&EPA
            United States
            Environmental Protection
            Agency
         Industrial Environmental Research
         Laboratory
         Cincinnati OH 45268
EPA-600/9-83-003
Apr. 1983
            Research and Development
Incineration and
Treatment of
Hazardous Waste:

Proceedings of the
Eighth Annual
Research Symposium

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                                                     EPA-600/9-83-003
        INCINERATION AND TREATMENT OF HAZARDOUS WASTE
    Proceedings of the Eighth Annual Research Symposium
        at Ft. Mitchell, Kentucky,  March 8-10,  1982
Sponsored by the U.S. EPA,  Office of Research & Development
        Municipal Environmental Research Laboratory
        Solid and Hazardous Waste Research Division
                            and
        Industrial Environmental Research Laboratory
           Industrial Pollution Control Division
                Edited by:  David W. Shultz

               Coordinated by:  David Black

               Southwest Research Institute
                San Antonio, Texas  78284
                  Contract No. 68-03-2962
                      Project Officer

                     Laurel J. Staley
        Industrial Environmental Research Laboratory
           Industrial Pollution Control Division
                  Cincinnati, Ohio  45268
        INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY
            OFFICE OF RESEARCH AND DEVELOPMENT
           U.S. ENVIRONMENTAL PROTECTION AGENCY
                  CINCINNATI, OHIO  45268

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                               DISCLAIMER

     These Proceedings have been peer reviewed by the U.S. Environmental
Protection Agency arid approved for publication.  Mention of trade- names or
commercial products does hot ednstitiite endorsement or recommendation for use.
                                   ii

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                                FOREWORD
     When energy and Material resources are extracted, processed, converted,
and usecl*. the related polltitional impacts on our environment and even on our
health often require that new and increasingly more efficient pollution control
methods be used.  The Industrial Environmental Research Laboratory .- Cincinnati
(lERL-Ci) assists in developing and'demonstrating new and improved methodologies
that will meet these needs both efficiently and economically*

     This report presents the results of completed and on-going research con-
cerning the incineration and treatment of hazardous wastes.  The information will
inform those who own* operate, design, or regulate hazardous waste incineration
and treatment facilities of current government-sponsored research in this area.
For further information on this subject, interested parties should contact the
Incineration Research Branch, Industrial Pollution Control Division, Industrial
Environmental Research Laboratory, USEPA, Cincinnati, Ohio 45268.
                                    David G. Stephan
                                    Director
                                    Industrial Environmental Research
                                      Laboratory
                                    Cincinnati, Ohio
                                   iii

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r
                                               PREFACE

                   These Proceedings are intended to disseminate up-to-date information on
              extramural research projects concerning land disposal, incineration, and
              treatment of hazardous waste.  These projects are funded by the U.S. Environ-
              mental Protection Agency's Office of Research and Development and have been
              reviewed in accordance with the requirements of EPA's Peer 'and Administrative
              Review Control System.

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   .,.-.,                    ABSTRACT                    .    . .

     The Eighth Annual Research Symposium on land disposal,  incineration
and treatment ,of hazardous wastes was held in Ft. Mitchell,  Kentucky,  on
March 8, 9, arid 10, 1982.  The purposes of the symposium were (1) to provide
a forum for a state-of-the-art review and discussion of ongoing and recently
completed research projects dealing with land disposal, incineration,  and
treatment of hazardous wastes; (2) to"bring together people concerned with
hazardous waste management who can benefit from an exchange of ideas and
information; and (3) to provide an arena for the peer review of the Solid
and Hazardous Waste Research Division's and the Industrial Pollution Con-
trol Division's research programs in hazardous waste management.  These
Proceedings are a compilation of papers presented by the symposium speakers.

     The symposium proceedings are being published as two separate documents.
In this document, Incineration and Treatment of Hazardous Waste, six tech-
nical areas are covered.  They are as follows:

     (1)  Hazardous Waste Incineration Overview
     (2)  Incineration of Hazardous Waste in High-Temperature
            Industrial Processes
     (3)  Laboratory and Pilot Scale Incineration Research and
            Development
     (4)  Incinerator Process Management
     (5)  Advanced Hazardous Waste Treatment and Control Technology
     (6)  Specialized Hazardous Waste Incineration Techniques
                                     v

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                              TABLE OF CONTENTS

                                                                           Page
Foreword	,	iii

Preface.	   iv

Abstract		    v


            SESSION B.  HAZARDOUS WASTE INCINERATION AND TREATMENT


B-l.  Hazardous Waste Incineration Overview

Profile of the Hazardous Waste Incinerator Manufacturing Industry
     Irwin Frankel, Neil Sanders and Greg Vqgel
     The MITRE Corporation	......	    1

Hazardous Waste Incineration Costs
     Gregory A. Vogel, Irwin Frankel and Neil Sanders
     The MITRE Corporation 	   14

Using Uncertainty Analysis to Estimate the Cost of Hazardous Waste
Incineration
     Haynep C. Goddard, U.S. Environmental Protection Agency .......   22

An Assessment of Emissions from a Hazardous Waste Incineration
Facility
     L. j. Staley, U.S. Environmental Prqtection Agency
     G. A. Holton, F.R. O'Donnell and C. A. Little
     Oak Ridge National Laboratory	, ,	   31

Characterization of Hazardous Wastes Generated by the Pesticide
Manufacturing Industry
     Bruce A. Tichenor, U.S. Environmental Protection Agency 	   41

Overview of Industry Studies Program
     Francine S, Jacoff, U.S. Environmental Protection Agency. ......   45

The Industry Studies Program:  Synthetic Organic Chemicals Industry
     Ronald J. Turner and Robert A. Olexsey
     U.S. Environmental Protection Agency. . . . .	   47
                                     vii

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                        TABLE OF CONTENTS (Cont'd)
                                                                          Page
The Industry Studies Program:  The Organic Dyes and the Organic
Pigments Industry
     Robert Olexsey and Yvonne M. Garbe
     U.S. Environmental Protection Agency	   53

Incineration Technology for Selected Small Quantity Hazardous Waste
Generators
     Victor S. Engleman and D. L. deLesdernier
     Science Applications, Inc.
     Sidney F. Paige, JRB Associates 	   56

Hazardous Waste Control Technology Data Base
     Richard L. Holberger, The MITRE Corporation
     Dr. C. C. Lee, U.S. Environmental Protection Agency	   63


B-2.  Incineration of Hazardous Waste in High-Temperature Industrial Processes

Overview of the Concept of Disposing of Hazardous Waste in
Industrial Boilers
     George L. Huffman, U.S. Environmental Protection Agency
     C. Dean Wolbach and Larry R. Waterland
     Acurex Corporation	   76

Boiler Site Identification, Sampling and Analysis Protocols, and
Characterization of Emissions from Boiler Tests
     Richard S. Merrill, C. Dean Wolbach, Robert McCormick and
     Larry Waterland, Acurex Corporation 	  85

Evaluation of Feasibility of Incinerating Hazardous Wastes "in
High-Temperature Industrial Processes
     F.D. Hall andW.F. Kemner, PEDCo Environmental, Inc.
     L. J. Staley, U.S. Environmental Protection Agency	   99


B-3.  Laboratory and Pilot Scale Incineration Research, and Development

A Suggested Laboratory Approach to Simplification of the
POHC - PIC Dilemma
     Frank C. Whitmore, Versar, Inc.
     Richard A. Carnes, "U.S. Environmental Protection Agency
     Wayne A. Rubey, University of Dayton	107

Siting and Design Consideration for the Environmental Protection
Agency Combustion Research Facility
     Richard A. Carnes, U.S. Environmental Protection Agency
     Frank C. Whitmore, Versar, Inc	118
                                   vixi

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                          TABLE OF CONTENTS  (Cont'd)
                                                                           Page
 Environmental  and  Performance  Assessment  at Hamilton County
 Hazardous Waste  Incinerator
     Boyd T. Riley,  Jr.,  RYCON,  Inc.
     John H. Trapp,  Metropolitan Sewer District  of
     Greater Cincinnati	125

 Trial Burn Verification Program  for Hazardous Waste  Incineration
     K. P. Ananth, P. Gorman and E. Hansen, Midwest  Research  Institute
     D. A. Oberacker, U.S. Environmental  Protection  Agency  	   131


 B-4.  Incinerator  Process Management

 Evaluation of  Potential VOC Screening Instruments
     Kenneth T. Menzies and Rose E. Fasano
     Arthur D. Little, Inc.
     Merrill,  Jackson, U.S. Environmental Protection Agency.  .  .  .  .  .  .   143

 Survey Methods for the Determination of Principal Organic Hazardous
 Constituents (POHCs) I.  Methods  for Laboratory Analysis
     Ruby H. James, H. Kenneth Dillon and Herbert C. Miller
     Southern Research Institute  	  ......  i  ...   159


 B—5.  Advanced Hazardous Waste Treatment  and Control Technology

 New Ideas in Hazardous Waste Management Technology
     Harry M. Freeman
     California Office of Appropriate Technology 	   174

 Recovering Metals from Metal Finishing Wastes
     Alfred B. Craig, Jr.
     U.S.  Environmental Protection Agency	182

 EPA Mining Waste Research
     S. Jackson Hubbard
     U.S.  Environmental Protection Agency		191

 Chemical Treatment of PCBs in the Environment
     Charles Rogers
     U.S.  Environmental Protection Agency. .  .  .  .  .  .,....-.  . .  . . . .  197

Destruction of Hazardous Waste Using Supercritical  Water
     Michael Modell,  Gary G.  Gaudet, Morris Simson,  Glenn T. Hong and
     Klaus Biemann, MODAR, Inc	.-..-.'.	202
                                     ix

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                         TABLE OF CONTENTS (Cont'd)
The Destruction of Various Organic Substances by a Catalyzed
Wet Oxidation Process
     Richard A. Miller and Mark D. Swientoniewski
     IT Enviroscience	
                                                                          213
B-6.  Specialized Hazardous Waste Incineration Techniques

Shipboard Incineration of Hazardous Chemical Waste - Routine Disposal
of Liquids and Experimental Destruction of Solids
     Gerald 0. Chapman and Donald A, Oberacker
     U.S. Environmental Protection Agency
     Robert J. Johnson, TRW Environmental Division
     Daniel W. Leubecker, Maritime Administration. . ... t ..... r
                                                                          222
Elimination of Hazardous Wastes by the Molten Salt Destruction Process
     James G. Johanson, Samuel J. Yosium, Larry G. Kellogg and
     Seymour Sudar, Rockwell International 	 ..,,.,..  234
Evaluation of Hazardous Waste - Incineration in a .Dry Process
Cement Kiln                                  '        •
     Gregory M. Higgins and Arthur J. Helmstetter
     SYSTECH Corporation	..........
                                                                          243
                                     x

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             PROFILE OF THE HAZARDOUS WASTE INCINERATOR MANUFACTURING INDUSTRY
                                       Irwin Frankel
                                •     ;  Neil Sanders ,   .
                                        Greg Vogel
                                   The MITRE Corporation
                                     McLean, VA 22102

                                         C.C. Lee
                           U.S.  Environmental Protection Agency
                                   Cincinnati, OH 45268
,1.0  INTRODUCTION

     The purpose of this document  :j.s twp-
 fold:   (1)  to present -'information  on the
 number, types, and capacities of hazardous
 waste  incinerators put  into  operation  since
"Ja'nuary ,19,69, and  (2) to present informa-
 tion which  analyzes and describe?  some of
 the more important design  features qf  the
 various types of incinerators.

 2,0  BACKGROUND

     Prior  to RCRA no major  distinction was
 made between incinerators  used  for hazard-
 ous or nonhazardous wastes.  They  all  had
 similar waste feed systems,  burners, fans
 or blowers,  closed comubsfion chambers
 (nearly always lined with  refractory
 materials),  and stacks  to  disperse the
 flue gases.  However, virtually .every
 incinerator facility now in  hazardous
 waste  service in the United  States should
 be equipped with at least  one air  pollution
 control device  (APCD).  The  addition of
 APCDs  does,  of course,  significantly add
 to incinerator capital  cost  requirements
 and operating expenses.

     Within the past few years, the value
 of thermal energy  has greatly appreciated,
 and thermal energy release from incinera~
 tors can be significant.   Accordingly,
 this study has  shown that  almost 90 percent
 of all hazardous waste  incinerator facil-
 ities  ordered or placed into operation
 during the past year has been equipped with
 energy recovery systems.
3.0  TECHNICAL APPROACH

     Most of the information collected for
this study was obtained from one or more
of the following sources:

     a)  Telephone, conversations between
         a member of the MITRE technical
         staff and a responsible person
         at the vendors' offices.

     b)  Perusal of technical bulletins
         and literature furnished by
         mqst of the vendors.

     c)  Personal interviews by one or
         more of MITRE's technical staff
         with one or more of the vendors'
         staff at a mutually convenient
         location.

     Initially, names, addresses and some
telephone numbers of vendors were obtained
from one or more listings in four current
vendor directories, including:

     a)  1981 Chemical Engineering Catalog

     b)  February 1981 Buyer's Guide,
         Solid Waste Management Magazine

     c)  1981 Catalog and Buyer's Guide,
         Pollution Equipment News
         (Nov. 1980, Vol. 13, No. 6)

     d)  1980-81 Directory and Resource
         Book, Air Pollution Control
         Association

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r
                  Names of vendors not listed in the
             above directories were obtained from
             various other sources.

             4.0  DATA PRESENTATION AND DISCUSSION

             4.1  Types and Numbers of Incinerators

                  A breakdown of the statistical data
             obtained in this study on types and numbers
             of hazardous waste incinerators is pre-
             sented in Tables 1, 2, and 3 on the follow-
             ing pages.  Table l.B shows a complete
             enumeration of hazardous waste incinerators,
             by type and by the number of companies
             offering each type.  In Table 2, there is
             a breakdown of the number of units of each
             principal type sold by the companies.
             Table 3 consists of individual listings of
             the 57 companies that market hazardous
             waste incinerators plus data pertaining to
             the types of incinerators that they market,
             the number, capacity, and wastes handled by
             each type in hazardous waste service, plus
             other details which were available on each
             company's product line or services.
             Table 3 occupies six pages, therefore only
             Page 1 of this table is presented in an
             abbreviated presentation.

                  A number of observations and conclu-
             sions can be drawn from analysis of the
             data in Tables 1, 2, and 3.  Some of these
             are as follows:

                  o  About 342 incinerators have been
                     put into hazardous waste service
                     since January 1969.  These units
                     were manufactured by 29 companies,
                     all of which were based in the
                     United States at the time the units
                     were delivered.  Within the past
                     year one of these companies (BSP
                     Envirotech) was purchased by a
                     West German firm, the Lurgi Corpor-
                     ation.  The count of 342 units is
                     believed to be reasonably accurate
                     but cannot be exact for the follow-
                     ing reasons:

                     a) A number of small vendor com-
                        panies have disappeared since
                        1969.  These companies have
                        probably manufactured a few
                        incinerators which are still in
                        use but their existence could
                        not be determined.
b) Incinerators originally sold for
   hazardous waste disposal, or for
   non-hazardous wastes, could be
   operating, at least partr-time,
   on the other waste.

c) Some incinerators have been
   manufactured strictly in accor-
   dance with a customer's specifi*-
   cations and the manufacturing
   company has no knowledge of, or
   declines to speculate on, the
   nature of the purchaser's
   wastes.

d) A few incinerators which have
   been manufactured since January
   1969 are probably no longer in
   use.  A vendor will not gener-
   ally know this.

e) A few incinerators manufactured
   since January 1969 cannot ful-
   fill the design function and
   are not operating.  Vendors will
   not voluntarily acknowledge
   these.

The most common type of hazardous
waste incinerator is liquid injec-
tion, representing 64.0 percent of
all hazardous waste incinerators
in service.  This type of inciner-
ator is not designed to operate on
liquids containing any significant
amount of salts or other suspended
or dissolved solids.

The next most common types of
hazardous waste incinerators are
the Fixed Hearth (F.H.) and the
Rotary Kiln (R.K.), with 17.3 and
12.3 percent, respectively, of the
total manufactured.  Both of these
types of units will dispose of
solids and/or liquid wastes, plus
fumes.

Although there are nine companies
offering Fluidized Bed (F.B.)
incinerators, only nine such units
are in hazardous waste service.
Apparently most of these nine com-
panies believe that the market is
potentially good for this
technology.

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                               TABLE 1

                         SUMMARY DATA SHEET
          HAZARDOUS WASTE INCINERATORS IN THE UNITED STATES
  A.  Number of Companies Offering Incinerators for Hazardous Waste
      Service:
              Offering 1 Type
                    Only
Offering 2 or
 More Types
Total No.
Companies
                     45
    12
                                                      57
 B.  Number of Hazardous Waste Incinerators in Service,  by Type,  and by
     Number of Companies Offering Each Type:



Type
L iqu id In j ec t ion
.Fixed Hearth
Rotary Kiln
Fluidized Bed
Multiple Hearth
Pulse Hearth
Rotary Hearth
Salt Bath
Induction Heating
Reciprocating Grate
Infrared Heating
Open Drum
Unknown


No . Companies
Offering
23
12
17
9
2
1
1
2
1
1
1
1
2
No . in
Hazardous
Waste
Service
219
59
42*, t
9
, 7
2
2A
0
0
1A
1
0
0


Percent
of Total
64.0%
17.3
12.3
2.6
.2.0
0.6
0.6
• • •
....
0.3
0.3
• * •
...
     Total
             342
                          100.0%
*Includes five R.K. units in construction

tlncludes one oscillating kiln

AOne unit is in construction

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           TABLE 2

 NUMBER OF COMPANIES SELLING
HAZARDOUS WASTE INCINERATORS,
           BY TYPE
Number Units
Sold
Per Company

Unk
0
1
2
3
5
6
8
10
12
17
18
19
22
54
75
Incinerator, Type
L.I. F,H. R.K. F.B. M.H.
.
2 1,1
8 85
3 1 3 1
2 2 2,2
2 3 1
1 1 11
1 ' 1
1 1 ',••'•
1 ••
1
1 .'''••
1 ' ' '
1
1
1
1 '

Total No.
Companies
Selling
Each Type
Incinerator .
23 12 17 9 2


Legend: L.I.
F.H.
R.K.
F.B.
M.H.
- Liquid injection
- Fixed Hearth
- Rotary Kiln
- Fluidized Bed
- Multihearth

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                      Two companies are actively market-
                      ing Fused Salt Bath technology but
                      there are no units in service or
                      under construction yet.

                      Of about 219 liquid injection units
                      in service, about 129 (59%) were
                      produced by two companies, John  Zink
                      and Trane Thermal.  The data fur-
                      nished by Zink are not well
                      verified.  Of 23 companies market-
                      ing L.I. incinerators, 8 have sold
                      no units to date.  However, several
                      of the 8 indicate that sales are
                      imminent.

                      Of the 17 companies offering Rotary
                      Kiln incinerators, 8 have sold none
                      to date.

                      Of the 9 companies offering Fluid-
                      ized Bed incinerators, 5 have sold
                      none to date.

                      Of a total of 57 companies offering
                      14 types of incinerators, 28 have
                      sold no units in the United States
                      (several companies represent
                      European technology, and all have
                      sold at least one unit, each, in
                      Europe).

                      The fact that 28 (of the total of
                      57 companies) have not sold any
                      units to date is indicative of the
                      extent of (1) new technology being
                      made available in the United States
                      by both U.S. and foreign companies,
                      (2) the formation of new corporate
                      ventures in this field of technol-
                      ogy, and (3) efforts by European
                      companies to invade the U.S. mar-
                      ket.  It is therefore believed that
                      the market, or technology, is not
                      static at this point in time.

                      Two companies are allegedly devel-
                      oping new technology, which they
                      would not describe at this time.
                      It is known that other companies
                      are researching other techniques
                      for hazardous waste incineration
                      but these techniques are not des-
                      cribed in this report.  The new
                      processes included plasma, micro-
                      wave plasma, and several unusual
                      fluidized bed techniques.
4.2  Capacities of Incinerators, by Type

     Results of this portion of the study
are summarized in Table 4.  Sufficient data
were obtained from the four predominant
types of incinerators to show design capac-
ity comparisons in terms of both pounds per
hour and millions of Btus per hour.
Results can be- summarized as follows:

     o  The typical Fixed Hearth inciner-
        ator is the smallest of the four
        predominant types.

     o  The typical Liquid Injection and
        Rotary Kiln incinerators have about
        the same capacities.

     o  On the basis of a small amount of
        data, the typical fluidized bed
        incinerator is the largest of the
        predominant types.

     The above summaries are based on a
limited amount of data (incomplete popula-
tion description), and therefore may not
be highly accurate.

     A few additional comments regarding
incineratory capacity are worthwhile, as
follows:

     o  The largest hazardous waste incin-
        erator noted (a liquid injection
        unit) was rated at 150 x !06Btu/hr,
        however vendors say that requests
        to quote on facilities as large as
        300 x 10^ Btu/hr are being received.
        Such facilities would have liquid
        injection or rotary kiln inciner-
        ators, or a combination of both
        feeding into a common afterburner.
        Fume incinerators or municipal
        waste incinerators as large as
        300 x 106 Btu/hr presently exist.

     o  The one manufacturer of the rotary
        hearth incinerator states that a.
        range of 3600-24,000 Ib/hr is
        feasible for this design.

4.3  Some Important Incinerator Design
     Details

     Design details investigated were, for
the most part, those of greatest interest
to an EPA or a state permit writer.  These
are as follows:

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                             TABLE 4

                 Comparison of  Design Capacity  of
            Several Types of Hazardous Waste Incinerators
Type Incinerator

Liqu id Inj ect ion
Fixed Hearth
Rotary Kiln
Fluidized Bed
Typical
Value
Used

Med ian
Average
Average
	
n*

43
48
2
1
Capacity,
Ib/hr

1,600
810
1,600
31,000
Typical
Value
Used

Med ian
Average
Median
Average
n*

50
4
34
5
Btu/hr
x 106
-"
8
4.9
10.3
45.5

* = Number of units for which capacity data were available.  In  some cases
    the same incinerators were used in both data sets  (when mass and heat
    data were convertible).

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     o  Operating temperatures, pressures,
        and residence times

     o  Incineration/Combustion heat
        release rates

     o  Air requirements, including re-
        quirements in each combustion
        chamber when more than one chamber
        is used

     o  Refractories

     o  Burners; purchased or manufactured
        internally (the burners are so
        varied in design and range of
        function that a separate study ,
        could be justified on just this
        class of item)

     o  Instrumentation, controls and mon-
        itors (also too large a class to
        be handled in depth by this report)

     o  Heat recovery

     o  Trial burn facilities

     o  Air pollution control devices

     o  Vendors' scope of capability

4.3.1  Operating Temperatures, Pressures
       and Residence Times

     Data obtained from 16 vendors of
several types of incinerators are present-
ed in Table 5.  Since the data were ob-
tained from small samples of rather small
populations, they are not necessarily
representative.

     With respect to operating pressures,
there is no wide range.  Most incinerators
operate a few inches w-c. (water column) on
the positive or negative side of atmospher-
ic pressure.  The determining factor for
the absolute pressure is the blower used.
If a forced draft fan or blower is used to
move combustion air and flue gases, then
the combustion chamber will operate under
a few inches of positive pressure.  Nega-
tive pressures are encountered at install-
ations with induced draft fans .  "Push-
pull" systems use both forced and induced
draft fans and can operate Under negative
or positive pressures at various equipment
locations.  According to our sampling of
the various populations:
     o  About half the vendors supply •
        liquid inj ectiori,incinerators
        which operate under slight vacuum,
        about half at slight positive ,
        pressure.                 .<•:.•

     o  All rotary kilns operate at slight
        vacuum.

     o  Fluidized bed incinerators requir6
        both forced draft and induced drdft
        fans.  The greatest pressure drop
        in the system is generally in the
        fluidized bed itself,

     o  Fixed hearth incinerators generally
        operate very close to atmospheric
        pressure (except in special cases),
        either on the positive or negative
        side.

     Residence times in the several incin-
erator types vary considerably, especially
in the Liquid Injection (L.I.) incinerators.
One liquid injection incinerator vendor
flatly specified 0.5 seconds gaseous resi-
dence time at 1800°F as an adequate condi-
tion for most wastes.  Howeverj most
vendors design for two seconds or more.
When solids are handled in rotary kilns,
rotary hearths, or fixed hearths, sblids
residence times vary from 10 minutes to
two hours; nevertheless, • the volatile or
evolved gases were always contained in an
afterburner at a minimum temperature of
1600-1800°F for an average of two seconds.

4.3.2  Heat .Release Rates

     Heat release rates in'the primary
combustion chamber were available from only
three vendors of entirely different types
of incinerators.  Surprisingly, the rates
were quite similar, as is seen below:
Incinerator Type

Rotary Kiln
Fluidized Bed
Liquid Injection
Heat Release Ralfe
   BtU/hr-ft3 .

  25,000-40,000
  20,000-35,000
  25,000
     It should be noted that both heat
release rates and excess air use in any
incinerator is largely a functidn of the
state of the waste and its susceptibility
to dispersion (i.e., viscosity in liquids
particle size in solids).

-------
4.3.3  Air Requirements
4.3.4  Refractories
  !   Requirements for combustion air vary
widely; however, there is general agreement
that the amount'of excess air should be
minimized if heat recovery is practiced.
The'following generalizations are made:

     o  Liquid injection incinerators
        always operate with an excess of
  :      air (20-60 percent in excess of
        stoichiometric air requirements),
        except when organic nitrogen con-
        taining compounds are burned.  In
        this latter situation, an after-
        burner is used, the primary combus-
        tion chamber operates under starved
        air conditions and the secondary
        chamber operates with excess air.

     o  There is wide variation in air used
        in the operation-of rotary kilns.
        Some kilns are operated in a
        starved air mode (50 to 100 percent
        of stoichiometric air); others are
        operated with up to 150 percent of
        excess air (250 percent of stoich-
        iometric) in the kiln.  Since
        rotary kilns are always operated
        with an oxidizing secondary combus-
        tion chamber (afterburner), the net
        result .is an Overall excess air
        usage (50-200 percent).  Our data
        show that smaller rotary kilns
        (5-20 million Btu/hr) may operate
        under starved air conditions, but
        the larger units nearly always
        operate on excess air.

     o  The rotary hearth operates at py-
        rolytic conditions (almost no air
        present), but the follow-on fume
        incinerator operates with excess
        air, and a 2-4 percent oxygen con-
        tent in the exhaust gas is desired.

     o  The one fluidized bed vendor that
        was interviewed quoted a 15 percent
        excess air usage in the bed.  No
        fluidized bed incinerators that we
        have knowledge of operate with an
        afterburner.

   :  o  Fixed hearth incinerators commonly,
        but not universally, operate in a
        starved air mode (30 to 100 percent
 -'-••      Of stoichiometric air) in the first
        chamber.  The afterburner always
        operates with operates with excess
        air, so that the overall excess air
        usage is about 30-100 percent.
     Of all design factors encountered in
hazardous waste incinerators manufactured,
the least consistent one appears to be the
choice of refractory.  Incinerator vendors
state that they tailor the choice of re-
fractory, to the job requirement, and it is
not possible to briefly summarize this
design factor.

4.3.5  Burners

     The industry, .overall, seems to "split
down the middle" .with respect to make-or-
buy decisions on burners.  Liquid injection
vendors are' more apt to make their own
burners (and to stress, in some cases, the
advantageous operating characteristics of
their burners), while rotary kiln vendors
are more apt to buy burners, including the
burners Manufactured by the liquid injec-
tion vendors.

4.3.6  Instrumentation, Controls and
       Monitors

     Littlfe uniformity was found in the
selection and placement of controls, instru-
ments and monitors supplied by the vendors.
The choice of instruments, etc. is gener-
ally dictated by the purchaser, who is
influenced by local codes,and federal regu-
lations, by his- own engineers, and possibly
by a consultant.  The philosophy of some
users is to instrument and monitor as in-
expensively and as sparsely as possible,
while others virtually "go overboard,"
i.e., they instrument to obtain as much
Operating data as possible, using the
finest equipment available.

     Keeping in mind that a purchaser's
specifications for instrumentation and
monitoring are variable and do not neces-
sarily constitute good engineering practice,
the following generalizations are made:

     o  Shielded thermocouples are the
        temperature measuring device of
        choice.  Two to four thermocouples
        •are sometimes mounted in the com-
      •  bustion zonfe of an incinerator, and
        temperature differences exceeding
        prespecified limits between any
        •two thermocouples can be cause for
        automatic shut-down or waste feed
        cut-off;.     •

     o  Pressure monitoring taps are
        usually placed around incinerators,

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       afterburners, quenches, scrubbers,
       other APCDs, fans and blowers,
       boilers, in  stacks.  Pressure drops
       (or rises) are monitored by differ-
       ential manometer devices, and abso-
       lute pressures by manometers or
       various types of pressure gages.'
       Instruments  can be of either indi-
       cating or  indicating/recording
       types.  Unusual pressure drops
       across equipment items  (especially
       the scrubbers) can actuate an
       automatic  shut-down.

     o  Nearly all flame detectors are U.V.
       types.  In smokey flames, flame
       rods are used to detect ionized
       gases, and in a few  small units,
       thermocouple type flame sensors may
       be immediately next  to  a burner and
       a pilot flame.  Although they are
       generally  used to insure continuity
       of a flame,  they are occasionally
       used to detect the presence of
       flame  in undesirable locations.
       These  detectors are  used in all
       types  of incinerators  except  fluid-
       ized beds  (since there is no macro-
       form of flame  in these units).
       Flame  detection is one of the pri-
       mary bases for controls relating  to
       automatic  fuel and waste feed cut-
       off  to burners and pilot lights.

     o Monitoring of  hot exhaust or  cool
       stack  gases  for  02,  CC>2, CO,  NOX,
        SOX, unburned  hydrocarbons, HC1,
       and particulate matter is generally
        specified  by the  customer.  The
       most  frequently monitored gases  are
       02,  CO, and  C02.  Some of the other
        items  are  monitored  once or twice
        per  year.   Most  customers and
       vendors prefer monitoring of  cooler
        stack  gases, but  a  few prefer hot
        zone monitoring.

4.3.7  Heat  Recovery

     Thirteen  hazardous waste  incinerator
vendors state  that 65  to  100 percent  of  all
recent inquiries  for incineration facil-
ities include  heat recovery.  The un-
weighted average is 87 percent.  Several
vendors automatically include heat  recovery
in any discussion with a prospective cus-
tomer unless the customer specifically
rules it out.
     Several vendors have limits of incin-
erator capacity below which they feel the
additional investment required for heat
recovery will not have an adequate pay-off.
However, there is little agreement on these
lower limits.  Some lower limits quoted
are:  2, 4, and 7 million Btu/hr and
30 gal/hr (roughly equivalent to 2 million
Btu/hr).

     Most vendors think of heat recovery in
terms of steam boilers, with steam pres-
sures up to 250 psig.  When an incinerator
combustion chamber operates at 1800°F, any
boiler should be able to generate steam at
pressure of 150 to 250 psig, with boiler
exhaust temperatures of 550°-600°F.  These
boilers are usually "water wall" type, have
soot blowers, and tubes are non-finned.  In
a few cases heat recovery is used to pro-
duce hot water, to preheat process gases,
to heat air for space heating, and to pre-
heat combustion air.

     Most vendors quote on water-wall
boilers, but one vendor prefers fire-tube
boilers and another vendor specified fire-
tube boilers when HC1 was present to any
significant extent in the hot exhaust gases.
However, fire-tube boilers are rarely con-
structed to exceed 15 x 10$ Btu/hr capacity.

     The presence of significant amounts of
alkaline salts  (Na, K, Ca) and heavy metals
will tend to depress the incinerator heat
release rate.   Further, the detrimental
effects of the  resulting particulates will
triple the price of a waste heat boiler.

4.3.8  Trial Burn Facilities

     Of 15 vendors, 11 have trial burn
units available, and two vendors will
attempt to lease a full-scale unit from a
prior customer  for trial burn purposes.
Two liquid injection vendors claim that
trial burns  are not required and that the
proper laboratory data will suffice  to
insure an adequate incinerator design.  The
range  in capacity of the above trial burn
units is from 150,000 to 3 x 106 Btu/hr.
Several of these units represent the  small-
est model of incinerator available from
the vendor.

4.3.9  Air Pollution  Control Devices

     The selection of  the proper air
pollution  control device (APCD) is
dependent  on a  number of factors,  including:
                                           11

-------
     o  Federal regulations regarding
        emissions

     o  Properties of the wastes burned

     o  Type of incinerator used

     o  Local codes in the areas where the
        facility is to be installed

     o  Customers' preferences

     o  Costs (capital and operating)

At least one APCD is required with most
incinerators, but a number of installations
(especially commercial incinerators)
require two devices, in series with each
other.

     It is not within the scope of this
study to describe the construction or mode
of operation of APCDs in any detail.  The
principle APCDs now in use include the
following:

     o  Venturi scrubber

     o  Packed tower scrubber

     o  Sieve tray scrubber

     o  Spray tower scrubber

     o  Ionizing wet scrubber

     o  Bag house (bag filter)

     o  Cyclone

     o  Electrostatic precipitator (ESP)

     o  Wet ESP

The most commonly used devices include the
venturi and the packed tower scrubbers.
The former is particularly effective with
high particulate loadings in the exhaust
gases, and the latter is particularly
effective in removing soluble acid gases
providing the particulate loading is low.
Bag houses have temperature limitations and
do nothing to undesirable gases.  ESPs are
very effective for particulate removal but
have a high capital cost.  Ionizing wet
scrubbers and wet ESP are also costly but
are gaining in popularity.
     APCDs are positioned downstream from
any energy recovery device, and frequently
require installation of a quench chamber to
cool the polluted gases to a point where
thermal damage will not occur to the APCD,
or to prevent excessive evaporation of  ••
water in the APCD.

     In prior years, venturi or packed
tower scrubbers were made of carbon steel,
stainless steel, or other alloys, depend- •
ing on the acidity and corrosivity of'the
gases.  However, in recent years these
devices have been manufactured using
Fiber Reinforced Plastic (FRP) or rubber-
lined steel, and this construction is now
very popular.

     Of 16 vendors contacted, 15 prefer
venturi and/or packed tower scrubbers, and
one vendor (for rotary hearths) says none
is needed for his unit.

4.3.10  Capability to Provide Services

     Sixteen incinerator vendors (including
one vendor who produces two types of incin-
erators) were queried regarding their
capabilities for furnishing services on
incinerator installations past the incin-
erator design and manufacturing stage.  The
following spectrum of responses was
obtained:

     o  Design and manufacturer only

     o  Design and manufacture only but
        refractories set in place in field
        installations

     o  Design, manufacture and install

     o  Design through start-up but no
        site development

     o  Design through start-up

     o  "Turnkey"

     o  "Turnkey" plus contract operation
        and/or maintenance

     For purposes of this report, a turn-
key contract is defined as a fixed price
contract in which a vendor agrees to design
and furnish a completely erected plant, and
will turn the facility over to a client
wholly operable and debugged, often includ-
ing performance guarantees.
                                            12

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   .  A. ptudy of,the above data does not
^eveal any .trend or prevalent scope of^
capability.  Many small units, and .parti-
cularly the fixed hearth incinerators, are
frequently supplied as skid-mpunted,
package units.  Larger incinerators require
field erection.  Installation costs aria
generally much less for the package units.
Nearly every vendor desires to attend or
participate in any facility start-up where
his equipment is involved,. even if he is
npt primarily responsibile for start-up.
                                            13

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                          HAZARDOUS WASTE INCINERATION COSTS
                                   Gregory A. Vogel
                                     Irwin Frankel
                                     Neil Sanders
                                The MITRE Corporation
                                   McLean, VA 22102

                                     Edward Martin
                         U.S. Environmental Protection Agency
                                Cincinnati, Ohio 45268
                                       ABSTRACT

     This paper describes the development of a method to estimate the capital and
direct operating costs associated with hazardous waste incineration.  The structure of
the cost estimating method is described and the factors affecting incineration costs
are listed.  Cost estimates developed using this method will provide a basis for the
financial analysis of incineration included a part of the Regulatory Impact Analysis
for the Interim Final Incinerator Standards.
INTRODUCTION

     The purpose of this study is to pro-
vide EPA with a method to estimate the
capital and operating costs associated
with hazardous waste incineration.  Cost
estimates developed using the informa-
tion obtained from this study will pro-
vide a basis for the financial analyses
included as part of the Regulatory Im-
pact Analysis for the Interim Final
Incinerator Standards.

     The cost analysis developed during
this study may be used to obtain budget
estimates of the capital and operating
costs for other purposes as well.  Such
estimates may be used by industry and
government agencies to evaluate the
costs of waste disposal options.  The
report developed from this study is
intended to fill the information gap
between engineers highly skilled in the
design and technology of hazardous
waste incinerators and those people
having an interest, but not extensive
experience, in this field.

     Hazardous waste incinerator .facili-
ty designs and costs vary considerably.
There are 57 companies presently market-
ing incinerators that may be used for
hazardous waste destruction.  Probably
no two incinerator designs developed by
these manufacturers are identical.
There is no  'typical' incinerator de-
sign or facility.  Recognizing this fact,
this method for cost estimation is de-
signed to address the many different
incinerator facility designs found with-
in the industry.  The versatility is
attained by identifying the major com-
ponents of an incinerator facility and
providing estimates of the cost of each
component.  The appropriate components
may be selected and a cost estimate
developed for a particular facility as
each situation warrants.

     The costs developed from this study
represent averages derived from a lim-
ited sampling of approximately 25 incin-
erator component manufacturers, and the
owners and operators of hazardous waste
incinerators.  The costs provided by
manufacturers are budget estimates,
accurate to within twenty percent of
actual costs.  In order to develop more
accurate cost figures, detailed design
specifications must be provided and
                                         14

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considerable engineering must be conduc-
ted.  A price quote for a complete in-
cinerator facility generally requires
about twelve man weeks to prepare and
may require as many as thirty man weeks.
The use of the predictive model dev-
eloped during this study will produce a
cost estimate in hours.

     The use of average costs suffers a
limitation in that quotations developed
by different vendors to the same speci-
fications often vary considerably.  The
highest bid for an incinerator facility
may be more than twice that of the
lowest.  The variations in quoted prices
are the result of different approaches
to design, inclusion of auxiliary
equipment, and different methods of con-
struction.  The competitiveness of the
incinerator market.also influences
prices, some vendors submit low bids in
order to establish a market.

Factors Affecting Incineration Costs

     The factors affecting the cost of
hazardous waste incineration are grouped
into three broad categories:

     •  Waste characteristics

     •  Facility characteristics

     •  Operating characteristics

The specific factors incorporated in' the
cost estimating method are listed in
Figure 1.  The major factor affecting
equipment costs is the heat input rate
to  the incinerator.  Accordingly, costs
are presented graphically as a function
of  equipment size, expressed as heat
input rate or flue gas volume flow rate.
The other factors are expressed as
multipliers that are applied to the
values obtained from the graphs.

     In order to obtain reasonably
accurate cost estimates, the incinerator
facility components must be properly
sized.  Equipment  sizes and the
 auxiliary fuel  requirement  are  obtained
from an elementary heat balance presen-
ted in the report.  The heat input from
the waste is subtracted' from the  sum
of  energy losses from  the 'incinerator,
 including flue  gas enthalpy, water vapor
 enthalpy, and radiation los'ses.   If the'
energy loss exceeds the heat input,  the
difference must be made up through the
use of auxiliary fuel.  The flue gas
enthalpy and water vapor enthalpy are
determined graphically, and a sample
calculation is shown in Figure 2.

     The flue gas volume is a function
of the incinerator heat input and excess
air usage.  Flue gas enthalpy is a
function of combustion zone temperature
and flue gas volume.  In this example,
energy losses exceed the heat input rate
by 4.8 million Btu and the dotted line
indicates the flue gas volume using
auxiliary fuel to compensate for the
loss.

     Not all the heat content of auxil-
iary fuel can be utilized because of
associated combustion gas enthalpy loss.
The enthalpy loss is a function of the
combustion zone temperature.  In Figure
3, the effects of enthalpy loss ex-
pressed as the combustion zone tempera-
ture on the costs of three auxiliary
fuels are shown.  It is much more expen-
sive to use #2 fuel oil as an auxiliary
fuel than' to use natural gas.

Incinerator Facility Costs

     Graphs showing equipment cost as a
function of size are presented in Figures
4, 5, and 6.  The costs of the three
major types -of hazardous waste incinera-
tor facilities include air pollution
control equipment, energy recovery equip-
ment, a waste storage and loading system,
and the combustion chambers.  The
capital cost of an installed incinera-
tion facility is approximately 1.5 times
the freight on board  (FOB) costs ob-
tain&d from the graphs.  It should be
noted that the costs of liquid injection
and hearth incineration facilities of
the same heat input are approximately
three times as "expensive.  The high cost
of the rotary kilns is offset by their
ability to incinerate all types of
wastes.

     More detailed estimates can be
developed using the graphs for each of
the major components  of an incinerator
facility that are  included in the re-
port.  Capital cost information  is pre-
sented for ram loaders, combustion
chambers, energy recovery equipment,  and
                                          15

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air pollution control equipment.  In-
cinerator facility installation, start-
up, spare parts, engineering, control
and instrumentation costs are estimated
as percentages of the total equipment
cost.

     Annual direct operating costs are
estimated using information included in
the report for each of the following
expenses:

     *  Labor

     •  Utilities and chemicals

     •  Incinerator effluent management

     •  Maintenance

     •  Laboratory analyses

Methods to estimate usage and rates are
presented for each of these functions
except for maintenance costs, which are,
estimated as a percentage of the total
capital cost.  Guidelines for selecting
typical operating conditions, including
water flow rate's, electrical power
consumption and chemical usage, are
provided.  Steam generated by energy
recovery equipment is applied as a
credit to the incinerator operating
cost,

   The total capital cost can be depre-
ciated on a straight line basis and
added to the annual operating cost
estimate to give an estimate of the
total annual cost of incineration.  Such
estimates may be used to compare the
effects of varying incinerator operating
conditions, such as combustion zone
temperature and residence time, and the
numerous incinerator design alternatives
on the total post of hazardous waste
incineration.  In addition, financial
analyses may be conducted, using the
information from this economic analysis,
to determine the costs of incineration
under various incinerator designs,
operating conditions, regulatory re-
quirements, and market-place conditions.
Such a financial analysis would incor-
porate the cost of money and revenues
from hazardous waste management into
the cost of hazardous waste incinera-
tion.
• Waste Characteristics

     - Physical stat.e

     - Heating value

     - Wa^er content

     - Organic chloride content

     - Alkali metal content

     - Container size



• Facility Characteristics

     ,.- Waste storage Capacity

    '- Incinerator type

  '   - Energy recovery

   •  - .Materials of construction



• Operating Characteristics

     - Waste input r^fe

     - Operating schedule

     r- Combustion zpne temperature

     - Combustion zon.e residence time

     - Excess air usage




              Figure 1

     Factors Affecting Hazardous
     Waste Incineration Costs
                                        16

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                                H

                                •U
                                     O
                                     H
17

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r
                           Basis:
1000                     2000

          Combustion Zone Temperature,

Stoichiometric combustion of fuels
                  March 1981 Price
                                  i?2  Fuel  Oil
                                  #6  Fuel
                                  Natural  Gas
                  $1.25 per gallon
                  $ .86 per gallon
                  $2.69 per 1000 scf
                                                                                      3000
Heat Content

137,000 Btu/gal
153,000 Btu/gal
1020 Btu/scf
                                                        FIGURE 3

                                      AUXILIARY FUEL COST AS A FUNCTION OF TEMPERATURE
                                         (DERIVED FROM AVAILABLE  HEAT CALCULATIONS)
                                                         18

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I
2,500
2,000

1,500

1,000
  900
  800
  700
  600
  500
  400

  300

  200
      100
       90
       80
       70
       60
       50
X
                                                                         X
                                    56789 10
                                                            20
                                                                   30    40   50  60  7  8 9 100
                                   Heat Input, Million Btu Per Hour
                                        Size Exponent - 0.87
                                            FIGURE 4
                             HEARTH  INCINERATOR FACILITY  COST AS  A
                                    FUNCTION  OF HEAT INPUT.
                                          19

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4.0

3.0

2.1



1.0
0.3
0.2
                     6  7 8 9 10
                                         20
                                                30
                                                     40  50 60 70 8  9 100
                      Heat Input, Million Btu Per Hour
                                Size Exponent » 6.45
                               FIGURE  5
             LIQUID INJECTION INCINERATOR FACILITY COST
                     AS A  FUNCTION OF HEAT INPUT
                               2Q

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•7.0
6.0
5.0
4.0
3.0
2.0
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4 5 6 7 8 9 10 20 30 40 50, 66 70 8 9 100
        Heat Input, Hlllion-Btu Per Hour            ''
                                Size Exponent - 0.52
              '  FIGURE 6
ROTARY  KILN INCINERATOR FACILITY COST  AS
        A FUNCTION  OF HEAT  INPUT
                 21

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                           USING UNCERTAINTY ANALYSIS TO ESTIMATE
                          THE  COST OF HAZARDOUS WASTE INCINERATION
                                  Haynes  C.  Goddard,  Ph.D.
                            U.S.  Environmental  Protection Agency
                                   Cincinnati,  Ohio 45268
                                          ABSTRACT

This  paper presents  the  rationale  for,  and  the  result  of  using uncertainty analysis or
probabilistic  simulation to  estimate  the  cost of hazardous waste  incineration.  Results
are presented  giving the probability  distributions  for capital cost  and  the present value
of average net costs over the  life of a rotary  kiln for PCB wastes.
 INTRODUCTION

      A major technology for the destruction
 of hazardous wastes is incineration,  for
 which there are a number of candidate tech-
 nologies available, some proven,  some not.
 The proven technologies are rotary kilns
 and liquid injection incinerators. The
 technologies that are still largely experi-
 mental are fluidized beds,  molten salt and
 co-incineration.

      Even for the proven technologies,
 however,  there is much uncertainty regard-
 ing the costs of  incinerating  the various
 wastes thought appropriate  for kilns  and
 liquid injection.   This uncertainty arises
 from three principal characteristics:
 variations in waste types,  facility design
 and economic  factors.   There is a wide
 variety of waste  types that require dif-
 ferent operating  conditions and input  com-
 binations,  such as  excess air,  supplemen-
 tary fuel,  neutralizing agents, etc.   Var-
 iability  in design  characteristics  stem
 from such  factors as variations in air
 pollution  control equipment and in heat
 recovery  technologies.   The third  major
 source of  uncertainty  stems from variations
 in  economic parameters  such as  interest
 rates,  fuel prices, steam prices, wage
 rates,  etc.

     These variabilities have always pre-
 sented a problem to the  cost analyst;  the
usual  procedure adopted  to  deal with the
problem has been to choose the "best" esti-
mate (a mean or judgmental figure) of
parameters, often consciously erring on the
conservative side (overestimating costs,
underestimating revenues).  In addition,.
analysts often state that the final figure
of interest (i.e. average cost, total cost,
etc.) may vary by a factor of, e.g., + 20%.
This latter statement usually bears only
a vague resemblance to the actual under-
lying variabilities, and as a result such
ad hoc procedures do not have much meaning
in a probabilistic sense.  Even if the _+20%
figure were interpreted in the context of
a standardized normal distribution, it
would typically involve an unwarranted in-
ference about the variance of the estimate
because the variance was not estimated
directly.

     In the light of these observations,
one can see that cost estimation is a
complex task even if done with the best of
historical data - it becomes precarious
with new and emerging technologies.  The
technique described above, denoted here as
the traditional approach, being essentially
ad hoc in nature, does not fully nor effec-
tively exploit the information possessed by
an analyst or the experts on which he may
rely regarding the variability of component
performance characteristics and costs.
This technique essentially throws away in-
formation about underlying variabilities or
probability distributions.
                                            22

-------
     Neither does  the  traditional approach
 allow decision makers  to know  the margin
 of  error  present when  choosing a given
 cost figure to represent the "best"  esti-
 mate to be used in policy making.  In
 particular, in an  environment  that heavily
.penalizes excessive costs,  it  is important
 for the decision-maker to know the proba-
 bility that a given cost figure will be
 exceeded, information  that  the traditional
 approach  does not  provide.  From the view-
 point of  environmental regulation, decision
 makers need to know the probability  attach-
 ed  to the cost of  meeting a standard, so
 that cost trade-offs can be analyzed expli-
 citly.  From the viewpoint  of  the regulated
 firm, it  is important  to know  the distribu-
 tion of costs for  meeting a standard,
 since this affects profit.

