods, chain-of-custody) as approved by EPA have been used to
obtain  the  data  supporting the CBC TSCA permit  for  PCB and the CBC HDD
permit  for  RCRA compounds.

3.0.  Treatability Test

3.1.   Scale Used  for  Testing (i.e.. Bench.  Pilot,  Full) and  Scale-up
Limitations

      A  16-inch  diameter commercial-scale unit  was  used for test work.
There are no scale-up limitations as already demonstrated by demonstrations
in this  commercial-size test  rig  as  applied to other  larger commercial
units burning varied solids/liquids whose bed cross-sections are many feet.
The data from the  16-inch  rig has  been basically the same as  in the  larger
rigs with no scale-up surprises.

3.2.  Number of Tests Conducted Under Variable Conditions.  Test Results in
a Summary Table Showing Both Operating Conditions and Performance Results

      There have been  over 5,000 test hours logged  in  the pilot plant  on
various non-hazardous and hazardous feeds.

      Two key  examples of  test  data on  hazardous  feeds are given in
Tables 3.2-1 and 3.2-2 for the TSCA  PCB  test and the  RCRA  liquids  test
(California Air Resources Board), respectively.

      See also Appendix A for more details on the PCB test for  TSCA.
                                     18

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3.3.  Performance Evaluation (i.e.. Removal Efficiency).   Could Performance
be  Improved?   Hov?   (Operating  Conditions  Change, Additional Pretreatment,
etc. )
      Performance improvements are centered only in maintaining consistent,
reliable  and  optimum feed  rates  of  sorbent (limestone) solids  and  the
contaminated  solids  and  liquids  feeds.  The CBC turbulence and  residence
time have  demonstrated well above the  required  DREs at temperatures  which
are much lower than other incinerators.

4.0.  Processed Residual

A.I.   Physical  Chemical  Characteristics and Analysis, Volume  Increase  or
Decrease

      The  dry ash produced  has been  well below  TSCA standards  for  PCB  (see
Appendix A) and  has  been at  delistable levels, if  such  delisting were
appropriate, for RCRA materials.

      Volume decreases of  over  20 to  1  have  been noted for some low-ash
liquids/sludges.  Volume stays essentially constant for contaminated soils.

4.2.  Regulatory Test  Protocol  Results  (i.e..  EP  Toxicity,  TCLP.  etc.).
Specify Test Performed

      Organics have been quantified  for PCB as given in Appendix A.  Metals
leachability tests have not been performed, though there have been perti-
nent studic* on fluoride leachability.

4.3.  Residual Disposal Method Used.  Reasons for Selection

      Pilot plant ash is either  returned to the test customer or sent to a
Class I facility under contract to the  test customer.  Though  the  ash  could
be delisted, the volume (a  few drums) are too small.
                                     21

-------
4.4.   Cost Requirements  (Per  Unit  of Time and Unit  of Mass of Waste
Treated)

      Costs depend  upon the size  of combustor and  the type of feed.
Examples of CBC treatment costs on varied moisture content  soil  for  36-inch
and 104-inch diameter CBCs are  given below:
Soil
Moisture
Z
10
16
30
Total
36-inch CBC
117
131
166
5/t
104-inch CBC
78
84
98
4.5.  Permit Requirements (Type of Permit Required,  Used)

     The following 5  permits  have been obtained for the pilot plant CBC:
(1) EPA-TSCA transportable  PCB incineration permit -  the first for all
10 EPA  regions;    (2) EPA-RCRA RD&D permit,  the first in  California;
(3) California Department  of  Health Services RD&D  Permit (Draft)  . .  .
(also, a Mitigated Negative Declaration of no  significance environmental
impact under the California Environmental Quality Act);   (4) San Diego Air
Pollution Control District  Permit including a  hazardous  emissions  impact
assessment, and;  (5) San Diego Industrial User Discharge Permit.

     The commercial CBCs  (nonhazardous  fuels) have  obtained air permits in
"nonattainment)" areas such as Bakersfield and Colton, California.
                                     22

-------
                           APPENDIX A
             PCB-CONTAHINATED SOIL TREATMENT IN A
            TRANSPORTABLE CIRCULATING BED COMBUSTOR
(Paper present to the Hazardous Materials Management Conference
and Exposition at Anaheim, California, April 29 - May 1,  1986.)