     This paper reports on  the application
 of  uncertainty analysis to  the problem  of
 estimating the cost of hazardous waste
 incineration.  The technique is variously
 known as  model sampling, stochastic  simu-
 lation or Monte Carlo  analysis. The tech-
 nique is  straightforward, and  requires
 only that the cost model be written  down
 as  a set  of equations, and  that all  vari-
 ables and parameters deemed to be uncertain
 be  written as probability distributions
 (either classical  or empirical).  EPA
 staff have prepared a  computer simulation
 program which conducts the  model sampling
 - the output is a  probability  distribution
 for the variable of interest,  as well as a
 number of other associated  outputs.*
 APPLICATION TO HAZARDOUS WASTE INCINERATION

      The technique was applied to model  of
 technologies for hazardous  waste inciner-
 ation,  rotary kiln and liquid  injection,
 for five wastes:  polychlorinated biphenyls,
 nitrochlorobenzene,  polyvinyl  chloride,
 ethylene glycol and methyl  methacrylate.
 The engineering model on which the cost
 estimates were based was a  fairly modest
 one,  in that it does not detail the basic
 *The simulation routine is named "MOUSE";
 copies of the program description and a
 tape of the program may be obtained  by
 contacting the author or Dr.  Albert  J.
 Klee,  Senior Science Advisor, IERL,  U.S.
 EPA, Cincinnati,  Ohio 45268,  (513 684-
 4319).
unit processes such as waste storage, load-
ing systems, combustion chambers, energy
recovery equipment, etc.  Capital items
were dichotomized into only the basic fur-
nace plus the air pollution control system,
and the basic inputs determining operating
costs were fuel, water, maintenance, neu-
tralizing lime, electricity and labor.
Only lime, supplementary fuel and the feed
rate varied as the waste type changed.
For the analysis, 15 variables and parame-
ters were deemed to be uncertain enough to
require probability distributions instead
of point estimates as input data - in all
cases, these were chosen as empirical dis-
tributions.  As an example, this distribu-
tion was chosen for the electricity cost
growth rate:
         Probability

            0.10 '
            0.20
            0.40
            0.20
            0.10
Rate

0.06
0.07
0.08
0.09
0.10
For most cost studies, it will likely be
true in general that the distributions for
economic parameters will have to be chosen
as empirical distributions; the engineering
parameters will be more amenable to the use
of parametric probability distributions.

     The procedure is straightforward - the
computer is instructed to make repeated
calculations of the model outputs choosing
randomly from the 15 probability distribu-
tions for each iteration (1000 iterations
is usually sufficient).

     For the present case study, the model
was programmed to yield the following out-
puts:

     1. probability distribution for capital
cost (furnace plus air pollution control
equipment).

     2. probability distribution of the
present value of average cost (defined as
the cost per ton of. waste incinerated over
the life of the facility).

     3. average net operating costs in each
of the years of operation.
                                             23

-------
      Two basic types of cost estimates were
 sought:  (1) financial cost or engineering
 cost estimates and (2) economic  cost es-
 timates.  Financial costs include interest
 payments and taxes not paid for a specific
 governmental service, whereas the economic
 costs do not include those. Financial costs
 are those of most interest to the owners
 and users of facilities, as they relate to
 current profits and budgets, whereas the
 economic costs focus on the opportunity
 costs of incineration, that is the value of
 resources actually employed in the facility.
 It is these latter costs that give the
 policy-maker a clue to the true economic
 burden that hazardous waste incineration
 places on the economy.

      Finally, the following 15 variables
 were estimated as empirical probability
 distributions for the kiln model:   kiln
 capital cost, kiln installation cost,  air
 pollution control capital  cost,  air pollu-
 tion control installation  cost,  facility
 life,  discount rate,  capacity utilization,
 labor cost  growth rate,  electricity cost,
 electricity cost  growth  rate,  water price,
 water price growth rate, steam price,
 steam/price growth rate, and fuel  price
 growth rate.

 THE COST ESTIMATES

     Tables 1-3 give  the estimates  of  the
 financial costs for incinerating PCB's  in  a
 rotary kiln.  Table 1  shows  the distri-
 bution for  the capital items  (furnace  plus
 air pollution control).  The mean estimate
 is  $13.3 million,  with a standard deviation
 of  $0.95 million.  Of more interest  is  the
 range  ($12  mm to  $16.3 mm), and the  proba-
 bility distribution of costs.  In particu-
 lar, one can  see  that the cummulative
 probability associated with the mean
 estimate is somewhat less than 65% - that
 is,  there is  a 65% probability that  the
 capital  cost will  be $13.3 mm,or less, and
 a 35% probability  that it will be  greater.

     Table 2 gives the present value of
 the net average financial cost of
 incinerating one ton of PCB waste over the
 life of  the facility (17 years here).  The
 figure shown is the cost net of steam re-
venues from the heat recovery operation.
The mean net cost of $87/ton occurs with
a cummulative.probability of 62%, and there
 is a 38% probability that the cost will
 exceed this figure.   There is,  however,
 only a 5% probability that the  net cost
 will exceed $110/ton.

      Table 3 gives the present  value of
 the net average economic '(as opposed 'to
 financial) cost for  the kiln.   This is
 significantly lower  than the financial
 cost figure .^32/tori  vs.  $81/ton),  the
 difference being solely that the economic
 costs exclude interest payments on debt,
 and financial cost figures include them.
 Thus, the true  economic cbst is sub-
 stantially less than the financial co'str,
 and furthermore,  the -two cost distributions
 do not overlap at all.   As mentioned
 earlier,  the financial cost figures are
 relevant  to facility owners and theijr
 customers,  and the economic cost estimates
 are relevant to environmental   policy
 makers who need to gage  the total  economic
 burden environmental regulation places  on
 the economy.

      An additional output  for which the
 model was  programmed was the annual average
 net operating cost in each year -of the  fa^
 cility life,  17 years in this case.   Table
 4  shows these figures for  the financial
 cost model.   The  output  shows 'that  beginrtirig
 in the seventh year  of operation,  the
 process yields a  negative  cost,  or a net
 operating  profit.  The economic  operatrng
 cost estimates for this  model are  the
 same,  as the  financial and  economic  cost
 models  differ only in the  treatment  of
 interest payments.

      Finally,  although one  may  readily
 agree  that  having  the probability  distri-
 butions of  costs represents  a valuable
 addition to available information,  there
 is  the  issue  of whether  or  not  the  cost of
 uncertainty analysis  is  so  high as  to
 exceed  the  perceived  benefits.  Actually,
 there is some  uncertainty about the  cost
 of using uncertainty  analysis,  so a
 stochastic  simulation was performed  on
 that question.  A model was constructed
using the following variables, with uniform
distributions  employed as the probability
distributions  (ranges appear in parenthe-
ses:  computer run time  (3  to 6 minutes),.
number of runs  (10 to 15),  labor cost
 ($8.93 to $15.41 per hour), number of
labor hours (40 to 60), cost per run a't-
                                            24

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afe.udy.
                                            29

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                      AN ASSESSMENT OF EMISSIONS FROM A HAZARDOUS
                              WASTE  INCINERATION FACILITY

                                      L. J. Staley
                      Industrial  Environmental  Research Laboratory
                          U.S.  Environmental  Protection Agency
                                 Cincinnati, Ohio  45268

                    6.  A. Holton,  F.  R. O'Donnell,  and C. A.  Little
                          Health and  Safety Research  Division
                             Oak Ridge National Laboratory
                              Oak  Ridge, Tennessee  37830


                                        ABSTRACT

     The exposure in a nearby population to volatile organic compounds (VOCs) from emis-
sions of a municipal hazardous waste incinerator is determined by measuring the emission
rates and estimating the dispersion of those pollutants over the surrounding community.
Measurements of fugitive VOC emissions from leaky pipe fittings, flanges, pumps, and
valves are made.  VOC emissions from the stack and air' pollution control devices are also
measured.  An emission assessment  is then performed to determine the percentage concentra-
tion and population exposure associated with selected emissions from each source at the
facility.  Results indicate that,  in this particular case,  fugitive and stack emissions
do not contribute significantly to pollutant concentration and population exposure.  Fur-
ther, data for specific constitutents of the VOC emissions also show extremely low con-
centrations and exposure, but these results are based on only a partial analysis and ad-
ditional qualitative emission analyses are.required.
INTRODUCTION

     Incineration of hazardous wastes pro-
duces stack and nonstack emissions.  Until
now, the Environmental Protection Agency
(EPA) has been concentrating on minimizing
stack emissions.  EPA has begun to suspect,
however, that stack emissions may not be
the predominant source of air emissions
from hazardous waste incinerators.  To bet-
ter characterize all sources of air pollu-
tion from these facilities, EPA has entered
into a three-year interagency agreement
with the Department of Energy at Oak Ridge
National Laboratory (DOE/ORNL) to determine
the relative magnitude and significance of
stack and nonstack emissions, and to ulti-
mately evaluate potential control tech-
niques.

     Although .stack testing is not new and
fugitive emissions measurements have been
made at oil refineries and chemical plants,
stack and fugitive emissions measurements
have not been made simultaneously at the
same hazardous waste facility.  Since this
is essential for comparison,,EPA decided
to do it at the first available opport-
unity.

     This paper presents results of an ex-
periment conducted at the liquid fluid
incinerator operated by Cincinnati's Metro-
politan Sewer District (MSD) in July 1981.
The purpose of the experiment was to deter-
mine for one set of conditions the popula-
tion exposure to hydrocarbons that are
emitted by an incinerator.  Hydrocarbon
emission rates from both stack and non-
stack sources were measured.  Atmospheric
concentrations were estimated from these
measurements using the Industrial Source
Complex Dispersion (ISC) model (3).
Population exposure to these concentrations
were then calculated.  Using toxicity data
for six principal organic hazardous con-
                                             31

-------
stituents (POHCs) contained in the hydro-
carbon emissions, the significance of these
exposures was assessed.

     This experiment represents the first
attempt EPA has made to measure both stack
and nonstack emissions simultaneously at
one incinerator.  Consequently, it is pre-
mature to draw broad general conclusions
about the relative significance of stack
and fugitive emissions at hazardous waste
incinerators from the work completed thus
far.

Source Term Development

     The Cincinnati MSD incinerator is a
two-year old facility with a thermal capa-
city of 3.50  x 1010 cal/hr (139 x 106 Btu/
hr).  It consists of a rotary kiln and a
liquid injection furnace in parallel fol-
lowed by a secondary combustion chamber,
quench, .high pressure venturi scrubber, and
packed bed absorber.  Nitrogen blanked
tanks, 9.46 x 104 1 (25,000 gallons), allow
for storage of liquid waste which is typi-
cally delivered by tank truck.

     Prior to conducting field measurements,
fugitive emission rates were estimated us-
ing emission factors for valves, flanges,
and pumps developed from studies of oil
refineries (8).  These calculations indi-
cated that, indeed, fugitive emissions may
greatly exceed stack emissions at 99.99
percent ORE and may be significant at lower
destruction and removal efficiencies.

     Results of these calculations are
shown in Figure 1 (7).  To gather some pre-
liminary information to determine the vali-
dity of these calculations, EPA monitored
the fugitive emissions at the Cincinnati
incinerator during a trial burn at which
stack testing was conducted.

     During the trial burn, approximately
3.41 x 105 1 (90, 000 gallons) of waste
containing chlorinated compounds as well as
alcohols, carbonyl compounds, and CQ - CQ
alkanes from nearby landfills were burned.
Hydrocarbon stack emissions, measured as
methane, were determined using the Dohrmann
DC-50 continuous monitor as a direct flame
ionization detector (1).   Fugitive hydro-
carbon emissions were determined by screen-
ing each valve, vent, flange, and pump seal
in the storage, loading dock, and at the
feed inlets to the incinerators using the
Century Systems OVA 108 and OVA 128 port-
able organic vapor analyzers and EPA stand-
ard Reference Method 21 (6).  Both instru-
ments were calibrated to methane and in-
dicated hydrocarbon concentrations in ppm
methane.  These readings were converted to
emission rates in g/hr using correlations
developed in another study (5).

Modeling Methodology

  .   The impact of these emissions on the
surrounding population was assessed using
the Industrial Source Complex Dispersion
Model.  Together with local meteorological
and popuTat-ioh data supplied by ORNL, the
model can be used to assess the air quality
impact of emissions from area and point
sources associated with an industrial com-
plex.  The model assumes Gaussian plume
dispersion and can account for the effects
of elevated terrain surrounding the incin-
erator and building wake effects.  Using
meteorological data and incinerator, design,
operation, and emission release data (Table
1),  the ISC computer model was run to esti-
mate downwind concentrations at 176 recep-
tors (16 directions and 11 distances) (see
Figure 2).  Each receptor point was defined
by the intersection of 1 of 11 rings of
various diameters centered around the in-
cinerator and 1 of 16 radial lines emanat-
ing  from the complex center.  Each radial
was separated by 22.5° intervals beginning
with due north (0°) and proceeding clock-
wise.  The 11 ring diameters were 0.2,  0.3,
0.5, 0.7, -r.0,,'2.0, 3.0, 5.0, 7.0, 10.0,
and  15.0"km..  These distances were chosen
to span!the'greater Cincinnati metropolitan
area.

     To account for Cincinnati's hilly ter-
rain,' elevations of each receptor point
were taken from topographic maps.  At 91 of
the  176 receptor locations where the eleva-
tion exceeded the stack height, the stack
height elevation less 30.5 cm (1 ft)  was
used.  Such treatment may be simplified,
but  it's conservative in that the concen-
tration calculated at this elevation would
be the maximum experienced at that particu-
lar  location.

     The concentration calculated by ISC
were than coupled with 1980 census data to
give population exposures (2, 4).

RESULTS

     Downwind concentration estimates at
the  176 receptors were calculated for total
                                            32

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-------
                               TABLE  3




LOCATIONS AND VALUES OF MAXIMUM AVERAGE  GROUND LEVEL AIR CONCENTRATIONS
POLLUTANT


CHCL3 '
CHCL3
CHCL3
CHO.3
CCL4
CCL4
CCL4
CCL4
C2CL4
C2CL4
C2CL4
C2CL4
HCCP
HCCP
HCCP
HCCP
C2CL6
C2CL6
C2CL6
C2CL6
C6CL6
C6CL6
C6CL6
C6CL6
SOURCE


STACK
STRUCTURE
TANK FARH
ALL SOURCES
STACK
STRUCTURE
TANK FARH
ALL SOURCES
STACK
STRUCTURE
TANK FARH
ALL SOURCES
STACK
STRUCTURE
TANK FARH
ALL SOURCES
STACK
STRUCTURE
TANK FARH
ALL SOURCES
STACK
STRUCTURE
TANK FARH
ALL SOURCES'
CONCENTRATION.
MTPOnnOAIfC PCD
rULKuoKHnb rtK
CUBIC HETER

1.33E-03
5.59E-05
7.32E-04
1.86E-03
1.80E-04
2.27E-05
2.98E-04
4.52E-04
7.82E-04
1.21E-06
1.58E-05
7.93E-04
l,i7E-05
7.31E-08
9.53E-07
1.75E-05
4.54E-05
1.A2E-08
2.12E-07
4.56E-05
4.20E-05
3.21E-09
4.19E-08
4.21E-05
LOCATION OF
DEGREES
FRQH NORTH
348,75
326,25
11.25
348,75
348.75
326,25
11,25
11,25
348,75
326,25
11,25
348.75
348.75
326,25
11,25
348,75
348,75
326.25
11,25
348,75
348,75
326,25
11.25
348.75
CENTROID
METERS
FROM ORIGIN
250,00
250.00
250.00
250,00
250,00
250,00
250,00
250,00
250,00
250,00
250,00
250.00
250,00
250,00
250,00
250,00
250.00
250,00
250,00
250.00
250.00
250.00
250.00
250.00
                                 ,.37

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                   TABLE  4


SUMMARY OF EXPOSURES TO  877641.  PERSONS AT
  CINCINNATI  MSD INCINERATOR - POHC RUN
POLLUTANT
CHCL3
CHCL3
CHCL3
CHCL3
ecu
CCL4
CCL4
CCL4
C2CL4
C2CL4
C2CL4
C2CL4
HCCP
HCCP
HCCP
HCCP,
C2CL6
C2CL6
C2CL6
C2CL6
C4CL&
C6CL6-
C6CL6
C6CL6
ALL 1C
ALLHC
ALLHC
ALLHC
SOURCE
STACK
STRUCTURE
TANK FARM
ALL SOURCES
STACK
STRUCTURE
TANK FARM
ALL SOURCES
STACK
STRUCTURE
TANK FARM
ALL SOURCES
STACK
STRUCTURE
TANK FARM
ALL SOURCES
STACK
STRUCTURE
TANK FARM
ALL SOURCES
STACK
STRUCTURE
TANK FARM
ALL SOURCES
STACK
STRUCTURE
TANK FARM
ALL SOURCES
TOTAL EXPOSURE!
PERSON«UG/M«3
3.30EI01
4.33E-01
5.22EIOO
3.87Et01
4.47E+00
1.76E-01
2.13E+00
6.80E+00
1.94EW1
9.35E-03
1.13E-01
1.96E+01
4.16E-01
5.66E-04
4.82E-03
4.23E-01
1.13E+00
1.26E-04
1.51E-03
1.13EWO
1.05E+00
2.49E-05
3.00E-04
1.05E+00
3,60Et04
3.12E+02
3.74E+03
4,01Et04
AVERAGE INDIVIDUAL
EXPOSURE* UG/H»*3
3.75E-05
4.94E-07
5.95E-06
4.41E-05
5.09E-06
2.01E-07
2.42E-06
7.74E-06
2.22E-05
1.07E-08
1.28E-07
2.23E-05
4.74E-07
6.45E-10
7.78E-09
4.82E-07
1.29E-06
1.43E-10
1.73E-09
1.29E-06
1.19E-06
2.83E-11
3.42E-10
1.19E-06
4.10E-02
3.55E-04 ,
4.28E-03
4.57E-02
                     38

-------
 hydrocarbon  (HC)  releases and  for release
 values  of six  specified  principal  organic
 hazardous constituents (POHCs).   Concentra-
 tions at  the 176  receptors were  calculated
 for each  of  three sources and  total  for  the
 seven pollutants  (HC  + 6 POHCs).   The  three
 sources were stack emissions,  fugitive
 emissions from the incinerator structure,
 and fugitive emissions from the  tank farm
 area.

 Total Hydrocarbon Air Concentration

      For  all directions,  the maximum con-
 centration occurred immediately  downwind.
 Not surprisingly, the average  concentrations
 decrease  rapidly  with distance to  less than
 2 percent of the  maximum at a  distance of
 12.5  km downwind.

 Contribution of Sources  to HC  Concentration

      As one  might expect,  the  relative con-
 tribution to total  ground  level  HC by  each
 of  the  three release  types varies with both
 distance  and direction from the  facility.
 Table 2 summarizes  the relative  contribu-
 tion  of each of the three  sources to total
 ground  level air  concentration of HC as  a
 function  of  distance.

 POHC Air  Concentration

     With fugitive  and stack data available
 for six POHCs,  a  more detailed emission/ex-
 posure  assessment  is  possible Table 3  con-
 tains maximum concentration  and  location
 data for  six identified  POHCs.  The  largest
 POHC concentration  is 1.86 x 10->Wj/m3
 (3.75 x ID'7 ppm) of chloroform  (CHC13)
 occurring in the  sector  segment described
 by the  centroid location of 250 m from the
 incinerator on  an angle of 348.75° clock-
 wise from due north.  This concentration is
 very low,  as is the concentration of the
 most toxic POHC,  hexachlorocyclopentadiene
 (HCCP), has a maximum concentration of
 1.75 x  lO-5^ g/m3  (1.54 x 10'9 ppm).

 Population Exposure to POHC

     Exposures to POHCs are also  very low.
Total exposure  (person-/4g/m3)  ranges from
 1.05 for C6C16  to 38.7 for CHC13  while
 average individual exposure (person-/tg/m3)
ranges from 1.19 x  1Q-6 for C6C16 to 4.41 x
 TO'5 for CHC13.  Table 4 also contains  the
total exposure  and average individual expo-
sure to each POHC from each source.   Clear-
ly,  most,POHC exposure is due to  stack  re-
 leases,  but significant exposure can also
 be due to fugitive releases when the POHC
 is volatile (CHCL3 and CC14 have the high-
 est vapor pressure of the identified POHCs
 so their fugitive emission rates are high-
 er).   For example, over 14 percent of total
 exposure to CHC13 is caused by fugitive  re-
 leases whereas  only about 0.03 percent of
 total  exposure  to semi-volatile C5C15 is
 caused by fugitive releases.

 CONCLUSIONS

     Public exposure to HC from this in-
 cinerator is low.   An  assessment of emission
 sources  shows that from the site 89.8 per-
 cent of  total exposure to HC  is due to
 stack  emissions,  but that for  locations
 close  to the incinerator,  fugitive HC
 sources  may dominate (5).   Perhaps,  because
 they are emitted  near  the ground,  fugitive
 emissions have  a  disproportionately high
 effect on close-in population  exposure.

     The methodology employed  to measure
 fugitive emissions has limitations  in ac-
 curacy and  composition identification.   For
 example,  actual samples could  have  been
 taken  of the gas  emitted  from  fugitive leaks
 to  verify the chemical  composition  of the
 leak and the leak  rate,  but shortages of
 both time and_ money prevented  this.   Never-
 theless,  results  of this  study are  useful.
 Not only are future research areas  defined,
 but also this study is based on  measured
 data which,  with future measurement,  can be
 used to  characterize emissions  from  hazard-
 ous waste incinerators.

     The  emission  assessment used data from
 a test burn  for a  very well run  incinerator
 which  achieved destruction  efficiencies
 that met  or  exceeded the 99.99 percent ORE
 standard.   (In addition, the facility was
 new and,  therefore, would not be expected to
 have as many fugitive  emissions  as an older
 less well maintained facility.)  This data
 reflects only one day  of operation which is
 extrapolated to annual operation, a  simpli-
 fying assumption that may lead to large
 source term  inaccuracies.  The validity of
 this assumption needs to be studied.  The
 possibility of large,  short-term releases
 due to accidents,  spills, and sprays should
 also be investigated.  If it is assumed that
day to day operation is similar to test
burn conditions, then  it seems reasonable
to conclude that normal incinerator opera-
tion at or exceeding the standard levels
produces minimum HC emissions.   Conclusions
                                            39

-------
concerning total hydrocarbon exposure re-
quire additional qualitative and quantita-
tive composition analyses.

REFERENCES

1.   Ananth, K. P., et al., Midwest Research
     Institute, 1981.  Work In Progress.

2.   Anderson, G. E., 1981.  Human Exposure
     to Atmospheric Concentration of Se-
     lected Chemicals, Attachment B.  Sys-
     tems Applications, Inc., San Rafael,
     California.

3.   Bowers, J. F., J. R. Bjorklund, and
     C. S. Cheney, 1979.  Industrial Source
     Complex (ISC) Dispersion Model User's
     Guide.  EPA-450/4-79-030.  H. E. Cramer
     Company, Inc., Salt Lake City, Utah.

4.   Durfee, R. C., 1981.  Work In Progress.

5.   Radian Corporation, 1980.  Assessment
     of Atmosphenic Emissions from Petrole-
     um Refining, Volumes 1, 3 and 4.  EPA-
     68-02-2147, Office of Research and De-
     velopment, U.S. Environmental Protec-
     tion Agency, Washington, D.C.

6    U.S. Environmental Protection Agency,
     1981.  EPA Standard Reference Method
     21.  Federal Register 46(2):  1160-
     1161.

7.   L. Staley, memo, "Estimation of Fugi-
     tive Emissions from Cincinnati's MSD
     Incinerator."

8.   Emission Factors and Frequency of Leak
     Occurrence for Fittingsin Refinery
     Process Units, Robert Wetherold and
     Lloyd Provost, EPA, February 1979.
                                            40

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                        CHARACTERIZATION OF HAZARDOUS WASTES

                  GENERATED BY THE PESTICIDE MANUFACTURING INDUSTRY
                                  Bruce A.  Tichenor
                        U.S. Environmental Protection Agency
                    Industrial Environmental Research Laboratory
                         Research Triangle  Park,  N.C.   27711
                                      ABSTRACT

     The paper describes a program conducted to characterize waste streams from pesticide
manufacturing processes to determine whether they should be considered as toxic hazardous
wastes under Section 3001 of the Resource Conservation and Recovery Act (RCRA).  The
program is being conducted by EPA's Office of Research and Development, Industrial
Environmental Research Laboratory, Research Triangle Parks NC, in support of the Agency's
Office of Solid Waste.  The study was initiated by classifying pesticide products and
ranking them by such factors as production volume, toxicity, bioaccumulation, and per-
sistence.   The rankings were then used to select those production processes to be
analyzed.   For each process selected, an Engineering Analysis is conducted to define
the process chemistry and determine potential hazardous waste streams.  These waste
streams are then sampled at an operating pesticide manufacturing plant.  The samples
are analyzed for those parameters necessary to make a hazardous waste determination,
such as:  chemical composition, corrosivity (pH), reactivity, and EP toxicity.  The
analytical results will be combined with the engineering analysis and presented to the
Office of Solid Waste in appropriate background reports.
INTRODUCTION

Purpose

     EPA's Office of Research and Develop-
ment j Industrial Environmental Research
Laboratory, Research Triangle Park, NC,
is conducting a study for the Agency's
Office of Solid Waste (OSW) to character-
ize waste streams from pesticide manufac-
turing plants.  The purpose of the char-
acterization is to enable OSW to determine
whether specific waste streams should be
listed as toxic hazardous wastes under
Section 3001 of the Resource Conservation
and Recovery Act (RCRA).

     The study is being supported by five
contracts:  a contract with TRW to perform
engineering, analyses and assist ORD in
overall project coordination and liaison;
three contracts (with TRWj A. D. Little,
and Battelle Columbus Laboratories) to
conduct on-site sampling and laboratory
analyses of pesticide manufacturing waste
streams; and contract with the Research
Triangle Institute to perform QA/QC audits
of the sampling and analysis phases of the
study.
              the Study would evaluate all
waste streams within the pesticide indus-
try; however, the magnitude of the indus-
try (92 corporate producers, 141 produc-
tion facilities, 288 pesticide products)*
precluded 100% coverage within the pro-
* Based on 1978 data
                                            41

-------
 ject's budget and time frame.  Thus,
 priorities were established to provide
 broad coverage of the pesticide manufactur-
 ing industry.  It is emphasized that this
 selection procedure does not presume that
 the waste streams from the processes
 selected for evaluation are, in fact,
 hazardous, nor is it presumed that other
 processes do not produce hazardous wastes
 Only a careful technical evaluation can
 determine whether a specific waste stream
 is hazardous.
 INDUSTRY CHARACTERIZATION

      As discussed above, it was necessary
 to develop priorities for directing evalu-
 ations of processes within the pesticide
 manufacturing industry.   This was accom-
 plished in three steps:

      1)  Classification  of Pesticides
      2)  Ranking of Pesticides
      3)  Selection of Processes to
             be Evaluated

 Pesticide Classification

      Pesticides can be classified in var-
 ious  ways,  including by:

      a)  Use,  and
      b)  Chemical Structure

   a)  Pesticide Use

      Classifying pesticides by use  results
 in the  following breakdown:

        *  Insecticide  (I)
        • Herbicide   (H)
        *  Fungicide   (F)
        • Nematicide & Fumigant  (N)
        • Rodenticide  (R)
        • Plant  Growth Regulator (P)

  b) Chemical  Structure

     Pesticides can be classified by chem-
ical structure  into the following
categories:

       I.   Chlorinated Hydrocarbons
       II.  Organophosphates
       III. Carbamates
       IV.  Triazines
       V.   Anilides
          VI .   Organometallics
          VII.   General Nitrogenous
          VIII.  Diene-based
          IX.    Ureas & Uracils
          X.    Nitrated Hydrocarbons
          XI.    Miscellaneous

     Since the wastes produced in any
process are a function of process chemis-
try, the classification by chemical struc-
ture was deemed more appropriate than
pesticide use.

Pesticide Ranking

     The pesticide processes were ranked
according to the following parameters
[Kelso, et al.  (2)]:

     • Production Volume
     • Acute Toxicity of the Pesticide
     • Special Toxicity of the Pesticide
     • Acute Toxicity of the Raw Material
     • Special Toxicity of the Raw Material
     * Persistence of the Pesticide
     * Bioaccumulation of the Pesticide

     For each of the 288 pesticides iden-
tified, each parameter was scored zero
through four,  with zero indicating no
impact and four indicating maximum impact.
The parameter values were then summed to
give a total value for each pesticide
[Harden, et al.  (1)].

Selection of Processes

     Three criteria were used to select
the pesticide processes to be evaluated:

     1)  Chemical Classification

     For each of the 11 chemical classi-
fications, it was desirable to have
several processes represented.

     2)  Pesticide Rank

     Higher ranked pesticides were given
priority over those with lower scores.

     3)  Current Production

     Many pesticides on the initial list
are no longer produced.  Only those in
current production or planned for future
manufacture were considered for evalua-
tion.
                                            42

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     Using the above three criteria, 22
pesticide manufacturing plants covering
73 pesticide processes were initially
selected for evaluation.
STUDY DESIGN

     Each pesticide manufacturing process
selected for evaluation is subjected to a
rigorous analysis involving several
elements:

Engineering Analysis

     Using information available in the
literature as well as other information
available through EPA, an engineering
analysis is conducted for each process.
This analysis produces the following
information:

     1)  Pesticide Properties (e.g., use
         and chemical classification,
         chemical name and structure,
         molecular weight, physical prop-
         erties, solubility, and toxicity).

     2)  Raw Materials.

     3)  Process Description and Flow
         Diagram.

     4)  Process Chemistry (including
         discussions of chemical reac-
         tions and side-reactions).

     5)  Waste Stream Descriptions (includ-
         ing potential chemical composi-
         tion) .

     6)  Waste Disposal Methods (based on
         current on-site practices).

     7)  Sampling Recommendations (i.e,
         designation of waste streams to
         be sampled at an operating
         facility).

Pre-Sampling Site Visit

     A pre-sampling site visit is made to
each facility to be sampled.   The pur-
poses of the visit are:

     1)  Determine the accuracy and com-
         pleteness of the engineering
         analysis.  (The analysis is sent
          to  the  facility  for  review prior
          to  the  visit.)

     2)   Determine  accessibility  to
          sampling locations via an  in-
          plant evaluation.

     3)   Answer  questions raised  by
          industry personnel.

     4)   Determine  sampling dates con-
          venient to the plant and consis-
          tent with  production schedules.

Sampling  and Analysis  Plan

     Subsequent  to  the pre-sampling site
visit, necessary corrections are made to
the engineering  analysis, and a sampling
and analysis plan is prepared covering
the following for each process:

     • Process Flow Diagram
       (revised  as  necessary)
     • Identification  of Sampling
              Locations
     • Specification of:
          - Sample  Code Numbers
          - Sampling Devices and
                 Containers
          - Sample  Volumes and Repetitions
          - Chain of Custody Procedures
          - Safety  Requirements
     • Specification of Analytical
              Procedures
          - Defined for Each Sample
          - Referenced to Protocol
               Manual*

     This plan, prepared by the Sampling
and Analysis Contractor, is reviewed by
OSW and ORD.   When  approved, it is  sent
to the pesticide plant prior to the
actual sampling.

On-Site Sampling

     Sampling is conducted at the facil-
ity in accordance with the Sampling and
Analysis Plan.   The samples are handled
and shipped in accordance with regula-
tions regarding transportation of
hazardous materials.
+ "Sampling and Analysis Procedures for
   Pesticide Manufacturing Wastes," pre-
   pared for EPA by A. D. Little, Inc.,
   under Contract No. 68-02-3111, Task
   Directive No. 123.
                                           43

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 Laboratory Analysis
                                                PROGRAM STATUS
      The samples are sent  to  the contrac-
  tor's  laboratory and analyzed according
  Co  the Sampling and Analysis  Plan.  The
  Protocol Manual defines the analytical
  procedures; however, modifications to the
  procedures may be required depending on
  the nature of the wastes.  Parameters to
  be determined include chemical composition,
  corrosivity, reactivity, and  EP toxicity.
  The range of analytical procedures includes
  pH, TOG, SSMS, ICAP/AA, HPLC, GS/FID,
 GS/HS, FTIR.  The procedures  selected for
 each sample depend upon the expected
 composition.

 QA/QC

      The study is being conducted under a
 Quality Assurance/Quality Control Program
 developed and directed by the Technical
 Support Staff (TSS)  of EPA's Industrial
 Environmental Research Laboratory,  Research
 Triangle Park,  NC.   Each of the three
 sampling and analysis contractors is  sub-
 ject to QA/QC audits by the Research Tri-
 angle Institute,  TSS's  QA/QC contractor,
 including:

         •  Sampling Audits
         •  Laboratory Performance  Audits
         •  Data  Validation Audits

      In addition, each  sampling and analy-
 sis  contractor  has prepared and revised a
 QA/QC plan which has  been approved  by
 TSS.
     The study was initiated in April 1981.
Process/plant selection was completed in
June, at which time contacts were made with
the selected plants and confidentiality
agreements negotiated between the con-
tractors and the manufacturers.  The ini-
tial pre-sampling meeting was conducted in
September, and the first samples were
collected in October.  As of December,
preliminary engineering analyses had been
completed for 6 plants/22 processes;' pre-
sampling visits made to 4 plants/16 proc-
esses; and sampling and analysis completed
at 2 plants/4 processes.
REFERENCES

1.  Harden, J. M., A. J. Kaufman,
    S. V, Kulkarni, and J. A. Kezerle.
    1981.  Pesticide Manufacturing Over^-
    view.  EPA Contract 68-02-3174, Task
    No. 28, U.S.  EPA, Industrial Environ^-••
    mental Research Laboratory, Research
    Triangle Park, N.C. 62 pp.(Unpublished)

2.  Kelso, G.  L., R. R. Wilkinson, •
    J. R. Malone, Jr.,  and T. L. Ferguson.
    1978.  Development of Information on
    Pesticides Manufacturing for Source
    Assessment.   EPA-600/2-78-100 (NTIS
    No. PB 283051), U.S. EPA, Industrial
    Environmental Research Laboratory,
    Research Triangle Park, N.C. 413 pp.
PROGRAM OUTPUTS

     The study will  result  in  the delivery
to OSW  of a background report  for each
pesticide process evaluated.   These  reports
will include engineering analyses, the
results of the sampling and analysis
effort, and, if available, supplementary
information gathered in response to RCRA
Section 3007 questionnaires sent to  the
pesticide producers by OSW.  The reports
will be used by OSW as input to the pro-
cess of determining whether or not a
specific waste stream should be listed as
a toxic hazardous waste under  Section '3001
of RCRA.  The reports will also be used
as supporting information for  the waste
management studies being conducted by
OSW.
                                           44

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                            OVERVIEW  OF  INDUSTRY  STUDIES  PROGRAM

                                             by

                                   Francine Sakin Jacoff
                            U.S.  Environmental  Protection Agerjcy
                                   Office of Solid Waste
                                  Washington, D.G.  20460
INTRODUCTION

     The Environmental Protection Agency is
conducting studies of selected industries
tto establish an extensive information base
with .regard to the generation and manage-
ment of hazardous waste.  The goal of the
Agency is more effective regulation of such
wastes.  In a sense, the Industry Studies
will become the basis for the next major
phase of regulations under the Resource
Conservation and Recovery Act of 1976
(R.CRA), as amended.

     EPA promulgated phase I of the hazard-
ous waste regulations on May 19, 1980.
This initial phase defined and listed
hazardous wastes and established require-
ments .for generators, transporters, and
treatment, storage, and disposal facili-
ties.  Despite the scope of these regula-
tions, they still constitute only the first
major step toward the comprehensive regula-
tion of hazardous waste.  EPA promulgated
phase II of the regulations in January and
February of 1981.  the phase II regulations
set  technical standards for specific types
of hazardous waste facilities.  These tech-
nical standards provide the basis for the
issuance of permits to these facilities.

     EPA also announced a third phase of
ru-lemaking.  This will involve further
.expansion and refinement of the lists of
hazardous wastes and  the promulgation of
facility standards tailored to the degree
and  type of hazard posed by specific wastes
pr  industries.  The hazardous wastes Indus-
try  Studies will form the major information
b'ase for these tailored regulations.
OBJECTIVES

     The objectives of the Industry
Studies program are to:

     fulfill the mandate of RCRA Section
     3001 which requires that EPA identify
     and characterize hazardous waste
     streams that should be subject to
     RCRA controls:

.    develop waste management guidance
     and/or regulations tailored to degree
     and type of hazard;

«    foster recycling/recpvery/treatment
     practices as alternatives to land
    .disposal;      „

.    provide the decisionmaking infor-
     mation necessary to accomplish an
    . integrated approach toward regulation
     of industry under RCRA and other.
     acts.

APPROACH

     The effective development, refinement,
and implementation of the regulatory pro-
gram in the future requires the rapid
establishment of an extensive information
base on the generation, composition,
management and ultimate fate of wastes
produced by industry.  To this end, the
Industry Studies program consists of two
related components; a waste character-
ization component and a waste management
assessment component.
                                            45

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   The data gathered under the waste
characterization component will determine
the waste streams of concern from specific
product/production processes for listing
under 40 CFR Part 261.32 of Section 3001
of RCRA.  The waste management component
will assist in the waste listing effort
by characterizing existing practices.
Additionally it will develop an informa-
tional framework from which decision
makers can select strategies for tailoring
of management standards.  This framework
will provide an integrated approach to
the type and degree of hazard posed by
particular waste/environment/technology
situations by means of a cross cutting
analysis of various alternatives.  The
analysis will provide the necessary
elements to fulfill  the requirements of
Executive Order 12291 which calls for a
Regulatory Impact Analysis (RIA)  for
proposed regulatory actions.

STATUS

     Studies are currently underway in
various industry segments of the  organic
chemical industry including:

     •    Industry Organic Chemicals

     •    Organic Chemical Products

          -  Pesticides
          -  Dyes
          -  Pigments
                                            46

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           THE INDUSTRY STUDIES PROGRAM:  SYNTHETIC ORGANIC CHEMICALS INDUSTRY
                                           by
                         Ronald J. Turner and Robert A. Olexsey
                          U. S. Environmental Protection Agency
                       Industrial Environmental Research Laboratory
                                 Cincinnati, Ohio  45268
INTRODUCTION
     The Resource Conservation and Recovery
Act (RCRA) of 1976, under Section 3001,
requires EPA to identify and list hazardous
wastes.  EPA's Office of Solid Waste (OSW)
is currently pursuing studies to determine
the waste streams from organic chemical
production processes which should be listed
as toxic under 40 CFR Part 261.32 of RCRA.
EPA's Office of Research and Development
(ORD)  is providing assistance to OSW in
this industry studies program.  The industry
segments assigned to ORD include pesticides,
nohchlorinated industrial organic chemicals,
and dyes and pigments.  This paper summa-
rize the approach and progress to date on
the study of the synthetic organic chemicals
industry  (SOCMI) being conducted by EPA's
Industrial Environmental Research Laboratory
(lERL-Ci).
APPROACH

     In the development of: a program to
assess the environmental impact of haz-
ardous wastes from the chemical industry,
it has been necessary to  (1) break down
the industry into manageable segments for
study and  (2) determine for each segment
which product/processes are potential
sources of hazardous wastes.  Table 1
lists the  industry breakdown into segments.
It was agreed with OSW that lERL-Cincinnati
would first address the industrial organics
and the organic dyes and organic pigments
segments of the industry;  IERL-RTP would
address pesticides.  Other industry groups
would be considered as funds become avail-
able .

     In view of the magnitude of the indus-
trial organics industry,  (roughly 400
individual product/process configurations) ,
it was important to establish an approach
which would reduce the need for a plant
sampling and analysis program to the abso-
lute minimum since S&A is by far the most
expensive phase of any such program.  It
was agreed that this approach would comprise
the following steps:

1.   Screening of the industrial organic
     product/processes to establish a basis
     for a priority ranking.

2.   Selection of an initial 35 product/
     processes for detailed engineering
     analysis to determine:  1) if there are
     sufficient data for listing the wastes
     as hazardous; 2) if there are insuffi-
     cient data but there is reason to pur-
     sue gathering additional data for
     listing purpose; and 3)  there is suffi-
     cient reason for removing that product/
     process from further concern.  This
     selection was done by lERL-Ci staff
     with OSW concurrence.

3.   Those product/processes from the 35
     which remain of concern would be sub-
     jected to site visits or supplemental
     questionnaires, and subsequent sampling
     and analysis where appropriate as per
     the logic diagram described in Figure
     1.

      Step 1 was carried out  by IT Enviro-
science using the data they  had developed
in their major study for OAQPS on the
organic chemicals industry.   The ITE report
lists product/processes ranked on the basis
of the total quantity of non-aqueous wastes.
It was agreed with OSW that selection of the
 initial 35 product/processes for detailed
engineering analysis would be based on that
list.  The following additional qualifica-
 tions also were specified by OSW:
                                             47

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         TABLE 1.SUMMARY OF DATA ON THE ORGANIC CHEMICALS PRODUCTS INDUSTRIES^1)


Industry
Basic Petrochemicals
Industrial Organics
Plastics & Resins
Synthetic Fibers
Synthetic Rubber
Plasticizers
Organic Dyes/Pigments
Pesticides
Pharmaceuticals
Surfactants
Specialty Organics
Flavors/Fragrances
Gum/Wood Chemicals
Fats & Oils
Production
Chemicals
(1)
11
398
79
175
17
150
1,000
200
100
ND
ND
ND
ND
ND

Processes
(#)
28
600
20
9
18
3
48
37
25






Companies
' (#)
34
• 260
323
60
71
60
58
104
300






Facilities
(#)
107
544
400
149
141
78
87
115
525






Volume
106 #/yr
67,000
139,000
22,000
6,000
4,000
2,000
350
1,300
1





        comprises rough estimates based largely on 1976-7 information contained in
   "Industrial Process Profiles for Environmental Use"
ND • No data
                                           48

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 1.  Chlorinated hydrocarbons were not
     included  since  these  are covered  by  a
     separate  OSW study.

 2.  Product/processes already covered
     adequately  by the RCRA hazardous
     waste listing were not included.
 STATUS

      As of the date of this paper,  prelimi-
 nary engineering analyses have been com-
 pleted for most of the 35 initial product/
 processes arrangements.  (Table 2).   These
 preliminary engineering  analysis  reports
 describe the industry and the  production
 processes and identify plants  that  produce
 the  subject product.  (Table 3). Available
 data on waste streams of concern  is pre-
 sented in the reports.

    In addition, a prototype questionnaire
 has  been prepared  for the pesticide  irSdustry
 segment.   Based on this  prototype,  question-
 naires tailored to each  industry  segment
 will  be  sent to specific plants.  This
 information gathering is done  under the
 provisions of Section 3007  of  RCRA,  which
 authorizes EPA to  obtain data  on processes
 and wastes pursuant to the  listing  process.
 The prototype questionnaire  is currently
 being  reviewed by  OMB for approval  prior
 to being  sent by EPA  to  targeted industrial
 concerns.

   A prioritized list of facilities to
 be visited  has  been prepared for each
 product/ process.  Site visits are  being
 scheduled. Table 4 summarizes the current
 program status.

   The outputs from this study will be a
 series of background  reports that will
provide information to the Office of
Solid Waste to be used in its decision
process for listing product/processes.
                                           50

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       TABLE 2.FIRST GROUP OF PRODUCT/PROCESSES RECOMMENDED FOR ENGINEERING ANALYSIS
                           (TOTAL NON-AQUEOUS WASTE,  Mg/yr - ITE)
 (1) Propylene oxide via saponification of propylene chlorohydrin (1,550,000 Mg/yr)
 (2) Epichlorohydrin via ally! chloride chlorination (179,000 Mg/yr)
 (3) Glycerin via allyl chloride, hydrogenation of acrolein, and isomerization of
     propylene oxide (113,000 Mg/yr, 5,000 Mg/yr and 4,496 Mg/yr)
 (4) Propylene oxide via peroxidation of ethylbenzene (23,000 Mg/yr)
 (5) Acrylic acid and acrolein via propylene oxidation, and acrylic esters via direct
     esterification of acrylic acid (21,000 Mg/yr, 6,000 Mg/yr and 9,000 Mg/yr)
 (6) Caprolactam via cyclohexanone (11,000 Mg/yr)
 (7) Adipic acid via cyclohexanol oxidation, and cyclohexanol/cyclohexanone via
     cyclohexane oxidation (400,000 Mg/yr)
 (8) Crude terephthalic acid via oxidation of p-xylene and dimethyl terephthalate via'
     p-xylene oxidation and esterification (213,000 Mg/yr and 192,000 Mg/yr)
 (9) Ethylene oxide/ethylene glycol via ethylene oxidation (56,000 Mg/yr and
     106,000 Mg/yr)
(10) Acrylamide (all processes (1,700 Mg/yr)
(11) Bisphenol A via phenol/acetone (2,700 Mg/yr)
(12) Oxo-alcohols, including n-butyl alcohol, 2 ethylhexanol (oxo-process) (43,000 Mg/yr)
(13) Butadiene via furfural extraction and other extraction process (28,000 Mg/yr)
(14) Phenol and acetone from cumene (154,000'Mg/yr)
(15) Cumene via benzene (1,100 Mg/yr)
(16) Benzene via toluene hydroalkylation (23,000 Mg/yr)
(17) Acetic acid via butane oxidation (131,000 Mg/yr)
(18) Cyanuric chloride via HCN chlorination (128,000 Mg/yr)
(19) Hexamethylene diamine via adipbnitrile and adiponitrile via butadiene (65,000 Mg/yr)
(20) Ethylamines via ethanol ammoholysis (31,000 Mg/yr)
(21) Ethyl benzene/styrene via benzene (160,000 Mg/yr and 1,900 Mg/yr)
(22) Maleic anhydride via benzene and n-butane (23,000 Mg/yr and 3,000 Mg/yr)
(23) Methyl methacrylate via acetone cyanohydrin (1,000,000 Mg/yr)
(24) Toluene diisocyanate via toluene (116,000 Mg/yr)
(25) Methylene diphenly diisocyanate via aniline condensation and phosgene via
     chlorination of carbon monoxide (181,000 Mg/yr and 34,000 Mg/yr)
(26) Phenol via toluene (4,343 Mg/yr)
(27) Cyclohexanol via hydrogenation of xylene (11,486 Mg/yr)
(28) Carbon disulfide (15,436 Mg/yr)
(29) Lead alkyls (726 Mg/yr)
(30) Isophthalic acid via oxidation of xylene (2,996 Mg/yr)
(31) Ethylene from natural gas and heavy liquids (307,812 Mg/yr and 205,208 Mg/yr)
(32) Methyl amine via ammonolysis of methanol (5,866 Mg/yr)
(33) Dimethyl hydrazine (4,485 Mg/yr)
(34) Ethylene diamine via ammonolysis of ethylene dichloride (2,978 Mg/yr)
(35) Acetic anhydride (5,599 Mg/yr)
                                             51

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                     TABLE 3:PRODUCT/PROCESS REPORT CONTENTS
                     INDUSTRY DESCRIPTION

                     PROCESS DESCRIPTION

                     INTERMEDIATE PROCESS STREAMS,  PROCESS WASTES,
                     BY-PRODUCTS

                     DISCUSSION ON AVAILABLE INDUSTRY INFORMATION

                       .  types and quantities of wastes generated

                       •  identification of known waste stream constituents

                       •  pollution control equipment

                       •  waste management practices
           TABLE 4.STATUS OP SYNTHETIC ORGANIC CHEMICALS STUDY  (3/82)


                                    Completed

1)  Development of Preliminary Engineering Analyses for 35 product/processes

2)  Drafted Questionnaires for 35 product/processes

3)  Evaluated Industry Responses for 2 product/processes

4)  Assigned 10 additional product/processes for Engineering Analysis (12/81)


                                 To Be Scheduled
1)  Pre-sampling Plant visits

2)  Sampling and Analysis as Required
                                        52

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                    THE INDUSTRY STUDIES PROGRAM:  The Organic Dyes and
                               the Organic Pigments Industry
                                       Robert  Olexsey
                            U.S.  Environmental  Protection  Agency
                        Industrial  Environmental  Research  Laboratory
                                  Cincinnati, Ohio:  45268

                                      Yvonne M. Garbe
                            U.S.  Environmental  Protection  Agency
                                   Office of Solid Waste
                                  Washington, D.C.  20460
INTRODUCTION

     The Resource Conservation and Recovery
Act (RCRA) of 1976, under Section 3001
requires EPA to identify and list hazardous
wastes.  EPA's Office of Solid Waste (OSW)
is currently pursuing studies to determine
which waste streams from particular pro-
duction processes of organic chemicals
should be listed as toxic under 40 CFR  •
Part 261.32 of RCRA.  EPA's Office of
Research and Development (ORD) is providing
assistance to OSW in this industry studies
program.  The industry segments assigned
to ORD include pesticides, non-chlorinated
industrial organic chemicals, dyes and
pigments.  This paper summarizes the
approach and progress to date on the study,
of the organic dyes industry and the or-
ganic pigments industry being conducted by
EPA's Industrial Environmental Research
Laboratory in Cincinnati, Ohio (IERL-Ci).

APPROACH

     The organic dye and organic pigment
industries are made up of approximately 70
plants which manufacture on the order of
2000 products.  Most products are of rela-
tively low volume compared to synthetic
organic chemicals  (SOCMI) products, but
there are indications that there may be
toxic waste streams produced from these
batch process operations.
The approach to this waste survey program
was to delineate a group of chemical
classes which included those organic dyes
and pigments which are most likely to have
associated wastes of concern, based on
engineering judgment and existing toxico-
logical information.

     The chemical classes which have been
selected include the following:

1.   Azo and Azoic dyes and pigments
     including the subclass benzidine and
     benzidine congener dyes and pigments.

2.   Anthraquinone dyes and pigments

3.   Stilbene dyes and pigments, including
     fluorescent brighteners

4.   Sulfur dyes and pigments

5.   Phthalocyanine dyes and pigments

6.   Poly-aryl methane dyes and pigments

7.   Methine and polymethine dyes and
     pigments

8.   Xanthene dyes and pigments.

     It is estimated that 80$ of the total
production volume of organic dyes and
organic pigments is covered in the Azo and
Anthraquinone classes.  •
                                            53

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     Selection of the number of product/
processes for each class will vary with the
intention of choosing a representative
group.

     It is very possible that the best
waste candidates for listing under RCRA
will exist as a result of manufacture of
intermediates.  Synthesis of intermediates
frequently involve use of chlorinated
hydrocarbon solvents which when reclaimed
could yield hazardous still bottoms.

     Other waste concerns involve the many
amine intermediates that are toxic or are
suspected carcinogens.  Benzidine from
benzidine dye manufacture was the first
major documented occupational cancer
causing problem in the chemical industry.
A waste which contains significant amounts
of benzidine or its congeners would be
considered potentially hazardous.

CURRENT PROJECT STATUS

     The waste survey program for the or-
ganic dye and tb,e organic pigment indus-
tries is being conducted by three con-
tractors. »0ne of the contractors, SRI, is
providing industry background documents for
each of the dye and pigment chemical
classes.  The other contractors, TRW and
6CA, are responsible for conducting the
plant surveys and subsequent sampling and
analyses.

     TRW and GCA are now in the final
stages of making initial industry contact
by verifying the number and types of dyes
and/or pigments produced at selected
plants.  Follow-up contact (e.g., site
visits, questionnaires, and/or sampling and
analyses) should begin early spring 1982.
                                            54

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                       FIGURE 1
                Dye and Pigment Plants
       Hazardous Waste Characterization Program
                     Logic  Diagram
                Select Plants to Cover
                   Chemical Classes
                                    I
Contractor
Literature search

& prel iminary
engineering analysis

s
X
Project Officer
initiates plant
contact
f


Reject
Plant

                      Plant Visit
               Set up secrecy agreement
          Contractor
       Preliminary draft.   Contact
       by telephone to verify current
       product/process
       Select product/process wastes of concern
     Information
      inadequate
Subsequent Sampling & Analysis
            of Waste
Information
   adequate
              Listing Background Document
                          55

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                           INCINERATION TECHNOLOGY FOR SELECTED
                         SMALL QUANTITY HAZARDOUS WASTE GENERATORS
                         Victor S. Engleman and D. L. deLesdernier
                                Science Applications, Inc.
                                       La Jolla, CA
                                           and
                                      Sidney F. Paige
                                       JRB Associates
                                         McLean, VA
                                          ABSTRACT
The purpose of this study is to assess the application of incineration technology for
destruction of small quantities of hazardous wastes generated by hospitals, universities,
research stations, and related industrial sectors.  The work includes characterization of
the hazardous waste, geographic locations and nature of activities of generators.  Quan- ,
titles and applicability of available incineration technology are assessed for selected
cases.  A number of incinerator types were examined in the study and selected hazardous
waste generators were contacted to determine their needs, problems, approaches, and
experience with incineration of toxic and hazardous wastes.  The generators included in
this study represent a diversity of waste types as well as quantity and frequency of
generation.  The special problems that this diversity provides for the application of
incineration are addressed in the paper.
INTRODUCTION

     While small volume generators (SVG's)
of hazardous wastes (with certain except-
ions, those that produce less than 1000 kg/
mo) are exempt from many of the provisions
of RCRA, the problems they face in disposal
of these wastes are similar to those faced
by large volume generators.  Since many
SVG's depend for waste disposal on contract
haulers and other outside organizations who
themselves are regulated by RCRA, they
still must comply with many of its require-
ments.

     Hospitals, universities and research
organizations represent a particularly
challenging set of problems for hazardous
waste disposal.  They generate a variety
of hazardous waste types from pathological
and infectious wastes to inorganic and
radioactive wastes.  In addition the waste
mix can vary substantially over a period
of time depending on the nature of activi-
It
ties at the facility.

     Increasing numbers of articles have
appeared recently in newspapers concerning
illegal dumping of hospital wastes and
improper disposal .of infectious wastes.
is not always clear from these articles
whether the problem is that these wastes
are placed in a proper landfill but are
properly sterilized, or that they are being
dumped in improper locations.  However, the
use of dumps or landfills for wastes of
this type does not represent an ultimate
solution since the wastes have not bee'n
destroyed.  On the other 'hand, incineratiohj
when effective, can convert hazardous
materials to innocuous forms.  However, in'-
cineration is hot applicable to all wastes
and may not be applicable to specific faci-
lities.  The purpose of this study is to
assess the application of incineration tech-
nology for destruction of small quantities
of hazardous wastes generated by hospital's,
universities, and research facilities.
                                            . 56

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CHARACTERIZATION OF WASTE

     The wastes produced by the three types
of generators under consideration generally
fall into ten categories: infectious wastes,
pathological wastes, carcinogens, waste
Pharmaceuticals, waste solvents and oils,
pesticides, explosives, radioactive wastes,
acids and alkalis, miscellaneous organic and
inorganic chemicals.  Infectious wastes are
contaminated with disease-carrying agents
and therefore require special' handling so
that they are not disseminated in the com-
munity.  The moisture content and heating
value varies considerably from burnable
solids to infected liquid specimens.  Path-
ological wastes, which are sometimes group-
ed with infectious wastes, are not specifi-
cally infectious but are subject to bio-
logical decay and may become a breeding
ground for disease carriers.  These wastes
are generally high in moisture content and
require auxiliary fuel for combustion.
Carcinogens are hazardous compounds and,
while many are combustible, they require
special handling to prevent dispersion
before combustion and they must be incin-
erated to a high degree of destruction.
Carcinogens are generated in relatively
small quantities.  Waste Pharmaceuticals
which are more likely to be generated by
pharmaceutical' industries than by the sub-
ject SIC's, are generated by hospitals in
small quantities and consist of drug resi-
dues and waste pills and capsules.  Con-
trolled substances may be subject to special
accountability.  Solvents and oils are
generally flammable liquids consisting of
hydrocarbons, chlorinated hydrocarbons, and
sulfur-containing solvents.  The value of
these materials makes them attractive for
recovery and reuse if the waste mixture
does not contain too many components.  Waste
pesticides are usually generated in low
volume or consist of spent containers.
These are generally organic materials and
include chlorinated hydrocarbons and phos-
phorus compounds.  These are incinerable in
special equipment with flue gas scrubbing
but are generally not recommended for in-
cineration in standard equipment.  Explo-
sives likewise are incinerable in special
equipment, but handling and cleanup require-
ments make these generally unattractive for
incineration.  Radioactive wastes are con-
trolled by special licensing procedures and
Will not be addressed here.  While many low-
level radioactive wastes are incinerable,
the incineration process does not change
the radioactivity of the substances, and
special handling and effluent controls would
 be  required.   Acids  and  alkalis  are  general-
 ly  liquid  wastes.that  are  corrosive  and
 poisonous.   They are most  easily handled  by
 neutralization and are not generally amena-
 ble to  incineration.  A  wide  variety of
 other organic  and inorganic substances may
 be  generated at research facilities  depend-
ing on  the specific  nature of ongoing
 research.
 GENERATION OF WASTE

      The applicability of incineration  may
 depend not only on  the characteristics  of
 the waste generated but also on  the quanti-
 ties and frequency  of waste generation  and,
 to a certain extent, on geographic location.
 The generation of consistently large quanti-
 ties of combustible hazardous waste makes
 on-site incineration more attractive pro-
 vided local  regulations can be met.

      Only limited data are available on the
 quantity and frequency of waste  generation
 and the data base is not sufficient to  pro-
 vide precise quantitative information.   How-
 ever, it appears that qualitative  and direc-
 tional information  can be derived  from  the
 data.  The information below was drawn  pri-
 marily from Reference 1 with cross-checks
 from a number of facility contacts made
 under this study.  While in some cases  the
 number of establishments contacted in this
 study exceeded the  number on which the
 statistics in Reference 1 were based, the
 information was generally in qualitative
 agreement.

      For the purposes of this study, small
 volume generators are those which  produce
 less than 1000 kg/mo of hazardous  waste.
 While RCRA controls certain substances  at
 lower generation rates, the 1000 kg/mo  value
 was used to examine the generation data
 base.  To put things in perspective for the
 three types of waste generators  under con-
 sideration, SIC 28-Chemicals and Allied
 Products produces a total If 1500  x 106
 kg/mo of hazardous  waste.  Small volume
 generators within SIC 28 (those  producing
 less than 1000 kg/mo produce a total  of 4.5
 x 106 kg/mo.

      Small volume generators in  the subject
 SIC codes produce the following  quantities
 of hazardous waste:

      •  SIC 806 - Hospitals
           0.8 x 106 kg/mo
      •  SIC 8071 -  Medical  Laboratories
                                            57

-------
            0.3 x 10s kg/mo
      •  SIC 822 - Colleges, Universities,
         Professional Schools, and Junior
         Colleges
            0.2 x 106 kg/mo
      •  SIC 892 - Noncommercial  Educational,
         Scientific, and Research Organiza-
         tions
            0.05 x 10G kg/mo
      •  SIC 7391 - Research and  Development
         Laboratories
            0.3 x 106 kg/mo
      *  SIC 7397 - Commercial  Testing
         Laboratories
            0.3 x 106 kg/mo

 It is important to emphasize that the above
 numbers  are based on limited data but are
 probably directionally correct.

      Census data were used in Reference  1 to
 provide  a breakdown by SIC code  of the num-
 ber of facilities in each  EPA region.  Using
 the assumption that small  volume generators
 are distributed geographically the same  way
 as all generators within the SIC code, Table
 1  provides an approximate  distribution of
 small  volume generators in the subject SIC
 codes.

      Using the above numbers for total
 quantities of hazardous wastes generated by
 small  volume generators and the  total  number
 of small  volume generators,  Table 2 provides
 an idea  of the average rate of hazardous
 waste  generation and the relationship  of
 small  volume generators to all generators in
 the SIC.
CURRENT WASTE MANAGEMENT PRACTICES

     Methods by which each of the waste
categories mentioned in a previous section
are managed by small and large volume gen-
erators will be discussed briefly.  For the
most part there are few differences in the
types of management practices used by small
and large generators, but economy of scale
will favor one management technique over
another.  In general, economics will deter-
mine the specific choice from among those
available.

     Infectious and pathological wastes are
generally treated by one of three methods.
They are usually disinfected by autoclaving,
or chemical treatment, or incineration, and
the residue is contract hauled or disposed
of as normal trash.  Waste drugs are gener-
ally incinerated on-site, returned to the
 manufacturer,  diluted to the sewer or sent
 to a drug enforcement agency.   Oils and
 solvents are generally sent to a recycler,
 treated for reuse on-site,  drummed and
 contract hauled,  or burned  in  a boiler or an
 incinerator.  Waste pesticide  liquids are
 generally drummed and contract hauled.
 Empty containers  are generally rinsed to the
 ground or the  sewer and the rinsed contain-
 ers are disposed  in the normal  trash.   Acids
 and alkalis are generally neutralized and
 diluted to the sewer.

      The wastes that are most  amenable to
 incineration from the  above are infectious
 and pathological  wastes, some  waste pharma-
 ceutical s, waste  solvents and  oils, and mis-
 cellaneous 'organic chemicals.   Decisions on
 the most suitable method for disposal  will
 be made on site-specific and economic  bases.

      Other methods that may help  reduce the
 ultimate amount of hazardous materials  dis-
 carded have been  suggested.  Management
 controls on procurement policy  to  discourage
 the ordering of surplus chemicals  and  to
 encourage recycling of chemicals may make a
 contribution to reducing the amount of  waste
 but will  not completely solve the  disposal
 problems.  (2)

      Contract  hauling  handles many problems
 for the waste  generator including  responsi-
 bility for disposal  and legal and  regulatory
 requirements.  However,  the  waste  generator
 may still  be liable  if the  contract  hauler
 disposes  of the hazardous material  improper-
 ly.   For some wastes contract hauling is the
 only viable solution.

      Incineration,  if  applicable and effec-
 tive,  provides an  ultimate  solution  to  the
 waste  disposal problem.  As  opposed  to  land
 disposal where the hazardous material still
 have the potential to  create environmental
 problems,  incineration  converts the  hazard-
 ous material into an innocuous form.  Un-
 fortunately, especially for  small volume
 generators,  there are operational, energy
 and economic problems that may limit its
 usefulness.
APPLICABILITY OF INCINERATOR TECHNOLOGY

     Since the current study is still  in
progress, it is premature to draw final
conclusions, but a number of incinerator
types have been examined and selected  haz-
ardous waste generators have been contacted
to determine their needs, problems,
                                            58

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approaches, and experience with incineration
of toxic and hazardous wastes.  Some of the
salient points will be summarized in this
section.

     Thirty-nine incinerator manufacturers
were contacted to obtain information on the
availability of incinerators for destruction
of hazardous wastes from small volume
generators.  Units with capacities as low as
11 kg/hr were found.  As waste generators
were contacted about their experience, addi-
tional  incinerator manufacturers were iden-
tified.  The approaches varied widely from
manufacturer to manufacturer.  The most
highly  developed hazardous waste incinera-
tion technology is represented by rotary
kiln and liquid injection incinerators.
Fluidized  bed and multiple hearth incinera-
tors are also commercially available.  A
number  of  innovative and emerging technolo-
gies, including starved air combustion/
pyrolysis, molten  salt incineration, molten
glass incineration and plasma  arc pyrolysis
have also  been put into use.   The assess-
ment of incinerators has not  been completed
at the  time of writing.  Descriptions of
the more common types of incinerators, their
status, wastes handled, advantages and dis-
advantages may be  found in EPA's  Engineering
Handbook for  Hazardous Waste  Incineration.
 (1)

     A  recent paper  from the  National
 Institutes of Health (2)  reported on  a
 screening  study of five incinerators  for
 their  general  suitability  for destruction
of  hazardous  organic chemicals.   Five  units
were  tested  1) a  two-chamber  refractory-
 lined  incinerator, 2)  a three-chamber,  ver-
 tically-aligned  incinerator,  3)  a dual-
 chamber,  rectangular incinerator, 4)  a  dual-
 chamber,  refractory-lined,  batch incinera-
 tor,  5) a  molten  salt catalytic  incinerator.
 An  organic chemical  tracer was used to
 monitor the  effectiveness  of  destruction  of
 common  organic chemicals  and  a fire retard-
 ant chemical  was  used to  monitor the ef-
 fectiveness  of combustion.   In addition,
 hydrocarbons, nitrogen oxides, hydrogen
 chloride,  sulfur oxides,  and particulates
 were monitored.  As indicated in Table 3,
 all  units demonstrated relatively good per-
 formance although Unit 5  had some problems
 with hydrocarbons and particulates, possi-
 bly caused by short-duration smoke  emissions
 after charging.

        Incineration offers significant ad-
 vantages in disposing of wastes consisting
 primarily of organic materials with high
heating values.   Unlikely candidates for
incineration are heavy metals, high-moisture
content waste, inert material, inorganic
salts, and material  with high inorganic con-
tent.  A number of small volume generators
already make use of incineration for wastes
not currently regulated by RCRA and it
appears that a number of units show promise
for waste disposal at hospitals, univer-
sities and research facilities.  While RCRA
does not require trial burns for small vol-
ume generators disposing of hazardous wastes
by incineration, many want assurance that a
particular incinerator can achieve a des-
truction/removal efficiency of 99.99% with
their mix of wastes.
REFERENCES

1.  Ghassemi, M., et^ al_ 1979.  Technical
    Environmental Impacts of Various
    Approaches for Regulating Small Volume
    Hazardous Waste Generators.  Final
    Report, Contract 68-02-2613 Work
    Assignment 27 and Contract 68-03-2560
    Work Directives T-5012, T-5014, and
    T-5015, U.S. Environmental Protection
    Agency, Washington, D.C.

2.  Rogers, H.W. 1979.  Hazardous Wastes-
    New Developments.  J. American College
    Health Association 28:  158-164.

3.  Bonner, T. e_tal_ 1980.  Engineering
    Handbook for Hazardous Waste Inciner-
    ation.  Draft Final Report, Contract
    68-03-2550 Work Directive T1016, U.S.
    Environmental Protection Agency,
    Cincinnati,  OH.
                                             59

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                                              62

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                      HAZARDOUS  WASTE CONTROL TECHNOLOGY DATA BASE

                                  Richard L.  Holberger
                                 The MITRE Corporation
                                    McLean,  VA  22102

                                     Dr.  C.  C. Lee
                          U.S.  Environmental Protection Agency
                                 Cincinnati,  Ohio  45268

               *
     This paper describes the program to develop an automated data base storing technical
information on the thermal destruction of hazardous wastes.   The data base will store
detailed design, .operating, and performance data obtained from incineration.facility
permit applications, trial burn reports, research and development projects, and contractor
data gathering efforts.  The paper describes the development process itself and presents
some of the details of the system as it will be implemented, including descriptions of the
data content and structure, and input and retrieval features.
INTRODUCTION

     Incineration has long been an impor-
tant technique for the destruction of
hazardous waste.  Recently, however,
especially since the passage of the
Resource Conservation and Recovery Act
(RCRA), incineration practices have begun
a period of rapid advances in technical
sophistication and complexity.  Many new
systems are evolving using a diverse group
of thermal destruction concepts and designs.

     As required by RCRA, EPA is developing
a regulatory program addressing the incin-
eration of hazardous wastes.  In order to
insure that this program is developed and
implemented with the benefit of the most
current industry experience with advanced
incineration techniques, there is a need
for EPA to obtain and analyze technical
design and operating data from both exist-
ing incineration facilities and research
activities in this area.

     As part of its support to the Office
of Solid Waste, the Incineration Research
Branch (IRB) of the Industrial Environmen-
tal Research Laboratory in Cincinnati has
a multi-faceted program underway to develop
such a data base, which will be called the
Hazardous Waste Control Technology Data
Base  (HWCTDB).  The objectives of this data
base are:
•  to provide direct technical support
   to^Regional permit and compliance
   programs, especially in the evalua-
   tion of requests for trial burn
   exemptions;

•  to form a sound technical basis for
   development and promulgation of
   future revisions of regulations for
   hazardous waste incinerators;

•  to define the range of current
   engineering practice, particularly
   regarding the performance associated
   with various design and operating
   characteristics;

•  to provide a foundation on which to
   plan future R&D efforts addressing
   thermal destruction of hazardous
   wastes.

   The data base will store detailed tech-
nical design, operating, and performance
data obtained from incineration facility
permit applications, trial burn reports,
research and development projects, and con-
tractor data gathering efforts.  Specific
data content was chosen based on a user
needs study conducted early in 1981
(Barrett, et. al., 1981), and on the infor-
mation requirements for permit evaluation as
                                            63

-------
 identified in the "Guidance Manual for
 Evaluating Permit Applications for the
 Operation of Hazardous Waste Incinerator
 Units" (Vogel, et. al., 1981).

      This paper describes the program to
 develop the data base as well as some of
 the details of the system as it will be
 implemented.  Since the system will not be
 completed until early 1982,  several months
 after preparation of this paper,  some of
 the details described here may be modified
 slightly in the operational system.  The
 program to develop this data base consists
 of three major phases, as described below:
 initial development,  implementaion, and
 system operation.

 INITIAL DEVELOPMENT

      The initial development phase was
 completed by the MITRE Corporation this
 summer.  It consisted of a user needs sur-
 vey to identify user  requirements for both
 content of and access to the data base,  a.
 review of existing data bases for potential
 implementation of  the HWCTDB,  and the de-
 velopment of an initial list and  descrip-
 tion of desired data  elements.

      The user needs study identified six-
 teen organizations within EPA and DOE as
 potential users of the data  base.   Discus-
 sions with various members of each
 organization indicated a need for obtaining
 a  wide range of data  on both administrative
 and technical features of incineration
 facilities,  as well as other types of
 facilities  destroying hazardous wastes.
 Further,  a strong  preference was  expressed
 for on-line retrievals and the ability to
 sort by many  different criteria,  including
 various waste characteristics and a range
 of incineration design and operating
 features.

      To minimize the  time and effort  re-
 quired for  system  development and  user
 training, and  to maximize standardization
 of EPA's  information  systems, an  effort was
 made to identify an existing data  base
 which could be easily  adapted to meet  the
 needs  defined  above (Dratch and Keitz,
 1981).  A review of EPA's  System Informa-
 tion Directory  (US EPA, 1980) revealed
 seven potentially  applicable data  bases.

     Further analysis narrowed the consi-
 deration to two systems:  the Hazardous
Waste Data Management System (HWDMS),
 operating for OSW,  and the Environmental
 Assessment Data Systems (EADS),  managed  by
 ORD.   Both utilize  Intel Systems Corpora-
 tion's System 2000  Data Base Management
 System to organize  their data.   Analysis
 of the two systems  indicated that each
 could be adapted to meet the needs of
 HWCTDB.   EADS is well suited to  storage  of.
 source characterization and emissions  test
 data, but would still require special  pro-
 grams to obtain many of the common sorting
 and retrieval capabilities desired by
 users.   HWDMS is designed to store and
 organize information received in applica-
 tions for hazardous waste facility permits.
 Current  plans are to expand the  data base-
 in phase with OSW's permit program to  even-
 tually include the  data received on Part  B
 applications.*  HWDMS,  therefore,  already
 contains the  administrative information
 desired  by users and would eventually  con-
 tain  much of  the technical design and
 operating data required on Part  B  facility
 permit applications.   Further HWDMS is
 already  familiar to and used by  OSW (who
 will  be  one of the  major users of HWCTDB),
 has a user-support  group in the  EPA Region-
 al Offices, and has a more versatile data
 input system  to facilitate data  entry and
 validation.   The planned expansion of HWDMS
 would also  provide  the  opportunity to build
 the desired capabilities into-the primary
 structure of  the data base.   Therefore, a
 recommendation was  made  to  build HWCTDB as
 an expansion  of HWDMS.

      The  final portion of  the initial de->
 velopment phase was the  construction of a
 preliminary data  dictionary describing the
 desired data  elements and their relation to
 each  other  (Holberger, 1981).  A total of
 155 data  elements,  grouped into 22 record
 groups (repeating .groups) were identified.
 This  effort also  included specification of
 some  of the reports and retrievals which
would be  requested  from the system.
*The application process for obtaining a
hazardous waste facility permit occurs in
two stages.  The Part A application re-
quires administrative information and a
general description of the facility.   It
is the basis EPA uses for granting interim
status.  The Part B application will con-
tain the detailed technical data necessary
for EPA's evaluation of the ability of the
facility to meet the requirements for a
full hazardous waste facility permit.
                                            64

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IMPLEMENTATION PHASE

     The Implementation Phase consists of
three parts:  systems development and
documentation, data collection, and accep-
tance testing (which includes the initial
data loading).  Both the systems develop-
ment and data collection portions are
underway as of this writing.

Systems Development and Documentation •

     This effort includes the finalization
of the system requirements; system design,
systems programming, documentation and
user training.  (Documentation and user
training activities will also extend into
the system operation phase.)  The final
system design, the systems programming,
and the software-related portions of the
documentation arid user training will be
prepared by the Computer Sciences Corpora-
tion (CSC), based on the system require-
ments specified by EPA and MITRE.  As of
this writing, the data dictionary is being
completed with the addition of edit cri-
teria and specification of required data
for input to the data base; a preliminary
system design is being prepared for final
review; CRT screen formats are being devel-
oped for data entry; and final report
formats and retrieval criteria are being
prepared.

     Figure 1 shows the structure and con-
tent of the data base as of this writing.
Final implementation may differ slightly.
At present, there are 159 data elements in
21 records (repeating groups).*  The pri-
mary record under which the others are
organized is the CO, or Facility Record.
It contains much of the administrative data
presently existing in HWDMS.  Each facility
would have one Facility Record.  All other
records would be considered descendants of
the Facility Record, and may occur many
times for each facility.  For .example,' a
given facility may burn more than one
waste, and each waste will contain numerous
constituents, some of which will be desig-
nated as Principle Organic Hazardous Con-
stituents (POHC's).  Therefore, the name of
each constituent analyzed in the waste, its
concentration in :t.he waste, and a flag in-
dicating its status as a POHC would com-
prise a separate Waste Composition Record
(C2840) descending from the Waste Charac-
terization Record (C1800) organizing the
complete description of that waste.  Each
group of records describing a single waste
stream (consisting of one C1800 record and
all its descendants) would be a separate
repeating group descending from the Facili-
ity Record (CO).

     As designed, the HWCTDB will store in-
formation on multiple units at each facil-
ity, each with multiple sets of operating
conditions.  Separate descriptions of de-
sign and operating conditions will be main-
tained for each chamber of multiple chamber
facilities, and many separate waste streams
may be associated with each chamber.  Since
the Waste Characterization Record is not a
descendant of the Operating Conditions
Record Group, data may be stored describing
the destruction of the same waste stream
under many different operating conditions
or designs without repeating the waste
description.  The use of comments describ-
ing distinctive characteristics of any
portion of the facility or its operations
is encouraged, with comment numbers design-
ed to indicate the subject of each comment.

     The system programming and CSC's in-
ternal testing will be conducted during the
winter of 1981-1982, with a planned turn-
over date in early spring 1982.  The pro-
gramming effort will involve actual con-
struction of the data base, programs to
load information from and maintain consis-
tency with HWDMS permit data, programs for
report generation, and the provisions for
a few special retrievals expected to be too
complicated for most users.

     Documentation of the data base will
include preparation of a System Management
Summary, System User's Guide,"System
Maintenance and Operations Manual and
Technical User's Guide.  The first three
documents will address the system-oriented
procedures for manipulating and maintaining
the data base.  The fourth document will
address the non-computer oriented user
community, providing descriptions of
methods to maximize utility of the data
base to support both regulators and re-
searchers.  User-training sessions will
proceed in parallel with the documentation.
*In this discussion, a record or repeating
group is defined as a group of related
data elements describing one particular
aspect of a facility and its operations.
Each record and each data element has been
assigned a .reference number prefixed by
the letter C.
                                            65

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Data Collection

     The second part of the implementation
phase is data collection.  The MITRE Cor-
poration has completed a task to obtain
data from manufacturers of incineration
systems, documented in "Profile of the
Hazardous Waste Incinerator Manufacturing
Industry" (Frankel, et. al., 1981).  Under
a separate task, MITRE has also begun
collecting information from operating
incineration facilities.  Data is collected
through telephone and personal interviews
with facility operators who have submitted
RCRA permit applications.  Data collected
during this and subsequent tasks will be
recorded on data entry forms designed to
correspond to the CRT screens used during
data entry to the system.

     Incorporation of this data into the
automated data base will not occur until
the acceptance tests are underway.  After
the initial loading of the data base, data
will be input to the system using full
screen CRT terminals connected to EPA's
PDF-11/70 minicomputers.  Figure 2 is an
example of one of the screens which will
be used to input data for the Major Compon-
ent Description Record (C3430).  The first
two lines identify the facility and design
records to which the data applies.  The
screen then contains a list of the elements
in the record, along with blanks sized for
the maximum length of each element.  The
cursor will automatically move from one
field to the next, allowing inputs only in
the appropriate positions.  As each data
element is entered, the edit program will
check to ensure that it is a valid entry.

     The edit procedure is a series of
computer programs which check that each
entry fits the description for the appro-
priate data element (i.e., correct type -
decimal, integer, or alphanumeric; and
correct number of characters)  and that the
entry has a valid value (some of the data
elements, such as the Item Code,  are re-
stricted to certain sets of common terms
or codes; other numeric data have valid
ranges,  outside of which they will not be
accepted by the data base, e.g.,  no
combustion temperatures will be allowed
outside the range 500-4000°F).  If the
screen entry does not pass the edit test,
the program will print an error message
and give the operator the opportunity to
correct it immediately.   After data for
each element has been entered on the
screen, the program will, give the operator
another opportunity to correct any errors
not detected by the edit program.

     After completing the entries for one
major incineration system component (e.g.,
.for the description of the waste feed
system), the operator may then request
another repetition of the screen for entry
of an additional record (e.g., for the
description of a venturi scrubber), or may
request the screen for a different record
group (e.g., for the data elements com-
prising the Monitor System Description
Record (C3460) ?t When the data meets the
approval of both the operator and the edit
procedure, the program will construct an
update file for later entry on the full
data base, which will physically reside in
EPA's IBM 370 in Research Triangle Park.

Acceptance Testing

     The final portion of the implementa-
tion phase is the acceptance testing and
system initialization, which will begin
as CSC completes the system programming
and "turns over" the software to EPA.  The
testing procedure will exercise each sys-
tem function (data entry, edits, update,
retrieval, etc.) with both valid and in-
valid "dummy" data.  System performance
will also be evaluated relative to the
design requirements.  Any deficiencies
will be noted for correction.  All data
introduced during the acceptance test will
be deleted after successful completion of
the test procedure.

     System initialization and performance
testing will begin with the initial load-
ing of "live" data on the data base, in-
cluding both the conversion of data from
the HWDMS and the entry of data collected
up to that time.  System performance and
integrity will be monitored closely for
several months to detect previously un-
discovered problems.  This effort will be
coordinated with user-training activities
and the establishment of procedures for
use of the data base by ORD and Regional
EPA personnel.

SYSTEM OPERATION

     The system operation phase of this
project includes completion of documenta-
tion and user training efforts and contin-
uation of data collection and entry as
described above, long term data base
                                            70

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management and maintenance, data base
Utilization, and continued system evalua-
tion and enhancement  (as required).

     Long term management and maintenance
will involve designating a data base admin-
istrator (DBA) who will be responsible for
access to the data base, data integrity,
file maintenance, backup and recovery
procedures, periodic  reconciliation with
1IWDMS, and monitoring the continued devel-
opment and use of the data base.  The DBA
will also control the data entry process,
taking the update files created by the
edit programs and incorporating them in
the data base.

     ,A user support group will be estab-"
lishcd to provide a retrieval service for
any users requiring assistance.  This
group will maintain a library of special
retrieval programs of general interest to
the user community, provide assistance in
formulating retrieval requests and inter-
preting outputs, and will operate an on-
line news service to  keep users informed
on new retrievals or  other items of inter-
est pertaining to the data base.  The user
support group will also coordinate the
creation and distribution of additional
documentation and the training .of new
users, as necessary.

     The system is being designed so that
many of the common retrievals may be per-
formed quickly in interactive terminal
sessions using System 2000's Natural
Language.  To perform such retrievals, the
user requires knowledge of the data base
logical structure (Figure 1), and usually
needs to attend a short user-training
course to learn the concepts of Natural
Language.  No other computer-related ex-
perience will be required for simple
retrievals.

     The basic retrieval procedures will
involve using Natural Language to identify
facilities with certain combinations of
characteristics (e.g., commercial liquid
injection units operating under starved
air conditions within a certain tempera-
ture range).  After identifying the facil-
ity identification number (element C101)
and any other information needed to unique-
ly identify the records meeting the selec-
tion criteria (e.g., waste sequence number
or system index), the user may choose one
or a combination of several output report
formats.  A list of the standard reports
and a summary of their contents is presen-
ted in Table 1.  A user may augment the
reports by requesting additional data
elements, depending on his needs.

     The final aspects of the system opera-
tional phase are continued evaluation and
enhancement, which include on-going evalua-
tion of system performance with respect to
both the original objectives and to the
continued evolution of EPA's programs.  An
annual assessment .will be prepared to,
document the current system performance,
identify new program needs which could be
met by the data base, and suggest enhance-
ments which would increase the utility of
the data base or improve procedures iden-
tified by users as cumbersome.  Recommended
enhancements could include the development
of additional retrieval capabilities and
new reports, modifications to the data
content or structure of the data base, or
simple expansion of the supporting documen-
tation.

REFERENCES

1.  Barrett, K., D. Dratch, and E. Keitz.
    1981.  User Needs Interviews for a
    Hazardous Waste Incineration Facility
    Data Management System.  WP-81W00140,
    MITRE Corporation, McLean, Virginia.

2.  Dratch, D., and E., Keitz.  1981.   A
    Review of Existing Information Systems
    for Potential Use with Hazardous Waste
    Incineration Facility Data.
    WP-81W00268, MITRE Corporation, McLean,
    Virginia.'

3.  Frankel, I., N. Sanders,  and G. Vogel.
    1981.  Profile of the Hazardous Waste
    Incineration Manufacturing Industry.
    WP-81W00443, MITRE Corporation, McLean,
    Virginia.

4.  Holberger, R.  1981.   Recommended
    Structure, Content, and Data Formats
    for a Hazardous Waste Control Technol-
    ogy Data Base (HWCTDB).  WP-81W00340,
    MITRE Corporation, McLean, Virginia.

5.  U.S.  EPA.  1980.  Systems Information
    Directory.  Management Information and
    Data Systems Division, National Compu-
    ter Center, Research Triangle Park,
    North Carolina.
                                            72

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                                  TABLE 1

                       STANDARD REPORTS FROM HWCTDB
             REPORT
                                                       CONTENTS
Basic Identification Package
Expanded Identification
 Package

Waste Stream
incinerator Design
Operating Conditions
Performance
Monitor Results
Facility name, location, identi-
fication number and permit status.

Contact name and phone, owner
name, mailing address.

Waste sequence number, description
and selected elements from the
Waste Characterization record and
its descendants

System index, System type, and
description, and other selected
elements from the Design-Instal-
lation record and Component Data
record and its descendants.

Operating conditions index, data
type and other selected elements
from .the Operating Conditions
record, Combustion Chamber re-
cord, Waste Feed record and Air
Pollution Control Device record.

Operating conditions index, data
type, total scrubber efficiency,
particulate emissions, and all
Emissions records containing a
value for DRE.

List all monitor records for a
specified monitor (given a facil-
ity ID, system index, and opera-
ting conditions index).
                                     73

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                                 TABLE 1

                               (Continued)
             REPORT
                                                      CONTENTS
Burn Summary
Data Base Summary
Extracts selected data elements
from the Facility record, Waste
Characterization record, Design/
Installation record, Component
Data record and Operating Con-
ditions record, providing a
summary of the type of waste
burned, type of system used,
operating conditions used, and
resulting emissions.

Provides total of certain values,
(e.g., total liquid injection
capacity); ranges of values (e.g.,
range of temperatures used in
rotary kilns); or counts of the
number of occurrences of certain
values (e.g., number of units
combining rotary kiln and liquid
injection).
                                    74

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Vogel, G., K. Brooks, J. Cross,
I. Frankel, S . Haus, and W. J'acobsen.
1981.  Guidance Manual for Evaluating
Permit Applications for the Operation
of Hazardous Waste Incinerator Units.
WP-80W00628, Rev. 3.  MITRE Corpora-:
tion, McLean, Virginia.
                                         75

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                          OVERVIEW OF THE  CONCEPT OF DISPOSING
                        OF HAZARDOUS WASTE IN  INDUSTRIAL BOILERS
                                    George L.  Huffman
                          U.S. Environmental Protection Agency
                       Industrial Environmental Research Laboratory
                                 Cincinnati, Ohio  45268

                         C. Dean Wolbach and Larry R. Waterland
                                   Acurex Corporation
                            Mountain View,  California  94042
                                        ABSTRACT

     This Paper discusses the results of the first phase of an overall study in which
 the  technical feasibility of the concept of disposing of hazardous waste by co-combusting
 it with conventional fuels in industrial boilers is examined.  The second phase of the
 study involves the generation of appropriate sampling and analysis protocols and the
 conduct of an investigation to locate candidate industrial boiler testing sites.  Phase
 three, just now getting into full swing, involves an actual Testing Program to determine
 the  effectiveness7of destroying hazardous wastes by co-firing them in industrial boilers.

     In this Paper, the estimated quantities of hazardous wastes generated each year are
 discussed, as are the projections of the number of industrial bpilers currently in opera-
 tion.  A kinetic model for the thermal destruction process that takes place in a boiler
 is described.  Waste decomposition rate curves are compared to boiler temperature/
 residence time curves to allow prediction of the waste's destructibility in a given
 industrial boiler.  The kinetic model is applied to a real-life PCB test burn situation
 and  the prediction-versus-reality is compared.
INTRODUCTION

     It has been estimated that approxi-
mately 41  million metric tons of hazardous
wastes are generated each year in the
United States (2,9).  The environmentally
acceptable disposal of these hazardous
wastes is a mandated goal of the Resource
Conservation and Recovery Act (RCRA).
Regulations proposed and promulgated by
the U.S. Environmental Protection Agency
(EPA) in response to RCRA place restric-
tions on the generators of these wastes,
including requirements for the manifesting
of any wastes to be transported and chain-
of-custody liability.  These requirements
provide, then, some economic incentives
for the onsite disposal of the hazardous
wastes that are generated on the Nation's
270,000 industrial plant sites (7).
     Thermal destruction is a method of
disposing of those hazardous wastes which
are highly organic.  One thermal destruc-
tion process is high-temperature inciner-
ation, a practice which is regulated by
RCRA.  Another one is the co-combustion or
the co-firing of organic wastes in indus-
trial boilers along with conventional
fuels (coal, natural gas, fuel oil).  Use
of this technique not only destroys the
wastes but also allows the recovery of the
waste's fuel value which, in turn,  lessens
the Nation's overall consumption of scarce
fuels.

     The primary purpose of industrial
boilers is the production of energy for
onsite process needs.   Current RCRA
                                            76

-------
regulations specifically exempt facilities
that burn wastes in energy-producing opera-
tions from complying with RCRA rules re-
garding the high-temperature incineration
of wastes.  These rules require that 99^99
percent destruction and removal efficiency
be achieved for the principal organic
hazardous constituents (POHC's) contained
in the waste to be incinerated.

     Industrial boilers offer great poten-
tial for the onsite thermal destruction of
hazardous waste.  If the time and tempera-
ture profile of a given boiler is similar
to the residence time and exposure tempera-
ture required to destroy a given waste,
then the disposal of the hazardous waste
in the boiler becomes a distinct possibili-
ty, one worthy of further evaluation (2).
As a first step in this evaluation process,
the U.S. EPA awarded a contract to the
Acurex Corporation to study the technical
worth of the overall concept.  This Paper
summarizes the findings of Phase I of that
study (2).
WASTE/BOILER AVAILABILITY

     National figures regarding the amount
of hazardous wastes generated in this
country are extremely difficult to project.
Nonetheless, some attempts have been made.
Table 1 presents the results of one such
estimate (2,9).  The values in this tabu-
lation were based 'on the assumption that
the ratio of the amount of hazardous waste
generated by an industry to the number of
employees in that industry is approximately
constant for each plant in each industry.
This is, to say the least, a highly specu-
lative assumption.

     Table 1 shows that over 41 million
metric tons of hazardous waste are gener-
ated each year within 17 of the 19 stand-
ard industrial classification (SIC) codes
comprising the manufacturing industry plus
one non-manufacturing code.  Not all of
this waste is amenable to thermal destruc-
tion however, since some portion of'the
wastes listed are inorganic. • The combusti-
ble or organic content of the wastes varies
from industry to industry, from perhaps a
low of 30 percent in SIC 33 to a high of
80 percent in SIC 24 (2).  Consequently, a
significant fraction of the 41 million
metric tons of hazardous waste generated
each year is organic, is combustible, and
is amenable to destruction in industrial
boilers.

     But, are there enough industrial boil-
ers in this country to do the hazardous
waste destruction job?  There are currently
about 367,000 boilers of all types in the
United States (8).  Of these, about 238,000
can be classified as industrial installa-
tions (7,8).  Most of these boilers, how-
ever, are very small natural gas- or oil-
fired firetube units used primarily for
space heating.  Such "packaged" units do
not easily lend themselves to waste co-
firing (7).  Nonetheless, there remains a
substantial number of industrial boilers
having capacities larger than 2.9MW (10
million Btu's per hour) which are more
suitable for waste co-firing operations.
Table 2 reveals that there are about 43,000
industrial boilers in the U.S. over that
size (2,3).  Table 2 also shows that the
boiler population matches fairly well the
distribution of waste generators across the
U.S., while providing an indication of the
regional breakdown of the total amount of
organic and inorganic hazardous wastes
generated (2).
KINETIC MODEL FOR THE THERMAL DESTRUCTION
PROCESS

    The EPA/Acurex study set out to develop
a mathematical expression that would
calculate the amount of residence time
needed in an industrial boiler operating
over a relatively fixed temperature regime
to insure a hazardous waste destruction
efficiency of, say, 99.99 percent (or any
other required level of detoxification).
The physical parameters that influence
destruction efficiency are the three T's -
—  time, temperature and turbulence.  The
rate of thermal destruction is dependent
upon whether the boiler is operating in a
true oxidation mode or in a mode approach-
ing pyrplysis in some of the boiler's
starved-for-oxygen passages.  It is also
dependent upon the values of the kinetic
constants for the hazardous waste compound
(or group of compounds) to be destroyed.
If the time, temperature and turbulence
requirements to meet the required destruc-
tion efficiency of a given compound can be
compared to the time, temperature and
turbulence conditions that exist in a
given boiler, then the ability of the
boiler to achieve the desired destruction
efficiency can be predicted (2).
                                            77

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r
                               TABLE 1.   SUMMARY OF ANNUAL HAZARDOUS WASTE GENERATION
                                            (1,000 METRIC TONS PER YEAR)(2,9)

SIC
22
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40

Code
Textile mill products
Lumber and wood products
Furniture and fixtures
Paper and allied products
Printing and publishing
Chemicals and allied products
Petroleum and coal products
Rubber and miscellaneous plastics products
Leather and leather products
Stone, clay, and glass products
Primary metal industries
Fabricated metal products
Machinery, except electrical
Electric and electronic equipment
Transportation equipment
Instruments and related products
Miscellaneous manufacturing industries
Non-manufacturing industries
Waste
Total
203
87
36
1,296
153
25,510
2,118
248
474
18
4,061
1,997
323
1,092
1,241
90
319
1,971
Percent
of Total
0.5
0.2
0.1
3 . 1
0.4
62.0
5. 1
0.6
1.1
0. 1
9 8
4 8
0.8
2.6
3.0
0.2
0.8
4.8
                    TOTAL
                                                                          41,237
                                                               100.0%
                  Acurex decided to build into their
             model a measure of conservatism so that
             any predictions made would be on the safe
             side.  Consequently, they chose to use a
             first-order kinetic expression that de-
             scribes a thermal cracking or pyrolytic
             decomposition mode because the kinetics of
             pyrolysis are slower than those of oxida-
             tion (2).  Slower kinetics translates into
             conservative estimates of the residence
             times needed for efficient waste destruc-
             tion.  The rate of disappearance of a
             hazardous waste constituent by pyrolysis
             can be expressed by:
                  dC
                  dt
- kC
(1)
             where C is  the  concentration of  the  consti-
             tuent at time t and k is  the temperature
             dependent rate  constant.   Solution of  this
             equation leads  to:
      In ±
        C0
                                              -Ae
                                                                             -E/RT
                               At
                                                                       (2)
where  C  = Concentration of material
            at residence time At
       C0 = Concentration of material at
            time = 0
       A  = Arrhenius pre-exponential
            factor, sec~l
       E  = JEnergy of activation for bond
            rupture, cal/g-mole
       R  = Gas constant, 1.987 cal/g-
            mole-°K
       T  = -Temperature, °K
     At  = Residence time in the firebox,
            seconds

Using kinetic data such as that being
generated by the University of Dayton
Research Institute for the U.S.  EPA's
Industrial Environmental Research Labora-
tory in Cincinnati, the A and E values can
be obtained for the hazardous waste in
                                                         78

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question (4).   Then,  assuming various
destruction efficiencies (for example, for
99.99  percent,  C/C0 = 0.0001), one can
make a plot of  Residence Time (At) versus
Destruction Temperature (T).   Figure 1 is
an example  of such a plot;  it gives three
destruction curves for 2,2',4,5,5' penta-
chlorobiphenyl,  one of the  PCB's  (2).
Figure 1 shows  the comparison between
thermally decomposing PCB to  the  99.99
percent  level by either the pyrolysis mode
or the air  oxidation mode,  as well as the
pyrolysis mode  of destruction to  the 99
percent  level.   Note  that pyrolysis is a
much slower destruction mode  (at  the same
residence time,  a higher temperature is
required to get the same destruction effi-
ciency or,  conversely,  at the same tem-
perature, much more residence time is
needed in the pyrolysis mode  than in the
oxidation mode).

     Table  3 presents some  A  and  E values
for certain selected  hazardous waste con-
stituents (1,2,4,6).  With  data such as
this,  use of Equation 2 will  yield des-
truction rate curves  similar  to Figure 1
for hazardous waste streams of interest.
BOILER TEMPERATURE PROFILE VERSUS  RESIDENCE
TIME CURVES

     To determine what a prospective  indus-
trial boiler can do in terms of  providing
the time and temperature required  for
efficient waste destruction, one must
3.000


 ifoa



(2,240)



1.000
                               2,2', 4,5,5'
                               Pentachloroblphenyl
                        Pyrolysis (99.99%)
                  Oxidation {air -99.99%)
                                         300° C
                                         (540"F)
      0.001        0,01         0.1

                   Time (Al), seconds



              Rgura 1, Destruction curves (or pantach.lorobfprtonyl
  ascertain what temperatures are reached in
  its  firebox,and offgas passages and relate
  them to bulk gas residence times.   A con-
  ventional boiler temperature profile, such
  as   the simplified  one shown in Figure 2,
  provides  that information (2).   Figure 3,
  on the other  hand,  is  a more complex set
  of boiler temperature  profiles  that
  attempts  to  illustrate the range of boiler
  conditions which are often encountered in
  actual industrial plant operations.  'Point
 A' on-Figure  3  depicts the exit gas tem-
  perature  at  full-load  and mean  residence
  time conditions.  Point B"  represents the
 exit gas  temperature at full-load  and
 "fast-path"  (i.e.,  one-half of  the  mean
 residence time)  conditions.   Points C'  and
 D" are the respective  exit gas  tempera-
 tures but at  half-load conditions.   The
 box connecting  these four points   has  been
 termed, by Acurex Corporation (2),  the
 "boiler kinetic  operational  zone",  the
 BKOZ, which of   course  is  the range  of
 outlet conditions typically  experienced
 in normal boiler  operations  (2).   Tempera-
 tures above the  exit temperature A',  for
 example,  are readily found inside  the
 boiler firebox;  they are  found along the
 A-A1  temperature  path,  but at lesser resi-
 dence times.
 WASTE DESTRUCTION VERSUS BOILER PROFILE
 CURVES

      To determine if a given hazardous
 waste can be destroyed in a prospective
 industrial boiler,  one should construct a
 chart in which the  waste destruction  rate
 curves of Figure 1  are superimposed on the
 boiler temperature  profile curves  of
 Figure 3.   One such chart is given in
 Figure 4;  on it,  the decomposition curves
 for waste compounds A through E are
 overlaid  onto the temperature profile
 curves  for a given boiler operating under
 various conditions  (2).   In this  example,
 Compound  E will  readily  be destroyed
 because temperatures higher than  that
 required  for  its destruction are found at
 every  point within  the boiler.  Conversely,
 Compound^  A will  not be  destroyed because
 all  temperatures  found within the boiler
 are  lower  than that  needed for  its des-
 truction.   If the boiler were to  be opera-
 ted  in only  the  half-load condition,  it
 is questionable whether  Compound  B could
be destroyed'  to  the efficiency required.
                                            80

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                TABLE 3.  KINETIC DATA FOR COMPOUNDS OCCURRING IN SELECTED
                                 HAZARDOUS WASTE  STREAMS (1,2,4,6)
Oxidation
(in air) Pyrolysis

Benzene
Hexachlorobenzene
Toluene
Pentachlorobiphenyl
Vinyl chloride
Acrylonitrile
A
(sec"1)
7.42 x
1.9 x
2.28 x
1.1 x
3.57 x
2.18 x

1021
10 16
1013
1016
10 I*
1012
E A E
(kcal/g-mole) (sec"1) (kcal/g-mole)
95.9
72.6 	
56.5 2.1 x l.O12 77.5
70.0 7.44 x 109 53.6
63.3
52.1
                  I
                 Log Time
                                     Maximum Bulk
                                     Gas Temperature
                                     Exit Temperature
                                       Tm full-load
                                        m   ,


                                       Tm half-load


                                       T full-load
                                                                   Log At
         Figure 2. Simplified boiler temperature profile2
                                                      Figure 3. Boiler temperature profiles under full- and half-load conditions
                                                      (at mean and one-half of mean residence times)!
THE KINETIC/BOILER MODEL  APPLIED TO TEST
BURN DATA:   IT WORKS II

     The  EPA/Acurex kinetic model des-
cribed  above has been utilized to predict
the destruction efficiency to be expected
when PCB  is co-fired along with conven-
tional  fuels in an industrial boiler 	
and 	 this result was compared with
actual  test burn data taken .by the GCA
Corporation for the U.S.  EPA during a May,
1980 PCB-burn at the General Motors plant
in Bay  City, Michigan (2,5).
     The GM boiler  that  was tested was  a
17.4 Mw (60 million Btu/hour) watertube
unit burning No. 6  distillate oil.  The
PCB-contaminated waste stream was a waste
oil containing approximately 500 ppm
Arochlor 1254.  The waste stream and  dis-
tillate oil were mixed in a ratio of  1:10
prior  to injection.  The boiler  was
operated at half-load (i.e., the fuel
injection rate was  half  the design rate)
(2,5).
                                                81

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      The time and temperature profile
within the firebox was generated by
Acurex using their Zonal Heat Balance
Program.   Kinetic data were derived from
the  thermal destruction unit  data on
2,2",4,  5,5' pentachlorobiphenyl generated
for  the U.S. EPA  by Duvall at the Univer-
sity of Dayton Research Institute (2,4).
      Time-abovo-tamperaUire
      cum}, full load,
     -lastpam  "
                     Time-above-temperature curve,
                     lull load, mean path
      Extended BKOZ
    _ Time-above-temperature curve,
      halt loud, fast path
                                Original BKOZ
                     0.1

                      1n time
                                  1.0
                                                     The input data for the kinetic model
                                               is summarized in  Table 4, and  the pre-
                                               dictive  model diagram is shown in Figure
                                               5.  The  model predicted that,  for  half-
                                               load  and 2.5 percent  oxygen content in the
                                               firebox,  the boiler should achieve greater
                                               than  99.99  percent  destruction.   The actual
                                               test  results are  given in  Table  5 and do,
                                               in fact,  confirm  this prediction  (2,4,5).
                                                     1,600
                                               5. 1,500
                                              o
                                               o 1,400

                                               ?
                                               £ 1,300
                                               a.