-------
OGDEN
ENVIRONMENTAL SERVICES, INC,
  PCB-CONTAMINATED SOIL
  TREATMENT IN A TRANSPORTABLE
  CIRCULATING BED COMBUSTOR
  by

  D. D. JENSEN
  Staff Scientist

  D. T. YOUNG
  Manager, Combustion Projects
  Presented at
  Hazardous Materials Management
  Conference and Exposition
  Anaheim, California
  April 29 - May 1. 1986
  OES was formerly the Hazardous Waste Management Division
  of GA Technologies Inc.

-------
                 PCS-CONTAMINATED SOIL TREATMENT IN A
             TRANSPORTABLE  CIRCULATING BED COMBUSTOR
                                           by
                      D. D.  Jensen, Ph. D.  and  D. T.  Young


                                GA Technologies Inc.
                                San Diego,  California
               ABSTRACT

    A trial burn of PCB-contaminated soils was
completed in  GA Technologies' transportable
Circulating Bed Combustor  (CBC). Over 4000
pounds of soil containing 1% PCB were treated
in three identical 4-hr runs at 1800°F. The re-
sults showed excellent compliance with U.S. En-
vironmental  Protection Agency (EPA) Toxic
Substances Control  Act (TSCA) requirements.
Destruction and  removal  efficiencies (DREs)
were greater than 99.9999% and PCB in com-
bustor ash was less than 200 ppb. No chlorinated
dioxins or furans were detected in the stack gas,
bed ash, or fly ash. In addition, no significant
concentrations of other Products of Incomplete
Combustion (PICs) were detected.  Combustion
efficiencies were greater than 99.9%, with CO
concentrations less than 50 ppm and  NOX  con-
centrations less than 75 ppm. Particulate emis-
sions were generally below 0.08 grain/dscf and
HC1 emissions were maintained below 4.0 Ib/hr
by introducing limestone directly into the com-
bustor. These results led to the first TSCA per-
mit for a transportable incinerator which can
be used in all ten EPA regions. This demon-
strates that the CBC is an environmentally ac-
ceptable means of treating  contaminated soil
containing PCB and other  organic wastes. In
addition,  the high thermal efficiency, the  ab-
sence of afterburners or scrubbers, and the use
of simple feed systems make  CBC treatment
competitive with soil removal and  transport to
landfills and other potential treatment/disposal
options.
            INTRODUCTION

    Polychlorinated  biphenyls, or PCBs, have
perhaps received more scrutiny than any other
hazardous chemicals found in waste sites around
the country. This group of 209 synthetic chlor-
inated organic compounds found wide use" as a
dielectric fluid  in utility transformers and ca-
pacitors, and as a high-temperature heat trans-
fer medium (1). However,  because of their ex-
ceptional  resistance to  degradation in the
biosphere and apparent toxicity, the manufac-
ture and sale of PCBs were banned in 1976 for
virtually all purposes. The control, treatment,
and disposal of PCBs was mandated by TSCA
and is currently handled through EPA's Office
of Toxic Substances.

    Until recently, it has been common practice
to remove contaminated soils for burial in a se-
cured landfill. However, this option is becoming
less desirable as landfill costs escalate, the num-
ber of available landfill sites drop, and gener-
ators or potential responsible parties (PRPs)
become increasingly aware of retained liability
associated with the contaminated soils, even  in
a secured landfill. Treatment of PCB-contami-
nated soil by incineration in the CBC can elim-
inate or significantly reduce the potential lia-
bility of generators or PRPs at a cost competitive
with landfill prices.

    The use of CBC technology for hazardous
waste treatment  builds on over 15 years expe-
rience at GA in  the design, development, and

-------
operation of fluidized bed combustors. In 1980
GA and Ahlstrom of Finland formed Pyropower
Corp(2000°F).
                                         TABLE 1
                            CIRCULATING BED TEST RESULTS
       Waste
   Form
Desctruction
Efficiency, %
   HC1
Capture, %
Ca/Cl2
 Ratio
Carbon Tetrachloride
Freon
Malathion
Dichlorobenzene
Aromatic Kitrile
Trichloroethane
Liquid
Liquid
Liquid
Sludge
Tacky solid
Liquid
    99.9992
    99.9995
  > 99.9999
     99.999
  > 99.9999
    99.9999
   99.3
   99.7