                                               £ 1,200
                                                 1,100
                          Full load
                          mean path
                                                                                      Pyrolysis (N2)
                                                     Oxidation
                                                     • (2.5% O2)

                                                  Oxidation (air)
                                                                 0.1
                                                                               1.0
                                                                         Time (sec)
                Figure 4, Bolter-compound overlay2
                                                              Figure 5. Predictive model diagram for the GM PCB test burn2
               TABLE 4.  INPUT PARAMETERS  FOR EXAMPLE  CASE'MODEL  APPLICATION2
      Compound  (.2,2',  4, 5, 5'  - Pentachlorobiphenyl)

                     Pyrolysis       Oxidation (2.5% 02)

E (Kcal/g-mole)

A (sec"1)

Boiler
    tnsean
    (02% in  flue gas
                      1700°K + 50°   (Flame)

                      1144°K + 50°   (Back wall)

                      0.4 sec

                      1.8 sec
}
                                         Acurex boiler
                                           zonal heat balance
                                                                    Oxidation (21% 02)
53.6
7.44 x lO9
66.7 + 0.5
2.6 x 1012
70.0
1.10 x 1016
                                                82

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              TABLE 5.  REPORTED DESTRUCTION EFFICIENCY OF PCB'S IN GM's
                                   INDUSTRIAL BOILER2>5


Run
number
PCB-2
PCB-3
PCB-4
PCB in fuel3
concentration
range
•(mg/kg)
34-72
34-76
34-76
PCBb
in
(mg/min)
480-1,000
480-1,100
480-1,100
PCB
out
(mg/min)
<5.8 x ID"2
<5.6 x 10~2
<5.6 x ID"2
PCBC
destruction
efficiency
>99.99d
>99.99d
»99.99d

 Note:   Density of 1:10 Dilution of Waste Oil:   No..  6 fuel oil is 3.4 kg/gal.
 aBased on GM and GCA reported results.
 "Fuel  combustion rate:  3.43  kg/gal x 4 gal/min fuel flow = 14 kg/min.

                             PCB in - PCB out
 cPercent destruction = 100,

 dThis assumes 100 percent sample collection efficiency.   A validated test sample
  collection efficiency was not conducted as part of this verification burn.
SUMMARY

     This Paper can be summarized as
follows:

     •    One estimate shows that about 41
          million metric tons of hazardous
          wastes are generated each year
          in the U.S.

     •    Of the 238,000 industrial boilers
          in this country,  about 43,000 of
          them are larger in capacity than
          2.9 Mw (10 million Btu's per
          hour).

     •    A first-order kinetic expression
          has been developed to model the
          waste destruction efficiency to
          be expected when hazardous wastes
          are co-fired along with conven-
          tional fuels in industrial boil-
          ers.  This expression relates
          destruction efficiency to boiler
          operating temperature and gas-
          phase residence time.

     •    Superimposition of the model-
          predicted waste destruction
          curves onto a plot of boiler
          temperature/residence times
          allows the prediction of whether
          a given hazardous waste can be
          effectively destroyed  in a
           prospective  industrial boiler.

          The kinetic model has  been
          utilized to predict PCB destruc-
          tion efficiency when co-fired
          with distillate oil in an indus-
          trial boiler and the result was
          compared with actual field data.
          The model predicted approxi-
          mately 99.99 percent waste des-
          truction efficiency; this effi-
          ciency was corroborated by
          analysis of the test burn data.
WHERE DO WE GO FROM HERE?

     The verification of any kinetic model
cannot be achieved  when there exists only
limited sets of field test data to analyze.
To fill the void, the U.S. EPA has embarked
upon a Testing Program for Hazardous Waste
Co-firing in Industrial Boilers.  When the
Testing Program starts producing, in mid-
1982, additional test data from industrial
co-firing operations that are already
underway, the current model can be checked
for its ability to make accurate, repro-
ducible and verifiable predictions as to
what hazardous waste destruction efficiency
is possible in a particular kind of boiler.
                                            83

-------
REFERENCES

1.   Benson, S.W. 1960.  The Foundations
     of Chemical Kinetics, Chapters 10 and
     11.  McGraw-Hill.

2.   Castaldini, C., H.K. Willard, C.D.
     Wolbach and L.R. Waterland. 1981.  A
     Technical Overview of the Concept of
     Disposing of Hazardous Wastes in
     Industrial Boilers.  Draft Report
     prepared by Acurex Corporation,
     Mountain View, California for the
     U.S. EPA, Cincinnati, Ohio.  180 pp.

3.   Devitt, T., et al. 1979.  Population
     and Characteristics of Industrial/
     Commercial Boilers in the U.S. EPA
     Publication No. EPA-600/7-79-178a.

4.   Duvall, D.S., W.A. Rubey and J.A.
     Mescher. 1980.  High temperature
     decomposition of organic hazardous
     waste.  In:  Proceedings of the 6th
     Annual Research Symposium on the
     Treatment of Hazardous Waste, U.S.
     EPA Publication No. EPA-600/9-80-011.
     181 pp.

5.   GCA Corporation. 1980.  Evaluation of
     PCB Destruction Efficiency in an
     Industrial Boiler.  Final Report
     prepared for the U.S. EPA, Research
     Triangle Park, North Carolina.  EPA
     Publication No. EPA-600/2-81-055a.

6.   Lee, K.C., et al. 1979.  Predictive
     model of the time-temperature require-
     ments for thermal destruction of
     dilute organic vapors.  72nd Annual
     Meeting of the Air Pollution Control
     Association.

7.   Olexsey, R.A. 1981.  Alternative
     thermal destruction processes for
     hazardous wastes.  To be presented at
     the May, 1982 ASME National Conference
     on Solid Waste Processing, New York
     City.

8.   Putnam, A.A., E.L. Kropp and R.E.
     Barrett. 1975.  Evaluation of National
     Boiler Inventory.  Final Report pre-
     pared by Battelle-Columbus Labora-
     tories, Columbus, Ohio, for the U.S.
     EPA, Research Triangle Park, North
     Carolina, NTIS # PB-248-100.  70 pp.

9.   United States Environmental Protec-
     tion Agency.  May 2, 1980.  Background
Document:  Resource Conservation and
Recovery Act, Subtitle C 	 Identi-
fication and Listing of Hazardous
Waste, Section 261.31 and 261.32.
Draft Document.
                                            84

-------
                    BOILER  SITE  IDENTIFICATION, SAMPLING AND ANALYSIS
             PROTOCOLS, AND CHARACTERIZATION OF EMISSIONS FROM BOILER TESTS
                                   Richard S. Merrill
                                    C. Dean Wolbach
                                    Robert McCormick
                                    Larry Water!and
                                   Acurex Corporation
                            Mountain View, California  94042
The development of the Acurex mathematical model predicting the degree of destruction
of organic waste  in industrial boilers must be followed by actual field testing and
further efforts to more quantitatively define the constituents in the exit gas stream.
Sponsored by the  Incineration Research Branch, IERL, Cincinnati, Ohio, this subsequent
field testing program includes several support elements.  Using public information,
facilities were identified that are cofiring wastes and fuels of interest to EPA; waste
and boiler combinations were prioritized; and each operator was approached to request
his participation.  A sampling and analysis protocol was developed to reflect the data
needs of the Office of Environmental Engineering and Technology, the Office of Solid
Waste, and the Office of Air Quality Planning and Standards; it includes a pretest
engineering assessment, test plan preparation, sampling and analysis procedures, and
reporting requirements.  Finally, air emissions are being evaluated for principal
organic species predicted to be present as products of incomplete destruction of input
materials, combustion products, and results of incremental  changes to the priority
pollutant.  This  program will establish a data base to support the disposal  of
wastes in boilers.
SITE IDENTIFICATION

     After contacting EPA officials at
five regional offices, at all 50 state
EPA offices, and in Puerto Rico, we
concluded that state air discharge
permitting officials and, to a lesser
extent, solid waste disposal permitting
officials could provide the most
information on waste cofiring in
boilers.  We requested that these
officials identify all sites within
their jurisdiction where potentially
hazardous wastes were being burned in
boilers or process heaters, giving as
much information as possible on the
boilers and wastes burned. . Since budget
and time limitations precluded a search
of permit files, we relied on the
personal knowledge of these officials
and their colleagues to initially
identify such sites, after which limited
information on boiler/waste
characteristics were obtained from the
permit files.

     We also conducted a comprehensive
search of 20 data bases abstracting
government reports and technical
literature through the DIALOG
Information Retrieval Service offered by
Lockheed Information Services.  This
literature search was extended to the
NEDS, SOTDAT, and EADS environmental
data systems offered by EPA.  We made
limited contact with EPA/ORD, EPA/OSW,
and EPA/OAQPS personnel, private
consultants, and industry
representatives as well.  Information
compiled from RCRA Part B permit
                                           85

-------
applications, required for all hazardous
waste disposal, was unavailable at the
time of our data search.

Discussion of Results

     We identified 129 sites in the
United States (not including the pulp
and paper industry) where hazardous or
potentially hazardous wastes are
currently being burned.  Since wastes
were often identified only as "process
residues" or "waste solvents" with
occasional specification of the process
raw material or product, we could not
always determine whether the waste was
hazardous under RCRA 3001 guidelines;
hence, the qualification "potentially
hazardous" waste.

     Even less data were available on
boiler characteristics.  The apparent
trend was for primarily liquid wastes to
be cofired with fuel oil as the primary
fuel, although natural gas and
pulverized coal were also listed.  We
suspect most of the boilers are
watertube designs, ranging from small
industrial heaters to utility sizes.  A
significant fraction were apparently
designed for waste cofiring; to
distinquish between boilers and
incinerators with a heat recovery
capability, we identified as boilers
those units having steam generation as
their primary function.

     The available data indicate that
cofiring of organic chemical process
byproducts, spent solvents, and waste
oils in boilers is widespread.  However,
the sites we identified are not a
comprehensive listing.  Many plants
burning wastes, particularly in modified
boilers, do not report this to the
permitting offices and are even less
likely to appear in the literature on
waste cofiring.  The lack of time and
funds to search the EPA permit files and
the general limitation of the EPA data
bases to boilers having a total
uncontrolled criteria pollutant emission
potential over 100 tons/yr also preclude
a comprehensive listing.  But the sites
identified were sufficient for
representative selection for sampling
and analysis.
Site Prioritization and Selection

     Our primary objective was to select
four to six sites for field testing,
covering a range from minimum waste
destruction efficiency to maximum
performance, which would provide the
basis for an across-the-board
environmental assessment of hazardous
waste cofiring in boilers.  Our
secondary objective was to select
boiler/waste combinations having
sufficient operational and kinetic data
available to test the Acurex computer
model for waste destruction.

     Of the organic constituents listed
as hazardous on the basis of toxicity
under RCRA, light hydrocarbon organic
process wastes are the least thermally
stable and so represent the best
destruction potential.  On the other
hand, halogenated or complex cyclic or
aromatic organics are the most difficult
wastes to destroy.

     Taking into account the boiler's
time-temperatuare profile and how
representative it is of the industry, we
gave higher priority to standard
firetube, suspension-fired watertube,
and stoker-fired designs burning coal,
fuel oil, or natural gas.  Of these
boilers, large watertube designs offer
superior time-temperature profiles for
organic compound destruction while small
firetube designs or small stokers
represent the worst case for such
destruction.  We recommend that greater
emphasis be placed on the worst case
testing.

     Table 1 lists the boiler/waste
combinations recommended for a six-test
matrix.  Final site selection requires
further investigation since data on
boiler design and waste composition for
the identified sites were limited.
Therefore, we separated the sites into
classes based on the available waste
characterization data.  Class A sites
are those burning wastes that can be
identified as hazardous.  Class B sites
are those burning unspecified process
residues or waste solvents.  Class C
sites are those burning waste oils, and
class D sites are those burning
                                            86

-------
               TABLE 1.  BOILER/WASTE COMBINATIONS FOR A SIX-TEST MATRIX
                          Boiler type
         Waste thermal stability
          Large pulverized coal- or residual-oil-fired
          watertube design

          Large residual-oil-fired watertube design

          Small gas/distillate-oil-fired watertube
          design

          Small gas/distillate-oil-fired watertube
          design

          Stoker-fired design, intermediate size range

          Small gas- or oil-fired firetube design
                  Low


                  High

                  Low


                  High


                  High

                  High
PCB-contaminated oils, as well as all
utility-scale boilers.

     We recommend that the class A and
class B sites be contacted for further
information on boiler design/operation
and waste composition before final
selection is made.
SAMPLING AND ANALYSIS PROTOCOL

     The sampling and analysis protocol
was developed for use in the test
program to generate a data base from
which regulations and permit application
procedures can be established;
characterize multimedia emissions;
evaluate the impact of waste cofiring on
air pollution control devices; and try and
validate the Acurex predictive model for
waste destruction.  Developed for
solid-fuel-fired boilers burning wastes
with a high thermal stability, the
protocol includes instructions for
conducting the field test program,
analyzing the collected samples, and
preparing the sampling/analysis reports.

Pretest Site Survey

     This 1-day survey involves
collecting waste and fuel samples,
obtaining boiler design and operating
data, acquiring meteorological  data, and
performing a site sampling evaluation.

     From the waste and fuel samples,
the major organic components present are
identified and quantified.  To minimize
the quantification effort, the
investigator should obtain as much
information as possible about the
process generating the waste and its
likely constituents.  These samples will
also determine the ultimate and
proximate analysis of each, gross flue
gas compositions, boiler heat release
rates, and trace element content of each
for verification of the material balance
estimate.

     Samples should be labeled and
logged on a data sheet.  The
investigator should determine from plant
personnel that these samples are
representative of wastes to be fired
during the field test program.

     From the boiler design and
operating characteristics, the
destruction efficiencies for organic
constituents and the formation  of
products of incomplete combustion are
predicted.  From meteorological data
available at the nearest weather
                                            87

-------
                                                        Preliminary
                                                        Engineering
                                                        Assessment
                                                          Pretest
                                                            Site
                                                           Survey
                                                             Boiler
                                                        Engineering
                                                           Evaluati
                                      Data
                                     on
                 TDAS Analysis for
                 PICS Identification
                 and Decomposition
                    Rate Data
                     Boiler
                 Time-Temperature
                     Profile
                   Development
        Identification
            D9I-
            PICS
Decomposition
    Rates
DC torsi ration of
  POHCS, PICS 1n
  Fuel and PICS
    In Haste
              Waste and Fuel
                Elemental
                Analysis
                                                                                                            1
             Site Sampling
              Engineering
            Dhta Evaluation
   Evaluation of
Available Emission
and Meteorological
       nata
                         Estination of
                      Boiler Destruction
                       of POHCS and PICS
Establish Elemental
   Mass  Balance
, .,,     4*
Analytical Criteria
                                                                     Establishment
                                                                    of Test, Sampling,
                                                                     and Analytical
                                                                        Matrix
                                                                          End
           Figure  1.   Preliminary engineering assessment information  flow  ehart.
                                                          88

-------
station, the maximum acceptable stack
emissions are calculated as a function •
of exposure and risk.

     The site sampling evaluation covers
the plant configuration, components to
be sampled, each sampling point, its
accessibility, necessary modifications,
and other sampling requirements, as well
as information on provisions for the
test crew's safety, lodging, etc.

     All data sheets and samples should
be returned to the contractor's office
for an analysis that may require up to
4 weeks.  Elements involved in this
preliminary assessment are outlined in
Figure 1.

Waste and Fuel Evaluation

     The waste and fuel samples are
analyzed to determine and quantify the
primary organic constituents present and
the waste/fuel combustion
characteristics; predict destruction
efficiencies and products of incomplete
combustion; and supplement the material
balance estimates.  The analytical
protocols and the organic compounds of
interest are discussed in the Acurex
report prepared under this contract.

     Determining the ultimate and
proximate analysis of the waste and fuel
allows the approximate stack gas
composition to be calculated at a given
air stoichiometric ratio.  The results
of thermal gravimetric analysis for
volatilization rates and differential
scanning calorimetry for heats of
vaporization determine the boiler
time-temperature profile when cofiring
wastes, for input to the predictive
model.  Finally, a Thermal Decomposition
Analytical System (TDAS) determines
potential, reaction products and their
decomposition rates; these data, with
the decomposition rates of the organic
constituents identified in the samples,
are also used in the predictive model.
The analytical procedures 'for obtaining
all these data are discussed in the same
report.

Boiler Evaluation

     By establishing a
time-above-temperature profile for the
combustion zone, conditions can be
determined for destroying a given
waste.  Time-temperature profiles are
computed using an Acurex zonal heat
balance computer code.  Inputs include
the fuel and air properties and boiler
operating and design features obtained
at the site, and other variables such as
turbulence or emissivity based on our
experience with combustion processes.

     Time-above-temperature profiles,
indicating the length of time combustion
gases are above a maximum; mean
temperature, are then generated from the
computer outputs.  Overlaying a given
compound's time and temperature
destruction requirements on a boiler's
time-above-temperature profile allows
various compounds to be screened for
destruction efficiencies by noting where
the compound line /alls under the boiler
curve.

Component Destruction Efficiency and
Reaction Product Formation

     Comparing the possible boiler
temperatures from the time-temperature
profile with the TDAS output at those
temperatures, allows those organic
species still present to be identified
and quantified and so determine the
primary species to look for in the stack
gas.

     The concentration of these
components, which determines the length
of each stack test, are calculated using
the equation
   In
where
    f x
-A  J    exp C-E/RT(t)] dt
   tm
        C = Concentration of material
            at time At

       C0 = Concentration of material
            at time o

        A = Arrenhuis preexponential
            factor

       t0 = Time at Tmax

       tx = Mean residence time
                                            89

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      T(t)
Reaction energy of
activation (cal/g mole)

Gas constant
(1.987 cal/g mole °K)

Temperature (°K) as
function of time in boiler
 For  compounds  of  known A  and E, the
 concentration  (C)  can be  calculated.
 When A  and  E are  unknown, the IDAS data
 must be further manipulated, using the
 retention time at  a  given temperature
 and  the ratio  of outlet to  inlet
 concentrations for a variety of test
 cases to compute A and E.

     Given  a known input  concentration,
 flue gas volume, and temperature, stack
 gas  concentrations can be estimated.

 Establishing the Test Matrix

     Using the data  assembled in the
 preliminary assessment, a test plan is
 formulated by  balancing the size of the
 program against available resources.
 This test program  assumes a large
 solid-fuel-fired boiler is to be
 sampled. The formulation process is
 outlined in Figure 2.

     For each  operating condition to be
 tested, including waste-to-fuel  ratio,
 boiler load, or excess air ratio, a
 baseline test  should identify discharges
 typical of the primary fuel, followed by
 triplicate tests at the desired
waste-to-fuel  ratio.

     Sampling  points should be
established to include all fuel  and
waste input streams, bottom ash
discharge, and inlet and outlet streams
from the air pollution control
device(s).  Operating data requirements
should be established to include boiler
 load, waste and fuel  temperature, and
feed rate, process temperatures, and
data to determine fuel  combustion
efficiency and operational stability.

     Sampling methods are dictated by
the preliminary assessment.   For solid
 streams  (i.e.,  the  solid fuel or bottom
 ash),  grab  samples  should be taken at
 hourly or shorter intervals.  Liquid
 samples  (i.e.,  waste) should be
 collected by  grab sampling or automatic
 compositing samples.  Gas phase samples
 should be collected using an EPA
 Method 5 or SASS train.

     Analytical sensitivities should be
 reviewed against detection limits.
 Sample sizes  should then be set
 according to  the predicted constituent
 concentrations  and detection limits of
 the sampling  equipment.

     Taking a set number of duplicate
 samples, split  samples, spike and
 recovery sequences, and surrogate
 samples for each set of test samples
 ensures meaningful data.  Each sample
 should be labeled and identified on the
 chain  of custody and analysis request
 forms.

     The requirements of the test plan
 should be compared to the available
 resources.  Funding constraints may
 require that test parameters be
 rewritten or low priority options
 eliminated.

 Preparing the Test Plan Document

     The test plan document should
 include the elements listed in  Table 2.
Acurex computer simulations and
 predictions  will be included as well,
 along with all pretest data.   The EPA
technical project monitor and the plant
operator must approve the test  plan.
                                  Field Testing

                                       Figure 3 outlines the field testing
                                  process.  A typical test program
                                  includes one baseline test, firing the
                                  boiler on fuel without waste, and three
                                  runs cofiring the boiler on fuel and
                                  waste standard settings.  One day is
                                  required for setup and the Methods 1
                                  through 4 stack gas analyses which
                                  involve measuring gas velocity and
                                  temperature, determining the presence of
                                            90

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                                                                        Conduct
                                                                      Sampling and
                                                                        Analysis
   Design Test
     Program
 From Pretest  Site
 Survey Determine
Maximum Info Requ,
    to Satisfy
 Program Objective
                                   Can
                                 Operating
                                 Matrix be
                                  Reduced
 Establish Matrix
 of Possible Oper.
   Conditions
  to be Tested
                                       Submit to
                                        TPH for
                                        Approval
         Is
       Matrix
     Maximized
  Establish Matrix
  of Samples and
  Data  Required for
 Each Test Sequence
                                                                           Are
                                                                    There  Sufficient
                                                                        Resources
     Can
Sample Matrix
 Be Reduced
         Is
       Matrix
      Maximized
                                                                    Estimate Resource
                                                                    Requirements  for
                                                                      Test Sequence
   Identify Sampling
    Methodology for
 Individual Samples
       and Data ~
                                                                           Are
                                                                    QA/QC Requirement
                                                                        Satisfied
       Identify
      Analytical
      Methodolony
                                                                          Prepare
                                                                          Project
                                                                        QA/QC Plan
         Are
     Methodologies
      Compatible
                                                     Have
                                                  All Samples
                                                 Been Reviewed
   Review Analytical
Sensitivities Against
 Desired Detection
       Limits
                                     Are
                                 Sample Sizes
                               Compatible with
                                   Methods
      Figure 2.   Matrix  for preparation of testing  program.

                                          91

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                       TABLE 2.  TEST PLAN DOCUMENT ORGANIZATION
                  Section
                   Description
        1.  Program Objective

        2.  Pretest Site Survey

        3.  Field Test Program




        4.  Analytical Methods



        5.  Cost and Schedule
Agreements with plant contractor commitments
   Test matrix, identifying samples, equipment,
   test times, personnel, and schedule
   Process operating data
   Sample storage/transport

   Sample identification
   Description of analyses in generic terms
   QA/QC procedures

   Site-specific cost impacts, manpower
   requirements, and schedule
C02» 02, H20, and Ng, and
calculating molecular weight.  Baseline
tests are run on the second day and
triplicate tests on the following
3 days, including cleanup and teardown.
A sixth day is used to finish
uncompleted tasks.

     The team leader records the data,
one person staffs the continuous monitor
van, one person takes grab samples, and
a team runs the particulate trains.  For
tests on solid-fuel-fired boilers, as
many as seven people may be needed.

Equipment Preparation

     Sampling equipment is calibrated
and checked before field testing;
calibration sheets for gas meters, pilot
tubes, and magnahelic*gages are
completed and filed.  Specialized
equipment or site modifications should
be arranged before arrival at the site.

Field Sampling

     Preliminary gas characteristics are
determined using Methods 1 through 4 at
             the beginning of  each  sampling  task  and
             as  necessary to account  for  changes  in
             process  conditions.
                  Source sampling is  conducted  using
             continuous monitors  to record  gaseous
             emissions and operational  variability,
             and isokinetic-sampling  to collect
             organic and particulate  materials.  The
             Method 5 particulate sampling  train  is
             traversed to sample  at several  points
             across the duct.   The Source Assessment
             Sampling System (SASS) which samples at
             a single point in  the duct has  three
             particulate sizing cyclones, an organic
             module with XAD-2  sorbent,  and  impinger
             bottles for trace  metal  capture.   This
             is  used to collect larger  sample sizes.
                  Process  data  measured  to  compute
             boiler efficiency  and  evaluate cofiring
             impacts on  unit  operation will  be
             collected.  These  operating data will be
             used  to estimate unit  efficiency and
             reduce the  emissions sampling  data.
                                           92

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                                        Sampling
                                           and
                                        Analysis
                                          Field
                                          Test
                                         Program
                                           _L
                        Conduct
                       Sampling
                      Activities
                                                            ±
                                     Gather
                                   Operational
                                   Data During
                                     Testing
      _L
   Determine
Concentrations
Of POHCS & PICS
  in Samples
Reduce Sampling
  Field Data
 (volume flow
 Rates, etc. )
  Determine
Concentration
 of Elements
 in Samples
                                   Establish
                                   Elemental
                                   Material
                                    Balance
                      ±
                Deternrine POHC
                PIC  Destruction
                 Efficiencies
                                       Compare
                                     Results  to
                                        Model
                                         I
                                       Prepare
                                       Report
             Figure 3.  Sampling and analysis activities.
                                    93

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 Analysis
 Data Reduction
      Posttest analyses of fuel and waste
 samples, ash grab samples, and the SASS
 sample catch may include a flue gas
 analysis of the SASS catch, inorganic
 analyses for selected trace metals and
 other species depending on the fuel and
 waste composition, and organic analyses
 when it is uncertain which organic
 species are present.  Should these data
 be already available, these analyses may
 be eliminated.

      Semi- and low-volatility organic
 compounds are determined with EPA Method
 625 involving base/neutral  extraction of
 the sample and extract concentration;
 the extract is analyzed by combined gas
 chromatography/mass  spectrometry
 (GC/MS).   Each sample is spiked with a
 surrogate standard prior to extraction,
 and quantitation  is  based on  comparing
 specific  ion  areas in each  analysis to
 that of a standard.   Other  organic
 compounds are determined with Method 625
 using acid extracts.   For both
 base/neutral  and  acid extracts, multiple
 injections of diluted and concentrated
 extracts  are  required to quantitate
 trace and high  level  species.

      Volatile organics are  determined
 using the purge and trap/GC/MS EPA
 Method  624.   Acurex uses  a  Tekman  LSC2
 automated  purge and trap device
 interfaced  to a Finnegan  4023  GC/MS.

      Once  the grab sample has  been
 screened  and  the pollutants for that
 particular matrix  identified,  routine
 methods will  be developed to confirm
 that  known methods work  for the samples
 in question.  These routine methods are
 based on the  600 series such as  Method
 610 for high-pressure  liquid
 chromatographic (HPLC) determinations.
All methods are evaluated for  precision
 and accuracy  using replicate analyses
 and spiked samples.

     All analyses should  be completed
within 6 weeks of sample receipt.  All
samples are saved until the final report
has been accepted by the  EPA technical
project monitor.
      The analytical  results will
 establish the boiler operating
 parameters and combustion  efficiency,
 destruction efficiency (per component
 and total), PIC emissions, air pollution
 control  device efficiency, material
 balance  closure,  chloride  balance,  and
 particulate emissions  and  size
 distribution.

      The reduced  data  will  be  compared
 to  the Acurex  model  predictions.
 EVALUATION  OF AIR  EMISSIONS

      POHC emissions  can be estimated by
 conducting  a zonal heat balance,
 estimating  volatilization rates,
 determining the degree of POHC
 destruction, and then calculating the
 emission rate.  Products of incomplete
 combustion  pose greater difficulties and
 are discussed in the following
 paragraphs.

 Products of Incomplete Combustion

     The complex mechanisms involved and
 the lack of information on such
 mechanisms hamper the prediction of the
 formation/destruction of products of
 incomplete combustion (PIC's).  Using
 chemical rate theory, however, upper
 bounds can be established by reducing a
 set of-pseudo first order kinetic
 equations to simpler cases that can then
 be used to develop concentration
 relationships for PIC formation and
 destruction.

     A set of reaction  schemes was
developed mathematically with  each  case
representing the disappearance of one
component (A)  and the formation and
disappearance  of a product component (?)
as follows:
     Case I   —
     Case II
All of A converts
to P and then P
disappears
A converts to many
different products
                                            94

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     Case III —
     Case IV  —
P is generated from
many different
components

P is generated by a
sequence of reactions
in series
following relationships hold (n is the
number of steps in the sequence):
     Case V   --  A converts to P by two
                  different mechanisms

     To find Cp/C/\j0 or the
concentration of P'at time t with
respect to the original concentration of
A, we: (1) reduced one or more cases to
a simpler, upper bound case; (2) reduced
one or more cases to the simple case of
the disappearance of P, and; (3)
directly compared the concentration of P
at time t with that of A at time t, both
with respect to A's original
concentration.

     In case I, Cp/CAj0 can be
calculated using the empirical pseudo
first order disappearance rates for POHC
(A) and PIC (P).  Calculating the time
at which Cp/C/\ 0 is a maximum
enables us in many cases to treat the
PIC (P) as a POHC.  This occurs if the
rate of disappearance of P is greater
than 100 seconds-"*.  Most of the other  :
cases can be reduced to case I as an
upper bound.

     For case II, the concentration of
any one P in this system can be
intuitively and analytically verified as
less than the concentration of P in case
I.  Therefore, case II reduces to case I
as an upper bound.

     For case III, the system is
mathematically equivalent to a system
where a POHC proceeds to a given PIC by
several mechanisms.  This also reduces
to case I as an upper bound by the
simple expedient of assuming that all
the various waste components proceed to
the PIC of interest.  This case is not
true, but it is a worst case.  Case IV
represents a much more complicated
problem, and a "good" upper bound has
not yet been established for the general
case.  With some stringent limitations,
solutions are available.  For example,
if all the rates are equal, and if all
the concentration of the intermediate
product are zero at time zero, the
                                                             (k!t)n
                   exp  (-kt),
                                        =    •  and
                                               exp  (-n)
                                  For the situation where all the
                             intermediate rates are faster than the
                             rate of disappearance of the PIC, it can
                             be shown that
                                   max < F~
                             or, in general,

                                          n
                                          mm

                                  However, the corresponding
                             relationships for concentration are not
                             true.  At this time, it can only be said
                             that for t > n/km-jn
                                   CT
                                    A,o
                                         «   exp  (-kt).
                                  Case V has not been thoroughly
                             explored.  It has been established that
                                         kmin.
                             and for the situation where all
                             intermediate rates are greater than
                             and t > n/kp
                                        <  2  kpt  exp(-kpt).
                                  In summary, steps have been taken
                             to set upper bounds on PIC emissions.
                             Some bounds have been set under
                                            95

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 stringent conditions that do not
 represent the real  world.  Our approach
 to  more realistic bounds is currently
 being pursued and looks  promising.

 Trace Element Emissions

      These elements should partition  as
 in  coal  or residual-oil-fired boilers,
 the quantity of any given metal
 depending on its concentration in  the
 fuel, boiler combustion  conditions, the
 type and efficiency of the air pollution
 control  device (APCD)  as a function of
 particle size, and  the properties  of  the
 element itself.

      Trace metals tend to concentrate in
 certain  waste particle streams of  a
 boiler,  leading to  the following
 classifications  by  stream for
 partitioning metals:

      Class I   — Bottom ash  or  slag  and
                  in the APCD inlet and
                  outlet flyash  in
                  approximately  the same
                  mass concentrations

      Class II  — Flyash,  mass entering
                  being  less  than mass
                  exiting

      Class  III — Vapors

      Class  I  elements  and  oxides are  not
 volatilized  in the  combustion  zone but
 remain condensed  throughout the  boiler
 cycle.   Class  II  elements,  however, do
 volatilize  and so concentrate  in flyash
 rather than slag; these  elements either
 form  condensation nuclei or condense  on
 existing particulate.  Waste burning  is
 not expected  to  affect trace metal
 emissions.

Criteria Pollutant  Effects

      Waste firing will impact  the
criteria pollutant  emissions from a
source.  The criteria pollutants of
concern  are particulates,  SOX, NOX,
and CO.  In general, it can be expected
that emissions will  change on  a
unit-mass-for-unit-mass basis, although
this will vary from pollutant to
pollutant.  If pollutant is generated
 from element in  the fuel,  and  the
 element is  in concentration  Cf in  the
 fuel, then  the original  pollutant
 emission  rate will  be   kRfCf where k
 is  the fraction  of  the  element converted
 to  the pollutant and Rf is the fuel
 feed rate in mass per unit time.   If the
 conversion  fraction  is  the same for the
 fuel  and  the waste,  the new  emission
 rate will  be k(R'fCf +  RWCW)
 where R'f is the new fuel feed rate, R
 is  the waste feed rate,  and  Cw is  the
 concentration of element in  the waste.

 Particulates

      Particulate emissions will probably
 follow this  pattern  based on ash
 content.  The distribution of  ash
 between bottom ash  and  flyash  may  change
 significantly depending  on the nature of
 the waste ash.

      Units  not designed  to handle
 ash-containing fuels (e.g.,  gas- and
 distillate-oil-fired units) will
 probably  not  fire wastes containing ash
 or  mineral-forming elements.   Thus,
 noncarbon particulate emissions are not
 expected  from these  units.  Carbonaceous
 materials (soot)  may increase  or
 decrease  depending on the burnout rate.
 This  is usually  controlled under normal
 boiler operating  procedures and is not
 expected  to  change under waste firing
 conditions.

      Units designed to handle  high-ash
 content fuels  such as the various
 coal-fired boilers may experience wide
 fluctuations  in  particulate emissions.
 It  is expected that, for the most part,
 the fluctuations will be on the
 downside.  This prediction is  based on
 the fact that most high organic content
wastes with high fuel potential .will
 have  a lower  ash content than  the
replaced fuel.

Sulfur Oxides Emissions

     The generation  of sulfur oxides
will be directly related to the
 incremental change in sulfur  content of
the fuel-waste mixture.   Reactivity of
flyash to sulfur oxide  chemisorption
will effect the emissions.  The process
                                            96

-------
is straightforward but not simple.
Normally, the emissions would be
expected to be
ESOX = CS,FRF + C
       - AS,WRW,A
where
     ESQV = Emission rate, of SOX
        A " •   • "
     CQ p = Molecular weight factor times
       '    concentration of sulfur fuel

     C$ w = Molecular weight factor times
            concentration of sulfur waste

       Rp = Fuel feed rate

       RW = Waste feed rate

     AS j = Unit chemisorptivity of
            SOX on fuel ash

     AS,W = Unit chemisorptivity of
            SOX on waste ash

     Rp^A = Rate of ash generation
            from fuel

     RW,A = Rate °f asn generation
            from waste
     However, the synergistic effects of
the fuel and waste ash chemistries will
probably change the unit chemisorbtivity
factors in other than a linear manner.
Thus, more or less sulfur oxides may be
chemisorbed in the ash (on a unit mass
basis) than would normally be expected.
Waste and fuel ash chemistries also may
cause alterations in the sulfur trioxide
(503) to sulfur dioxide (S02)
ratio.  Oxidation catalysts such as
vanadium and titanium are known to shift
the distribution to higher $03
content.  These types of elements can be
expected to be present in many of the
waste streams under consideration for
boiler destruction.

NOx Emissions

     Nitrogen oxides  (NOX) are formed
in combustion processes through two
basic mechanisms:  The fixation of the
nitrogen in the combustion air by
oxygen, termed thermal  NOX, and the
oxidation of fuel-bound nitrogen termed
fuel NOX.  The rate of thermal NOX
formation is highly dependent on local
temperatures and, less so, on 02
concentrations.  The detailed mechanisms
of fuel NOX formation are poorly
understood, but fuel NOX formation
rates are most affected by local 02
concentrations, and are relatively
independent of temperature.

     Since thermal NOX formation is
dependent on temperature and 02
concentrations, changes in a boiler's
combustion conditions attendant with
waste cofiririg may affect thermal NOX
levels. , For example, if excess air
levels are increased to facilitate
increasing destruction efficiencies,
then emitted NOX levels will
increase.  Perhaps of greater importance
from a thermal NOX standpoint, though,
is  if the heat content of the waste
cofired is sufficiently different than
that of the fuel displaced, then the
maximum flame temperature change along
with corresponding effects on thermal
NOX prediction.  For example, if the
heat content per unit mass of the waste
cofired is substantially higher than  the
fuel displaced then flame temperature
will increase and thermal NOX
prediction will  increase.  Corresponding
effects leading  to lower thermal NOX
formation occur when waste content is
substantially less than that of the fuel
displaced.

     Since fuel  NOX formation derives
from oxidation of fuel- (or waste-)
bound nitrogen,  emitted NOX levels
through this mechanism will be affected
depending on the relative nitrogen
contents of the  waste cofired and the
fuel displaced.  For example, if a high
nitrogen waste is cofired in  a
distillate-oil-fired boiler  (very low
nitrogen), emitted NOX levels due to
fuel NOX will increase.  The  increase
will not reflect total conversion of  the
added waste nitrogen to NOX,  though.
Total conversion of fuel nitrogen to
NOX does not occur for any combustion
process.  Typical percent fuel nitrogen
conversions range from about  20 percent
for high nitrogen  (1 to 2 percent N)
fuels such as some bituminous coals to
about 80 percent for very  low  (less than
0.1 percent N) fuels such  as  distillate
                                            97

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oils (H. B. Mason, et al., Preliminary
Environmental Assessment of Combustion
Modification Techniques — Volume II,
Technical Results, EPA-600/7-77-119b,
October 1977).

     In addition, however, other changes
in boiler operation attendant with waste
cofiring may have significant effects on
fuel NOX production from fuel- and/or
waste-bound nitrogen.  As was the case
for thermal NOX formation, if excess
air levels are raised to help promote
waste destruction, then thermal NOX
formation will increase as well.  If the
burner is retrofit to increase flame
distribution and mixing (thereby
removing fuel-rich eddies) then fuel
NOX formation will increase.
     In summary, NOX formation by both
mechanisms will be increased by positive
incremental changes:
     •  Btu con tent/unit mass
     •  Heat release rate
     •  Excess air
     •  Flame turbulence
Carbon Monoxide

     Carbon monoxide levels should not
be affected by combustion of wastes.
This is because carbon monoxide
concentrations are mechanically
controlled to maintain boiler
operational efficiency.
                                            98

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               EVALUATION OF FEASIBILITY OF INCINERATING HAZARDOUS WASTES
                        IN HIGH-TEMPERATURE INDUSTRIAL PROCESSES
                 F,  D.  Hall and W.  F.  Kemner, PEDCo Environmental, Inc.
                              Cincinnati, Ohio  45246-0100
           L.  J,  Staley, Project Officer, U.S. Environmental Protection Agency
                                 Cincinnati, Ohio  45268


                                        ABSTRACT

In the search for disposal alternatives, the U.S. Environmental Protection Agency is
evaluating the potential use of high-temperature processes for the incineration of haz-
ardous wastes.  Many kinds of waste have already been disposed of in boilers and cement
kilns; this report considers the many other potential processes, such as metallurgical
furnaces, brick and lime kilns, glass furnaces, and sewage sludge corabustors.   Each
process is examined against such criteria as time/temperature profile, geographical
location, product quality considerations, institutional factors, and environmental
impacts.  Promising alternatives are identified.
INTRODUCTION

     The Incineration Research Branch of
the U.S. Environmental Protection Agency
(EPA) has a variety of ongoing programs to
investigate, develop, and promote inciner-
ation as a means for ultimate destruction
of hazardous wastes.  One of these pro-
grams concerns the use of high-temperature
industrial processes.  The first processes
to be investigated under this program were
industrial boilers and cement kilns, which
were chosen partially because of their
ubiquity and partially because of the
interest many boiler and kiln operators
expressed in recovering the heating value
of wastes.  At this point in time several
demonstration test burns are either com-
pleted or underway.

     Interest in other processes prompted
EPA to initiate a feasibility screening
study for all high-temperature processes.
Such a study would provide consistent and
uniform criteria for selecting those
processes that offer feasible combustion
conditions and that should be examined
further for overall suitability.
PROCESS SELECTION CRITERIA

     The first task was to select common
industries using high-temperature proces-
ses.   Table 1 summarizes the screening
criteria against which each process was
evaluated.

TABLE 1.  SCREENING CRITERIA FOR POTENTIAL
    HIGH-TEMPERATURE PROCESSES FOR THE
      DESTRUCTION OF HAZARDOUS WASTE

  0  Compatibility of process
     -  Thermal destruction conditions:
        temperature and residence time
        (turbulence not considered)
     -  Product quality
     -  Potential for fugitive emissions

  0  Number of facilities

  0  Geographic matching of industry loca-
     tion and waste generators

     The initial list of processes was
based on operating temperature; any major
process with an operating temperature of
greater than 1200°F was included.  The
                                            99

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 initial listing of approximately 100
 processes included the metallurgical,
 chemical, and mineral industries and
 sludge and waste incinerators.   When the
 other criteria in Table 1 were applied,
 several of these processes were eliminated
 from consideration.

      Gas residence time within the process
 at the high-temperature condition was an
 important consideration; the lower the
 process temperature,  the longer the resi-
 dence time required for 99.99 percent
 thermal destruction.   Turbulence, the
 other condition necessary for combustion,
 was not considered because little informa-
 tion is generally available on this param-
 eter.   Residence time and product quality
 considerations eliminated organic and
 miscellaneous chemical  manufacturing
 processes from consideration.   These
 processes often attain high temperatures
 in reactors,  but residence times are quite
 short.

      Product quality,  both actual and
 perceived, was an important consideration.
 Destructing  hazardous  waste in  a steel
 furnace,  for example,  could increase trace
 elements  in  the steel  and affect its
 physical  properties.   In all  cases hazard-
 ous waste disposal was  considered second-
 ary to  product quality.   This criterion
 eliminated processes such as  basic oxygen
 and electric  arc furnaces in  the steel
 industry  because these  processes produce a
 high-quality  steel that cannot  tolerate
 residues  from hazardous waste destruction.
 This criterion also affected  chemical
 manufacturing,  food processing  (human and
 animal  consumption), and petroleum refin-
 ing processes.

     The more potential  a process  had for
 fugitive emissions, the  less  likely  it  is
 to  be suitable  for hazardous waste dis-
 posal.  Raw materials handling procedures
 affect the potential of  a process  for
 fugitive emissions and  for hazardous waste
 disposal.  In a sintering process  at an
 iron and steel  mill, for  example,  open
 conveyors are used to transport  raw mate-
 rials to the pug mill (mixing device) and
to the sinter strand, which is also open.
Because of the major modifications to the
materials-handling system  that would be
required to correct this  high potential
for fugitive emissions and because of the
short residence time at the maximum
 temperature of about 2200°F,* the iron and
 steel sintering process was eliminated
 from consideration.

      The number of facilities available in
 the hazardous waste generation areas was
 another major consideration.   For example,
 specialty processes that existed at only a
 few widely scattered locations or develop-
 ing processes that were currently opera-
 tional  at only a few sites were not con-
 sidered.   The processes selected for
 detailed analysis were those  that'had the
 potential for disposing of significant
 quantities of hazardous wastes.

      Table 2 lists those industries and
 processes that remained after several
 processes had been eliminated from further
 consideration by the application of the
 screening criteria.   These processes were
 evaluated in more detail  by use of a
 hazardous waste destruction model  derived
 from an earlier model  developed by Acurex
 Corporation (1).
 HAZARDOUS WASTE DESTRUCTION MODEL

     The efficient destruction of hazard-
 ous wastes  in any industrial process is
 primarily dependent on the temperature and
 residence time of the combustion products
 in the furnace employed by the process.
 Hence, a matching of the residence time-
 temperature relationship for the indus-
 trial process with that required for
 complete destruction (99.99%) of the
 hazardous waste should enable one to
 identify potentially destructible hazard-
 ous waste categories.  Based on kinetic
 data for the constituents in the wastes,
 characteristic curves showing various
 time-temperature combinations for destruc-
 tion of the wastes were obtained.   For the
 industrial process, knowing the furnace
 volume, volumetric flow rate of gases,  and
 temperature range of the furnace made it
 possible to plot "process curves"  that
 showed the residence time at which the
 furnace gas is above a certain temperature
within the furnace.   By laying the "proc-
 ess curves" over the hazardous waste
 characteristic curves,  it was possible  to
  Refer to conversions table at the end of
  the paper for metric equivalents to
  English units used throughout.
                                            100

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      TABLE 2.  INDUSTRIES AND PROCESSES SELECTED FOR FURTHER HAZARDOUS
                        WASTE DESTRUCTION EVALUATION
Industry
Brick
Carbon black
Primary copper
Primary lead
Iron and steel
Lime
Glass
Sewage sludge
Hazardous waste
incineration
Exit and maximum
Process or furnace temperatures (°F)
Tunnel kiln
Oil furnace process
Reverberatory furnace
Blast furnace
Blast furnace
Open hearth furnace
Long rotary kiln
Short rotary kiln with
stone preheater
Melting furnace
Fluid-bed furnace
Multiple-hearth furnace
Rotary kiln
Liquid injection
500-2150
1600-2550
2370-2570
1300-2200
2000^-3400
2200-3250
1265-3440
2115-3340
1140-2700
1400-1600
900-1800
1500-2900
1300-3000
Residence time
(seconds, unless
otherwise noted)*
4.3
1.1
2.2
5.9
1.1? •
2.0
8.3
7.6
4.1
1.4
0.5
2.0-2 hours8
0.5-2
  Residence time above the greater of the exit temperature or 1400°F.

  Represents estimated temperature at the top of the combustion zone in the
  blast furnace.

T Residence time has been calculated using 33% of the total furnace volume
#
  Included for comparison only.
o
8 The residence time for solids and sludges can be adjusted.
                                     101

-------
 predict the waste categories  destructible
 at various  temperatures.   The required
 99.99  percent destruction is  predicted for
 those  wastes whose lines  are  below and to
 the left of the process curves.

     During a preliminary review the
 following waste categories were  eliminated
 from consideration because of their low
 destructibility by high-temperature pro-
 cesses or their high  explosion potential:
 inorganic pigments, inorganic chemicals,
 explosives,  iron and  steel, and  secondary
 lead.   Other wastes listed in the RCRA
 Background  Document (2) were  included  in
 the model and grouped according  to non-
 specific sources (F series) and  specific
 sources (K  series).   These categories  were
 plotted according to  the  required tempera-
 ture and time for 99.99 percent  destruction
 by use of the relationship:
          £n At = Sin
where
  At - time required to reach 99.99 per-
       cent destruction, s

   A = Arrhenius pre-exponent frequency
       factor (s-1)

   E = Energy of activation (Btu/1fa-
       mo! e)

   R = Universal gas constant (1.987
       Btu/lb-mole - °R)

   T = Absolute temperature (°R)

Figure 1 shows the destruction lines for
the selected hazardous waste categories.

     Process curves were overlayed on the
destruction lines to determine the hazard-
ous waste categories that should be con-
sidered for destruction.  These process
curves were calculated for the gas resi-
dence time above specific temperatures by
use of the following calculation:


          t -   31800 V      T
          u — ~A' ' y-*.   • '•'«.—I- jin =—
                CTe - V
                              m
where
  t = residence time above a given temper-
      ature (T), s
 Te = process exit temperature, °R
 T  = process maximum temperature, °R

  V = volume of process temperature zone,
      ft3

  Q = volumetric  flow rate, scfm

This relationship assumes that gas temper-
ature varies linearly with axial distance
between the point of maximum temperature
(T ) and the exit temperature.  The rela-
tionship was plotted for each process for
both the mean residence time as calculated
by the equation and the "fast path" resi-
dence time (0.5 t).  Figure 2 shows the
process curves for a short rotary lime
kiln.
EXAMPLE PROCESS ANALYSIS

     The process analysis included model-
derived technical time-temperature consid-
erations, geographic matching of industry
location and waste generators, environ-
mental factors, and institutional factors.
Although all the processes listed in Table
2 will destruct at least some categories
of waste, application of all the analysis
criteria indicates that lime kilns provide
one of the best candidates.

     Figure 2 also shows the time-tempera-
ture relationship for rotary lime kilns.
Figure 3 shows the 1978-79 geographical
distribution of lime kilns according to
the Department of Interior (2).   Theoret-
ically, all the waste categories consid-
ered could be destructed in a typical lime
kiln, and as the figure shows, the geo-
graphic distribution of these kilns is
wide.

     Most lime kilns are well controlled
by high-energy scrubbers, fabric filters,
or electrostatic precipitators.   Regula-
tions dictate the use of a scrubber for
air pollution control of some wastes
(e.g., those containing halogenated hydro-
carbons).   Any increase in particulate
loadings from the burning of hazardous
wastes should not create a problem, par-
ticularly if the plant is now operating
well within allowable particulate emission
limits.

     Environmental  problems  could result,
however, from the potential  formation of
hazardous products  of combustion.   The
model considers only the destruction of
                                           1Q2

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                                                      103

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-------
the waste components and does not predict
the compounds generated during combustion.

     Institutional factors could be the
greatest obstacle to disposing of hazard-
ous wastes in lime kilns.  Preliminary
contacts with industry representatives
have been favorable, however, because of
the potential fuel savings from burning
combustible wastes.
CONCLUSIONS

     The process evaluations and discus-
sions with many persons in industry and
government lead to the conclusion that the
major impediments to the use of high-
temperature processes are both technical
factors and institutional factors.  The
economics of each case have not been
evaluated in detail, but will clearly be
proportional to the energy cost pressures
and the degree of hazard associated with
the waste.  The term hazardous waste is an
unfortunate one because it raises a uniform
sceptre of alarm for a universe of mate-
rials which vary from deadly toxins to
everyday household substances.  This
raises public concern over utilizing
existing high temperature sources, most of
Which are located in urbanized areas.
Similarly, it magnifies worker concern
over exposure and potential accidents.

     The driving force to utilize high-
temperature processes must come from the
companies involved.  The availability of
low- or zero-cost energy combined with
possible disposal fees from generators
must be sufficiently attractive to justify
the effort required to conduct test burns,
make the necessary modifications, and con-
vince disparagers of the overall environ-
mental benefit of this approach.
3.    U.S.  Environmental Protection Agency.
     1980.   Resource Conservation and
     Recovery Act, Subtitle C; Background
     Document.  Office of Solid Waste,
     Washington, D.C.
To convert
   from
             CONVERSION TABLE
                                                               To
Multiply by
°R
ft3
scfm
Btu/lb-mole
Btu/lb-mole °R
°c

°K
m3
Nms/s
J/kg-mole
J/kg-mole °K
5.56 (°F-32)
E-01
5.56 E-01
2.832 E-02
4.383 E-04
2.324 E+03
8.314 E+03
REFERENCES

1.   Acurex Corporation.  1981.  A Tech-
     nical Overview of the Concept of
     Disposing of Hazardous Wastes in an
     Industrial Boiler.   Prepared for U.S.
     Environmental Protection Agency,
     Cincinnati, Ohio.

2.   U.S. Department of the Interior.
     1980.  Minerals Yearbook, Volume I,
     Metals and Minerals, 1978-79.   Bureau
     of Mines, Washington, D.C.
                                            106

-------
                A SUGGESTED LABORATORY APPROACH TO SIMPLIFICATION OF  THE
                                  POHC - PIC DILEMMA*
                                   Frank C. Whitmore
                                  Principal Scientist
                                      Versar,  Inc.
                              Springfield,  Virginia  22151

                             ;      Richard A. Carnes
                                Environmental Scientist
                          U.S.  Environmental  Protection Agency
                                Cincinnati, Ohio   45268

                                     Wayne A.  Rubey
                                 Environmental Engineer
                                  University of Dayton
                                  Dayton, Ohio  45469
INTRODUCTION

     Recently promulgated regulations gov-
erning the operation of a hazardous waste
incinerator (1) are a significant departure
from those that govern the thermal disposal
of PCBs and PCB-contaminated wastes (2).
In the latter case, the PCB disposal regu-
lations carefully specify the range of al-
lowable operating conditions that are re-
quired to obtain a permit for the incinera-
tion regulations.  Regulations issued under
the mandate of the Resource Conservation
and Recovery Act (RCRA) leave far more to
the engineering judgement of the individual
permit writer.  Specifically, once those
hazardous organic compounds in the waste
that will most seriously challenge the
particular incineration technology, the
principal organic hazardous constituents
(POHCs) are chosen, it is then required
that the necessary operating conditions for
the incinerator be identified that will in-
sure the attainment of the destruction and
removal efficiency (ORE) that is required
for each POHC, i.e., a ORE of at least
99.99 percent.

     Obviously, this approach requires a
considerable amount of information, both

*POHC - Principal Organic Hazardous Con-
 stituent(s)
 PIC - Product(s) of Incomplete Combustion
for the would-be permittee, as well as for
the permit writer.   The question of avail-
ability of thermal  stability information
will be treated below.   Here it is import-
ant to discuss the problems that are in-
herent -in the requirement that the POHCs
be first identified from the large number
of compounds that make  up a typical indus-
trial waste stream.  We are specially con-
cerned with those waste that have been
classified and/or listed by the Agency as
hazardous.  Therefore,  one might suspect
that the compounds that cause the waste to
be classified as hazardous would be the
most likely POHCs.   An  example that illus-
trates this point is benzene.  A waste con-
taining benzene would likely be classified
as hazardous due to the fact that  it is a
suspected carcinogen.  However, benzene
also contains sufficient heat content, more
than 15,000 Btu/lb, thus it has a consider-
able fuel value.  Such  a compound, although
properly classified as  a POHC, would not
seriously challenge a properly operating
incinerator (i.e.,  one  operating in a fuel
lean oxidizing environment).

     A waste containing hexachlorobenzene
(HCB) may not be classified as hazardous
simply based on its known toxicity.  How-
ever, HCB is known to be one of the most
thermally stable organic compounds under
most incineration conditions and must be
                                           1Q7

-------
 considered as a POHC for any waste known to
 contain this particular compound.   What is
 needed is a distinction between those com-
 pounds that are toxic by themselves and
 those compounds that present a challenge to
 the incinerator so a better POHC classifica-
 tion system can be developed.   One way to
 do this would be through the detailed chem-
 ical  analysis route.  On the basis of the
 identification of the chemical  constituents
 of a waste,  a comparison of the specific
 thermal characteristics can.be made.   The
 identification of the POHCs can then  be
 made.   Unfortunately, this  body of inciner-
 ability data does not presently exist and
 the process of attaining it could  be  prohi-
 bitively expensive.

      In recognition  of the  fact that  there
 simply was not enough data  on  the* incinera-
 tion  characteristics of even the most com-
 mon industrial  compounds, and  the  fact that
 full-scale test burns would.be. far too ex-
 pensive and  time consuming, 'the U.S.  En-
 vironmental  Protection Agency  (USEPA)  spon-.
 sored  a research program at the University
 of Dayton Research Institute (UDRI)  (3)  for
 the design,  fabrication,  and operation of
 a  laboratory-scale process  to  simulate
 nonflame thermal  decomposition  environ-
 ments.   What has evolved  has become known
 as  the thermal  decomposition analytical
 system (IDAS)  (4).

 CONCEPT AND  BASIC DESIGN  OF  TDAS

     The rationale behind the design  con-  '
 cept of the  TDAS has  not  changed basically
 from that of the earlier  discontinuous
 system (5, 6).   The  sample  is still insert-
 ed  into the  system and  then  gradually va-
 porized in a flowing  carrier gas.  The va-  .,
 porized compounds are  subsequently subject-
 ed  to  a controlled,  high-temperature  expo-
 sure.   The components of the vaporized mix-
 ture that  emerge  from the high-temperature
 environment  are  then collected  and subject-
 ed  to  instrumental chemical  analysis.  This
 same thermal  analysis format has been  em-
 ployed  with  respect  to  the TDAS, but  each
 operation within  the system  is much more
 sophisticated, thereby  producing greatly
 increased experimental  versatility.

     The major design changes over the ear-
 lier system  are centered around the design
of the  reactor,  the closed continuous  sys-
tem concept, and  also the vastly increased
 analytical capability that is now provided
by an  in-line gas chromatograph/mass spec-
  trometer/dedicated  computer  (GCMS-COMP).
       Many design  objectives were  associated
  with  the  development  of  the TDAS.  This  sys-
  tem should be  capable of conducting precise
  thermal decomposition tests.  More precise-
  ly,  it  should  be  capsble of experimentally
  determining the effects  of the five pro-
  minent  thermal decomposition variables—ex-
  posure  temperature, gaseous atmosphere,
  pressure,  mean residence time, and resid-
  ence  time  distribution.   In addition, the
  TDAS  should be able to accommodate almost
  any type of organic material.  Also, it
  should  be .capable of  analyzing all of the
  thermal decomposition effluent products.
  This  closed continuous system should be
  capable of  dealing with  toxic materials.
  Also, the TDAS should be  capable of gener-
  ating data  on a quick response basis.

„.   ,   Figure 1 shoys a bloqk,.. diagram of the
  TDAS  and Figure 2 is  an  artist's conception
  of  the  assembled TDAS components.  Studies
  can be  conducted with the TDAS using almost
  any compressed gas as the carrier and ther-
  mal decomposition'atmosphere.   Indeed, py-
  rolytic studies can be performed using in-
  ert gases,  and oxidative  studies can be con-
  ducted using air or any  other oxygen-con-
  taining carrier.   Accurate measurements of
  pressure and flow can be  readily obtained
  with  the TDAS.  The internal pressure in
  the reactor  and mass flow rate (thus mean
  residence time) can be continuously moni-
  tored by in-stre.am instrumentation.

       In the earlier work with  the discon-
  tinuous system, only  low-volatility organic
  samples could be  tested.   The  TDAS has been
 designed for measuring the thermal decom-
  position properties of a wide  range  of or-
 ganic samples—gases,  liquids,  solids,  and
 even polymers.  Complicated organic  mix-
 tures can  also be tested  with  the TDAS,by
 using the  process of slow vaporization of
 the sample.  After vaporization,  the gas
 phase molecules are subjected  to  precise
 high-temperature  conditions (these range
 between 200° and  1150°C and are  held with
 j^2°C)  in a fused  quartz tube reactor.   The
 emerging products are  then rapidly swept
 into a cryogenic,  absorbent in-line  trap
 where the  condensable  products  are captured
 at temperatures down to minus  110°.   The
 collected  effluent products are subsequent-
 ly thermally desorbed  from the trap  and
 then subjected to  GC analysis  using  high-
 resolution glass,  open tubular columns.
                                            108

-------
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                            FIGURE  1
                            109

-------
110

-------
The separated compounds are then subjected
to detailed analysis by mass spectrometry
(MS).   The thermal decomposition test para-
meters and the chemical analysis data are
then retained, and a complete analysis of
the thermal decomposition process is carri-
ed out.

     Although the TDAS is a complicated
system with many interesting components,
the operation of this system and the con-
ducting of thermal decomposition tests can
be accomplished with relative ease (i.e.,
after suitable familiarization and experi-
ence).  Most of the crucial instrumentation
for conducting experiments with the TDAS
have been mounted in an instrumentation
console, and most of the test functions can
be continuously monitored on this console.

     The basic procedure for testing a par-
ticular sample* begins with selection of
the thermal decomposition atmosphere or
carrier gas.  Next the mode of sample in-
sertion must be selected.  Then the actual
exposure temperature is chosen and each of
the furnace zones are set to this tempera-
ture.  The  internal pressure under which
the test is to be conducted can be esta-
blished by  adjusting the gas flow restric-
tors situated downstream of the reactor.
The next parameter to, be established is the
mean residence time. . Once the other vari-
ables have  been stabilized and measured,  it
is a simple matter of calculating the de-
sired carrier flow and dialing off that
value with  the adjustable flow control.

     After  establishing the thermal decom-
position test parameters, the next step  in
the procedure is to cool down the effluent
collection  trap so that the condensable
products can be captured in the absorptive
cryogenic  trap.  The remaining steps are
relatively routine.  The sample must then
be admitted, the products collected, and
after  switching to helium carrier gas, the
captured products must be subjected to in-
line analysis by GCMS-COMP.

     The above test procedures would yield
one set of data points in the thermal de-
composition procedure.  Any one of the
above  variables could  now be changed for


     *A.ll  samples subjected to analysis  by
the TDAS would be screened beforehand using
other  chromatpgraphic  instruments to verify
that the sample would  indeed be conducive
to a TDAS  examination.
the next thermal decomposition test, and
so on, until the thermal decomposition pro-
perties of the sample are adequately char-
acterized.

UTILIZATION OF TDAS DERIVED DATA

     In support of the vast cleanup at the
Morris Foreman Wastewater Treatment Plant
in Louisville, Kentucky, UDRI was requested
to carry out a TDAS study on "Hex" waste.
"Hex" waste being derived from the produc-
tion of chlorinated pesticides and the
waste being established as the cause of
contamination of the Louisville sewer sys-
tem and the cause for shutdown of the treat-
ment plant.  The source of the "Hex" was
the illegal dumping into the system by
waste haulers.  Suffice it to say an ex-
tremely serious environmental situation ex-
isted that required sound remedies to bring
the plant back into operation.

     Results of the analysis of the basic
sample as received are shown in Figure 3.
It must be noted here that the analysis in-
dicated that there was at a minimum, 185
compounds present in this waste stream.
The principal components of the waste (prin-
cipal with regard to concentration) are
listed in Table 1, with the exception of
compound "e" which has been tentatively
identified and classed as a major product
of incomplete combustion.

      A series of controlled TDAS experi-
ments was conducted to determine the ther-
mal stability of the waste and its behavior
upon thermal stressing.  The results are
presented in Figure 4 and show how several
major constituents of the waste thermally
decompose.  Special-note should be made of
Compound C which was observed to increase
in concentration as the waste was exposed to
progressively higher temperatures.  The com-
pound was identified as hexchlorobenzene
(HCB) and it was revealed through the lit-
erature that HCB has a high temperature for-
mation process known, to the industry.  HCB
was of concern from several standpoints in
this study  in that it was a POHC, it was a
PIC, and .it is one of the most thermally
stable compounds investigated on the TDAS.

     Figure 3 goes on to show that compound
"e" was formed during decomposition of the
starting material ("Hex" waste) and has the
tentative identification of hexchloroinden-
one assigned to it.  Figure 5 is a  log-skel-
etal chromatogram of the "Hex" waste identi-
                                            111

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                       112

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FIGURE  3-
                                                  40
                                                                   50
                           113

-------
THERMAL DECOMPOSITION PROFILES OF 'HEX' WASTE
        0   200   400   600   800   1000
            EXPOSURE TEMPERATURE PC)

                   FIGURE 4
                    114

-------
fying the six (6) major POHCs.  It can be
observed from Figure 5, as we proceed from
an exposure temperature of 300°C through
1000°C, the change in chromatographic char-
acteristics.  There are several PICs that
become noticeable during the studies, par-
ticularly in the 500° to 700° range.

     From the data generated on the IDAS,
it was possible to say that the temperature
and residence times that were available at
the Morris Foreman Plant incinerator would
be sufficient for the final disposal of the
contaminated sludge.  During the actual
field disposal of the waste, the incinera-
tor effluent was monitored (7) with the
findings that:  (a) the contaminated waste
was successfully destroyed and (b) the
principal chemical species found in the ef-
fluent was HCB.

OBSERVATIONS/CONCLUSION

     The availability of the TDAS data
greatly simplified the work at Louisville
by showing that disposal of the contaminat-
ed material was feasible and by flagging
specific compounds for which the incinera-
tor exhaust gases should be monitored.
The overwhelming complexity of the "Hex"
waste indicated that chemical analysis of
the waste for identification of individual
components would be a serious analytical
challenge, be very time consuming, and pose
severe economic problems.   Through the use
of the TDAS and exposing a sample to a ser-
ies of temperatures in a controlled labora-
tory environment, the entire complexity of
the analysis and understanding of the ther-
mal stability of the sample were reduced
and clarified.

     From the published regulations con-
cerning hazardous waste incineration (1)>
the definition of a POHC lies in its abil-
ity to challenge an incinerator or put an-
other way, its degree of incinerability.
At this time, a specific ranking of POHCs
via an incinerability index is inconclusive
at .best.  From the results of the "Hex" re-
search on the TDAS and other compounds in-
vestigated, it appears that the TDAS may
serve as the primary analytical tool in the
characterization of a hazardous waste for
its POHCs.  Again, this was demonstrated
in the early log-skeletal  chromatograms of
the "Hex" waste when on exposure to 300°C,
the original waste was reduced'to approxi-
mately 5.5 percent of its starting com-
pounds.   These then become the primary
POHCs for this waste and we then proceed
with developing the decomposition profiles
while being acutely aware of PIC forma-
tion during this process.  By the discrete
interpretation of these results, it becomes
possible to identify.POHCs in the starting
waste for monitoring the incinerators per-
formance and to identify PICs for setting
up the analytical requirements for stack
gases sampled during the test period.

     In conclusion, it is acknowledged that
while the TDAS-type of thermal analysis will
not take the place of field situation test
burns in support of RCRA incineration per-
mits, it can and does provide an invaluable
insight into planning and evaluating the re-
sults of such a test burn.  Additionally,
as the data base of TDAS information grows,
there is every expectation that EPA and in-
dustry can readily predict the conditions
for adequate destruction and/or problems
associated with the incineration of indus-
trial wastes.

REFERENCES

1.  Environmental Protection Agency.  In-
    cinerator Standards for Owners and Op-
    ertors of Hazardous Waste Management
    Facilities, Interim Final Rule and Pro-
    posal Rule.  Federal Register, Vol.  46,
    No.  15, Friday, January 23, 1981, pp.
    7666-7690.

2.  Environmental Protection Agency.  Poly-
    chlorinated Biphenyls (PCBs):  Disposal '•
    and Marking.  Federal Register, Vol.  43,
    No.  15, Friday, February 17, 1978, pp.
    7150-7690.

3.  Duvall, D. S., et al., "High-Tempera-
    ture Degradation Characteristics of
    Hazardous Organic Wastes - A Laboratory
    Approach," Draft Final Report for USEPA
    Research Grant R805117, January 1980.

4.  Rubey, W.  A., "Design Consideration for
    a Thermal  Decomposition Analytical Sys-
    tem (TDAS)."  EPA/600-2-80-098, August
    1980.

5.  Duvall, D. S., et al., "High Tempera-
    ture Destruction of Kepone and Related
    Pesticides."  Presented at 173rd Ameri-
    can  Chemical Society National Meeting,
    New Orleans, LA, March 1977.

6.  Carnes, R. A., et al., "A Laboratory
    Approach to Thermal  Degradation of Or-
    ganic Compounds.  In:  Proceedings of
    70th Annual Meeting  of the Air Pollu-
                                            115

-------
tion Control Association, Toronto, On-
tario, June 1977.
                                           116

-------
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-------
                  SITING AND DESIGN CONSIDERATION FOR THE ENVIRONMENTAL
                     PROTECTION AGENCY COMBUSTION RESEARCH FACILITY
                                    Richard A.  Carnes
                                 Environmental  Scientist
                           U.S. Environmental Protection Agency
                       Industrial  Environmental Research Laboratory
                                 Cincinnati, Ohio  45268

                                    Frank C. Whitmore
                                   Principal Scientist
                                       Versar,  Inc.
                                  6621 Electronic Drive
                              Springfield,  Virginia   22151
BACKGROUND

     In 1975, the EPA published the results
of a major research program entitled "De-
termination of Incinerator Operating Con-
ditions Necessary for Safe Disposal of
Pesticides" (1).  This report presented the
results of a number of incineration tests
covering several pesticide formulations and
molecular structures.  At that time, it
represented the Agency's first attempt to
define safe operating conditions for the
thermal destruction of hazardous sub-
stances.  Further, under the authority
granted the Agency by the Resource Conser-
vation and Recovery Act of 1976 (RCRA), the
Agency used this report along with other
documents (2) to support the establishment
of incineration conditions that are requir-
ed for the incineration of hazardous wastes
as listed in appropriate Federal Register
publications (3, 4).

     During the regulatory development ex-
ercise, it became apparent that a consid-
erably greater amount of incineration data
would be required for the enormous number
of compounds and mixtures of compounds to
be regulated under RCRA.  A major research
and development effort was determined to
be necessary to provide that data.  This
program was planned to consist of two ma-
jor efforts:  (a) a laboratory research
program to provide basic data on the ther-
mal stability of specific hazardous com-
pounds, which would also support the
second effort; (b) an extensive series of
full-scale test burns using existing equip-
ment and facilities.

     It soon became apparent in other relat-
ed work that there were significant differ-
ences in data observed in the large-scale
experiments from those derived from the
laboratory studies.  Such differences are
thought to arise from the simplifications
that have been made in the incineration
conditions maintained in the laboratory-
scale experiments.

     A need was recognized for an interme-
diate-scale study that would more nearly
approximate the thermal and chemical con-
ditions that exist  in full-scale technolo-
gy, but at the same time be close enough
to the laboratory studies so as to provide
a bridge between the two.  In July of 1978,
a research contract was awarded to conduct
parametric investigations of a pilot-scale
hazardous waste incinerator.  The program
was originally scheduled to rent the tech-
nology at the manufacturer's facility and
have contract personnel conduct the nec-
essary experiments on an intermittent
basis so as not to disrupt activities of
the manufacturer.  Unfortunately, this pro-
cedure was found to be unsatisfactory for
a number of reasons including the inability
of the manufacturer to make the equipment
available:  Eventually, the EPA authorized
                                           118

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the contractor to purchase the incinerator
and move it to a suitable site at which the
experiments would be carried out.

     The contractor found a suitable iso-
lated site that was zoned for industrial
research and development and that was with-
in commuting distance from his office and
laboratories.  Permits were received from
the state.  All agreements were drawn up
and modifications to the site initiated,
when local citizens became concerned and
effectively blocked the continuation of the
program.  A very vital lesson in communi-
cation was learned and subsequently report-
ed on in the literature (6).

NATIONAL SITE SEARCH

     In September 1979, after the two sit-
ing failures, the authors were charged by
the Agency to find an acceptable site, pre-
ferably on Government-owned land, for the
incinerator and to conduct the research at
that site.  An analysis of the earlier sit-
ing failures strongly suggested that the
public would never accept the concept of
this type of research being carried out in
anything suggesting a makeshift facility.
What was required would be a fully dedicat-
ed facility specifically designed for in-
cineration research and for the handling of
hazardous materials.  As an essential first
step in the search for suitable facilities,
it was required that the criteria for such
a laboratory facility be carefully outlined
and a general layout for the facility be
designed.  The details of the resulting fa-
cility will be treated below, suffice it'to
say here that the essential criteria were
defined as follows:  (a) the laboratory
must be staffed and equipped so as to be
capable of on-site analyses of both the in-
coming candidate waste streams and of all
effluent streams from the facility; (b) the
operations should be entirely professional
and the resulting data made available to
the interested public; (c) safety of the
operating personnel, the facility, and the
surrounding area must be the first consid-
eration in all operations; and (d) since
recently published data (7) indicate that
the products of incomplete combustion
(PICs) may,  in many cases be significantly
more hazardous than the components of the
waste that require the latter to be classi-
fied as hazardous, the laboratory must be
of a quality to allow the safe handling of
toxic materials including carcinogens.
With these criteria in hand, an exhaustive
site search was undertaken.  The approach
was, in every case, begun by a search of
available Government space (this was se-
lected as a criterion since thereby it
would be possible to avoid zoning problems)
followed by direct contact with the respon-
sible authorities at the available sites.
In most cases, very little enthusiasm was
exhibited so that no further action was
necessary.  Eventually, the National Center
for Toxicological Research (NCTR) in Jeffer-
son, Arkansas, suggested that they could
and would make space available.  The
authors visited the decision officials,
were well received, and shown that the site
was ideal for the proposed facility.  Spe-
cifically, NCTR is located on the northern
boundary of the Pine Bluff Arsenal on a
good all-weather road in a location'that is
sparesely populated'and served by a commu-
nity that is well conditioned to understand
the dangers inherent in the handling of ex-
plosive and toxic materials (the Arsenal is
the national depot of chemical weapons for
the Army).

PREPARATION FOR PERMIT OF OPERATIONS

     With the approval in principle by the
management of NCTR, preparations were begun
to obtain the approval of the state and
local officials that would be concerned and
to properly inform the public of the plann-
ed facility (8).  Previous experience had
shown that the latter element of the infor-
mational program was at least as critical as
the former.   The steps taken were the fol-
lowing:

   (1)  Confer with and inform the cogni-
zant USEPA Regional Administrator and staff
of the proposed facility and its mission.

   (2)  Confer with and inform the highest
state officials of the proposed facility
and its planned mission.

     When these individuals were satisfied
with the general notion and indicated that
they would actively support the facility,
the next series of steps were taken.  Spe-
cifically, these consisted of the follow-
ing:

   (3)  A series of meetings with the Ar-
kansas Department of Pollution Control and
Ecology (DPCE) were held covering the gener-
al concept of the facility, its mode of
operation, and the nature of the staff
were outlined.  The meetings finally led to
                                            119

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an application for a construction permit
and the assurance that, if there are no
public objections, the operating permits
would be forthcoming.

     (4)  A series of meetings with state
officials and agencies that would be im-
pacted by the facility.  This included the
health, police, and transportation depart-
ments among others.

     (5)  A series of meetings with local
officials and with the members of the state
legislation who represented the area that
would be most immediately impacted by the
facility.

     (6)  Civic groups were offered the
opportunity for informal (or for that mat-
ter, formal) presentations of the planned
facility and its mandate.

     (7)  The state  industrial organization
were considered important in this informa-
tional program since they were concerned
with hazardous waste disposal problems,
maintained important informational services
for the state officials, and could be ex-
pected to serve as sources of test mate-
rials in the active phase of the research
program.

     The format of the  individual informa-
tional meetings was, of course, tailored
for the specific group to be addressed.
There were, however, many features of each
of these meetings that were common.  In
order to be assured that all parties were
aware of the magnitude of the hazardous
waste disposal problem  in the United
States, a slide show using selected exam-
ples of the poor practices used in the past
and the consequences that all too often
have accompanied such practices was pre-
sented by Agency officials.  After this  in-
troduction, the detailed program proposed
for the CRF was discussed.  In each meet-
ing, sufficient time was allotted for ques-
tions from the concerned audience.  In some
cases, for example with the DPCE of Ar-
kansas, there were a number of meetings,
most of which were working sessions where-
in the specific requirements for permitting
the facility and  its operation were dis-
cussed and finally incorporated into the
construction permit and  into the protocol
for the operation of the facility.

     During this extensive series of infor-
  tional meetings and briefings, the media
were informed, in detail, by both press con-
ferences and detailed handouts that care-
fully and fully described the proposed pro"
gram.  Further, the national congressional
delegations was kept informed by frequent
letters that described the promotional ac-
tivities that were underway.

     The culmination of this activity was a
public meeting in Pine Bluff, Arkansas, at
which the public was afforded the opport-
unity to present their questions and pos-
sible concerns.  The meeting was chaired by
the Director of DPCE supported by respon-
sible staff from the Agency and from the
EPA Contractor.  The attendance at the
meeting was approximately equally divided
between media persons and the technical and
administrative officials there to defend
the program.  The informational program
that had been conducted had apparently an-
swered questions and there was no public
concern expressed.  Shortly after this
meeting, the State of Arkansas issued a
contruction permit for the facility.

THE COMBUSTION RESEARCH FACILITY (CRF)

     In the course of the discussion between
the authors and the officials of the State
explicit, as well as, several implicit con-
ditions existed in the permit-conditions
that would have a significant impact on the
design, staffing, and operation of the CRF.

   •  Safety assumes such an important as-
      pect in the overall program that a
      trained specialist (Safety Officer)
      will be an integral part of the per-
      manent staff.

   •  The concern about carcinogenic by-
      products of combustion required
      strict adherence to NIOSH and OSHA
      requirements for the laboratories at
      CRF.

   •  Continuous monitoring of all efflu-
      ents must occur during any incinera-
      tor tests.

   .  The facility must be equipped to con-
      duct the majority of analyses in-
      house.

   .  To the extent possible, all candi-
      date waste streams should originate
      from within Arkansas.
                                            120

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     •  To the extent possible,  local  per-
        sonnel should be hired to staff
        the operations.

     .  The senior staff of the facility
        must be full-time on site.

     When all requirements are brought to-
gether, the resulting facility takes the
form shown in Figures T through 3.  The
latter figure presents an artist's concep-
tion of the interior of the facility.   Some
of the outstanding features of the faci-
lity are:

     •  The incinerator(s) will  be housed
        in an isolated room accessible
        only through the change room/show-
        er.  All controls and monitoring
        readout equipment will be monitor-
        ed from the operations room.

     •  Each laboratory will be provided
        with a hood and separate outside
        air source and will be designed to
       . safely handle carcinogens.

     •  Internal connections between la-
        boratories have been designed to
        reduce the potential of cross-con-
        tamination to an absolute minimum.

     .  The characterization laboratory
        will allow the complete determina-
        tion of the required combustion
        conditions for a given waste and
        to determine the nature of the air
        pollution control equipment re-
        quired for each waste.

     .  The analytical laboratory will be
        fully equipped to allow analysis
        of all necessary organic com-
        pounds.

FUNCTIONS OF THE CRF

     The original purpose of the research
program, which eventually lead to the con-
cept of the CRF, was to carry out a number
of pilot-scale test burns on materials that
had previously been studied at the labora-
tory Scale (9).  The purpose of these ex-
periments was to better allow the extrapo-
lation of the laboratory data to large-
scale  systems and to indicate differences
between the  idealized  laboratory system and
the realtor Id equipment.   In the coursfe of
the development of that program and spurred
by the needs of the EPA, and the require-
ments stipulated by the State of Arkansas,
a number of additional elements of the pro-
gram to be carried out at the CRF have sur-
faced.  Several Of the more important of
these will be briefly described below.
WASTE CHARACTERIZATION

     It has been stipulated that, prior to
the undertaking of a test series on a parti-
cular waste, it will be necessary for the
staff of the CRF to produce a detailed pro-
tocol for the proposed tests.  Only after
review and acceptance by both the DPCE and
the EPA Project Manager, will the actual
tests be undertaken.  Clearly such a re-
quirement means that the necessary inciner-
ation parameters must be established prior
to the preparation of such a protocol.  It
is the function of the Characterization
Laboratory (Figure 3) to produce these
tests.  A literal reading of the Incinera-
tion Regulations (4) (1/23/81 - FR) would
suggest that this will require the detailed
analysis of the wastes for the identifica-
tion of the principal organic hazardous
compounds (POHCs), a determination of which
of, these POHCs will most seriously chal-
lenge the incinerator [and thereby be the
compound(s) for which the minimum operating
conditions must be determined], and a de-
termination of the air pollution control
equipment that is most appropriate.

     An alternative procedure to this dif-
ficult requirement has been proposed and
will be a major element of the program at
the CRF.  This alternative procedure will,
among other results, serve to  identify both
the POHC(s) for which the incinerator ef-
fluents must be sampled and will also serve
to suggest the nature of the products of
incomplete combustion (PICs) that might be
involved.

DEVELOPMENT OF STANDARD PROTOCOLS FOR HIGH
TEMPERATURE SAMPLING

     The nature, of the  incinerator technolo-
gy that will initially be located at the CRF
is such that the primary chamber can be
operated at sufficiently low temperatures
so as to allow the determination of de-
struction efficiency (DE) as a function of
temperature while at the same time operat-  .
ing the secondary chamber at sufficiently
high temperatures that assures there are no
hazardous effluents.  This ability carries
the necessity to develop and test various
                                            121

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FIGURE 1:  RELATIVE POSITION OF PLANNED' CRF TO EXISTING
           POLLUTION CONTROL FACILITIES AT NCTR
            FIGURE 2:  CLOSE-UP VIEW OF CRF
  FIGURE 3:  ARTIST RENDERING OF CRF CUTAWAY SHOWING
             LABORATORIES AND.INCINERATOR ROOM
                          122

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hot-zone sampling equipment and procedures.
There are a number of practical situations
in which a certified and widely accepted
sampling method would be of significance.

ANALTYICAL LABORATORY AND PROCEDURES

     As has been mentioned, one serious
stipulation on the operation of the CRF  is
the requirement for on-site laboratories to
be equipped and staffed so that analyses of
any and all effluent streams from the sys-
tem can be conducted.  For many of the an-
ticipated trace compounds there does not
exist well established and widely accepted
analytical methods.  It will be part of the
function of this laboratory to assist in
the development of such methods where nec-
essary.  Furthermore, many of the accepted
sampling and collection methods and media
have not been adequately verified.  This,
too, will be part of the mission of this
laboratory.

     A somewhat esoteric aspect of the re-
search program will be the determination of
the effects of sample storage on the valid-
ity of analytical data.  In most large
technology te'st burns, there is a consider-
able time lapse between the taking of sam-
ples and the subsequent analysis of those
samples.  There is some concern that during
this extended interval relatively short
lived species might well be altered either
in nature or concentration, or both.  A
program will be undertaken to determine the
possibility of this effect and acceptable
methods of control.

INCINERATION INSTRUMENTATION

     Presently available original equipment
manufacturer (OEM) supplied control instru-
mentation is not of sufficient range or
reliability to adequately meet the control
requirements of, for example, the PCB In-
cineration Regulations (3).  It will be
necessary that additional instrumentation
be developed and tested under standard con-
ditions for the measurement of (on-line and
in real time) such parameters as hot zone,
mass flow, temperature (both average and
temperature fluctuation magnitude), resi-
dence time and its fluctuation, and, if
possible, the actual concentration of or-
ganic compounds in the gaseous effluent
from the incinerator.  Each of these
measurement sensors must be such as to pre-
sent its output in a form that can be used
to control the waste blend feed of an in-
cinerator.

AIR POLLUTION CONTROL DEVICES (APCD)

     At present, the major source of 'opera-
tional information on the many different
devices that are used for air pollution
control is the vendors of that equipment.
It would be of great utility if there ex-
isted a standard series of tests and test
conditions whereby each such device could
be treated for its performance and chal-
lenged as to its design and capacity.  In
this manner there would exist data that
would then allow the intercomparison of
apparently comparable devices under a set
of standard conditions.  Clearly this would
better allow the designer of a facility to
make proper judgements.  The incinerator
at the CRF will be sufficiently well char-
acterized as to allow the design of and the
carrying out of such'tests.

CONCLUSIONS

     One of the disadvantages of the use of
trial burns in existing equipment lies in.
the difficulty in the intercomparison of
such data.  The present difficulties with
the available data base derive principally
from this program.  It was for the specific
purpose of circumventing this inherent un-
certainty that the CRF was designed.  With
the availability of a dedicated facility
and a full-time dedicated staff, the rate
of return of comparable and reliable data
on the thermal characteristics of a variety
of industrial waste streams will soon be
forthcoming.

BIBLIOGRAPHY

1. Ferguson, Thomas L., et a!., "Determina-
   of Incinerator Operating Conditions Nec-
   essary for Safe Disposal of Pesticides,"
   EPA-600/2-75-041, December 1975.

2. "Destroying Chemical Wastes in Commer-
   cial-Scale Incinerators," Phase II.
   Final  Report (SW-155c) under Contract
   68-01-2966, 1975.

3. Polychlorinated Biphenyls:  Disposal  and
   Marking.  Federal Register 43, No. 34,
   February 17, 1978, pp. 7150^7164.

4. Environmental Protection Agency Incin-
   erator Standard for Owners and Opera-
   tors of Hazardous Waste Management
                                           123

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     Facilities; Interim Final Rule and
     Proposed Rule.  Federal Register, Vol.
     46, No. 15, Friday, January 23, 1981,
     pp. 7666-7690.

5.   Bell, B. A. and F. C. Whitmore, "The
     Kepone Incineration Test Program,"
     EPA-600/2-78-108, May 1978.

6.   Whitmore, F. C. and R. A. Games,
     "Windmills, Incinerator, and Siting,"
     In Press, J. of Hazardous Materials,
     1981.

7.   Lustenhouwer, S. W. A., et al.,
     "Chlorinated Dibenzo-p-dioxins and
     Related Compounds in Incinerator Ef-
     fluents."  Chemosphere 9, 501-522
     (1980).

8.   Private communication.  Maryevelyn W.
     Soller, USEPA, Cincinnati, Ohio 45268.

9.   Rubey, Wayne A., "Use of Advanced
     Thermal Systems for Studying Decom-
     position of Hazardous Organic Wastes,"
     EPA Cooperative Agreement CR 807815.
                                           124

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                 ENVIRONMENTAL AND PERFORMANCE ASSESSMENT

              AT HAMILTON COUNTY HAZARDOUS WASTE INCINERATOR
                                     Boyd T. Riley Jr.
                                  RYCON, Incorporated
                                  Cincinnati, Ohio  45229

                                      John H. Trapp
                    Metropolitan Sewer District of Greater Cincinnati
                                  Cincinnati, Ohio  45204
                                        ABSTRACT

       This paper offers a brief description of the  facility and an overview of the  task
  areas being developed in order to enhance the value of the MSD complex for USEPA and
  MSD purposes.   Another paper to be presented later in this conference describes  the re-
  sults of emissions  and combustion efficiency tests conducted in the early fall of  1980.
INTRODUCTION
      The MSD serving Cincinnati, Ham-
  ilton County and associated municipali-
  ties determined a need  for a solid and
  liquid waste incinerator complex to
  serve the area needs in the late  1960's.
  Operations were  initiated at the  facility
  in 1979.

      Recently, Hamilton County and the
  U.S. Environmental Protection Agency,
  Incineration Branch,  formalized a co-
  operative agreement whereby the
  USEPA could begin to participate in the
  management  of the  incinerator complex
  for the purpose of generating data to
  support permit writing  activities for
  other hazardous waste  incinerator com-
  plexes.   Management of the day-to-day
  operations  of the MSD complex remains
  with MSD personnel; however, review of
  past experiences with the facility, possi-
  ble modifications and improvements to
  the MSD complex for data  generation
  purposes are presently being planned and
will be implemented on a cooperative
basis in the near future.

    The MSD complex was constructed
on the premises of the Millcreek Sewage
Treatment Plant,  located in the Lower
Price Hill area of downtown Cincinnati.
The sewage treatment plant includes pri-
mary settling, and conventional activated
sludge treatment facilities.  Sludge is
treated in sludge digesters to produce
methane which fuels a stationary electri-
cal generating plant of 4 mw capacity.
Digested  sludge is disposed of by
multiple hearth incinerators.

DESCRIPTION OF THE SYSTEM

    Wastes are most commonly deliver -
ed by tanker truck from a variety of
sources  to the receiving station of the
incinerator complex.   The waste is
pumped from the truck through pre-
strainers whose round hole openings may
be varied from 1/8  in. to 3/8 in. open-
ings according to information available
on the waste.  Selection of the screen is
                                           125

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dependent on the viscosity of the material
and the known solids content.  (The
screens are being replaced by continuous
shredders to minimize unloading delays.)
The wastes are pumped by one or more
of four pumps to a holding tank for place -
ment in selected storage tanks in the
tank field.

    A small drum unloading and dis-
charge area is available for the manage -
ment of drummed wastes, although the
delivery of drummed wastes is  not en-
couraged by MSD.  An elevated unload-
ing dock is  provided for the removal of
drums from trucks and a drum tilt and
discharge mechanism into a sump from
which wastes are pumped to a holding
tank is provided.

    From the unloading point, the
wastes may be delivered either to the
6, 000 gal holding tanks  or directly to
selected storage tanks of 25, 000 gal
capacity.   The tank farm includes four
6, 000 gal preliminary holding tanks  and
ten 25, 000 gal storage tanks, four
12, 000 gal storage tanks and  an addition-
al 25, 000 gal uninsulated tank for fuel
oil storage  to service the facility.

    The entire tank farm is housed on a
concrete apron with a concrete  spillwall
and trench drain which is valved to pre-
vent spills but will allow the removal of
rainwater.   Drainage from the tank
farm  is directed to the inlet of the sew-
age treatment plant or returned to one
or more storage tanks.   Each waste
Storage tank is insulated and was origin-
ally designed with internal steam heat-
ing coils of the suction type.  Due to
corrosion problems associated with  the
heating coils and caking of the waste on
the coils, which negated their heating
efficiency,  the heat  exchangers  in the
waste storage tanks were removed.
When necessary, wastes are heated  by
operating a 40 HP mixer on each tank
until suitable temperatures and viscosi-
ties are achieved.   A differential
pressure transducer is mounted on the
base of each tank to provide continuous
digital weight read-outs at the control
panel.   Tanks are also monitored with a
liquid level gauge located in the  control
room.   In general,  the tanks in the tank
farm are clustered in groups of  two or
three and each group is served by two or
more pumps which may be operated
separately or concurrently to remove or
to add wastes to each tank.  Under .nor -
mal operating conditions, two  of the ten
storage tanks are planned to be used for
storage of skimmings  from clarifiers and
primary settling tanks  at the municipal
sewage treatment plant.

     The total diked containment capacity
is approximately 650, 000 gal.    Total
tank farm capacity including holding tanks,
storage tanks,  fuel oil  storage,  etc. is
approximately 460, 000 gal, leaving
approximately a one and one-half ft free-
board in the  event of a  catastrophic spill.
A complete foamite fire protection sys-
tem is installed throughout the tank farm.
In addition, each tank is overlaid w.ith
nitrogen to reduce the possibility of oxi-
dation,  polymerization or spontaneous
combustion events while waste is stored,
loaded or unloaded.

     During incinerator operation, the
wastes are removed from the storage
tanks and combined in one or more of
four batching tanks.  Wastes are blended
according to chemical compatibility and
heat content  and, thus,  provide a relative-
ly uniform fuel value to the combustion
systems.  A target of  7, 500 Btu's per
pound is used for blending schedules.
The tanks are flat bottom in design and
are not washed between different waste
charges.   To date,  no difficulties have
been encountered with reactions  between
waste residues in the tanks and new
wastes.

     The blended wastes are removed
from the batching tanks and delivered to
either of two combustion systems.  One
is a rotary kiln combustion system with
the capability of burning liquid wastes in
addition to certain types of granular
solid materials.   The second is  a liquid
                                       126

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                                      TABLE 1
Volumetric

Equipment
Kiln
Cyclone
Combustion
chamber
capacity
gal/hr
1200
1200
N/A

Maximum heat °F
release
MMBtu/ hr
65
77
N/A

Maximum
temperature
2400
3100
2500

Minimum
residence
time /sec
0.6
0. 1
2.0

injection combustion chamber.   Both of
these primary combustion chambers dis-
charge into a secondary combustion
chamber.

     Table 1 describes  the design capaci-
ties  of the rotary kiln,  the liquid injection
c.ombustor and the  secondary combustion
chamber.

     Liquid wastes  are  delivered by heat
traced, insulated pipelines from the
batching tanks to externally atomized
type nozzles in both the rotary kiln and
the liquid injection combustion chamber.
Atomization was originally provided at
these nozzles with steam; however, high
steam .demand in other operations of the
waste water treatment plant created a
need to temporarily use compressed air
as the atomizing agent.  Air is being.
supplied by portable  rotary air compres -
sors pending installation of new dedicated
boilers.   In addition,  compressed air is
used to operate all controls in  both the
tank farm and combustion facilities.

     A solids handling system available
at the plant has two distinct capabilities.
The first is an in-ground hopper for re-
ceiving grit by dump truck delivered by
the municipal sewage treatment plant.
It consists basically of three receiving
chambers of approximately 8 cu yd
capacity from which solids are removed
by screw conveyor and fed to a bucket
elevator.  The bucket elevator delivers
the  solids to a lateral conveyor which
delivers the material to the gravity feed
chute of the rotary kiln.   This system
could be used for contaminated combusti-
ble, solids that are  finely divided, e.g.,
PCB-contaminated soil.

    Bulky solids may also be handled by
the system.   A single truck discharge
hopper is  provided to receive oversize
material which is conveyed by a steel
plate conveyor to a 150 HP Eidal shred-
der.  The output from the shredder is
carried by belt conveyor to the bucket
elevator which lifts the material, to the
discharge point of  the rotary kiln.
Neither solids handling system is capable
of accepting semi-solid material at the
present time.   In  addition, due to the
open handling system, solids contamin-
ated with  extremely volatile or powdery
materials cannot be accepted because of
the danger of excessive fugitive emissions
from the system.  The design could be
modified to accept these materials should
a waste generator  require this  type of
service.

     The rotary kiln combustion cham.ber
is approximately 20 ft in length and 12 ft
outside diameter.  Inside diameter and
length of the kiln are 10 ft and 20 ft.  The
injection combustion chamber is approxi-
mately  6 ft  in diameter  and 11  ft in
length.   The secondary combustion
chamber is vertically oriented with hot
gases entering the base and leaving the
top of the chamber.   It is cylindrical,
approximately 13 ft 6 in. in diameter by
40 ft in height, and surmounted by an
emergency stack bypass for use when
                                         127

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 power or scrubber water is lost.   The
 three combustion chambers are con-
 structed of carbon steel,  ASTM A-283,
 and lined with refractory and insulating
 brick.   Maximum operating tempera-
 tures are 3100° F in the liquid injection
 chamber,  2400° F in the kiln and 2500°F
 in the combustion chamber exit.  Ash and
 slag are removed in a  quench tank and
 transported via pipeline to a holding
 lagoon located near the incinerator.

     The hot gas flows  from the secondary
 combustion chamber into a horizontal
 duct where quench water sprays reduce
 the temperature of the gas stream to
 200° F.   Thence, they pass  into a verti-
 cally oriented variable throat venturi
 scrubber where recirculated water is
 added to remove particulate matter.  The
 duct work and venturi scrubber are lined
 with silicon  carbide block, while the
 shell is  constructed of Corten (ASTM A-
 242).  The gas stream turns 90° and
 enters the base of an acid neutralization
 scrubber.    This absorber is vertically
 oriented, approximately 15 ft in diameter
 and  30 ft tall, and is of the sieve tray
 type.  Its function is to neutralize acid
 gases.   The scrubber  shell is  lined with
 glass flake polyester to minimize corro-
 sion.  The trays are 316 stainless steel.
 Absorber water is supplied from the
 principal blowdown tank after pH adjust-
 ment with 50% caustic (sodium  hydroxide)
 from two standby 10, 000 gal storage
 tanks.   The cooled,  neutralized gas
 flow exits the top of the scrubber, passes
 through a demister and is conducted ver-
 tically down to an induced draft fan
 powered by a 1500 HP motor.   The fan
 housing is lined with rubber and the fan
 blades are constructed of Inconel 625.
 Gases exiting the induced draft  blower
 pass into a 7 ft diameter  stack  approxi-
 mately 90 ft  in height,  incorporating
 sound suppression baffles and construc-
 ted of cylindrical sections of 3/16 in.
 stainless steel.  Three pumps  are used
 to supply water to the quench system and
 to the venturi scrubber.   Two more are
used to recirculate flow from the blow-
 down tank to the neutralization scrubber.
 An emergency water supply mounted on a
 vertical tower approximately 120 ft in
 height is designed to supply quench water
 to the system should pumping capabilities
 or power  be lost to the system.  Quench
 water is supplied for 5 min of operation
 which is sufficient to allow shutdown of
 the system and opening of the emergency
 cap.

     After the complete scrubbing system,
 gas exits  at approximately 180° F; emis-
 sions are designed to be a maximum of
 . 03 grains per standard cubic foot at
 70° F and 12% CO2.   Emission tests
 have indicated that acid emissions have
 been completely neutralized, <2 ppm HC1,
• but that particulate emissions, while
 within state limits, are about .08 grains
 per DSCF.  Better quenching and im,-
 proved demisting should allow achieve-
 ment  of the original  design goal.

     Process control and operation is
 carried out in a centrally located  building
 housing the main control panel.    The
 control panel offers complete monitoring
 of both the tank farm and the combustion
 facilities.   The tanks are  monitored for
 both valve position, i.e., in-flow, out-
 flow,  non-operation,  liquid level,  and
 weight of tanks'.  Pump motors are indi-
 cated to be in  an on-off position and
 valve  openings are displayed. Digital
 read-outs are provided for waste temper-
 atures in each tank.   On the combustion
 system, temperatures are monitored both
 by drum type direct reading gauge and
 continuous recorder  as well as digital
 temperature read-out.   Temperature
 monitoring points are at the exits  of the
 rotary kiln and liquid combustion cham-
 ber and at the  exit of the secondary com-
 bustion chamber.  Overall system con-
 trol is based on the Btu content of the
 waste to be burned.   Waste flow is auto-
 matically varied to maintain set point
 temperatures and negative  draft in the
 combustion chamber  (about 1-1/2 in.
 water), venturi pressure drop (28  - 30
 in. water), and pH of recirculated water
                                        128

-------
exiting the absorber (6.5 - 7.0) are conr
trolled.

    A broad variety of liquid wastes can
be burned in the incinerator system.
Reasonable quantities of bulky solids may
be burned after shredding and granular
wastes can be incinerated.  A  general
category of wastes which are currently
excluded from the incinerator is semi-
solid material that is too viscous to be
handled as a pumpable  fluid but too
sticky to be handled in a dry solids hand-
ling system, such as the bucket elevators
and conveyor represent.  Should a
demand for this type of service be
sufficiently great,  equipment could be
added to the system which would allow
its  combustion.
FUTURE TASK AREAS

     The purpose of the cooperative
venture between USEPA and MSD is  to
allow EPA to develop in a cooperative
fashion a full scale  test and evaluation
facility for evaluating the destructive
efficacy of the facility on various types
of hazardous wastes.  The evaluation
will include:  technical modifications re -
quired to increase the facility's produc-
tion or  decrease costs; monitoring re-
quirements to more  completely measure
emissions; and steps necessary to in-
crease  the variety of hazardous wastes
which can be and are burned at the
facility.  Throughout all operations,
data will be collected and analyzed to
support the permitting of other full scale
incineration facilities throughout the
United States.  Thus, where questions of
compatibility of/an incinerator with  a
specific hazardous material cannot be
resolved by other data or by the litera-
ture, it'will be possible for EPA to  con-
duct a preliminary full scale, controlled
trial burn on the material in question.

     A number of tasks are envisioned to
contribute to the modification of facility
operations in order to accommodate the
EPA requirements for a full scale
hazardous waste incinerator test facility.
Among those tasks presently being devel-
oped are the following:

1.  Substantial additional effort will be
    dedicated to the detailed monitoring
    of on-going incineration operations
    at the facility.   Included will be a
    definition and description of all
    problem areas that are encountered
    by the facility in order that this in-
    formation may be passed along to
    incinerator design personnel.-  Many
    areas will be examined as  unit oper -
    ations.  This will include  personnel
    assignments, overall management,
    laboratory operations  for monitoring
    and control of wastes,' receiving
    area operations,  storage operations
    and compatibility control require-
    ments, staging of wastes for com-
    bustion, incinerator control oper-
    ations, and the emission control re-
    quirements .   In short, a detailed
    description of operations at the
    facility will-be created to be used as
    a reference manual for future
    hazardous waste incinerator oper-
    ations .