     99

     99
  2.2
  2.4

  1.7

  1.7

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              COMBUSTOR

            LIMESTONE
            FEED
	,    FLUE GAS
 -*-      1  XrnniPR
      SOIL
      FEED
                                                             FLUE GAS
                                                              (DUST)
                                                              FILTER
                                                                               STACK
           FD
                                           COOLING
                                           WATER
                                ASH
                                CONVEYOR
                                SYSTEM
          Fig. 1. Schematic flow diagram of circulating bed combustor for soil treatment
           TEST DESCRIPTION

    A variety  of  requirements  are imposed
prior  to and during a PCB trial burn (2). The
key target of a trial burn is to ensure that PCB
DREs are > 99.9999% at  the operating condi-
tions chosen for the incinerator. In addition, the
concentration of PCB in ash from the unit must
not exceed 2 ppm. The potential formation of
PICs is also carefully evaluated, with particular
attention  given to polychlorinated dibenzo-p-
dioxins (PCDDs) and polychlorinated dibenzo-p-
furans (PCDFs). The combustion efficiency of
the unit must be >99.9% and particulate emis-
sion must not exceed 0.08  grain/dscf.

    The CBC trial burn was carried out in GA's
transportable  unit, shown  in Figure 2. Soil
treated in the test was obtained from a former
chemical processing site known to contain pock-
ets of PCB up  to 6000 ppm, as well as  other
organic and inorganic wastes. In order to ensure
that the CBC would  be permitted to treat all
likely site concentrations of PCB, uncontami-
nated soil from the site was "spiked" with liquid
PCB to 10,000 ppm. Spiking was carried out by
blending a 50:50 commercial mixture of  PCB
     "1248" and  trichlorobenzene with  a ribbon
     blender in 1000 Ib lots. Approximately 4000 Ib
     of soil was spiked for the three burns required
     by the TSCA trial burn permit.


         While the CBC was maintained  at 1800T
     using natural gas as the auxiliary fuel, several
     barrels of clean site soil were introduced into
     the  CBC  prior to the addition of spiked soil.
     During this time all operating parameters and
     system components were confirmed to be in the
     required operating ranges. Process parameters
     monitored included:
            Temperature around the loop
            Pressure drop  across the loop
            Soil feed rate
            Primary air flow
            Secondary air  flow
            Loop seal air flow
            Total air flow
            Methane flow
            CO concentration
            COo concentration
            Excess oxygen level
                 concentration.

-------
Fig. 2. Transportable 16-inch circulating bed combu?tor

-------
     Spiked soil was pneumatically transported
to a bunker and screw feeder. Soil feeding, lime-
stone addition,  and stack gas monitoring were
started simultaneously.  An  EPA Modified
Method 5 sample train  (3) was used to sample
stack gas emissions. In addition, a separate Vol-
atile Organic Sampling Train (VOSl)  (4) was
used to sample  for volatile organic PICs. Feed.
bed ash, and fly ash samples were also gathered
throughout the test (see Figure 1 for sample port
locations). Three identical tests of  spiked soil
(4 hours each) were carried out over two days
in late May 1985. Each test was observed and/
or audited by EPA personnel or representatives.
All feed, ash, and stack gas samples were sub-
sequently analyzed for  PCBs, PCDDs,  and
PCDFs. Fly ash. bed ash. and stack gas samples
were also analyzed for other PICs (both volatile
and semivolatilei. Stack gases were analyzed for
fly ash and chloride release as well.

                RESULTS

    Table 2 presents a  summary  of the trial
burn operational data and test  results gathered
during the tests. Near-identical conditions were
maintained for each of the tests. In each case
PCB DREs were well in  excess of the EPA-re-
(juired 99.99997,. PCB concentration in the bed
ash and the fly ash did not exceed 200 ppb. No
PCDDs or PCDFs were detected in the stack gas,
bed ash, or fly ash. Combustion efficiencies were
                                         TABLE 2
               PCB TRIAL BURN OPERATIONAL DATA AND TEST RESULTS
Parameter
Test Duration, hr
Operating Temperature, °F
Soil Feed Rate, Ib/hr
Total Soil Feed, Ib
PCB Concentration in Feed,
ppm
DRE, 5,
PCB Concentration
— Bed Ash, ppm
— Fly Ash, ppm
Dioxin/Furan Concentration
— Stack Gas, pp
— Bed Ash, ppm
— Fly Ash, ppm
Combustion Efficiency, %
Acid Gas Release, Ib/hr
Particulate Emissions,
grain/scf (dry)
Excess Oxygen, %
CO, ppm
C02, %
NOX, ppm
TSCA
Requirement
-4
—
—
—