 2.  A detailed review and documentation
    of the original plant design vs.  the
    actual plant as it exists will be made.
    Included in the document will be
    definitions and reasons for the
    changes that have been brought about
    and a description of the types of
    problems which were  overcome by
    the  changes.

 3.  A quarterly operating cost summary
    for  the facility will be generated in
    order to indicate, the level of cost of
    operation.   Sufficient detail will be
    developed in the costs in order, to
    show those costs that  are accrued
    while the facility is not in  operation,
    as  well as those that are accrued
    during operation.   Modification of
    the  facility costs will  also be de-
    fined.

 4.  One area of substantial interest to
                                         129

-------
    both EPA and MSD is the creation of
    a system which will allow the collec-
    tion of extensive data on various
    hazardous  waste incineration tests
    at the lowest possible cost.   As a
    result,  a number of alternative
    approaches to long term sampling
    and analysis problems of hazardous
    waste incinerator facilities will be
    examined.   Principal among these
    will be the preliminary consider -
    ations for creating sampling  slip-
    streams from various points  in the
    facility coupled with  automatic mon-
    itoring instrumentation in an instru-
    ment bank  and computerized  collec-
    tion and reduction and presentation
    of the data as it is generated. Such
    an advanced system would, of course,
    allow for the accumulation of large
    quantities of data at very low cost
    after the initial installation costs of
    the system.

5.  Substantial effort will be dedicated
    to the classification of the principal
    organic hazardous constituent
    groups (POHC's) that have been
    burned at the facility since its doors
    opened several years ago.   This
    data collection effort will  create a
    backlog of  information concerning
    those hazardous materials that have
    been successfully burned at this
    type of facility.

6.  Pursuant to the information devel-
    oped in (5), a definition of POHC's
    that  may be burned at the facility
    will  also be created.   Along  with
    these POHC's, appropriate sources
    of typical wastes will be compiled.
    Constraints on the incinerator
    facility for accepting and burning
    these materials will  be  defined.
    This would include permitting re -
    quirements, time required for per-
    mits, and the possible quantities
    and locations of waste that could be
    accumulated for combustion at the
    facility.
 7.   In order to carry out experiments
     during the period of transition from
     present operations  at the facility to
     those  that might be exemplified by
     improved data collection systems in
     the future,  an experimental data
     collection and operating protocol for
     the facility will be prepared in order
     that data may be collected on
     POHC's as soon as possible that may
     be of immediate interest to EPA
     permit writers.   This  protocol
     would include a detailed definition of
     operations by the various personnel
     at the facility, as well as data which
     should be collected and how it should
     be collected.

     The preceding tasks summarize .a
number of areas of significant interest to
EPA and MSD.   A number of other tasks
are also being  considered for inclusion
in the overall scope of the project, either
in this initial phase or in future phases.
Areas that may be of interest to others
in the hazardous waste incineration field
would be welcomed as possible suggested
tasks for inclusion in the cooperative
agreement.  These should be submitted
to Mr. John.. Trapp of MSD of Greater
Cincinnati or Mr. Donald Oberacker of
the USEPA as soon as possible.

     At the conclusion of the project,  EPA
expects to have a full scale test facility
representing the most cost effective
approach to the gathering of data under
carefully controlled and monitored con-
ditions for a variety of POHC's of inter-
est to the Agency.  This will be done
without altering or interfering with the
normal operation of the  facility which
will continue to earn its own capital re -
payment and operating expenses through
the services rendered.
                                        130

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                             TRIAL BURN VERIFICATION PROGRAM
                            FOR HAZARDOUS WASTE INCINERATION
                           K. P. Ananth, P. Gorman, E. Hansen
                               Midwest Research Institute
                              Kansas City, Missouri  64110

                                     D. A. Oberacker
                         Incineration Research Branch, U.S. EPA
                                 Cincinnati, Ohio  45268
                                        ABSTRACT

The trial  burn protocol described ift the  EPA Guidance Manual for Evaluating Permit Ap-
plications for the  Operation of Incinerator  Units  has been followed in a case study of
the Cincinnati Metropolitan Sewer  District's (MSD)  incineration facility.   This paper
summarizes trial  burn protocol  requirements and presents  the results  of the protocol
verification tests carried out at the MSD incineration research facility.
INTRODUCTION

     Hazardous waste incineration regula-
tions, as published in the Federal Regis-
ter,  January 23,   1981,  include stipula-
tions that  will  require "trial burns" in
incinerators.   Therefore,  EPA has  pre-
pared a  Draft Guidance  Manual that pre-
sents a draft protocol for conducting the
trial burns (1).  Midwest Research Insti-
tute  (MRI)   has   a  contract  with  EPA
through Rockwell  International to verify
the  protocol described  in  the guidance
manual,  on a  case study basis,   at the
Cincinnati  MSD   incineration  facility.
This  paper  describes   the  protocol  re-
quirements,  the  incineration  facility,
and  the  sampling and  analysis that have
been  carried  out to verify the protocol
and  to  determine the  performance of the
incinerator.
SUMMARY OF  TRIAL BURN  PROTOCOL REQUIRE-
  MENTS

     This section  summarizes  the salient
aspects of the trial burn requirements as
we understand and interpret them.  A more
detailed description  of the  trial  burn,
including waste  analysis  and evaluation
of  incinerator  performance,  can be found
in Reference  (1).

     The  purpose of  a trial burn  is to
(a)   demonstrate  incinerator  operating
conditions such  that a "new" waste can be
burned  within the regulatory performance
standards and (b) demonstrate that a new
incinerator can  operate similarly.  "New"
wastes  are  defined  as  those  hazardous
wastes  with  compositions  different from
hazardous wastes specified in the facil-
ity  permit.   Either  a  trial  burn plan
must  be  submitted  with each  request to
incinerate  a  new waste,  or data showing
that the waste has been previously incin-
erated in a similar incinerator in an en-
vironmentally  safe manner  must  be  sub-
mitted.   If a trial  burn  is required by
the permitting agency, the following ele-
ments must be contained in the trial burn
plan.

Waste Analysis

     The analysis parameters in this cat-
egory are heating value,  viscosity, con-
centrations of all hazardous constituents
present in  the  waste,  PCB concentrations
above 50 ppm, chlorine content, hazardous
metals  content,  kinematic  viscosity (for
                                          131

-------
 liquids),   percent  solids  (insolubles),
 ash, content,  flash, point,  elemental anal-
 ysis,  water  content,  and  thermogravimet-
 ric analysis.  The rationale for  selec-
 tion of  these parameters  and the  waste
 sampling  and analysis methods are  desig-
 nated  in Reference (1).  One of  the major
 objectives of  the waste  analysis   is  to
 select principal  organic  hazardous  con-
 stituents   (POHCs)  for  establishing  the
 effectiveness of  the  incinerator based on
 the destruction  and  removal efficiency
 (DRE)  of  the selected POHCs.  The  selec-
 tion of POHCs is dependent  upon the con-
 centration of the  POHC  in the waste  and
 its heat  of  combustion,  as presented  by
 EPA.

     If the hazardous wastes are blended
 prior   to   incineration,   all  the   above
 analyses   should   be  performed  on  the
 blend.   Also,  if  an  operator wishes  to
 vary  the   chlorine  content,  the   waste
 analysis  should be reported for each  of
 the various  chlorine-containing wastes.
 If  the auxiliary fuel is  not a conven-
 tional  fuel,  then the feed  to the  incin-
 erator should  be  considered a blended
 waste.

 Descriptions  of Incinerator  Components

     This  category includes  type of  in-
 cinerator,  manufacturer's  name and  model
 number  of  major components,  dimensions  of
 major   incinerator  components  including
 combustion chamber, description of auxil-
 iary  fuel  system,  nozzle  and burner de-
 sign, capacities of prime movers  and man-
 ufacturer's  curves, stack gas monitoring
 and pollution control monitoring  systems,
 locations  and descriptions  for   tempera-
 ture, pressure and  flow sensors, and con-
 struction  materials.

 Provisions for Sampling/Analysis and Mon-
  itoring  of  Incineration Process

     Procedures  and  locations for  moni-
 toring  combustion temperature, waste and
 fuel  feed  rates,  air flow  rates,  CO in
 stack  gas, and excess air  in stack gas
 should be  described.  In addition, equip-
ment and procedures must be specified for
 determining POHCs in the waste, including
 sampling and analysis  of ash,  scrubber
 effluent,   particulate  emissions,  stack
 gas  flow   rate   and   temperature,   POHC
 concentrations  in  the  waste  and  stack
 gas,  and HC1  concentration in the  stack
 gas.

 Trial Burn  Operating  Conditions and
   Schedule

      Factors included here  are  combustion
 zone  temperature,  waste feed  rate, air
 feed  rate,  auxiliary fuel  feed rate, op-
 erating  conditions  for pollution  control
 devices,  and procedures  for stopping feed
 and  safely  shutting down the incinerator
 and  controlling emissions  in case  of an
 emergency.   Aspects  connected with the
 schedule  are dates of  trial burn,  dura-
 tion  of trial burn, and  quantity of  waste
 to be burned.
 CINCINNATI MSD INCINERATION FACILITY

     Only a brief summary of the inciner-
 ation facility is provided in this paper,
 since  there  will  be  another  paper com-
 pletely  dedicated  to  discussing  the in-
 cineration  facility,  its  various compo-
 nents, and their design features.

     The    incineration   facility    at
 Cincinnati  is owned and  operated by the
 City of  Cincinnati's MSD.   It is a full-
 scale, modern installation with a liquid
 injection  cyclone  furnace  and a  rotary
 kiln capable  of  handling both liquid and
 solid waste.  The system can handle about
 151,413 £/day .(40,000  gal/day)  of waste;
 the cyclone  furnace  handles  waste at the
 rate  of 75.7  £pm  (20  gpm)  and the  kiln
 about 37.8 Apm (10 gpm).  The Btu ratings
 on  the  cyclone furnace and  the kiln are
 65 x  106  kJ/h (62 x 106  Btu/h) and 55 x
 106 kJ/h  (52  x 106  Btu/h),  respectively.

     The cyclone furnace and the kiln are
 connected to  a common  secondary  combus-
 tion chamber  (combustor) which has a vol-
 ume  of  162  m3  (5,726 ft3).   Combustion
 gases leaving the combustor  are quenched
before  they  enter  a   venturi  scrubber
which has  an operating pressure  drop  of
 76.2 cm (30 in.) water.  From  the scrub-
ber, the  gases go to  a  caustic absorber
and then exit through the stack.  The ash
 from the  combustor  and the rotary  kiln
drop  into a  four-compartment  ash  tank
which is  sluiced to a lagoon  once  every
8-h shift.
                                           132

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SAMPLING AND ANALYSIS

     In keeping with  the requirements of
a  trial burn,  the overall  objective of
the sampling  and  analysis program was to
characterize the waste burned, select the
POHCs,  determine  DSEs  for  the  selected
POHCs  for  various  incinerator operating
conditions,  establish particulate  grain
loadings,  and determine  chloride removal
efficiencies.   Present  RCRA regulations
require  99.99% efficiency  for  POHC  de-
struction and removal, 99% hydrogen chlo-
ride  removal  efficiency, and  a  particu-
late grain loading  of 0.183 g/dscm (0.08
gr/dscf) corrected to 12% C02.

     A   schematic  illustration   of  the
Cincinnati   MSB  incineration  facility
showing  the  various  sampling points is
presented  in  Figure 1.   As  shown in the
figure,  liquid  waste which  was  fired in
the cyclone furnace as well as the rotary
kiln was sampled.   In addition,  one sam-
ple of the fuel  oil  was taken to deter-
mine whether any of the POHCs selected in
the waste  were also  present in  the fuel
oil.   Using   the  same rationale,  quench
water  samples were  also taken  for POHC
analysis.  These  two  streams (fuel  oil
and  quench water)  are  not  directly re-
quired by the trial burn protocol; but to
establish  input  of  POHCs,   one  needs to
sample  and analyze  these streams for the
selected POHCs.   Table 1 shows  the test
matrix  used in  the  trial burn at the MSB
facility and is complementary to Figure 1
with  respect  to  sampling points,  number
of samples taken per test day and the re-
sulting number of samples, and the analy-
ses carried out on the samples.

     A  few additional points should be
made with  regard  to  Table  1 which bring
out the ambiguities in the protocol.  The
first one  deals with the duration of the
trial burn.   It is  not clear from Refer-
ence  (1)  what  the  duration  should  be.
For purposes  of this  program, we chose a
6-day  duration  for the  trial burn based
on  three  operating temperatures  and  two
residence  times.  The operating  tempera-
tures  and  residence times  were  selected
to  provide  a good  range to evaluate DRE
as a function of  both parameters.  Also,
an  8-h test  day  was chosen.   Secondly,
the EPA guidance  document  does  not pre-
scribe   stack  sampling  times.    Since
sampling  time  is related  to the concen-
tration  of POHC  in  the  waste,  the ex-
pected concentration  of  the same POHC in
the  stack,  and the  detectability of the
analysis procedure, we thought it prudent
to conduct  stack  sampling for both a 2-h
period  and a  6-h period.   The  2-h sam-
pling   time   corresponds   to   the  EPA
Method 5  requirement,  and the 6-h period
was chosen to enable collection of a suf-
ficient quantity  of  POHC if it was pres-
ent at the 100-ppm level in  the waste and
was destroyed at the 99.99%-level.  These
two sampling times would provide a better
perspective  for  selection  of  sampling
durations in future trial burns.

     Waste sample collection times or in-
tervals  are  also not well prescribed.
Since industrial  waste is often nonhomo-
geneous,  one  must ensure  that the waste
characterized is indeed the  waste that is
burned throughout the trial  burn.  To ad-
dress  this aspect we took, as  shown in
Table 1, grab samples of waste as well as
integrated  samples  over  the  2-h period
and  the  6-h period  corresponding to the
2-h and 6-h stack sampling times.

     The  sampling train used  during the
trial  burn is  shown  in  Figure 2.   This
train is similar to that used for captur-
ing organic emissions  from various emis-
sion sources.  The XAD resin and the two
impingers downstream  of  the resin enable
capture of POHCs, and  the impinger con-
taining silver-catalyzed  solution is for
capture of volatile  metals,  viz As, Se,
and Hg.  Due to the high moisture content
in  the stack, we used a  4-liter bottle
downstream  of the XAD resin  instead of
the regular impinger,  shown in Figure 2,
for a second set of tests.

     Many of the  analysis procedures for
POHCs  and chlorides  had  to be developed
as part of this program, since methods in
Reference  (1) were  primarily based  on
analysis  of organics  in  wastewater  and
could not be  used here.   In many of the
samples we  encountered two  separate or-
ganic  phases  and   a  semisolid  phase.

     In all cases, the four  components of
each train (probe rinse, filter, XAD, and
condensate) were  extracted and then com-
bined for POHC analysis  by GC/MS so that
DRE  could be  calculated  for  each POHC.
                                          133

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                              Quench
                               Water
  Auxiliary
  Fuel Oil
Liquid Waste
   Feed
To Stack
                                                            Slowdown
Ash
Tank





Sluice
Gate
©

                                                                 To Lagoon
                                              V2CUU
      Sampling Points

      SIA, S1B - Liquid Waste Feed
      SBA. S2B = Auxiliary Fuel Oil
           S3 = Ash Sluicing
           S4 — Scrubber Slowdown
           S5 == Quench Water
           S6 = Stack

  Figure 1.  Schematic illustration of incineration facility with sampling points.
                                         134

-------
















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To  ensure  that  volatile POHCs were  ac-
counted for,  we used  integrated  gas  bag
samples to collect stack gases for analy-
sis,  in addition  to the  sampling train
itself.  In  a  similar  vein,  additional
analyses were carried out for the samples
collected by the chloride sampling trains
used at the stack.  This was done because
the sampling/analysis method suggested in
Reference  (1)  measures  total chlorides,
whereas the  regulation  specifies  99% HC1
removal.

     In spite of the above difficulties,
we  successfully  completed  trial  burns
on two liquid wastes.  Some of the avail-
able results of  the first trial burn are
presented  below; other  results will  be
discussed during the presentation of this
paper,

Waste Analysis and Selection of POHC

     Analysis results of the six 6-h in-
tegrated waste  samples  for all potential
POHCs  (both  volatile  and semivolatile)
are  shown  in  Table 2,   in the  order  of
their  heat of combustion.   This  list is
limited to those compounds present at 100
ppm or greater,  since, as noted in Refer-
ence (1),  detection of compounds present
at < 100 ppm would present detection dif-
ficulties  in the stack  samples  at a DRE
of 99.99%.

     From  the  list  of  POHCs in Table 2,
the first four were selected for analysis
in  all samples.  In addition, we recom-
mended that hexachlorobenzene be included
as  one of the  selected POHCs because of
EPA's interest in this compound as a sur-
rogate for PCS.  We also recommended that
hexachlorocyclopentadiene  (HCCP)  be  in-
cluded  as  another  of  the selected POHCs
because it is  present at relatively high
concentrations  in  the  waste  (14,000  to
39,000  ppm).   It is  a  pesticide of par-
ticular  interest to the  Cincinnati  MSB
and EPA.   In summary,  the six POHCs se-
lected  for analysis  in all  samples  are
carbon  tetrachloride,  hexachloroethane,
chloroform,  tetrachloroethene, hexachlo-
robenzene, and hexachlorocyclopentadiene.

     Results  of the metals  analysis  on
the six 6-h  integrated waste samples are
shown  in Table  3.   The  analysis data are
presented  for  the  liquid  phases  as well
as. the  solid phase of  each sample since
the waste samples  were  biphasic and non-
homogeneous.    The   metals  listed   in
Table 3 are  those  required by the proto-
col.

Destruction/Removal Efficiency (DRE) of
  Selected POHCs

     Determination  of DRE  is  of  utmost
importance in a  trial burn.  For the six
POHCs  selected,   analytical  results  are
available  for both  6-h  trains used  in
Runs 1, 2, and  3.   Using these stack re-
sults and the results of the waste analy-
sis,  DREs have been computed for the six
POHCs of interest.  These DRE results are
shown in Table 4.

     These results show that the required
99.99% DRE  was  achieved  for  five  of the
six POHCs.  The DRE for tetrachloroethyl-
ene was slightly  below  99.99% in most of
the tests.   If  one "rounds off"  the re-
sults  for this  compound,  it  can  be seen
that in each run one of the simultaneous
6-h trains  would  show 99.99%  while the
other would  show  somewhat less  (99.97 to
99.98%).  Thus,  further analyses  of data
from, other runs  will  be needed to assess
the  precision,  of  the  sampling/analysis
results,

     Review of the data given in Table 4
indicates,  somewhat  surprisingly,  that
the DRE  for each  of  the  POHCs  was unaf-
fected  by  the  combustion  temperatures
chosen for the  tests  (Run 1 - 899°C, Run
2 - 1093°C,  and Run  3  - ^L3i60C).   This,
in effect, means that 899^Cis) adequate to
obtain high  DREs  for  the POHCs selected.

     More data on DRE will be reported at
the meeting, after  review of all analysis
data on the 2-h and 6-h trains.

Chloride Removal Efficiency

     Chloride   removal    efficiency  was
based  on  analysis for  chlorine   in the
waste . feed and  two  HC1  sampling  trains
operated  on  each  test  day.  Results are
given in Table 5.

     The results show that there was only
one test  (2A) in  which the required re-
moval  efficiency  of  99%  was  achieved.
However,  as  we  have   discussed,  the
                                           137

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             TABLE 2.  ANALYSIS RESULTS AND RANKINGS FOR POTENTIAL POHCs
                         (> 100 (Jg/g) IN 6-h INTEGRATED WASTE FEED SAMPLES

Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
He*
0.24
0.46
0.75
1.19
1.70
1.74
1.79
1.99
2.05
2.10
2.12
3.00
3.38
3.40
3.75
4.51
4.57
6.60
6.92
7.34
7.78
8.07
8.07
8.29
8.42
8.51
9.62
10.03
100/Hc*
416.7
117.4
133.3
84.0
58,8
57.5
55.9
50.3
48.8
47.6
47.2
33.3
29.6
29.4
26.7
22.2
21.9
15.2
14.5
13.6
12.9
12.4
12.4
12.1
11.9
11.8
10.4
10.0
Compound
Carbon tetrachloride
Hexachloroethane
Chloroform
Tetrachloroetheae
Methylene chloride
Trichloroethylene
Hexachlorobenzene
Trichloroethane
Penta chlo r ob enz ene
Hexachlorocyclopeatadiene
Hexachlorobutadiene
Dichloroethane
Isodrin
Trichlorobenzene
Aldrin
DDT
Dichlorobenzene
Chlorobenzene
Chlo ro toluene
Di-n-butylphthalate
Phenol
Toluene
Methyl ethyl keton
Butylbenzylphthalate
Bis (2-ethylhexyl)phthalate
Dimethy Ipheno 1
Naphthalene
Benzene
Concentration range
(Hg/g)
1,600-9,800
310-650
2,000-12,000
1,300-1,800
1,000-7,300
500-680
120-260
1,000-13,000
< 100-110
14,000-39,000
450-1,200
1,000-5,100
2,000-2,700
< 100-110
180-300
130-280
1,100-5,100
1,600-4,600
1,200-1,700
100-180
100-3,800
3,100-5,100
1,600-3,700
< 100-150
100-2,300
150-560
680-1,600
200-1,000
Class*
V or SV
V
SV
V
V
V
V
SV
V
SV
SV
SV
V
SV
SV
SV
SV
SV
V
SV
SV
SV
V
V
SV
SV
SV
SV
V
*  HC = Heat of combustion in kcal/g.

/  Concentration range shown is the lowest and highest concentration found in the
   six 6-h integrated waste feed samples.

£  Class designates whether the compound is a volatile (V) or semivolatile (SV).
   This designation reflects the analysis techniques for the waste feed samples and
   the fact that, subsequently, volatiles will most likely be detected in the inte-
   grated gas bag samples while semivolatiles will most likely be detected in the
   modified Method 5 train samples.
                                         138

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          TABLE 5.  SUMMARY OF CHLORIDE REMOVAL EFFICIENCY DATA

Run No.
1
1
2
2
3
3
4
4
5
5
6
6
HC1 test No.
1A
IB
2A
2B
3A
3B
4A
4B
5A
5B
6A
6B
Cl in waste
feed (%)
2.96
5.76
9.23
10.09
2.97
6.92
6.24
5.76
9.60
8.86
11.16
11,16
Chloride removal
efficiency (%)
Total
95.4
97.8
99.0
98.9
96.2
98.4
97.8
86.1
95.9
94.8
97.9
32.0
Excluding plug
97.7
99.7
99.8
99.7
99.4
99.8
99.5
98.2
98.6
99.0
99.8
80.0

             TABLE 6.  SUMMARY OF PARTICULATE DETERMINATIONS
                                       Particulate concentration
Run No.


   2

   5
Train No.


M5(2)-2B

M5(2)-5B
g/dscm (gr/dscf)


0.2124 (0.0928)

0.0819 (0.0358)
g/dscm (gr/dscf)
  corrected to
    12% C02
0.3272 (0.143)

0.1467 (0.0641)
                                  141

-------
regulations   require  99%  HC1  removal,
whereas the  sampling method measures to-
tal Cl  emissions.   Thus,  if there is any
mist  or droplets of the  scrubbing solu-
tion  in the  stack,  they will probably be
captured by the glass wool "plug" used in
the front  of the HC1 sampling probe, ac-
cording to the method specified in Refer-
ence  (l).  For this reason, Table 5 also
shows HC1  removal  when excluding the Cl
determined in the  plug component of the
sampling train.   In all  tests contribu-
tion  of the plug to the  total was quite
large.

     Exclusion of the plug shows that the
99%  removal  efficiency  requirement  was
met in 8 of the 12  runs.  In order to in-
vestigate  the possibility that carryover
of scrubber  solution was  causing the low
removal  efficiency,  components  of  the
sampling train are  presently  being ana-
lyzed for sodium.

     It was noted that there seemed to be
considerable  variability  in the chlorine
level in the waste  feed samples.  This is
presently being investigated.

Particulate Emissions

     Two  2-h  modified  Method 5  trains
were  used during  each  test,   which  re-
sulted  in  a  total  of 12  trains.   Since
these were primarily  intended for POHC
analysis,  only two  of  these trains were
utilized for determination of particulate
catch.   This  involved  evaporation  and
weighing of  the  probe rinse and desicca-
tion  and  weighing  of the  filters.   Re-
sults of these particulate determinations
are summarized in Table 6.

     It can  be seen in Table  6 that the
corrected  particulate concentration  for
Run 2 exceeded  the  RCRA  limit of 0.183
g/dscm  (0.08  gr/dscf), while the concen-
tration  in  Run 5   was  below  the  limit.
However, neither of the above particulate
data is considered very reliable since it
was  obvious   that  the  fiberglass-packed
sound dampeners in the stack were deteri-
orating rapidly and pieces  of the fiber-
glass were being emitted  from the stack
and were  interfering  with  the sampling
probes.
REFERENCES
     Guidance Manual  for  Evaluating  Per-
     mit  Applications for the  Operation
     of   Hazardous   Waste   Incinerator
     Units, prepared  by the  Mitre  Corpo-
     ration as a draft document under EPA
     Contract No.  68-01-6092, April  17,
     1981.
ACKNOWLEDGMENTS

     We would like to acknowledge the as-
sistance  of  Dr. Larry  Johnson of  EPA's
IERL/RTP  and   Mr.  John  Trapp   of   the
Cincinnati MSD.   Principal MRI  partici-
pants  on this  project  were  Mr. George
Cobb,  Mr. Steve  Swanson,  and  Dr.  Greg
Jungclaus.
                                           142

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                    EVALUATION OF POTENTIAL VOC SCREENING INSTRUMENTS
                          Kenneth T.  Menzies and Rose E.  Fasano
                                  Arthur D.  Little,  Inc.
                                 Cambridge,  Massachusetts
                        -             Merrill Jackson
                                 Technical Support Staff
                      Industrial Environmental Research Laboratory
                          U.S. Environmental Protection Agency
                         Research Triangle Park,  North Carolina
                                        ABSTRACT

This paper describes the evaluation of potential fugitive source emission screening
instruments for analysis of volatile organic compounds (VOC).  An initial review of
available portable VOC detection instruments indicated that detectors operating on
several principles (i.e., flame ionization, catalytic combustion, photoionization,  infra-
red absorption, and thermal conductivity) might be useful for VOC analysis.   However,
flame ionization and catalytic combustion devices evaluated previously have shown poor
sensitivity for highly substituted aliphatic and aromatic organic compounds.   Instruments
operating on the photoionization and infrared principles may be able to meet  necessary
criteria for practical and accurate VOC analysis of highly substituted organics.   There-
fore, three commercially available instruments were selected, modified, and evaluated  for
32 such compounds in the concentration range of 100 to 10,000 ppmv.   The results indicate
that the photoionization principle may be suitable for general VOC screening  but a
reliable instrument/dilution system does not exist at present.  The infrared  absorption
principle will apparently not provide a suitable general VOC screening device but may  be
useful for analysis of some classes of organic compounds.
INTRODUCTION

    The U.S. Environmental Protection
Agency has issued guidelines (6) for vol-
atile organic compounds (VOC) from several
stationary source categories such as sur-
face coating operations.  These guidelines
are for industries which emit significant
quantities of air pollutants.  It has
become apparent that sources other than
classical point sources may also emit
VOC's into the workplace and surround-
ing atmosphere.  The EPA1 s Office of
Air Quality Planning and Standards
(OAQPS) is, therefore, evaluating the
need for the control of fugitive emis-
sions of VOC's, from such sources as
valves, pumps, and drains.  As described
in EPA Method 21, Determination of Volatile
Organic Compound Leaks (7), technically and
economically feasible devices suitable for
monitoring such leaks include only a few
portable detectors.  These devices can be
placed near possible points of emissions
and will respond to releases of the organic
compounds.  Specific instruments suitable
for this purpose include, but are not
limited to, catalytic oxidation, flame
ionization, infrared absorption, and
photoionization detectors.

    Unfortunately, due to the chemical
complexity of many fugitive sources and
the lack of universal sensitivity of these
detectors, the detectors previously evalu-
ated cannot adequately measure all the
                                           143

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volatile chemicals likely to be released.
Tills fact has been documented  (2) for two
commercially available detectors using
flame ionization  (FID) and catalytic com-
bustion principles.  Among 168 compounds
tested, 23 showed sufficiently poor res-
ponse that the actual and measured
concentrations differed by a factor of
greater than five (Table 1).  The classes
of compounds which show the poorest agree-
ment with the actual concentration
generally incorporate functional groups
such as halides, hydroxyls (alcohols),
carbonyls (aldehydes, ketones), and car-
boxylates (acids) and include both
substituted aromatic hydrocarbons and low
molecular weight, highly substituted
aliphatic compounds.

    Additional portable devices which res-
pond accurately to these compounds are
                   needed  for VOC  screening.  Instruments
                   other than flame ionization or catalytic
                   oxidation detectors which might meet this
                   goal operate on the principles of infrared
                   absorption, photoionization, and thermal
                   conductivity (1).

                      The first step in this task was to
                   select  and procure one or more units ,of
                   those detectors which meet the mechanical
                   specifications  of Method 21 (7).  The VOC
                   instrument had  to be rugged, reliable,
                   relatively inexpensive, portable, and easy
                   to operate.  The instrument had to be
                   intrinsically safe for operation in explo-
                   sive atmospheres as defined by the appli-
                   cable National  Electric Code.   Of course,
                   it had  to respond to the organic compounds
                   of interest and be able to measure the
                   leak definition concentration specified
                   in the  regulations.  At this time, few
         TABLE 1.  COMPOUNDS WITH RESPONSE FACTORS EQUAL TO OR GREATER THAN FIVE

OCPDB*
ID No.
120
—
490
790
810
830
—
—
—
—
2060
1221
2073
2105
—
2500
—
2690
1660
2770
2910
—
3291
Compound Name
Acetophenone
Acetyl-l-propanol,3-
Benzoyl Chloride
Carbon Disulfide
Carbon Tetrachloride
Chloro-Acetaldehyde
Dichloro-l-propanol,2 , 3-
Dichloro-2-propanol,l,3-
Diisopropyl Benzene,!, 3-
Dimethyl Styrene,2,4-
Formic Acid
Freon 12
Furfural
Glycidol
Hydroxyacetone
Methanol
Methyl-2, 4-pentanediol,2r:
Methylstyrene, a-
Monoethanolamine
Nitrobenzene
Phenol
Phenyl-2-propanol, 2-
Tetrachloroethane, 1, 1,2,2-
FID
Response Factor
10.98
10.87
6.40
571.92
21.28
13.40
61.51
29.34
9.43
37.09
34.87
9.65
7.96
8.42
8.70
5.69
96.34
10.24
28.04
29.77
11.75
89.56
6.06

        *0rganic Chemical Producers Data Base
         Response Factor

        Source:   (2)
Actual Concentration
Measured Concentration
                                          144

-------
detectors are "approved."

    The" second step in this task was to set
up a laboratory system capable of mixing
known volumes of vapors with air and
delivering the mixtures of known concen-
tration to the detectors.  Tedlar bags and
a volumetric mixing system were selected
for sample preparation since they provide
adequate accuracy/precision and require.
little cost or time to set up.

    The third step in' this task was evalu-
ation of the detectors for response to
the compounds of interest.  The response
factors were determined at several con-
centrations over the range of 100 to
10,000 ppmv.  Measurements were limited
to concentrations approaching about 90%
of the saturation concentration or 75% of
the lower explosive limit (LEL).  In order
to permit statistically valid interpreta-
tion of the measured response factors,
five replicate measurements at three con-
centrations were conducted.  Data analysis
included calculations of mean response
factors and confidence intervals.

    Subsequent to this evaluation, a photo-
ionization detector attached to a gas
chromatograph was utilized to independently
confirm the r^sonse factors observed with
the portable detectors.  This step provided
appropriate quality assurance and expanded
the available data base.
INSTRUMENT SELECTION

General Rationale

    A recent summary of available portable
VOC detection devices  (1) lists a number
of instruments operating on the following
principles:

    Flame lonization (FID)
    Photoionization (PID)
    Infrared Absorption (IR)
    Thermal Conductivity (TC)
    Hot Wire/Catalyst  Combustion
      (Combustion)

The majority of available instruments
operate on one of three principles; i.e.,
FID, IR, or Combustion (1).  As noted
previously: (2), two specific FID and Com-
bustion devices were shown to have poor
sensitivity to several substituted organic
compounds.  Due to this observation and
with the assumption that other FID or
Combustion detectors available from dif-
ferent manufacturers probably do not differ
significantly in their basic response
factors, alternative VOC screening devices
were evaluated.  These were selected from
instruments operating on other detection
principles, including PID, IR, and TC (1).

    The selection of potential VOC detectors
from this list depends on several criteria
which are outlined in EPA Method 21.  That
is, an instrument suitable for screening
should have the following .characteristics:

    1.  Fast response (<30 seconds);
    2.  Measurement range 100 to
        10,000 ppmv;
    3.  Similar responsiveness to a variety
        of organic vapors;
    4.  Portable;
    5.  Rugged;
    6.  Reliable;
    7.  Inexpensive;
    8.  Easy to operate; and
    9.  Intrinsically safe (as per National
        Electric Code).

    Each of the first three characteristics
is of primary importance in providing a
practical instrument for VOC screening.
Fast response time is necessary for rapid
screening of a large number of fugitive
sources.  The specified measurement range
is required by the need to limit signifi-
cant leaks of VOC's.

    Equal molar sensitivity to compounds of
widely differing functional character is
not achievable with currently evaluated
instruments but is a desirable goal.  The
other characteristics, such as portability
and intrinsic safety, are also important
but none should be considered individually
critical to the acceptance of a potential
detector.

    Assuming that characteristics of fast
response and appropriate measurement range
are available in potential VOC detectors,
the ability of the devices to meet the
criterion of similar responsiveness needs
to be reviewed prior to final instrument
selection.  Thus, the efficacy of various
operating principles to meet this criterion
is discussed below.

    Photoionization detectors utilize
ultraviolet radiation to ionize a small
fraction of molecules introduced into an
                                           145

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ionization chamber.  The ionization process
is initiated by absorption of a photon of
sufficient energy  (i.e., greater than the
ionization potential) to remove an electron
from its ground state to infinity.  A free
electron and positively charged ion are
thus formed:

             R + hv •*- R+ + e~

    If the energy of the UV lamp is less
than the ionization potential of the com-
pound, no ionization takes place.  Ions
formed in the detector/ionization chamber
may reach the electrodes under the in-
fluence of an electric field and produce
a small current.  The number of ions which
reach the electrode is proportional to the
concentration, although only a very small
fraction ("vO.01%) of the molecules in the
ionization chamber are ionized by incident
radiation.  Depending on the character of
the electrons (e.g., sigma vs pi electrons)
the yield of ions  (photoionization effi-
ciency) may vary as a function of the
energy of incident photons.  At present,
UV sources are available for commercial
instruments which emit photons of approxi-
mately 9, 10, or 12 eV.  Based on the
ionization potentials of organic com-
pounds (5), it is apparent that certain
classes of compounds (e.g., aromatics and
aliphatics greater than carbon number C7)
can be ionized by a 10 eV lamp while many
substituted aliphatics require photons of
at least 11 eV.  This observation leads to
the conclusion that with sufficient energy
roost organic compounds can be ionized and
detected.  A practical upper energy limit
for VOC analysis is about 12 eV since the
major components of air (such as nitrogen,
carbon monoxide, carbon dioxide, and water)
have ionization potentials above this
level.  As well as the ionization
potential, the photoionization efficiency
is important since this parameter deter-
mines sensitivity of the technique to
different compounds.  A recent paper (4)
indicates that the molar sensitivity of
aliphatic and oxygenated aliphatic com-
pounds is several times less than that of
aromatic compounds if incident radiation
is about 10.2 eV.  In fact, for aliphatic
hydrocarbons of carbon number less than
C8, the relative sensitivity is less than
one-tenth that for benzene.  If incident
radiation is about 11.7 eV, the relative
sensitivity of aliphatic and aromatic
compounds is similar (3) and perhaps
within a factor of two.  Based on this
assumption, a commercially available
photoionization instrument with a lamp of
about 12 eV may provide a generally appli-
cable VOC detection technique.

    Typical nondispersive infrared devices
operate by passing infrared radiation
through two separate absorption cells:  a
reference cell and a sample cell.  The
sealed reference cell is filled with non-
absorbing gas, such as nitrogen or argon.
The sample cell is physically identical to
the reference cell and receives a continu-
ous stream of gas being analyzed.  Sub-
sequently, the net radiation in the two
beams are passed into and absorbed in
matched selective detectors (e.g., Luft
detector) containing the vapor to be
detected.  When organic vapors are present
in the sample cell, energy is absorbed,
and the temperature and pressure in the
corresponding detector is reduced' relative
to that in' the detector on the reference
side.of the analyzer.  A diaphragm between
the two detectors is displaced and the
amount of displacement is detected, elec-
tronically amplified, and an output signal
proportional to concentration produced.
In other NDlR systems, narrow bandwidth
filters which pass energy which corresponds
to that absorbed by the compound of
interest are used along with simple solid
state IR detectors.  In both cases, inter-
ference from compounds with overlapping
absorption bands is possible.   More
importantly, the maximum absorbing wave-
length for different organic species in
the sample gas may not correspond to .the
maximum absorbing wavelength of the cali-
bration compound used in the detector.
Within reason, several different calibra-
tion compounds could be used in the
detector to improve responsiveness for
several compounds.  Alternatively, by
selection of a single narrow bandwidth
filter with a' wavelength corresponding to
a general aliphatic C-H stretch, many
aliphatic hydrocarbons might be detected
quite uniformly.   Based on the maximum
absorption wavelength of aromatic hydro-
carbons, a separate filter or cell would
be needed for this class of compounds.  In
practice, the specificity of the detection
principle has precluded the manufacture of
an NDIR device suitable as a general
(i.e., both aliphatic and aromatic)
organic vapor detector.

    An alternative IR detection scheme
involves"dispersive IR analysis in which
                                          146

-------
the specific wavelength absorbed by the
organic vapor of interest is passed through
a single sample cell.   In this case, selec-
tivity is provided by a monochromatic light
source rather than a selective detector.
Such a device is inherently more selective
than an NDIR and thus may be less appro-
priate as a VOC screening device.  However,
by successive, rapid monitoring of IR.
absorption at several selected wavelengths
corresponding to the maximum absorption
wavelengths for several organic functional
groups (e.g., aliphatic CH, aromatic CH,
C-C1, C=0), it may be possible to identify
and quantify a wide variety of organic
vapors in a fugitive emisson source.

Unit Selection

    On the basis of the factors discussed
above, both the IR and PI principles might
be suitable for general VOC screening.
However, a comparison of the specifications
of commercially available instruments
operating by these principles and the
criteria of Method 21 leads to a rather un-
fortunate conclusion:  No instruments of
these types are adequate for screening of
VOC emissions.  In terms of a desire to
expand the list of potential detectors,
such a finding is unsatisfactory.

    What criteria led to this finding?  The
most obvious answer is the requirement for
an intrinsically safe device.  No IR or PI
devices are certified for use in Class I,
Division 1 environments.  One PID is cer-
tified for use in Class I, Division 2.  It
should be noted, however, that in the future
other devices may be modified so as to
meet Class I, Division 1 certification.
Alternatively, the use of an instrument
only in less hazardous environments may not
be considered as particularly restrictive.
For these reasons, the criterion of intrin-
sic safety was given lesser significance
and not used  to rule out potential devices
for screening in this program.

    The other criteria listed previously
were ranked in approximately descending
order of importance for field application.
Thus, a response time of less than 30 sec-
onds was given the highest- importance.  In
fact,, fast response time is very important
to practical measurement of VOC  leaks, and
several instruments with faster  than 30-
second response time are availabile.  Thus,
it was decided that this criterion must be
met by any instrument to be evaluated.  The
criteria of portability, ruggedness, and
ease of operation are also important but
were not chosen as absolute selection
criteria.  Portability can be evaluated
subjectively, and devices operated with
automobile batteries placed on a small
cart may be considered to have adequate
portability.  Devices operated with AC
power are less practical in many indus-
trial environments.

    Current literature and additional
manufacturers' information were reviewed
using the modified criteria described
above.  A list of potential VOC detectors
was developed (Table 2).  This list in-
cludes instruments which operate on PI
and IR principles and which meet mo.st of
the Method 21 criteria.  It is obvious
that not all of the IR instruments that
meet most of the criteria are included.
Since the goal of this study is to evalu-
ate the usefulness of the; IR principle
rather than all available IR devices, only
selected IR devices suitable on the basis
of the criteria for VOC screening were
included.

    The list, therefore, includes a dis-'
persive IR device and NDIR devices with
or without solid state detectors.  The'
NDIR devices may be useful for a specific
group of organics; e.g., aliphatic hydro-
carbons.  Also included are two devices
operating on other detection principles;
i.e., ion capture and UV spark.  These
instruments are only useful for a specific
class of organics  (i.e., halogenated hydro-
carbons) but were included due to the
widespread industrial use of these
solvents.

    The final instruments selected for
evaluation were:
Ins trument

AID Model 580
HNU PI-101
Foxboro Miran 80
Principle of Operation

  Photoionization
  Photoaonization
  Dispersive Infrared
    The .rationale for the selection of
 these instruments is based on both suit-
 ability and availability.  As noted
 previously, PI may be a particularly suit-
 able VOC detector for aliphatic, aromatic,
 and substituted organic vapors.  Either of
 the commercially available, portable
 instruments meets most Method 21 criteria
 and may be suitable for evaluation.
                                            147

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     The Miran 80 instrument is the one
 available infrared device which permits a
 selection of wavelength as opposed to
 selection of a test compound in a reference
 cell.   This option permits the rapid (a
 few seconds) assessment of the suitability
 of several wavelengths for the measurement
 of the substituted organics of interest.
 Specific examples are an aliphatic C-H
 stretch, aromatic C-H stretch, or a C=0
 stretch.  Other portable IR devices utilize
 a filter at one specific wavelength band
 corresponding,  for example,  to an aliphatic
 C-H stretch.  Thus,  they have an inherent
 selectivity against  aromatic or substituted
 species.  Since all  three classes of com-
 pounds are of interest,  the latter devices
 are not preferred as VOC screening devices.
 It is  possible that  one wavelength may be
 suitable for analysis of a wide variety
 of organic vapors.   If that is the case,
 other  IR instruments could potentially
 be used for VOC leak, detection.   In
 summary, the Miran 80 (with associated
 microprocessor)  permits the  most rapid and
 cost-effective  assessment of the IR
 principle as a  general VOC detector.   Other
 IR devices were,  therefore,  not  evaluated.

     The halocarbon specific  detectors
 (i.e.,  General  Electric  TVM. 1 and Gas  Tech
 Halide Detector),  were not selected for
 evaluation despite the potential usefulness
 of such a device  in  environments subject  to
 halocarbon solvent contamination.   Neither
 the GE TVM 1 nor  an  equivalent model is
 now sold.   The  Gas Tech  device could not
 be modified  to meet  the  intrinsic safety
 requirements of Method 21 due to  the
 presence of  a spark  in the detector
 section.

     No  other instruments  appeared  to have
 a  reasonable expectation  of meeting the
 Method  21  criteria and of  providing a
 significantly different performance than
 those devices evaluated previously  or
 selected for evaluation in this study.

 Unit Modifications

    Both photoionization devices operate
with a maximum quoted  linear range  of
 0-2000 ppmv.  In fact, the linear range
 is frequently reported to be only about
0-1500 ppmv.  Since the maximum concen-
 tration of concern in VOC screening is
10,000 ppmv, dilution of sample air is
necessary for both instruments to operate
in the linear range.   Both HNU'Systems, Inc.
 and AID, Inc. provided their instruments
 with dilution systems designed in their
 respective laboratories.   The HNU Systems,
 Inc. design consisted of (1) a fine bore
 restrictor which limited the flow of sample
 air and (2) a charcoal tube which passed an
 excess (lOx) of hydrocarbon-free air
 (methane is not removed but does not res-
 pond in the detector).  The sample stream
 is thus diluted about 1. to 10.   The AID,
 Inc. design consisted of  a pump and needle
 valve which diverted 90% of the incoming
 sample air through a charcoal tube and 10%
 to the normal exhaust point.  The hydro-
 carbon-free (except for methane) sample
 air is combined with the  incoming sample
 stream and thus a continuous tenfold
 dilution is provided.

     Problems were observed with .these
 dilution systems and the  UV lamps provided
 with both instruments. The absolute
 accuracy of the dilution  ratios is in some
 doubt since independent flow rates were
 difficult  to measure.   The UV lamps
 provided with both instruments  were subject
 to degradation during the life  of the study.
 In fact,  the 11.8 eV lamp supplied with the
 AID,  Inc.  device failed during  the study
 and,  unfortunately,  a replacement could
 not be obtained  in time to  collect useful
 data with  this instrument.   The 11.7  eV
 lamp supplied  with the HNU Systems,  Inc.
 device failed  during the  study  and a
 replacement was  provided.   The  difference
 in energy  output from the two HNU Systems,
 Inc.  lamps  was large (i.e.,  a factor  of
 three to ten depending on the age of  the
 lamp).  This variation affected  the linear
 range of the•instrument and  created prob-
 lems  in obtaining  consistent results.   In
 some  cases  with  the  new lamp, saturation
 of  the  detector  occurred  even with the
 dilution probe attached to  the  instrument.
 The  test results reported must,  therefore.
 be  carefully interpreted  and conclusions
 narrowly drawn.

    The Miran  80 operates over  the concen-
 tration range  from ppm to percent.  The
wide dynamic range is provided by a cell
 in which the pathlength of IR radiation
 can be changed by optical folding of the
 incident beam.  At the concentration range
of interest (i.e., 100 to 10,000 ppmv), the
incident beam traversed a distance of about
0.75 m.  At this pathlength, the full-scale
absorbance for vapors of interest at a
concentration of 10,000 ppmv was about
1 absorbance unit.  Once the cell
                                          149

-------
pathlength was set, no other modifications
of operating conditions were required.
COMPOUND SELECTION

    As noted in the Introduction, 168
compounds had previously been tested for
response factor on two commercially avail-
able VOC detectors (2).  Twenty-three
showed sufficiently poor response that
the actual and measured concentrations
differed by a factor of greater than
five (Table 1).  The classes of compounds
showing poor agreement were generally
highly substituted aliphatic and aromatic
compounds and those compounds incorpo-
rating functional groups such as carbonyl
and hydroxyl groups.   These 23 compounds
were selected for testing on the alter-
native VOC screening devices to be evalu-
ated in this study.  Several other
compounds, which were not evaluated in
the previous work, were added to the list.

    These compounds include only a portion
of those commonly used in chemical produc-
tion.  At the request of OAQPS, other
industrial compounds which have a vapor
pressure greater than 0.3 kPa but which
were not considered previously were
reviewed.  This extensive list of 76
compounds includes many species for which
an FID or catalytic combustion detector
would respond well.  However, others are
highly substituted compounds which will
probably not give adequate response on
these two detectors.   Selected substituted
compounds from the list were included in
the detector evaluation.

    The selection criteria required a
response to several questions:

    1.   Are subsequent groups present
        or absent?  If absent, don't
        test,
    2.   Are the compounds similar
        (functionally and/or isomerically)
        to others previously evaluated?
        If they are,  don't test,
    3.   Are response factors on an FID
        instrument likely to exceed five?
        If not, don't test, and
    4.   Do the compounds pose a serious
        health hazard to laboratory
        personnel?  If they do, cautiously
        consider evaluation.
    As a result of the responses, the
compounds were separated into two groups:
compounds that should and those that need
not be analyzed.  Within the first group,
the compounds were prioritized on the
basis of (1) their similarity to other
vapors to be analyzed (for example,
positional isomers of compounds selected
for testing were given lower priority),
and (2) their health hazard (extremely
toxic compounds with little commercial
application or likelihood of release and
which require complex/expensive handling
were given lower priority).

    The compounds selected for evaluation
in this program are listed in Table 3.
They are listed in the approximate order
of testing.
EXPERIMENTAL PROCEDURES

    Determination of response factors
required initial calibration of the VOC
detectors with a gas or gases of known
concentration.  Methane had been used
previously for calibration of FID and com-
bustion analyzers (2).   However, the PID's
do not respond to this compound, and the
multiple wavelength analysis by dispersive
IR spectrometry cannot be carried out by
the use of methane as a single calibration
gas.

    Therefore, 1,2-dichloroethane was
selected as the calibration gas for the
PID's.  This compound can be detected by
the instruments and it has a response
factor of about one (compared to methane)
when analyzed on an FID.  As a result,
data collected in this study may be
comparable to data collected in a previous
EPA study (2).