> 99.9999

<2
<2

_
—
—
>99.9
<4.0
3.0
—
—
—
1
4
1800
328
1592
11,000

99.999995

0.0035
0.066

ND(a)
ND
ND
99.94
0.16
0.095(b)

7.9
35
6.2
26
Test Number
2
4
1800
412
1321
12,000

99.999981

0.033
0.0099

ND
ND
ND
99.95
0.58
0.043

6.8
28
6.0
25
3
4
1800
324
1711
9,800

99.999977

0.186
0.0032

ND
ND
ND
99.97
0.70
0.0024

6.8
22
7.5
76
(a'ND - Not detected.
(b)Derived from 2-hr makeup test.

-------
greater than 99.9^ and acid gas release was well
below  the required 4 Ib/hr. Particulate emis-
sion? were generally less than the required O.OS
grain/d>cf. Only the grain loading from the first
test, obtained from a 2-hr makeup test after the
completion of Tests 1 through 3, showed  a value
slightly higher than the limit. This is attributed
to off-normal  process conditions for  the bag-
house, i.e., excessive blowback air pressure along
with a higher-than-normal number of  blowback
cycles. Nitrogen oxides and CO levels  remained
low as a result of the staged combustion utilized
in the CBC  and the relatively low combustion
temperature (1800°F).  These results demon-
strate that  the CBC is an effective  mean? to
destroy PCBs contained in a soil matrix, without
the need for high temperatures, afterburners,
or wet scrubbers. In particular,  the absence of
undesirable  combustion byproducts helps en-
sure that effective treatment of soil can be ob-
tained in an environmentally acceptable manner.

     These results confirm the design of GA's
transportable CBC shown in Figure 3. The com-
bustor  and all other plant  components are de-
signed  as  modular units which can be trans-
ported by truck or rail. These units are assembled
at the site into an operating unit  in four to six
weeks. The major components of this CBC plant
include  the  combustor loop, feed  system, and
pollution control  and air induction equipment.
GA's 30-inch transportable CBC  is capable of
processing up to 4 t/hr of dry soil on a 24-hour
basis, requiring an operating crew of only two
persons per  shift. Soil treatment  costs may bi'
as low  as $100/ton for a large site. For smaller
site? or sites having unique treatment require-
ments, costs may approach "$400/ton.
                               STACK
                COMBUSTION
                CHAMBER
                CYCLONE
                INDUCED
                DRAFT FAN
                SOLIDS
                FEED
                                                                FLUE GAS
                                                                COOLER
                                                                        BAGHOUSE
                                                                        FLY ASH
                                                                        CONVEYOR
                COMBUSTOR
                ASH REMOVAL
                       FORCED
                       DRAFT
                       FAN
                  Fig. 3. Isometric of site-assemblied circulating bed combustor

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              CONCLUSION

    The results  of the PCE soil trial burn in
GA's CBC demonstrated compliance with EPA
TSCA requirements. The CBC is now one of only
seven incinerators nationwide permitted to burn
PCB. and one of  only two permitted transport-
able incinerators, the other being the EPA ro-
tary kiln. It i? the first transportable incinerator
to be  permitted  in all ten EPA  regions. Stack
emissions from the CBC are well  within regu-
latory requirement? and residual PCB in bed ash
and fly ash is well  below regulatory require-
ments. The superior thermal efficiency, high
throughput, and small staffing requirements of
the CBC provide  a soil treatment option that is
cost competitive with landfill disposal while at
the same time reducing overall  liability of the
generator or PEP.
              REFERENCES

1.  SCS Engineers,  Inc.. "PCB Disposal Man-
   ual," Palo Alto. C.A: Electric Po\\er Research
   Institute. Report No. CS-409S, June 19S.r>

2.  'Tolychlonnated  Riphcnyls tPCBs' Manu-
   facture.  Processing.  Distribution in Com-
   merce and Use Prohibition," -10 CFK 701.To.

u.  "Test Methods for Evaluating Solid Waste."
   U.S. EPA Report SW-NJG, 2nd  Edition, 1HS4.

4.  "Proposed Sampling and Analytical Meth-
   odologies for Addition  to Test Methods for
   Evaluating Solid  Waste: Physical/Chemical
   Methods (SW-84G. 2nd  Edition)," U.S. EPA
   Report PB55-103026, 19S4.

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