    Several calibration compounds were
used for the IR evaluation since several
wavelengths were scanned in the dispersive
IR instrument to determine if any wave-
length gave similar response factors for
all the compounds of interest.  The wave-
lengths were selected to correspond to
key functional groups of the test com-
pounds to be analyzed.   The wavelengths,
functional groups, and calibration compounds
are listed in Table 4.-

    Once calibrated, the instruments were
                                          150

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                             TABLE 3.  COMPOUNDS FOR EVALUATION
  Carbon Bisulfide
  Carbon Tetrachloride
  Chloro-Acetaldehyde
  Bichloro-l-^propanol,.2,-3-
  Dichloro-2-propanol,1,3-
  Biisopropyl Benzene,1,3-
  Dimethyl Styrene,2,4-
  Formic Acid
  Freon 12
  Methanol
  Methylstyrene, a-
  Tetrachloroethane,1,1,2,2-
  Ethanol
  Formaldehyde
  Ethylene Bichloride (Bichloroethylene)
  Chlorinated Ethanes (C2H5C1, etc.)
  Chlorinated Methanes (CHsCl, etc.)
  Acetophenone
  Benzoyl Chloride
  Furfural
  Monoethanolamine
  Nitrobenzene
  Phenol
  Acetyl-1-propanol,3-
  Glycidol
  Hydroxyacetone
  Methyl-2,4-pentanediol,2-
  Phenyl-2-propanol,2-
  Aniline Hydrochloride
  Bifluoroethane
  Diketene
  Bimethylsulfide
  Glyceroldichlorohydrin
  Paraldehyde
  Perchloromethylmercaptan
  Propylene Chlorohydrin
  Toluenesulfonic Acid
  Toluene Sulfonylchloride
  Ethylene Glycol Bimethyl Ether
  Ethylene Glycol Monoethyl Ether Acetate
  1-Pentanethiol
  Acetal
  Chlorobenzoylchloride
  Chlorodifluoromethane
  Chlorotrifluoromethane
  Tr ichloro fluoromethane
  Trichlorotrifluoroethane
  Cyanoacetic Acid
  Neopentaneoic Acid
  AmyImercaptans
     2-methyl-2-butanethiol
     2-methyl-l-butanethiol
     3-methyl-l-butanethiol
  Glycols
     Ethylene Glycol Monoethyl Ether
     Ethylene Glycol Monomethyl Ether
     Ethylene Glycol Monomethyl
        Ether Acetate
  Ethylene Glycol Monopropyl Ether
  Glycol Methyl Ether (Bioxolane)
 used to analyze the test compounds at three
 concentrations over the range, of 100-10,000
 ppmv.  Details of the operation of each.
 instrument are given in the manufacturer1s
 instruction manual.  Buring'the tests, 'the
 lamp in Model 580 failed and a replacement
 could not be obtained.   Therefore, only the
 PI-lOl and Miran 80 were evaluated.  The
<^£Jsonse5factor was determined by calculating
 the ratio of the actual concentration to the
 concentration indicated by the instrument.
 The following paragraphs describe the
 procedures involved in calibration and
 operation of the instruments, preparation
 of test gas samples, and calculation of
 response factors.

     Gas mixtures tested in this study were
 prepared in Tedlar gas sampling bags of a
 nominal 25 liter volume.  These bags
 provide a relatively inert surface to pre-
 clude absorption, reaction, or permeation.
 They also permit visual inspection of the
 bag interior to provide an indication of
sample condensation or reaction.  The bags
are equipped with two valves to facilitate
flushing of sample gas and a septum to
permit injection of sample liquid with a
syringe.

    Gas samples were prepared by the
following procedure:

    1.  Flush and evacuate bag three
        times with hydrocarbon-free' air
        •(i.e., until no hydrocarbons are
        detected on each instrument).
    2.  Fill bag with 20.0 L of hydro-
        carbon—free air.
    3.  Inject a known volume of test
        compound into the bag.
    4.  Permit at least 1 hour equilibra-
        tion to ensure adequate evaporation
        and mixing.
    5.  Braw gas sample from bag with
        each instrument.

    The target concentrations prepared for
                                            151

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                        TABLE 4.  CALIBRATION SCHEME FOR MIRAN 80
      Wavelength (pm)
Functional Group(s)
Calibration Compound
3.3
3.4
3.6
4.0
5.7
6.35

8.8
9.5
13.5
Aromatic & Unsaturated C-H
Saturated C-H
Aldehyde C-H
Reference Wavelength
Carbonyl C=0
Aromatic C-C,
conj C=C (also N-H, C-S)
Ether C-O-C
Alcohol C-O-H
C-C1
Toluene • .
Pentane
Butyraldehyde
Air
Acetone
Toluene

Diisopropyl Ether
Isopropanol
1, 2-dichloroethane
each compound were 500, 1000, 5000, and
10,000 ppmv.  In several cases, it was not
possible to prepare the higher concentra-
tions due to the low vapor pressure of the
compound or due to safety reasons; that is,
such a concentration would exceed the lower
explosive limit.  In these cases, a con-
centration of 100 ppm was often prepared.
For each target concentration, the required
volume of liquid was calculated and
measured in a microliter syringe.

    Each instrument was initially
calibrated (spanned) with a gas sample
prepared in triplicate at a concentration
of 10,000 ppmv.  Calibration curves were
then prepared by introducing samples of
the calibration gas, prepared in triplicate
at five concentrations over the range of
100 to 10,000 ppmv, into the instruments
and recording the response.  The PI-101
was calibrated with 1,2-dichloroethane.
while the Miran 80 was calibrated at
individual analytical wavelengths with
the compounds listed in Table 1.

    During subsequent analysis of each
test compound, the HNU PI-101 instrument
was spanned with an 8040 ppmv 1,2-dichloro-
ethane certified gas standard provided by
Scott Specialty Gas, Inc. of Plumsteadville,
PA.  This span was carried out just'prior
to analysis of each set of sample bags for
each test compound.

    The Foxboro Miran 80 instrument was
electronically zeroed and spanned according
to the manufacturer's instructions.  This
zero and span check was carried out prior
to analysis of each set of sample bags
for each test compound.
                      The response factor reported in the
                  following test results section is the
                  number that, when multiplied by the
                  apparent concentration based on instrument
                  response, yields the actual concentration
                  as calculated to exist in the gas bag
                  sample.  That is:
                  Response Factor (RF)
            Actual Bag
         Concentration (C)
          Concentration
         Calculated from
       Instrument Response
                      Response factors were determined at
                  three actual concentrations; i.e., generally
                  100, 500, 1000, 5000, or 10,000 ppmv.  No
                  attempt wa's made tp fit the three response
                  factors for each compound to a particular
                  function.  For some compounds, the response
                  factor is nearly identical for each con-
                  centration; whereas, for others it differs
                  dramatically and in a complex manner.  The
                  response factor for individual compounds
                  is, therefore, not reported for an observed
                  instrument response of 10,000 ppmv.  In-
                  stead, the mean response factors calculated
                  from up to five replicate data points at
                  each of the three actual bag concentrations
                  are reported along with the standard devi-
                  ation.  Also reported is the 95% confidence
                  intervals for the response factors as
                  calculated from Student's t-test.

                      To provide additional quality control,
                  expand the data base, and confirm response
                  factors, HNU Systems, Inc. photoionization
                  detector Model PI-51 was installed on a
                  Varian 2800 gas chromatograph.  Using an
                  11.7 eV lamp, solutions 'of specific organic
                  compounds and toluene (reference compound)
                                           152

-------
in several solvents were analyzed on a
3% SP 2250 on 100/120 ,S,upelcoport column.
Peak areas for the compound of interest
and toluene were measured and relative
detector:.sensitivities were determined on
a molar basis and normalized against the
detector response for toluene.

    The molar sensitivity relative to
toluene was calculated using the following
equation:
            RF =
                 A(tol)
B
where RF is the response,factor,
      A is the peak area of the compound
        of interest,
      A(tol) is the peak area of the
        toluene peak,
      B is the molar concentration of
        the compound of interest, and
      B(tol) is the molar concentration
        of the toluene in the solution.
RESULTS AND DISCUSSION

Photoionization Detection

    The .photoipnization technique was
evaluated for a limited number of compounds
due to both chemical and, more signifi-
cantly, equipment problems.  The PI-101
was calibrated with dichloromethane so as
to permit direct comparison with response
factors reported by Brown et al. (2).  The
response factors observed for the 16 com-
pounds tested on the photoionization
detector, PI-101, range from 0.50 to 48.
Seventy-five percent (12) of the compounds
have response factors of less than five
and greater than 0.2.  There appears to
be no obvious trend of response factor
with molecular weight (carbon number) or
functionality within this group.  On the
other hand, it is interesting to note
that, both alcohols tested (i.e., methanol
and ethanol) have response factors greater
than five, and the values for methanol (Cl)
are higher than those for ethanol (C2).
Thus, it appears that non-bonding electrons
on the oxygen atom of the alcohols do not
provide a much greater photoionization
yield than other sigma-bonded electrons in
compounds with similar carbon numbers.
The high response factor for trichlorotri-
fluoroethane is consistent with its high
ionization potential (11.78 eV).  In fact,
this, ionization potential is slightly
higher than the quoted energy of the UV
lamp used in the study.  This may indicate
that thermal energy provides sufficient
additional.energy to permit some ioniza-
tion when coupled to the energy provided
by the UV light.

    Although the specific response factors
for the limited number of compounds tested
do not unequivocally confirm the suit-
ability of photoionization as a general
VOC screening technique, an important but
cautious observation can be made.  That is,
based on this, small sample of compounds
tested, which includes an aromatic compound
(i.e., toluene), an ether (i.e., acetal),
an alcohol (i.e., ethanol), and chlorinated
alkanes (i.e., trichloroethane and chloro-
form) , the response factor over a concen-
tration range of 500 to 10,000 ppmv may be
within a factor of five.  This result is
consistent with an expectation of more
similar photoionization yields from sigma
and pi electrons when the compound is
influenced by UV radiation of approximately
12 eV rather than 10 eV.  The expectation
that photoionization yields for aliphatic
and aromatic compounds may be similar
indicates the potential usefulness of
photoionization as a VOC screening tool.

    In terms of current availability as a
potential VOC detector, the most signif-
icant result with respect to the photo-
ionization detector (HNU Systems, Inc.
PI-101 and AID, Inc. 580) is probably the
difficulty observed in operating the
prototype dilution system.  Both dilution
probes were designed and fabricated by the
respective manufacturers under severe time
limitations.   Neither probe was designed
in a manner which permitted reliable
independent measurement of dilution ratio
or reproducible adjustment.  Thus, the
absolute dilution ratio is in some doubt.
The ability to adjust the dilution ratios
was practically nonexistent.  As noted
previously,  the fixed dilution ratios were
inappropriate for analysis of vapor
concentrations which yielded instrument
responses much above 10,000 ppmv or much
below 1000 ppmv.  Detector saturation
was observed somewhat above an instrument
response of 10,000 ppmv.  At the
span settings required for adequate
operation, the background instrument
response to zero air was quite
high.
                                           153

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    Whenever the intensity of the UV lamps
began to decrease (note that the AID, Inc.
lamp failed early in the program), the
instrument span had to be increased
regularly.  Some alteration to the span
potentiometer setting could be made to
correct for this decrease in response.
However, for some tests the correction was
not sufficient to yield an identical cal-
ibration.  Under these conditions, response
factors were calculated at a different
absolute instrument response.  However,
since the calibration curve is linear
over the range of 0-10,000 ppmv (with
dilution, that is about 0-1000 ppmv), no
systematic error should occur due to the
change in absolute response.

    Due to declining instrument response
and low vapor pressure of many compounds,
half of the compounds tested did not
yield reliable response factors.  The
problems noted above and limited data
obtained indicate that, at the present
time, a reliable photoionization system
does not exist to operate over a VOC
concentration range of 100 to 10,000 ppmv.
More accurately, a reliable dilution/photo-
ionization system is not available.

    As noted previously, a comparison of
response factors determined on the portable
PI-101 analyzer and the PI-51 attached to
a GO was conducted to independently confirm
the accuracy of the data.  The response
factors for three chlorinated hydrocarbons
listed below (Table 5) indicate good
agreement (i.e., within ± 13%) on both
instruments.

    As a result of this agreement, the GC
technique was utilized to effectively
gather response factor data for homologues
of several compound classes.   Limited data
have been attained (Table 6).
    It is apparent that the response
factor depends upon carbon number and
functional character.  For the three com-
pound classes analyzed—aromatic hydro-
carbons, halogenated aromatics, and
chlorinated aliphatics—the response factor
(relative to toluene) increases as the
carbon number increases.  Also, for the
aromatic halides, the response factor
increases as the electronegativity de-
creases.

    Based on these observations it appears
that a photoionization detector with an
11.7 eV lamp acts as a rough carbon counter
and is able to respond to organic compounds
with as few as one carbon atom and with
significant substitution.

Infrared Detection

    The results of the evaluation of the
Miran 80 are more complete.  A total of 32
compounds were analyzed.  As noted pre-
viously, other compounds were not tested
for several reasons, including (1) low
vapor pressure; (2) reactivity; (3) lack
of availability; and (4) close chemical
similarity to compounds previously tested.
Prior to testing, the instrument was
calibrated with individual span gases at
eight analytical wavelengths which cor-
respond to individual functional groups;
e.g., C-H, C-C1, C-OH.  The calibration
curve data indicate that the absorbance
values observed over the concentration
range of 100 to 10,000 ppmv are linear.
Test compounds were then run and the .
instrument response calculated on the basis
of the response indicated by the specific
span gas used at individual analytical
wavelengths.

    An analysis of the data indicates
that the response factors for most compounds
         TABLE 5.  COMPARISON OF RESPONSE FACTORS FOR PHOTOIONIZATION DETECTORS

Compound
1, 2-Dichloroethane
Methylene Chloride
Dichloroethylene
RF (PI-101)
N=5
0.56
0.37
0.41
RF (PI-51)
N=8
0.62
0.40
0.36
% Agreement
90.3
93.. 3
87.8
                                           154

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               TABLE 6.  RESPONSE FACTORS DETERMINED ON THE HNU SYSTEMS, INC.

                                       PI-51 DETECTOR



                        Compound                      Response Factor

                                    Aromatic Hydrocarbons
                        Benzene    :
                        Ethyl benzene
                        n-Propyl benzene
                        Cumene
                        n-Di±sopropylbenzene
                                    Halogenated Aromatlcs
                        Fluorob enzene
                        Chlorobenzene
                        Bromobenzene
                        lodobenzene
                                   Chlorinated  Aliphatics
                        Dichloromethane
                        1,2-Dichloroethane
                        1,3-Dichloropropane
                        1,4-Dichlorobutane
                                0.49
                                1.34
                                1.58
                                1.30
                                2.30
                                0.60
                                1.45
                                2.28
                                3.31
                                0.40
                                0.62
                                1.12
                                1.54
with a particular functional group, deter-
mined at an analytical wavelength which
corresponds to that functional group
(Table 4), are generally less than a
value of twenty.  This is consistent with
the general observation that the functional
group is more important than the remainder
of the molecule in determining the IR
extinction coefficient of the compound
at the wavelength of interest.

    For example, three of the four aromatic
compounds tested have reasonable response
factors (less than five) at 6.35 ym as
shown below.  This wavelength is within a
broad aromatic ring stretch area.
Compound

Diisopropyl Benzene
Dimethyl Styrene,2,4-
Methyl Styrene
Response Factor
	Range	

2.42  - 3.75
0.185 - 0.394
0.229 - 0.718
    Within this group, the addition of the
large aliphatic group (isopropyl) on the
benzene ring appears to reduce the sensi-
tivity (larger response factor) at the
aromatic C -^ C  stretch wavelength as
compared to less alkylated arbmatics.

    In the case  of aliphatic and substi-
tuted aliphatic  compounds, the C-H stretch
wavelength of  3.3 ym yields suitable
response factors (less than five) for
about 52% of  those tested.  The classical
aliphatic C-H  stretch is observed at 3.4ym,
but some overlap of 3.3 and 3.4 ym IR bands
may occur in the Miran 80 due to incomplete
resolution.  Also, some shift of the CH
stretch wavelength probably occurs due to
nearby oxygen  or halogens.  A list of
aliphatic compounds and corresponding res-
ponse factor ranges at this wavelength are
shown in Table 7.  If one-includes alkylated
aromatic compounds in the list of com-
pounds with response factors less than five
at 3.3-3.. 4 ym, the percentage of compounds
tested with suitable response factors
increases to 62%.

    Ten chlorinated hydrocarbons tested in
this program yielded measurable response
factors at 13.5 ym.   Seventy percent were
observed to yield response factors less
than five at this wavelength.  The compounds
                                           155

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 and respective response factors are given
 in Table 8.

     Since the ultimate goal of this
 instrument evaluation is to assess  the   "
 suitability of IR as a general VOC  screen-
 ing technique,  an assessment of the use-
 fulness  of a single wavelength for
 measurement of  organic compounds of varied
 molecular weight  and functionality  is in
 order.   A review  of the data indicates
 that the number of test compounds (total
 of  32) which yield response factors of
 less than 20 or greater than 0.05 at each
 analytical wavelength is as follows:
Wavelength  (urn)

     3.3
     3.4
     3.6
     5.7
     6.35
     8.8
     9.5
    13.5
Number of Compounds

        23
        12
        13
        17
        17
        11
        25
        14
    In some cases, the response factors at
a particular wavelength (e.g., 5.7 ym) are
Strongly a function of concentration.  It
appears that this may be due to a concen-
                        tration broadening phenomenon which is
                        frequently observed ..in gas-phase IR spec-
                        trometry. ' If only those compounds which
                        show a response factor between 5 and 0.2,
                        and those which show no strong-variation
                        in response factor with concentration
                        (i.e., less than a factor of two from 1000
                        to 10,000 ppmv)"are summarized as above,
                        fewer compounds yield suitable response
                        factors:

                        Wavelength (um) ,    ,  Number of Compounds
     3.3
     3.4
     3.6
     5.7
     6.35
     8.8
     9.5
    13.5
12
 4
 3
 1
 3
 4
15
 7
The results indicate that only 3.3, 9.5,
and 13.5 ym analytical wavelengths respond
acceptably for a large number of compounds
(i.e., greater than 10% of the total number
of compounds).  However, in any case,
fewer than 50% of the compounds are
reliably detected.  ' The aliphatic and
aromatic compounds do not overlap at
6.35 ym but do overlap at 3.3 ym.  However,
             TABLE 7.  SUBSTITUTED ALIPHATIC COMPOUNDS WITH RESPONSE FACTORS

                               LESS THAN TWENTY AT 3.3 ym
              Compound
                                 Response Factor Range
Acetyl-1-propano 1,3-
Chloro-acetaldehyde
Dichloro-1-propanol ,2,3-
Dichloro-2-propanol, 1, 3-
Diketene
Dimethylsulfide
Ethanol
Ethylene Glycol Dimethyl Ether
Ethylene Glycol Monoethyl Ether Acetate
Formaldehyde
Formic Acid
Glycidol
Methanol
Methylene Chloride
Pentanethiol, 1-
Propylene Chlorohydrin
Tetrachloroethane, 1, 1, 2,2-
Trichloroethane, 1,1,1-
1.23 - 2.02
2.73 - 8.62
18.5
5.29 ,
8.06 - 14.1
0.488 - 0.495
0.261 - 0.292
0.196 - 0.296
0.280 - 0.488
1.09 - 1.88
0.529 - 0.722
0.382
0.294 - 0.410
2.67 - 2.87
0.314 - 0.633
0.334 - 0.403
8.59, - 9.90
1.69 - 3.76
                                          156

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              TABLE 8,  CHLORINATED COMPOUNDS AND RESPONSE FACTORS AT 13.5 ym
                   Compound
        Response Factor Range
Carbon Tetrachloride •"
Chlorp-acetaldehyde
Chloroform
Dichloro-l-propanol,2,3-
Diehloro-1-propanol, 1,3-
Methylene Chloride
Propylene Chldrohydrin
Tetrachloroathane, 1, 1, 2, 2-
Trichloroethane, 1, 1,1-
Trichlorotrif luoroethane, 1, 1, 2-
0.233
0.435
0.150
0.431
0.467
0.0333
0.118
0.0500
0.243
4.41
- 0.302
- 0.705
- 0.292
- 0.538
- 0.522
- 0.0840
- 0.132
- 0.0990
- 0.344
- 4.55

note that only alkylated aromatics have
good response at 3.3 ym.  Thus, there is
apparently no useful agreement in response
factors between, for example, a large
number of aromatic compounds and aliphatic
compounds (e. g., 50%, of those tested) at
analytical wavelengths specific to each
compound class*  It is apparent that the
overlap of IR absorbance bands of different
functional groups is not sufficient to
yield one analytical wavelength which might
be used to quantify both compound classes
with the expectation of agreement within
a factor of five.  This observation
Indicates that infrared-spectrophotbmetry
is hot particularly suitable for general
VOC screening.

    On the other hand, the fact that the
response factors do not vary by large
values (i.e., greater than five) fbr some
classes of compounds (e.g., halbgenated
aliphatics at 13.5 ym and aliphatic and
alklyated aromatics at 3.3-3.4 ym) cor-
roborates the suitability of IR spectro-
photoinetry for VOC screening of compounds
belonging to one functional group.  Even
in this case, only 30 to 80% of the com-
pounds in a given class may yield response
factors of less than five at a single
specific IR wavelength.
    4.
    5.
    6.
VOC emissions of a single organic
functional group character.

IR screening of organic compounds
of a single functional class
(e.g., C-C1.) may be suitable for
as many as 80% of compounds in the
class.

IR screening at a wavelength cor-
responding to both aliphatic and
aromatic CH stretches may be suit-
able for as many as 30-50% of
organic compounds.

A portable PID is not currently
available for VOC screening in the
concentration range of 100 to
10,000 ppmv.

The development of" a reliable
dilution probe for use on a PID
is close'at hand.

With such a dilution probe, it
appears that a PID with an 11.7
or 11.8 eV UV lamp may be used
for reliable analysis of VOC
fugitive emissions.
                                               LITERATURE CITED
CONCLUSIONS

    In summary, based on the results of
this evaluation, it appears that:

    1.  IR spectrophotometry is not suit-
        able for general VOC screening,
        with the exception of -analysis of
1.   Anastas, M.Y. and H.J.  Belknap.
    March 1980.   Summary of available
    portable VOC detection instruments.
    EPA-340/1-80-010, U.S.  Environmental
    Protection Agency.

2.   Brown, G.E., D.A. DuBose,
    W.R. Phillips and G.E.  Harris.
                                           157

-------
    January 1981.  Response factors
    of VOC analyzers calibrated with
    methane for selected organic chemicals.
    EPA-600/2-81-002 (OTIS PB81-136194),
    U.S. Environmental Protection Agency.

3.  Driscoll, J.  June 1981.
    HNU Systems, Inc.  Personal
    Communication *

4.  Langhorst, M.L.  February 1981.
    Photoionization detector
    sensitivity of organic compounds.
    J. Chromat. Sci., 19:98-103.

5.  Spain, D., J.J. Decorpo, and
    J.R. Holtzclaw.  August 1980.
    Use of a photoionization detector
    as a hydrocarbon trace gas analyzer.
    Naval Research Laboratory, Memo
    Report No.  4239.

6.   U.S. Environmental Protection
    Agency.  September 1979.   Measure-
    ment of volatile organic compounds.
    EPA-450/2-78-041 (NTIS PB80-221674).

7.   U.S. Environmental Protection
    Agency.  January 5,  1981.
    Method 21.   Determination of
    volatile organic compound leaks.
    Proposed regulations.   Federal
    Register, 46.
                                           158

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                          SURVEY METHODS FOR THE DETERMINATION
                   OF PRINCIPAL ORGANIC HAZARDOUS CONSTITUENTS (POHCs)
                           I.  Methods for Laboratory Analysis
                 Ruby H. James, H. Kenneth Dillon, and Herbert C. Miller
                               Southern Research Institute
                                Birmingham, Alabama  35255
                                        ABSTRACT
     The U. S. Environmental Protection Agency (EPA) has established survey methods for
the analysis of a specific list of priority pollutants.  There are potentially other
compounds whose presence or absence should be determined in analyzing incineration
streams.  To assess the applicability of EPA methods or similar survey methods to the
determination of a broader range of principal organic hazardous constituents (POHCs),
we have evaluated gas chromatography/mass spectrometry (GC/MS) and high-performance
liquid chromatography (HPLC) methods for the determination of about 70 compounds (other
than priority pollutants) from the list of POHCs.

     The methods evaluated are presented, analytical results are given, and the
potential applications of these survey methods are discussed.
INTRODUCTION

     As part of the Resource Conservation
and Recovery Act (RCRA), the U. S.
Environmental Protection Agency (EPA) has
promulgated interim final and proposed
regulations for the owners and operators
of facilities that treat hazardous wastes
by incineration (4).  The regulations
cover a range of activities including
operational performance standards, waste
analysis, trial burns, monitoring and
inspections, record keeping and reporting,
and1the establishment of emission control
criteria.  The specific details for each
incinerator facility are authorized by
facility permits.

     As part of the supporting
documentation for  the permit writer and
for the incinerator facility owners and
operators, a manual of sampling and
analytical methods (5) has been compiled
by the EPA for use in measuring the levels
of principal organic hazardous constituents
(POHCs) in the various streams of an
incinerator facility, including inlet
wastes, stack gas, process waters, fly
ash, and bottom ash.  This manual, referred
to as the "Methods Manual," expands upon
and augments the information in Reference
7.  The Methods Manual is intended to be a
resource document for the preparation and
execution of a sampling and analysis plan
for hazardous waste incinerators.  Existing
collections of sampling and analysis
methods documentation such'as References 1
and 6 have not been directly incorporated
into the Methods Manual, but are
incorporated by reference.
     Although the Methods Manual includes
test procedures for proximate, survey,
                                            159

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and directed (or specific-compound)
analysis, the emphasis of our work was
limited to directed analysis.  The
directed-analysis portion of the waste
characterization scheme provides
qualitative confirmation of compound
identity and quantitative data with
appropriate quality control for the
potentially hazardous constituents that
might reasonably be expected to be present
in the waste, based on engineering judg-
ment and on the results of proximate and
survey analyses.

     The Methods Manual recommends a
variety of directed-analysis techniques
for the determination of the list of POHCs
given in Appendix VIII, Part 261, 40 CFR.
Whenever documentation was available to
support the practice, the methods were
written to incorporate a high-resolution
analytical technique—fused-silica
capillary gas chromatography—and a highly
specific detection technique—mass
spectrometry.  Also, whenever possible,
high-performance liquid chromatography
(HPLC) was recommended for the
determination of compounds that could not
be determined by gas chromatography with
mass spectrometric detection (GC/MS).
Nevertheless, there were many compounds
for which limited documentation was
available to support the recommendation of
the use of either GC/MS or HPLC.
Consequently, on the basis of the
demonstrated need to reduce the number and
complexity of analytical methods in the
Methods Manual, we developed generalized
GC/MS and HPLC techniques for the determi-
nation of as many as possible of the
chemicals on the list of hazardous wastes.
In the effort described in the subsequent
sections of this manuscript, we
concentrated on about 70 POHCs.
•ionization detection (FID)—in addition to
MS—was employed to aid in establishing
operating,conditions.

     We gave no consideration to the .
modification of sampling procedures
or sample-preparation .procedures
reported in the Methods Manual.   Changes
in these procedures were beyond the •
scope of the present assignment.  The
investigation described here involved
the development,of instrumental
analytical methods using solutions of
the selected POHCs in solvents that
were .compatible with GC/MS or HPLC/UV
determinations.         •

     The laboratory work was structured
to lead systematically from the
determination .of the feasibility of
developing generalized test methods  to the
calibration of the ensuing methods for
selected POHCs.  First, we selected
(largely on the basis of commercial
availability) a variety of POHCs (from
Appendix VIII, Part -261, 40 CFR) for
preliminary investigation.  Included in
this selection were a variety of compound
types including alcohols, esters,
chlorinated aliphatics and aromatics,
carboxylic acids and acid.anhydrides,
aliphatic and aromatic amines, nitrated
aromatics, nitrosamines, hydrazines,
nitriles, organosulfur compounds, and
polynuclear aromatics and heterocyclics.
We then analyzed standard solutions of
mixtures of these POHCs (in appropriate
solvents) to optimize instrumental
operating conditions.  Once suitable
operating conditions had been established,
we analyzed a series of standard
solutions of each of the selected POHCs
to estimate detection limits and to
establish calibration curves.
TECHNICAL APPROACH

General Considerations

     The focus of our experimental work
was to develop two generalized analytical
methods for the determination of POHCs in
appropriate organic solvents.  One
analytical technique involved GC/MS with
the use of a capillary column, and the
other involved HPLC with reverse-phase
GIB columns and with ultraviolet spectro-
photometric detection (HPLC/UV).  During
the optimization of the GC methods, flame
GC Analysis Procedures

     Description of instruments and
general,operating conditions.  We
developed the GC/MS generalized test
method on the Hewlett-Packard Model 5985
Gas Chromatograph-Mass Spectrometer-Data
System.  The supplemental GC/FID work was
performed with a Hewlett-Packard Model
5840 Gas Chromatograph that was equipped
for use with papillary columns.

     The work with both GC/MS and GC/FID
involved capillary chromatography with
matched, fused-silica SE-54 wall-coated
                                           160

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 capillary columns.   The initial operating
 conditions were chosen as a compromise of
 the conditions given for several capillary
 GC methods in the Methods Manual.   The
 initial starting column temperature was
 40 °C;  the temperature was- then programmed
 at 10 °C/min to 280 °C and maintained at
 280 °C for 15 min.   The carrier gas,
 helium, was maintained at' a volume flow
 rate through the column of about
 2 mL/min.   In the GC/FID work,  the
 carrier gas flow was split downstream
 from the-'injection  port in the  con-
 ventional  manner at a ratio of  about 1
 part to the column  for every 40 parts
 vented.  Thus,  only a few percent  of an
 injected sample was actually passed onto
 the column.   In the GC/MS work,  the
 "splitless"  injection technique was
 employed.   Consequently,  we assumed that
 essentially  all of  the injected sample
 reached the  column  in GC/MS determi-
 nations.

      Optimization and calibration  of
 GC/FID  procedure.   GC operating conditions
 were optimized  by analyzing methylene
 chloride solutions  containing a variety
 of  the  candidate POHCs  by the GC/FID
 technique.   The column head pressure was
 adjusted to  maximize the  FID response
 to  test  mixtures.   We used these
 adjustments  to  pinpoint the optimum
 carrier  gas  velocity, which in  turn
 defined  the  splitting ratio.

      Once we had  established the optimum
 operating conditions, we  calibrated  the
 GC/FID procedure with external  standards
 and  prepared a  five-point  calibration
 curve for each  of the POHCs  investigated
 by GC.   Each curve  was  a  plot of the  FID
 response (in peak area  counts) as a
 function of  the quantity  of  the  particular
 POHC  on  the  GC  column.  The  detection
 limit for each  candidate POHC was
 estimated as the quantity of the POHC on
 the GC column that  gave rise to a signal
 approximately twice  the background noise
 level.

     Optimization and calibration of GC/MS
 procedure.  Having  established GC
 operating conditions by the GC/FID
 procedure,  we then applied the method to
 the determination of the candidate POHCs
 by GC/MS.  We also  established reference
mass spectra for the identification of
 the individual POHCs.  The mass
 spectrometer was operated in a full-mass-
 scanning range (41 to 350 or 450 amu) in
 the electron impact (El) mode.  The scan
 time was maintained at _
-------
we found that a few of the candidate POHCs
either were not retained by the Perkin-
Elmer column or did not chromatograph well
on the Perkin-Elmer column.

     Rather than attempt to establish one
rigid set of HPLC operating conditions for
the method, our strategy in the develop-
ment of a generalized HPLC method was
to identify various procedural options
that would allow determinations of a
broad range of compound types.  Conse-
quently, we investigated the use of
numerous isocratic and gradient elution
programs with the acetonitrile/water
mobile phase.  In the determination of
several POHCs (including the phenoxy-
acetic acid), the eluent was acidified.
The wavelength of UV detection was also
varied as required to optimize
sensitivity.  A Gary Model 17 Spectro-
photometer was used to establish an
absorption maximum in the range of 190
to 600 nm that would be suitable for
the quantification of each POHC by the
UV detector of the HPLC instrument.

     As in the GC investigations, we
determined the precision of the method
with replicate injections of standard
solutions of the analytes; however, an
internal standard was not used in these
determinations.  The precision of analysis
was determined for only a representative
group of the compounds investigated by
HPLC.
RESULTS AND DISCUSSION

GC Analysis

     Table 1 presents the GC/FID results.
The retention time and on-column
detection limit are given for each
compound.  The compounds are listed in the
order of their elution from the GC column.
Retention times are relative to that
observed for the internal standard,
dio-anthracene.  The on-column detection
limit is the quantity of each analyte that
was estimated to yield an FID response of
twice the background noise; three-fourths
of the detection limits were in the
subnanogram range.

     A chromatogram of a mixture of all
of the candidate POHCs investigated by
GC/FID is presented in Figure 1.  The
chromatogram demonstrates the observed
absolute retention times, the peak shapes,
and any shifts in the base line that
occurred.  Although two of the candidate
POHCs may not coexist in a field situation
and therefore may not require simultaneous
determination, the chromatogram
demonstrates the resolving power of the
capillary column.

     Each reference calibration curve was
a point-to-point plot of FID response as
a function of the quantity of the analyte
on the GC column, which was calculated
from the quantity injected and the split
ratio.  Each plot can be used to estimate
the sensitivity expected in the
determination of a particular analyte.  In
generating these curves, we made no
attempt to determine the upper limit of
the linear range of determinations;
however, each plot demonstrated the
linearity of response within the range
of quantities investigated.  Linear
regression analysis of the curves
typically yielded correlation coefficients
of 21.0.999.  A typical curve (the curve for
N-nitrosopyrrolidine) is presented as
Figure 2.

     Table 2 summarizes the GC/MS
determinations.  As in Table 1, the
retention times are given relative to the
internal standard, dio-anthracene.
Table 2 also lists the five most abundant
mass fragments of each compound and,
moreover, specifies the mass of the ion
of each compound that was used for the
establishment of detection limits and for
the generation of calibration curves.  The
detection limits are the quantities of the
analytes that were estimated to yield ion
currents '(of the selected ions) corre-
sponding to about twice the background ion
currents.  Typical values of the detection
limits were 1 to 5 ng.

     Reference ion chromatograms,
calibration curves, and mass spectra were
generated for each of the compounds
listed in Table 2.  A chromatogram for the
determination of a mixture of all of the
compounds investigated by GC/MS is
presented in Figure 3.

     Several compounds were determined by
GC/FID but were not determined by GC/MS.
These compounds—methylhydrazine,
dimethylhydrazine, and ethylenediamine—
were volatile enough to be partially swept
from the splitless injector of the GC/MS
                                           162

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TABLE 1.  SUMMARY OF GC/FID DETERMINATIONS OF CANDIDATE POHCs
Compound
Methylhydraz ine
1 , 2-Dimethylhydrazine
Ethylenediamine
IJ-Nitroso-N-methylethylamine
Malononitrile
Dimethyl sulfate
l,3-Dichloro-2-propanol
IJ-Nitrosodiethylamine
tl-Nitroso-N-methylurethane
Ethyl methanesulfonate"
Pentachloroethane
Benzyl chloride
N-Nitrosopyrrolidine
2 , 6-Dichlorophenol
4-Chloroaniline
Mh-Nitrosodibutylamine
Safrole
-3 , 4-Diaminotoluene
1,2,4, 5-Tetrachlorobenz ene
Nicotine
2,4, 5-Trichlorophenol
2 , 6 -Diamino toluene
2, 4-Diamino toluene
1 , 4-Naphthoquinone
£-Dinitrobenzene
m-Dinitrobenzene
Pentachlorobenzene
a-Naphthylamine
£-Nitroaniline
2-Acetamidofluorene
9 , 10-Dimethyl-l , 2-benzanthracene
Dibenz [a, j ] acridine
Relative
retention
time , min
0.06
0.07
0.08
0.18
0.20-
0.21
0.23
0.24
0.27
0.28
0.30
0.34
0.41
0.53
0.53
0.59
0.61
0.63
0.64
0.66
0.67
0.70
0.70
0.72
0.73
0.75
0.81
0.82
0.88
1.38
1.60
1.93 '•'"-
On-column
detection
limit, b ng
0.45
3.8
0.43
0.58 •
0.62
4.9
0.60
0.18
2.2.
0.70
1.1
0.20
0.22
1.5
0.20
0.21
0.26
0.39
0.49
0.35
1.7
0.11
1.7
0.44
0.53
0.12
0.67
0.23
"• 0.48
0.37
1.4
0.82
   Relative  to  the  retention  time  of  d!0-anthracene, 16 min.

   Quantity  required  to yield a  response  twice  the magnitude
   of  the background  signal.
                            163

-------
                               13
                             +14
             27
                      29
                     10
                 4
                +5
           1
         +2
      JLi
                   6
                  +7
                        12
 1618
       21
     +22
15
                                      L9
     2(
         23
        +24
         25
                                            26
                                                 28
                                                                                      31
                        JJLLu
                                                                           30
                                     10
                                                     15
                                                                     20
                                                                                    25
                                                                                                    30
                                                                                                                   35
                                                   RETENTION TIME, min
Figure 1.   Chromatogrsm of all candidate POHCs by GC/FID. Peak 1: methylhydrazine; 2: 12-dtmethylhydrazine; 3: N-nitroso-N.-
nathylethylimine; 4: malononitrile; 5: dimethyl sulfate; 6: 1 £-dichloro-2-propanol; 7: fJ-fiitrosodiethy/amine; 8: fH-nitroso-N.-methy/-
unthina; 9: ethyl methaneailfonata; 10: pentachloroethane; } 1: benzyl chloride; 12: N'nitrosopyrrolidine; 13: 2,6-dichlorophenol;
14: 4-cbionaniHne;  IS: N-nitrosodibutylamine;  16: safrote; 17: 3,4Jiaminoto/uene; 13: 1 £,4,B-tetrachlorobamane; 19: nicotine;
20: 2,4.5-trichtorophenol; 21: 2,&
-------
                           2400

                           2200

                           2990

                           1800

                           1600

                           1408

                           1200

                           1900

                           390

                           690

                           490

                           209
                                  '»   29   30   «9    ii   ta
                                              OMMnTVONCOLUMH.ni
                               2  Calibration curve for N-nitrosopyrrolidine by GC/MS.
i
                                                                                               32
      4  S  •*./•  *  9/101112 13 14 1516 1713 19292122232^262728 29 33 31 32> 3334
                                                                                                    803-130
                            Figun 3.  Chromatogram of all candidate POHCs by GC/MS.
                                                 165

-------
 i—l en cr\ CM oo in iH  CM p r^» vo

      -»


    6                               I-t                  1-1       r-t CM
 O  B
•r)  CO
   •a

•rt  3        VO »-% CO r~ O Op  vp CM vp OO CO Op i-l  CM CM CM tH CO vo ON vo O CM CM  CT\ -
-------
system along with the solvent and thus
were not determined.  It is likely that
these compounds could .be determined, with
some loss in sensitivity, by GC/MS with
split injection techniques.

     Some other compounds investigated
could not be determined reliably by GC/FID
or GC/MS.  These included maleic
anhydride, thiophenol, cyclophosphamide,
and ^-toluidine.  Apparently these
compounds either were irreversibly sorbed
by the GC column or were decomposed in
solution, on the column, or in the
injection port.

     Table 3 presents the results of
triplicate GC/FID determinations of
approximately 0.05-yg quantities of all
of the candidate POHCs listed in Table 1
except the hydrazines.  The calculated
values of the standard deviation (SD) and
relative standard deviation (RSD) in
Table 3 indicate that most GC/FID
determinations were very precise.  RSDs
greater than about 5% were, however,
obtained for several of the compounds—
11-nitrosodiethylamine, II-nitroso-N^
methylurethane, ethyl methanesulfonate,
pentachloroethane, benzyl chloride,
2,6-dichlorophenol, and 1,2,4,5-tetra-
chlorobenzene.  The less precise
determinations were the result of
anomalously low responses obtained with
the first in the series of three
determinations for each of these
compounds.  Perhaps at least one injection
was required to condition the GC column
and thereby to prevent loss of the
compounds in subsequent injections.

     Table 4 presents the results of
triplicate GC/MS determinations of
about O.l-yg quantities of all of the
POHCs listed in Table 2 except malono-
nitrile.  In general, the GC/MS
determinations were less precise than the
GC/FID determinations.  Nevertheless,
about two-thirds of the compounds were
determined with an RSD of <5%.  Several of
the compounds for which we obtained
relatively imprecise determinations by
GC/FID were also found to yield RSDs of
>5% by GC/MS; these included K[-nitroso-
diethylamine, pentachloroethane, and
benzyl chloride.

HPLC Analysis

     Six procedural options were included
in the generalized HPLC/UV method.  Three
were formulated for the Perkin-Elmer
reverse-phase C\e column; three for the
Waters column.  The options for both
columns were either variations of the
isocratic composition of the acetonitrile/
water mobile phase or variations of the
solvent program.  The various procedures
for the Perkin-Elmer column were as
follows:

     • Option 1A

       Solvent A:  Distilled, deionized
                   water
       Solvent B:  Acetonitrile
       Solvent program:  10% B, 5 min;
                         10 to 100% B in
                         35 min; 100% B,
                         10 min
       Solvent flow rate:,  1 mL/min

     • Option IB

       Solvent A:  1% (v/v) acetic acid
                   in distilled,
                   deionized water
       Solvent B:  Acetonitrile
       Solvent program:  20% B, 10 min;
                         20 to 50% B in
                         10 min; 50% B,
                         5 min.
       Solvent flow rate:  2 mL/min

     • Option 1C

       Solvent A:  1% (v/v) acetic acid
                   in distilled,
                   deionized water
       Solvent B:  Acetonitrile
       Solvent program:  10% B, 2 min;
                         10 to 100% B in
                         18 min
       Solvent flow rate:  2 mL/min

     The various procedures for the Waters
column were as follows:

     • Option 2A

       Solvent A:  Distilled, deionized
                   water
       Solvent B:  Acetonitrile
       Solvent program:  2% B, isocratic
       Solvent flow rate:  1 mL/min
                                           167

-------
r
                                     TABLE  3.   PRECISION  OF  GC/FID  DETERMINATIONS

Relative GC/FID
response2
Compound
E thylened iamine
fl[-Nitroso-N_-inethylethylamine
Malononitrile
Dimethyl sulfate
l,3-D±chloro— 2-propanol
|l-Nitrosodiethy Iamine
jtf-Nitroso-IT-methylurethane
Ethyl methanesulfonate
Fentachloroethane
Benzyl chloride
tl-Nitrosopyrrolidine
2 , 6-Dichlorophenol
' 4-Chloroaniline
N_-Nitrosodibutylamine
Safrole
3 , 4 -D iamino to luene
1,2,4,5-Tetrachlorobenzene
Nicotine
2,4, 5-Trichlorophenol
2 , 6 -D iamino to luene
2 , 4-Diamino to luene
1 , 4-Naphthoquinone
£-Dinitrobenzene
m-Dinitrob enz ene
Pentachlorobenzene
a-Naphthylamine
jg_-Nitroaniline
2-Acetamido f luor ene
9 , 10-Dimethyl-l , 2-benzanthracene
Dibenz [a, j ] acridine
Detnb
No. 1
19.2
1.70
8.34
16.4
3.44
1.24
5.66
3.12
3.94
1.00
1.06
2.11
1.23
1.09
1.32
1.06
2.11
1.35
2.24
1.27
1.07
2.47
2.29
1.86
2.41
0.86
1.31
1.43
0.927
1.37
Detn
No. 2
19.6
1.75
9.12
16.3
3.76
1.45
6.16
3.81
4.47
1.12
1.15
2.30
1.32
1.17
1.35
1.07
2.39
1.38
2.29
1.27
1.04
2.61
2.29
1.84
2.66
0.88
1.27
1.44
0.927
1.35
Detn
No. 3
18.5
1.61
8.72
15.3
3.79
1.27
6.41
3.62
4.41
1.12
1.07
2.40
1.23
1.11
1.38
1.04
2.39
1.36
2.23
1.28
1.06
2.33
2.28
1.83
2.67
0.89
1.28
1.48
0.920
1.36
Mean
19.1
1.69
8.73
16.0
3.66
1.32
6.08
3.52
4.27
1.08
1.09
2.27
1.26
1.12
1.35
1.06
2.30
1.36
2.25
1.27
1.06
2.47
2.29
1.84
2.58
0.88
1.29
1.45
0.924
1.36
SD
0.6
0.07
0.39
0.6
0.19
0.11
0.38
0.36
0.29
0.07
0.05
0.14
0.05
0.04
0.03
0.02
0.16
0.02
0.03
0.01
0.01
0.14
0.002
0.01
0.15
0.02
0.02
0.02
0.004
0.01
RSD, %
2.9
4.2
4.5
3.9
5.3
8.5
6.3
10.2
6.9
6.5
4.4
6,4
4.2
4.0
2.0
1.7
7.0
1.1
1.3
0.6
1.2
5.6
0.1
0.7
5.7
1.9
1.6
1.7
0.4
0.8

                       (Peak area of internal standard)/(Peak area of POHC)



                       Detn ^ determination.
                                                          168

-------
               TABLE 4.  PRECISION OF GC/MS DETERMINATIONS
Relative GC/MS
a
response
Compound
N^Nitroso-iN-methylethylamine
Dimethyl sulfate
1 , 3-Dichloro-2-propanol
EJ-Nitrosodiethylamine
N-Nitroso-N-methylurethane
Ethyl methanesulfonate
Pentachloroethane
Benzyl chloride
N-Nitrosopyrrolidine
2 , 6-Dichlorophenol
4-Chloroaniline
tl-Nitrosodibutylamine
Safrole
3 , 4-Diaminotoluene
1,2,4, 5-Tetrachlor obenzene
Nicotine
2,4, 5-Trichlorophenol
2 , 6-Diaminotoluene
2 , 4-Diaminotoluene
1 , 4-Naphthoquinone
_p_-Dinitrobenzene
m-Dinitrobenzene
Pentachlor obenzene
ct-Naphthylamine
£-Nitroaniline
2-Acetamidof luorene
9 , 10-Dimethyl-l , 2-benzanthracene
Dibenz [a, j ] acridine
Detnb
No. 1
7.39
4.31
4.76
3.66
7.45
3.18
6.19
1.43
3.04
3.51
1.98
2.58
4.91
5.12
3.81
. 2.47
2.62
4.70
2.50
2.59
11.8
5.36
3.81
1.14
6.51
4.81
23.4
3.12
Detn
No. 2
7.71
4.60
4.79
3.45
7.56
3.14
5.33
1.77
3.35
3.64
1.87
2.92
5.08
5.32
3.68
2.87
2.54
4.80
2.50
2.77
12.0
4.82
4.03
1.12
5.76
5.59
24.6
3.35
Detn
No. 3
7.47
4.08
4.41
4.01
7.00
2.97
5.27
1.77
3.60
3.42
1.95
3.11
5.12
5.49
3.44
2.40
2.44
4.81
2.58
2.68
12.2
5.08
3.96
1.16
6.02
5.39
32.2
3.75
Mean
7.52
4.33
4.65
3.71
7.34
3.10
5.60
1.66
3.33
3.52
1.93
2.87
5.04
5.31
3.64
2.58
2.54
4.77
2.52
2.68
12.0
5.09
3.93
1.14
6.10
5.26
26.7
3.41
SD
0.17
0.26
0.21
0.28
0.29
0.11
0.51
0.20
0.28
0.11
0.06
0.27
0.11
0.19
0.19
0.25
0.10
0.06
0.05
0.09
0.2
0.27
0.11
0.02
0.38
0.40
4.8
0.32
RSD, %
2.2
6.0
4.5
7.6
4.0
3.6
9.2
11.8
8.4
3.2
3.1
9.2
2.2
3.5
5.1
9.8
3.6
1.3
1.8
3.3
1.4
5.2
2.9
1.6
6.2
7.7
17.9
9.2
(Peak area of internal standard)/(Peak area of POHC)



Detn = determination.
                                  169

-------
     • Option 2B

       Solvent A:  Distilled, deionized
                   water
       Solvent B:  Acetonitrile
       Solvent program:  10% B, isocratic
       Solvent flow rate:  1 mL/min

     • Option 2C

       Solvent A:  Distilled, deionized
                   water
       Solvent B:  Acetonitrile
       Solvent program:  20% to 100% B in
                         20 min; 100% B,
                         10 min
       Solvent flow rate:  1 mL/min

     In Table 5, the option used in the
determination of each compound
investigated by HPLC/UV is specified.
Two-thirds of the listed compounds were
determined by Option 1A.  Option IB,
which involved the acidification of the
eluent, was instituted primarily for the
determination of the phenoxyacetic acids.
We observed that 4,6-dinitro-p_-cresol and
methyl yellow chromatographed very poorly
without the inclusion of acid in the
eluent; thus, Option 1C was established
for the determination of these two
compounds.  Option 2A was suitable for
the determination of 11-nitroso-ll-
methylurea; Option 2B for saccharin.,
(Option 2C was used for the determination
of other compounds discussed later.  See
Table 6.)  For some of the compounds, it
is likely that another option—either one
of the other options listed here or a new
set of operating conditions—would have
given results comparable to those
presented in Table 5.

     The application of the specified
procedures yielded the retention times and
detection limits given in Table 5.  For
most of the compounds listed, the initial
determinations were made at a detector
wavelength of 254 nm, the wavelength of
maximum absorbance for the phenyl
functional group.  After we had selected
optimum wavelengths for analysis, we
redetermined some of the compounds to
establish lower detection limits.  The
limits established for the optimum wave-
lengths were typically <10 ng and usually
at least a factor of 10 lower than the
limits at 254 nm.

     Reference chromatograms, UV spectra,
and calibration curves were generated for
the compounds listed in Table 5.  The
calibration curves typically yielded
linear-least-squares correlation
coefficients of X).999.  For some
exceptions, such as phenol, we obtained
calibration curves that were nonlinear.
Because these curves did appear to be
useful in determining the substances with
reasonable accuracy, however, we did not
consider it necessary to determine these
substances on other HPLC columns or with
alternative solvent programs.

     In addition to the compounds cited
in Table 5, we found others that may be
determined by the generalized HPLC/UV
test procedure.  Because of time
constraints, the investigation of these
substances was not completed; neverthe-
less , several compounds are presented in
Table 6 as potential candidates for
analysis by the HPLC procedure.  Retention
times and approximate detection limits
were determined for the compounds on the
basis of a limited number of injections
of standard solutions.  The retention
times of several of the compounds—
thiourea, thioacetamide, and ethylene
thiourea—were uncertain because several
major peaks were observed in their
chromatograms.  The presence of more than
one major peak in a chromatogram was
interpreted as an indication of gross
contamination of the sample or as an .
indication of the decomposition of the
analyte on the HPLC column.  Thus, the
feasibility of the application of the
method to the determination of these four
compounds is uncertain.

     The precision of HPLC determinations
for a representative group of the
candidate POHCs is demonstrated by the
data in Table 7.  All but two of the
triplicate sets of results were very
precise.  The precision of the
determinations of acetophenetidin was
biased by one value that was 15% higher
than the other two.  Perhaps additional
replicate determinations would have
proven the high result to be a statistical
outlier.  The determinations of 5-nitro-o_-
toluidine yielded increasing responses
with each subsequent determination; such a
trend is usually indicative of column
conditioning.  Perhaps the response would
have reached a stable value after repeated
injections.
                                          170

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      TABLE 5.  SUMMARY OF HPLC/UV DETERMINATIONS OF CANDIDATE POHCs
ProceduraL
Compound option3
Streptozotocin

Phenol

4-Nitrophenol

o-Chlorophenol

Acetophenetidin

5-Nitro-o-toluidine

Tetramethylthiouram disulf ide

4-Chloro-m-cresol

2 , 4-Dichlorophenol

3-(a-Acetonylben2yl) -
4-hydroxycoumarin
2,4, 6-Trichlorophenol

2,3,4, 6-Tetrachlorophenol

Reserpine

Chlorambucil

2,4-Dichlorophenoxyacetic acid

2,4, 5-Trichlorophenoxyacetic
acid
2-( 2 , 4 , 5-Tr ichlorophenoxy) -
propionic acid
4 , 6-Dinitro-o-cresol
Methyl yellow
N-Nitroso-N_-methylurea

Saccharin

LA

1A

LA

1A

1A

LA

LA

1A

1A

LA

LA

LA

1A

1A

IB

IB

IB

1C
1C
2A

2B

Retention
time , min
1.4

5.4

9.5

12.4

12.6

14.3

16.3

16.8

17.6

19.8
,
20.0

21.5

22.7

23.9

7.6

14.2

16.5

7.6
13.1
1 8.4

3.2

On-column
detection
limit, ng
2
— —
78
—
54
6
.72
6
1
—
1
—
1
—
77
4
100
2
2
—
53
7
19
17
28
—
1
- — .
69
—
55
—
38
—
20
3
10
—
2

Wavelength of
detection, nm
254
c
230
254
f*
280
254
c
280
254
280C
254
C
248
254
253C
254
280C
254 .
280C
254
C*
. 280C
254
280
254
/•»
280
254
280
254
267°
254
r>
258
254
284°
254
287°
254
287C
378°
400C
254
234C
254c
224
 See text for description of options.

 Quantity injected that is required to yield a response twice the magnitude of
 background signal.

CThis wavelength was selected from the referenced UV spectrum as the optimum
 wavelength for analysis.

                                    171

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               TABLE 6.   POTENTIAL CANDIDATES FOR ANALYSIS BY HPLC/UV
Compound
Trypan blue
Epinephrine
Thiosemicarbazide
Thiourea
Thioacetamide
Ethylene thiourea
Crotonaldehyde
Diethylstilbestrol
Mitomycin C
Melphalan
3 , 3 '-Dimethoxybenzidine
dihydrochloride
Daunomycin
Azaserine
Procedural
option3
2C
2C
2C
2C
2C
2C
2C
2C
1A
1A
1A

IB
2A
Retention
time, min
3
3
3
~3C
~4C
~4C
5
14
5
14
-19

8
4
Approximate
on-column
detection
limit, ng
20
60
5
6
2
8
1
4
17
10
, 9

75
2
Wavelength of
detection, nm
315
279
254
, 254
254,
254
230
240 ,
254
254
254

254
254
    See text for description of options.

    Quantity injected that should yield a response of 1000 counts on the integrator.
   C                                                                           '
    The presence of several major peaks in the chromatogram made the assignment of
    a retention time difficult.
                    TABLE 7.  PRECISION OF HPLC DETERMINATIONS

Compound
Quantity
injected,
UK
HPLC/UV response^ '
area counts x 10 ?
Detna Detn Detn
No. 1 No. 2 No. 3 Mean
SD RSD, %
3-(ct-Acetonylbenzyl)-       9.39
  4-hydroxycoumarin
Acetophenetidin             2.52
Chlorambucil                1.76
N^-Nitroso-N-methylurea      4.96
5~Nitro-p_-toluidine         2.48
Reserpine                   7.50
Saccharin                   0.98
Tetramethylthiuram          9.45
  disulfide
 895

1060
 452
 109
 690
  58.
  43.
 264
886

915
449
108
750
 56.4
 43.2
266
902

909
457
107
801
 61.4
 42.0
264
894

962
452
108,
747
 58.8
 42.7
264
 8

85
 4
 1
56
 2.5
 0.7
0.9
8.9
0.9
0.8
7.4
4.2
•1.5
0.4
     iDetn «• determination.
                                       172

-------
SUMMARY AND CONCLUSIONS

     A generalized GC/MS (and GC/FID) test
procedure and a generalized HPLC/UV
procedure have been developed for the
determination of approximately 70
candidate POHCs.  Additional details of
the methods evaluation and reference
chromatograms, calibration curves, mass
spectra, and UV spectra are given in
Reference 2.

     The candidate POHCs are of a variety
of compound types including alcohols,
esters, chlorinated aliphatics and
aromatics, carboxylic acids and acid
anhydrides, aliphatic and aromatic amines,
nitrated aromatics, nitrosamines,
hydrazines, nitriles, organosulfur
compounds, and polynuclear aromatics and
heterocyclics.  The generalized procedures
are likely to be applicable to the
determination of compounds similar to
those tested.

     The methods have been calibrated
for candidate POHCs over concentration
ranges of interest and have demonstrated
acceptable precision in the determination
of most of the POHCs.  The ultimate
accuracy of the methods in the
determination of POHCs in incinerator
wastes and effluent will, of course,
depend on the prudent choice of
appropriate sampling procedures and
^ample-preparation procedures.
ACKNOWLEDGMENTS

     This work was sponsored by the
U. S. Environmental Protection Agency
under Contract No. 68-02^-2685, Work
Assignment 111, Larry D. Johnson,
IERL-RTP, Project Officer.
REFERENCES

1.  de Vera, E. R., B. P. Simmons,
    R. D, Stephens, and D. L. Storm. 1980.
    Samplers and Sampling Procedures for
    Hazardous Waste Streams. EPA-600/
    2-80-018 (NTIS PB 80-135353), U. S.
    Environmental Protection Agency,
    Cincinnati, Ohio.
2.  Dillon, H. K., and R. H. James. 1981.
    SATS Sampling and Analysis Methods:
    Draft Report. EPA Contract 68-02-2685,
    Work Assignment 111, U. S.
    Environmental Protection Agency,
    Research Triangle Park, North
    Carolina.

3.  Federal Register 44;69540-59; 1979.

4.  Federal Register 46_:7666-90; 1981.

5.  Rechsteiner, C., J. C. Harris,
    K. E. Thrun, D. J. Sorlin, and
    V. Grady. 1981. Sampling and Analysis
    Methods for Hazardous Waste
    Incineration:  Draft Report. EPA
    Contract 68-02-3111, Work Assignment
    124, U. S. Environmental Protection
    Agency, Research Triangle Park, North
    Carolina.

6.  U. S. Environmental Protection Agency.
    1980. Test Methods for Evaluating
    Solid Waste:  Physical/Chemical
    Methods. EPA Report No. SW-846, U. S.
    Environmental Protection Agency,
    Cincinnati, Ohio.

7.  Vogel, G., K. Brooks, J. Cross,
    I. Frankel, S.  Huas, and W. Jacobsen.
    1981. Guidance Manual for Evaluating
    Permit Applications for the Operation
    of Hazardous Waste Incinerator Units:
    Draft Report. EPA Contract 68-01-6092,
    U. S. Environmental Protection Agency,
    Washington, D.C.
                                           173

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              NEW IDEAS IN  HAZARDOUS WASTE MANAGEMENT TECHNOLOGY
                                      Harry M. Freeman
                          California Office of Appropriate Technology
                                    Sacramento, CA  9581*
                                          ABSTRACT
This paper  discusses the initial results  of an EPA/State of  California co-sponsored project to
evaluate emerging innovative  technologies for managing hazardous  wastes.   Over 40 proposals
submitted by  various  waste management technology developers  were evaluated by an Office of
Appropriate Technology (OAT) technical panel to  select 12  for possible  demonstration within
California.  The  selected proposals,  which include  five  thermal, two biological and  five physi-
cal/chemical processes, are briefly discussed.
INTRODUCTION
THERMAL PROCESSES
     Under a cooperative agreement initiated
in March 1980 with the U.S. EPA, the California
Office  of  Appropriate Technology (OAT)  has
begun a project to evaluate and possibly demon-
strate  innovative processes for  treating  and
detoxifying hazardous wastes.   The project is
part of a  program supported by  various State
agencies to encourage the detoxification, reduc-
tion,  recycling,  or  destruction  of  hazardous
wastes as  an alternative  to landfills.

     Processes for this project were obtained
primarily from  a request for  proposals  which
was  run in  several  prominent  technical  and
environmental magazines.  A review panel con-
sisting of OAT staff members selected 12 pro-
cesses from the approximately  45 submitted.
The technologies chosen for further  evaluation
are shown  in Table I.   Discussion of the tech-
nologies follows.  The inclusion of these pro-
cesses in this  paper is not intended to  be an
endorsement of the processes by either OAT or
EPA.  Neither OAT nor EPA, at this time, have
evaluated the claims made for the processes or
in any way determined their accuracy.  This is
the purpose of  the  study which will  follow.
Persons interested in learning more about these
technologies are  urged to talk with the contact
person indicated.
Pyrolytic Incineration
Midland Ross Corporation

     The  system  as  described  by the vendor
includes three components in sequence: a rotary
hearth furnace, a rich fume reactor, and a heat
recovery device.  Waste is fed onto the rotary
hearth and held at 1000° to 1400°F for  15  to
30 minutes depending  upon the type of waste.
As the waste is volatilized, the gaseous fraction
is passed  to  the reactor and is combusted  to
complete  the  destruction  of  hazardous  com-
pounds. The reactor  is reported to operate  at
temperatures in the range of 1800° to 3000°F
depending upon the toxicity of gaseous com-
ponents.  Following combustion  in  the  reactor,
the gaseous fraction is released to a boiler for
the extraction  of  heat energy.

     The  pyrolytic incineration process  oper-
ates under quiescent atmosphere, so particulate
carry over is claimed  to be lower than for the
conventional  incineration  process.   Inorganic
chemical  constituents containing sulfur,  phos-
phorus, and halides may be retained in the char
because of lower pyrolysis temperature.  Scrub-
bing equipment can be added,  if  need arises,
to remove chemical  pollutants such as  SO2,
                                              174

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HC1, or ^2^5 to meet emission standards. The
process is commercially available.


Cement Kiln Co-Combustion
Systech Corporation

     The  process  is  to burn ignitable organic
wastes as  a supplemental fuel in a cement kiln
at a location in Southern California.  The proj-
ect is  patterned on  a similar operation being
run by the applicant  at a plant  in Ohio.

     It is  reported  that at  the Ohio  plant,
selected waste  materials, waste solvents and
industrial oils are procured directly from gener-
ators,  transported  to the facility  using tank
trucks, and  off-loaded at the receiving station
directly into the storage tanks located at the
cement manufacturing facility.  Chemical anal-
yses are performed at the receiving station to
assure  that the materials received comply with
the permit  requirements,  and to be sure that
the materials delivered to the cement kiln com-
ply with specifications  designed to guarantee
that the cement manufacturing  process  is not
negatively  impacted.    The  material  is then
pumped to  the cement kiln and  fired in con-
junction with the  standard fuel utilized  in the
kiln.

     No environmental emissions are expected
by  the vendor  from  this process  beyond the
normal  products  from  combustion  processes.
Particulate emissions, it is claimed,  will remain
consistent with those from the fossil fuels nor-
mally  used  in the  cement  kiln, and will  be
controlled by the  existing air  pollution control
equipment  on the kilns.  All the organics are
claimed to be completely destroyed in the kiln
due to the high temperature  and long retention
times of the process.   Metals or chlorine con-
tained  in the  waste  products are  said  to be
incorporated in an essentially unleachable form
into the  cement  product or  the  dust.   The
process may actually  reduce the sulfur  emission
from the cement kilns due to the fact that less
sulfur may be in the waste fuels than is present
in the  coal  that  is  replaced  (coal  is used in
95% of the kilns in the United States).
High Temperature Fluid Wall
Thagard Research Company

     The Thagard HTFW process is a high tem-
perature  process for quickly reducing organic
wastes to their elemental state.  The reduction
is carried out  in  a  patented  reactor  which
consists  of a tubular core of  porous refractory
material capable of  emitting sufficient radiant
energy to activate reactants fed into the tubular
space.   The core material is designed to be of
uniform porosity to  allow the  permeation of a
radiation-transparent gas  through the core wall
into the interior.  The core is completely jack-
eted and insulated in a fluid-tight pressure ves-
sel.   Electrodes located  in the annular space
between jacket  and core  provide  the energy
required to heat the core to radiant  tempera-
tures.

     The principle,   it is claimed, which  dif-
ferentiates the HTFW Reactor from other high
temperature devices is the method of energy
transfer to  the reactants.   While the  latter
employs convective or conductive techniques to
transfer energy to the Reactor feed, the HTFW
Reactor,  according   to claims,  uses  radiative
coupling to  heat the reactants.   The core is
heated  by the external electrodes and its  inner
surface re-radiates the energy into the tubular
space   where  the  reactants  are  introduced.
Radiative power densities of over 1200 watts/
in^ are claimed, and the finely divided reactants
are  heated  by  the direct impingement of  elec-
tromagnetic radiation.  The advantages of this
method of  energy  transfer are  that the  re-
actants are instantaneously heated,  and  the
chemical  reactions  are  greatly  accelerated
without the necessity for heating the  entire
process stream to reaction temperature.  The
rate of energy transfer is independent of either
the  contact of the reactants with the Reactor
surfaces or of the flow regime of the reactants.

      Another  distinctive feature reported by
the builder for the HTFW Reactor is the pat-
ented fluid-wall. A gas, which is transparent
to  the radiation  (and  therefore  largely  not
energy  consuming),   is   introduced   radially
through the porous  walls of  the Reactor to
produce an annular envelope of gas which blan-
kets the  walls.   This  envelope  reduces  the
contact of  the reactants with the Reactor sur^
faces  to minimize  deposition  of  reactants or
products on the radiator surface.  This feature
offers  an  improvement  over  other  gasifiers,
since the operational life of the  Reactor com-
ponents is  not. subject to slagging with its at-
tendant core wear.

      Because  energy transfer is  accomplished
by radiation, heating of the reactants is claimed
 to be very rapid —  on the order  of millions of
 degrees per second  for reactant surfaces.  Nor-
 mal operating  temperatures are in the region
 of 4000°F.  Externally published literature does
 not provide kinetic  data and models for reac-
 tions  at these temperatures, and most  data
                                               175

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  derived  by Thagard is at the state-of-the art.
  The vendor also claims evidence that in  these
  temperature  regimes,  the reactions differ  in
  kind, not simply in degree. However, empirical
  data from  several thousand  hours of Thagard
  testing shows that, in these ranges, the rate  of
  surface heating tends to preclude the formation
  of  intermediate compounds  from  partial re-
  actions  of  feed material.  Since  these  com-
  pounds may contribute to  downstream pollution
  abatement   requirements,  their   elimination
  would assure a higher level  of  product purity
  with  reduced  cost  for  downstream clean-up
  equipment. Reaction times are  almost instan-
  taneous.   Residence time  for reactants can be
  greatly reduced and  reactor size can be  mini-
  mized.   Consequently, capital costs lower than
  systems  based on lower-temperature processes
  are  claimed.
 Catalytic, Low Temperature Fluidized Bed
 Energy Incorporated

      The incineration process is described by
 the manufacturer as a catalytic, low  tempera-
 ture, fluidized bed process for the  destruction
 of toxic  and hazardous wastes.   The  system
 incorporates a dry exhaust gas clean-up method
 for removal of the process by-products.

      As  presented, liquid waste  is  metered
 (along  with  fuel oil when  required) into  an
 injection tube which pneumatically  injects the
 waste near the bottom of a fluidized bed oper-
 ating at a low temperature.  The bed itself is
 composed of  a mixture  of  granular combustion
 catalyst and limestone.  Fluidizing air is forced
 up through this bed at  a high  enough velocity
 that  the  mixture behaves very similar to a
 boiling liquid.  During  operation, limestone is
 continuously added to the bed to  replenish that
 expended by reaction with combustion products.
 Also during operation, bed material  is periodi-
 cally drained from the  vessel to maintain the
 appropriate bed height.

      In the pilot plant, a single  cyclone separa-
 tor is used to remove paniculate matter from
 the off-gas.  In a  deliverable full  sized system,
 it is  likely that  a multiclone  or other  more
 efficient particulate removal system would be
 necessary.  During the past year, the El fluid-
 ized bed incineration system has been demon-
 strate^ for the destruction of chlorinated hydro-
 carbons and organophosphates.  The chlorinated
 waste  demonstration has  used  carbon tetra-
 chloride as a representative aliphatic hydrocar-
 bon  and  dichlorobenzene  as a representative
aromatic hydrocarbon.   Tributylphosphate has
 been used  to  represent organo phosphate ma-
 terials.   The program for further waste types
 to be evaluated includes phenols, chlorophenols,
 hexacnlorobenzene, PCBs,  and mixtures of these
 wastes.  Optimization of fuel (where necessary),
 catalyst use, absorbent use, and system  operat-
 ing and  design-parameters are not complete so
 no complete process economics are now avail-
 able. According to El, preliminary data  suggest
 that  the technology may offer a considerable
 economic advantage over other systems because
 of low temperatures, reduced  amount  of fuel
 oil where required, and less exotic materials of
 construction.
 Wet Air Oxidation
 Zimpro, Inc.

      Wet Air Oxidation is a process to oxidize
 dissolved or  suspended organic substances at
 elevated  temperatures and pressures.   Water,
 which makes ,up the bulk of the aqueous phase,
 serves  to  catalyze  the oxidation  reactions so
 that  they proceed at  relatively low tempera-
 tures  (350 F  to  650°F) and at the same  time
 serves to moderate the oxidation rates removing
 excess heat by evaporation.  Water also  provides
 a heat transfer  medium which, it is  claimed,
 enables  the Wet  Air  Oxidation process to be
 thermally self-sustaining with relatively low or-
 ganic feed concentrations.  The process is be-
 lieved  by  the vendor to be  most  useful for
 wastes too dilute to  incinerate economically,
 yet too toxic to treat biologically.

      The oxygen required by the Wet Air Oxida-
 tion reactions is provided  by  an  oxygen-con-
 taining gas, usually  air, bubbled  through the
 liquid  phase in  a reactor used to contain the
 process; thus the commonly used term "wet air
 oxidation."  The process pressure is maintained
 at a  level  high enough  to  prevent excessive
 evaporation of the liquid phase, generally be-
 tween 300 and 3,000 psi.

      As  described  by  the  manufacturer,  a
 wastewater stream containing  oxidizable  con-
 taminants is pumped to the system pressure by
 means of a positive  displacement type pump.
 The wastewater passes through a heat exchanger
 which  pre.heats the waste by indirect heat ex-
 change with the  hot  oxidized  effluent.   The
 temperature of the incoming feed  is increased
 to a  level necessary  to support the oxidation
 reaction in the reactor vessel.  Air  and the
incoming  liquid  are injected  into  the  reactor
 where the oxidation begins  to take place.  As
oxidation progresses up through the reactor, the
 heat of combustion is  liberated, increasing the
                                              176

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temperature of the reaction mixture.  This heat
of oxidation is recovered by interchanging with
the  incoming  feed thus  giving, in  many  in-
stances,  thermally self-sustaining  operation.
After  energy  removal,  the oxidized effluent,
comprised mainly of water, carbon dioxide, and
nitrogen is  reduced in pressure  through a spe-
cially designed automatic control valve, accord-
ing to the manufacturer's designs.
BIOLOGICAL PROCESSES
Soil Enrichment
Veale Tract Farms

     The applicant is an operating farm which
applies  various inorganic industrial by-products
and wastes directly into the land to bring about
soil enrichment.  Much of the material handled
by the process could  be classified  as hazardous
wastes  if it were to be disposed of  in  a  com-
mercial chemical landfill.  Veale  Tract Farms
is not classified  as a waste disposal site.   All
materials have been declassified as  waste  for
use  as  agricultural soil amendment, after  ex-
tensive  analysis and review. All materials bene-
ficial to agriculture are applied at recommended
rates, and are used in  an environmentally safe
manner.

     The applicant  has  conducted  operations
since 1975 and is currently the only such opera-
tion in the United States.  Some of the materials
utilized are limerock, paper pulp effluent, lime
sulfur slurry,  ammonium sulfate, digested sew-
age sludges, lime sludge, and  gypsum.

     There  are  no direct emissions from  the
operations.    Indirectly,  sodium  and  alkaline
water is leached  from the cropland and drained
to a central location.  The farm operates under
discharge requirements set  by the  California
Regional  Water Quality Board.  The operation
appears to  offer a very  attractive alternative
for at least some of the materials  now going
into landfills.
Specialized Microbes For
In Situ Hazardous Materials Control
Polybac Corporation

     The process involves the addition of mi-
crobes specially developed to break down highly
refractory toxic materials to conventional and
specialized   biological   treatment   processes.
These microbes have been developed through a
process of  "selective adaptation" through in-
creased exposure to model substrates, and sub-
sequent mutation to  genetically fix the bio-
degradation enhancement. The wastes for which
this process can be used comprise a very broad
list,   ranging  from  dilute  aqueous  solutions
through highly concentrated aqueous solutions,
and  including semi-solid and  solid  materials.
Microbes have been developed for breaking down
extremely refractory compounds such as 2,4-D
and certain PCBs.

      The  biological  process has been shown to
be less energy intensive  and  expensive than
other ultimate destruction technologies such as
oxidation  or  incineration.   The process also
produces  no secondary  disposal  problems for
toxic residuals.

      The  end product of biodecontamination is
carbon  dioxide, water and cell mass.    Where
small quantities  of  waste are being degraded
at a  single  site or where  the  decontamination
is occurring in the  soil, the final residue (the
cell mass) is totally compatible with the natural
bioprocess and will be readily reassimilated into
the  natural eco-system.   Where  very large
amounts of wastes are being degraded at  a
single site,  a substantial microbial residue will
develop which must be  handled.  This residue
can  be handled  through  biological anaerobic
digestion  with the  concomitant production of
energy (methane gas). The final stable residue
from  anaerobic digestion can be ultimately used
to re-establish the viability of lands which have
been  made  sterile by man's activities.   This
would include stripped mine land reclamation,
reforestation,  etc.
PHYSICAL/CHEMICAL PROCESSES
Ultra Violet  Disinfection
Pure Water Systems, Inc.

     The process as reported  uses ultra-violet
light to  accelerate  the biological degradation
of organic wastes in dilute concentrations.  Al-
though the mechanisms by which the UV process
detoxifies chemicals is still under investigation,
the reaction appears to be  a  chemical oxida-
tion/reduction reaction involving  the generation
of ozone.  Waste streams currently being studied
are halogenated  aromatic compounds, chloro-
dioxins, copper wastes, and waste streams from
synthetic fuels production.  The USDA pesticide
laboratory has carried out  research on the pro-
cess and found that biological activity increased
                                             177

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 dramatically following pretreatment  with UV.
 The USDA has entered into an agreement with
 the appplicant to construct some portable, 10
 GPM,   units  for detoxifying  waste  lagoons.
 These portable units  could be made available
 for a California demonstration.
 Encapsulation
 Environmental Protection Polymers

      The  process, according to the  manufac-
 turer, "fixes"  hazardous waste  for  deposit  in
 the earth.  It  mixes participated contaminants
 with  polybutadiene,  a  material employed for
 manufacturing rubber tires, and then thermosets
 the mixture to form a  block of  waste.   The
 block is  then encased  in a seamless, 54-inch
 thick jacket of polyethylene, a material used
 In jacketing electrical cable.  The process,  it
 is claimed, does not significantly  increase the
 volume of material requiring disposal, a factor
 that could contribute greatly to the attractive-
 ness  of the process.  The resulting  product  is
 reported  by the vendor to exhibit outstanding
 resistance  to  water  leaching,  and   chemical,
 physical, and mechanical stresses.  Additionally,
 the process claims to offer the advantages  of
 "disposing"  of  the  waste in a manner in which
 it can be easily and safely retrieved.
Adsorption
Dr. Samia Fadl

      The process is designed to remove haz-
ardous materials, mainly heavy metal ions, dis-
solved organics,  phenol and cyanides from  in-
dustrial sewage.   The method uses carbon to
adsorb the contaminants, but rather than  using
activated carbon, uses low rank lignite coals,
an abundant natural  resource in North America.

      Lignite coals cost approximately one tenth
the amount for activated carbon and have been
found by  the applicant to be superior to  acti-
vated carbon for selected  contaminants.   In
addition to clarifying effluent, the lignite might
also be useful as a source of energy when its
adsorbing capacity is exhausted.  The  process
has been tested at the bench scale using simula-
ted wastes and is at a stage for expansion to
a pilot scale.
Waste Oil Conversion
Soil Recovery, Inc.

     The Soil Recovery Process is claimed to
be a method of converting oily wastes such as
those found in waste lagoons into an inert mass
which has several useful properties.  The process
consists of mixing a  specially  adapted reagent
with the waste at the site of the pond. After
proper mixing, the reaction, which is exother-
mic, occurs and the waste is converted into a
dry,  hydrophobic pulverized mass.   Once  the
waste has been converted into the solid, water-
repellant material, it can either remain on the
treatment  site or  be returned to the lagoon
from  which it came.

      Advantages claimed for  the  process  are
1) waste can be treated on site; 2) the treated
material is environmentally safe; and  3) treated
material need not  be disposed of  in chemical
landfills.  Process is  claimed to be very price
competitive.
Encapsulation/Coagulation
Colloid Piepho

     The process is described by the vendor to
utilize a one-step chemical encapsulation/coag-
ulation system followed by filtration dewatering
to clean  oily and  petrochemical wastewaters.
Typical wastestreams for which such a process
could  be applicable  include  oily  wastewaters
from the metal working industries, spray booths,
PCB waste from   electrical  transformers  and
waste  effluents from  the computer chip in-
dustry.

     According to  the developer, a montmoril-
lonite  based formulation is added directly to
oily  wastewater and  agitated vigorously using
a turbine mixer.  The polymers disperse and as
the acids and bases dissolve,  polymer-oil com-
plexes  are formed  and  immediately covered by
sodium montmorillonite.   Experience indicates
that most emulsions treat best  if  the  pH is
first lowered.  To do this, an organic acid is
chosen with a fast solubility  rate  and left un-
coated.   Other acids  and bases are coated to
prevent them from  interfering with the lowering
of the pH at this  point.  After sufficient time
has been given for oil collection and sodium
montmorillonite covering, the pH is affected by
the slower dissolving acids/bases.  Once  again,
flocculation and  montmorillonite covering oc-
curs.   Another  acid/base dissolves and the floc-
culation sequence  occurs again until almost all
of the oil is fixated.  The mixer is  turned off
and conventional sludge settling and dewatering
can  be done.   The  applicant  has found that
most   oily wastes  can be  effectively cleaned
with one of eleven formulations commercially
available.
                                              178

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     Operational  results  have demonstrated
that greater than 99% of its emulsified oil and
other  dispersed  contaminants  are  removed.
Clarified  liquid is  dischargeable to  the sewer
and the sludge generated by the system is high
solids content  and nonleachable.
SUMMARY
     As is illustrated by the processes discussed
in this  paper,  there  are  either in commercial
existence or under development, many processes
that appear  to offer  promise as answers to
hazardous  waste  problems.    It  is  simply no
longer necessary  and certainly not  desireable
to put highly toxic and persistent wastes  into
landfills  without treatment.   There  are many
options  far more environmentally  preferable.

     There is  presently underway within Cali-
fornia  a program  to  phase out the disposal of
certain  highly  toxic  wastes in landfills.  This
program was initiated by a Governor's Executive
Order and seems to have broad support through-
out the State.  We  believe that it  is only a
matter  of time before similar approaches to
waste management, i.e. treatment rather than
burying,  will  be  adopted  in  other   industrial
states.  We hope  that the processes discussed
in this  paper will accelerate  these  adoptions.
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                     TABLE 1.  PROCESSES SELECTED FOR DEMONSTRATION
       Applicant
Type of Process     Waste Streams
                           Description
 3.K. Shah
 Midland Ross Corp.
 900 N. Westwood
 Toledo, OH  43696
 (419) 537-6242
Arthur  3. Helmstetter
Systech Corporation
245  North Valley Road
Xenia, OH  45385
(513) 372-8077
Ed Matovich
Thagard Research Co.
2712 Kelvin Avenue
Irvine, CA  92714
(714) 523-2034
Roger D. Kuhl
Energy Incorporated
P.O. Box 736
Idaho Falls, ID  84301
(208) 529-1000
Phillip Schaefer
Zimpro, Inc.
Rothschild, WI  54474
(715)  359-7211
Brad Thomson
Veale Tract Farms
Knightsen, CA  94548
(415) 684-2193
Thomas G. Zitrides
Polybac Corporation
1251 South Cedar
  Crest Blvd.
Allentown, PA  18103
(215) 433-1711
Incineration/
Pyrolysis
Mixed Wastes
Cement Kiln
Co-Combustion
Liquid
Combustible
Wastes
High Temperature
Pyrolysis
Organic Waste
Fluidized  Bed
Incineration
Specific
Organic Waste
Wet  Air
Oxidation
Organics in
Water
Soil
Beneficiation
Biological
Various  Non-
toxic Indus-
trial Wastes
Toxic Organic
Wastes
                                              180
 A thermal oxidation process for li-
 quids and sludges which  combines
 starved air pyrolysis with fume in-
 cineration. The process requires no
 participate clean-up  and achieves
 EPA  required destruction efficien-
 cies.

 The process  involves the co-com-
 bustion of liquid wastes in a cement
 kiln during the production  of ce-
 ment.  Energy value of the waste
 is  recovered  directly as heat to
 make  cement.   Destruction  effi-
 ciencies  for the wastes involved is
 very  high.

 The  process  uses  radiative  heat
 transfer  in a  proprietary reactor to
 bring about temperatures of  4000°F
 on  the surface of waste particles.
 Destruction  is  instantaneous  and
 complete with only combustion pro-
 ducts remaining.

 The incineration process is a cata-
 lytic,  low temperature,  fluidized
 bed system.  The system  incorpor-
 ates  a dry  exhaust  gas  clean-up
 method for the removal of process
 emissions.

 The process is a method of destruc-
 tion and detoxification of dilute ha-
 zardous wastewaters.  The  system
 can be used as a means to recover
 useable  inorganics   from  streams
 containing organics and inorganics
 in wastewaters.

 Various nontoxic solids and sludges
are disked into  an  operating  farm
 to improve the quality of  the soil.
 Wastes are approved  by the State
 and water run-off  from the  farm
 closely monitored.

 Microbes  have been  developed to
 selectively break  down  toxic or-
 ganic wastes  such as 2,4-D;  2,4,5T;
 and some PCBs. The microbes can
 be  added to  conventional systems
 and are  added through  specialized
 treatment systems (CTX Treatment
 Systems).

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Tom Creeden
Pure Water Systems,
  Inc.
4 Edison Place
Fairfield, NJ  07006
(201) 575-8750
H.R. Luowitz
Environmental Protection
 Polymers, Inc.
13414 Prairie Avenue
Hawthorne,  CA  '90250
(213) 675-3555
Dr. Samia Fadl
Simon Fraser
  University
Burnaby, B.C.  Canada
219-3573

Joel Shofel
Soil Recovery, Inc.
P.O. Box  2147
95 Madison Avenue
Mqrristown, NJ
(201) 540-0566

Rick Brinkman
Colloid  Piepho
5100 Suf field  Ct.
Skokie,  IL  60077
(313) 966-5720
Ultfa-Violet
Encapsulation
Adsorption
Waste  Oil •
Conversion
Encapsulation/
Coagulation
 Organics  in      Water  containing  toxic  organic
 Water           wastes is  exposed  to  ultra-violet
                 light  which accelerates  the degra-
                 dation  of  halogenated  aromatic
                 compounds  by naturally occurring
                 bacteria.   Process  is most appli-
                 cable  to  detoxifying  on-site  la-
                 goons.

 Toxic Non-      The process is a technology using
 Combustibles    polymers to encapsulate extremely
                 toxic wastes.  The wastes can be
                 either dry  and unconfined,  sludges,
                 or  containerized.  The  end result
                 of the encapsulation process is the
                 isolation of the  waste in question
                 for  either  retrievable  storage or
                 burial.

 Wastewater      An adsorption technique for remov-
                 ing  organics  and  metals  from
                 wastewaters using low value lignite
                 coals.  Spent coal from the process
                 could be used as an energy source.

•Organic         The process involves adding a rea-
 Sludges          gent to sludgey  wastes  to  produce
                 a dry,  hydrophobic pulverized mass.
                 The resulting material which is sol-
                 id and water repellent can  be used
                 as clean fill.

 Contaminated    A one-step chemical additive sys-
 Aqueous         tern for small volumes of emulsified
 Streams         and water  insoluble wastes.
                                              181

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                      RECOVERING METALS FROM METAL FINISHING WASTES
                                  Alfred  B.  Craig,  Jr.
                           U.S.  Environmental Protection Agency
                                  Cincinnati, Ohio 45268
                                        ABSTRACT

This paper gives an overview of recovery methods used in metal finishing operations.   It
provides some details on a pilot plant designed to recover metals from waste treatment
sludges and other manufacturing byproducts.
INTRODUCTION

     Recycling  of  metals  by  industry  is
practiced at  significant  levels.   But this
practice is largely restricted  to the pure,
solid, scrap metal. As  an example, recycled
copper constitutes about  20 percent of the
total copper metal available  in the market.
This is the scrap  that needs  simple melting
and  refining.   The  scrap  comes  from two
sources:  removal from capital goods such as
buildings,  industrial machinery,  etc.,  or
consumer goods  such as automobiles,  appli-
ances, etc.  as  well  as  scrap generated in
their manufacture.*

     On  the  other hand,  permanent  metal
losses are  also tremendous.    Of  all the
recorded production of copper in this coun-
try, 72.5 million  short tons, about 60% are
traceable as being in use presently.  Forty
percent or 29 million  short  tons (58 billion
pounds) are lost  permanently due  to wear,
abrasion, chemicals,  fabrication,  etc.  At
today's  prices,  this  loss amounts  to  58
billion  dollars  figured  at  the  price  of
finished copper product.  The loss is stag-
gering when figured in terms of  the finished
capital and consumer  goods.2

     An example  of this  loss from chemical
and  metal  processing is  provided, by the
electroless  copper plating industry.   The
printed circuit board  industry comprises ten
percent of  all  the electroplaters in busi-
ness. They  generated about a million gallons
of  liquid  waste  (sludges)  annually.   Typ-
ically., one gallon of  this sludge weighs about
ten pounds and contains ten percent copper,
so  about a  million pounds  of  copper  are
contained in this sludge.  Disposal of such
waste is not always carried out with future
recovery  in mind,  so  a very  significant
amount is lost each year.

     Metal-containing wastes are not treated
for recovery for many  reasons.   Generally,
recovery is not an economical proposition in
terms of capital and operating costs,  it is
an  incompatible  operation,  or individually
the quantities  generated are not  large  e-
nough  to justify  a  recovery system  when
evaluated  simply  on  the economics of  the
metals-  themselves.     The  broader  picture
which includes disposal and treatment  costs
as  well  as  liabilities  merit  additional
cons iderat ion.

Regulations

     Federal regulation of pollution control
has been closely followed by state and local
governments issuing their own wastewater and
hazardous waste  programs.    These  programs
can be,  and  often  are, more stringent than
federal programs.  Their basic goal has been
to  protect  the  health  and  safety of  the
general  public by  controlling  industrial
discharges of all types to the environment.
This has been accomplished by increasing the
degree  of  complication and  precaution  re-
quired at each  waste  treatment or disposal
operation.  This has usually come in the form
of  more advanced  technology,  often  at  a
greater cost.  Further, elimination of some
                                            182

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         Table 1. Economic Penalty for Losses of  Plating Chemicals
                                                  Cost ($/lb)
Replacement Treatment3 Disposal*1
Nickel:
As NiS04 	
As NiCI, 	
Zinc cyanide as Zn(CN)2:
Using CI2 for cyanide oxida-
tion 	
Using NaOCI for cyanide oxida-
tion 	
Chromic acid as H2CrO4:
Using SO2 for chromium reduc-
tion 	 	 	
Using NaHSO3 for chromium
reduction 	
0.76
1.04
1.41
1.41
0.78
0.78
0.28
0.29
0.72
1.53
0.48
O.69
0.17
0.24
0.25
0.25
0.32
O.37
Total
1.21
1.57
2.38
3.19
1.58
1 79
            Copper cyanide as Cu(CN)2:
               Using CI2 for cyanide oxidation ...
               Using  NaOCI for cyanide oxida-
                 tion	
            Copper sulfate as CuSO.	
1.95

1.95
0.56
         0.72
1.53
0.28
0.25

0.25
0.17
               2.92
3.73
1.01
            a Based on chemical system described in  Tables 2  and 3.
            b. Based on Figure 1 at  $0.10/gal  sludge  disposed.

           Table 2, Chemical.and  Sludge Disposal Cost:Example System'
                               a  4
Treatment chemicals Sludge disposal
Tntol
Treatment step
Chromium reduction ....

Neutralization:
Chrome effluent .
Cyanide effluent .
Acid/alkali waste 	
Precipitation 	

Flocculation 	
Total

Chemicals 	
Sludge disposal 	

Waste streams
30 gal/min = 1 800 gal/h
0.75 Ib/h Cr+6
0.15 Ib/h Cr+3
20 gal/min — 1 200 gal/h
0.80 Ib/h CN~
0.60 Ib/h Zn+2
1 800 gal/h
1 200 gal/h
60 gal/min = 3 600 gal/h
0.90 Ib/h Cr+3
0.60 Ib/h Zn+2
3.01 Ib/h Fe+2
2.41 Ib/h Ni+2
1 .51 Ib/h Cu+2
110 gal/min = 6 600 gal/h





Rates
(Ib/h)
1 .86 S02
0.36 H2S04
5.6 CI2
6.4 NaOH
2.7 NaOH
(b)
3.6 NaOH
2.1 NaOH
1.2 NaOH
6.0 NaOH
4.8 NaOH
3.0 NaOH
17.1 NaOH
0.66 polyelectrolyte
1 .8 SO2
0.36 H,SO.
5.6 CI2
29.8 NaOH
0.66 polyelectrolyte

Cost Dry solids
rates generated
($/h) (Ib/h)
0.18
0.93
0.22
0.29
0.17 1.80
0.10 0.91
0.48 4.83
0.38 3.80
0.24 2.30
1.37 13.64
0.66
3.65 1 3.64°

Disposal annual costs
cost ($)
($/h)

0.53
0.28
1.44
1.10
0.68
4.03
4.03
1 7,500
1 9,300
aSystem described in Table 3
bp"H adjustment  not required
^Sludge volume  at 4% solids=40 gal/h.
                                           183

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                  Table  3. Investment  Cost: Example  System*
                                     Component
                                                                         Cpst
           Chromium reduction unit (continuous system rated at 30 gal/min, from Figure 2)	
           Cyanide oxidation unit (continuous system rated at 20 gal/min, from Figure 3)....
           Noutralizer(single-stage continuous system rated at 110 gal/min, from Figure 4).....
           Flocculation/clarification unit (continuous system  rated at 110 gal/min, from
             Figure 5)	,.....'..
           Polymer feed tank, mixer, and feed pump.	
           Sludge storage tank (5,000-gal tank to provide sludge storage volume, from Figure
             6)	-	....,.:.;.
               Total equipment and installation cost	
           Contingency (10% of total equipment and installation cost).
               Total installed cost
 23,000
 40,000
 28,000

 26,000
  3,000

 13.000

133,000
 13,000

146,000
           *References  listed  in  table are  irrelevant  to
            this  report.
              Table 4.  Annual Cost  Summary: Example  System*
                                    Component
          	B	 Hii, '	M	™
           Operating labor (based on 2 h per shift)
          *References listed in table  are irrelevant -to
            this report.

Tables 3  and  4  describe the  capital  and operating costs  for an  example
waste  treatment system.
                                            184

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      100 i-
   o
   o
   £
   03
   a
   3
   <
       75
       50
       25
                   Legend:
                         disposal cost at $0.30/gal
                         disposal cost at $0.10/gal
         0           25           50           75

                          SLUDGE VOLUME (gal/h)

         Note.—Based on operating time of 3,000 h/yr. Costs in 1979 dollars.
100
 Figure 1
 Annual Cost for Sludge Disposal


Figure 1  shows what sludge disposal did  cost,  what it  costs
now,  or will cost  in the  future.   The dotted  line reflects
the  loaded  disposal cost  for electroplating sludges disposed
in a  secure landfill at  $1.00/gal,
                             185

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treatment  options  has occurred  because of
public opposition to landfills and inciner-
ators,  etc.   Today,  landfilling  of  metal
bearing wastes  is  at best a  difficult and
costly  option.    It begs  the question 'of
liability if something should go wrong in the
future at the landfill site.   The future may
show that while land disposal  is today's most
widely  used  option, resource  recovery and
associated  detoxification is  the  optimum
approach.

Economics^

     Do you know what it costs-?

     The "whys" of pollution control have a
strong economic side.   Pollution is really
process  chemicals  going  down   the  drain.
Efforts  to control  discharges will provide
real dollar  savings.   Consider this,  these
chemicals have been bought  and paid for once
and  now,  as pollution,  require  additional
expenditures of capital for treatment equip-
ment and,  of course,  more chemicals.   Fur-
ther, the  cost of disposal of these process
and  treatment  chemicals  carry a hefty dump
fee, not to mention any contingent liability
which  may exist  if the  disposal  facility
fails to maintain proper disposal standards.
How  long  will  these  facilities  for   land
storage of wastes exist?  As they  become more
scarce  their users' costs will increase.

     Table 1 describes what it costs to waste
chemicals  in 1979  dollars.^   Capital goods
have increased about  20  percent  since  then-
and  the  cost of disposal  has increased to
$0.50-$1.00/gal,  far  beyond  the $0.10/gal
used as the basis for this chart, a summary
of Tables  2, 3, and 4 and Figure 1.

     Table  2 describes  what  chemicals are
used for treatment and what they cost.^

     Tables 3 and 4 describe  the  capital and
operating  costs for an example waste treat-
ment system.41

     Figure  1  shows  what sludge  disposal
used to cost, what it costs now or will  cost
in the future.  The dotted line reflects the
disposal  cost  for electroplating sludges
disposed in a secure landfill.

     These charts show that pollution costs
all  of us money.   If  the waste  treatment
costs  are  tagged  onto some profit centers,
some of them may turn out to be costing money
to  operate.    Their  profitability may be
restored by  cutting waste; that  which  re-
sults  from  inefficient operations  and  ex-
travagant wastes of process chemicals.  This
is  the subject of  this  paper—how  to  ac-
complish waste  reduction  and  recovery from
metal  finishing operations.

METALS RECOVERY

     Do An Inventory

     The word recovery indicates that some-
thing  has been  lost  and  in many metal fin-
ishing  plants,  indeed something  has.   The
quickest and  surest way  of  conserving  and
recovering metals  is  to  prevent  them from
becoming part of a mixed metal waste stream.
Recover  them  before they  are  lost as pol-
lution.

     This recovery  process must be started
with a good inventory  of your plant and its
wastes  generation  characteristics.  Review
each plating  tank,  rectifier,  hoist, steam
coil or other piece  of equipment; and do it
in  a new suit and shoes.  The place you are
most reluctant  to go in your new clothes is
probably the area that needs  the most atten-
tion.  Determine the actual flow of each line
using  the bucket  and stop watch method.
Review your water bills to see  if your total
water  use ifnventory  is consistent with what
you've been  buying.    Chemical  purchases
representing  a six-month  period  should be
studied carefully.   This  inventory  of water
and chemical usage will be the  beginning of
identifying  where  the metals  are exiting
your process and entering the sewer. Deter-
mine how frequently dumping of  process chem-
icals  occurs and  why' it  occurs.   Contam-
ination  that could be  eliminated may  reduce
the associated  pollutant load  and  maintain
more of the process chemicals in the process.

     Equipment  design and layout  can be  a
major  source  of pollution if one  considers
how much chemical waste occurs if parts must
be  carried across  a  plant  between  opera-
tions.   Proper work  patterns  can  restore
efficiency  to  an  operation  while  further
minimizing 'floor spills  and contamination.
If  reorganizing the shop is  not  feasible,
consider  letting the  batch of  parts  remain
above  the process for  an extra 15 seconds to
allow  additional draining.  This  keeps the
process  solutions in the tanks;  off the floor
and equally  important,  out of other  pro-
cesses.    Orienting   pieces  to  facilitate
drainage will  also  aid this process.^
                                           186

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     Salvaging improperly prepared parts is
expensive from several perspectives.  First,
the pollution has been generated during its
first preparation.   Stripping or reversing
completed preparation processes will gener-
ate additional pollution.  Then the piece has
to be  reworked.   Look at  the cause of the
rework  required.    Is there  a contaminant
causing  this?   If  so, eliminate  it at the
source and  reduce  the associated pollution
caused by rework and salvage.  It is  of major
consequence.

     Conserve that which you have bought.

     Conservation  of these materials  is  a
major factor in controlling pollution.  Keep
them out of the sewer.  Many processes can be
operated at a lower concentration than con-
ventional  wisdom  would  have  you  believe.
Experiment with this possibility and pursue
it with  any and all knowledgeable  people;
including  your suppliers.    Chemical  sub-
stitutions play a role here.  Will a chloride
bath do just as good a job as  a cyanide bath?
If  so,   you've just conserved  $10-40,000
worth of a cyanide waste treatment system.5

     Water  conservation  will help  conserve
other things as well.  In plating,  counter-
flow rinsing  is  a  monumental step  towards
conserving chemicals and water.  The concept
can be applied to  other  uses of chemicals.
Basically, use a chemical more than once if
you  can  and  then  recycle  it;  e.g.,  use
sulfuric acid  for  steel  pickling and  then
reuse  it to neutralize  a caustic  stream.
Flow restrictors  can further  reduce water
usage where counterflow  rinses have  been
installed or where room is insufficient' for
additional tanks.  A three-stage counterflow
rinse can  recover  about  90 percent  of the
chemicals which would be lost  in a single
stage rinse. Spray and timed rinses can also
be of major consequence for water saving.

     Only after rigid water  and  chemical
conservation at the point  of generation is a
common practice,  should  one  begin  to con-
sider recovery  equipment as  part   of  the
process.   The cost of any  piece of treatment
equipment will be  some function of  its  hy-
draulic capacity.   The bigger  the flow,  the
greater  the capital cost and  floor space
requirement.

     "It is extravagant and often futile to
     consider  any  recovery process  equip-
     ment until the maximum flow reduction
     has been  achieved  in each and  every
     operation  that  has  recycling  poten-
     tial.  The best and most reliable way
     to specify any  recovery method is by
     measuring  the  flow  and  assiduously
     monitoring and  analyzing  the  waste-
     water  in  concern.    Without  specific
     data,  equipment may be  recommended
     purely on speculation, thus increasing
     the  possibility of  under- or  over-
     design.    The latter is not  a func-
     tional disaster—just a waste of mon-
     ey.    Conversely,  under-design  will
     spur financial and emotional problems
     in that  the  recovery system will be
     expected  to   perform in  ways  never
     intended.  Again, complete your water
     conservation program and then consider
     and  select the  appropriate treatment
     technology for  the  specific  applica-
     tions  in your plant.""

IN PROCESS RECOVERY SYSTEMS

     Recovery  equipment  should be  chosen
with the  understanding that  it can be  a
money  saver but  that  it is  a piece of
process equipment  just like any other chem-
ical system.  It will not  operate by itself
but must have some form of maintenance and
operational  attention.    Diminished  waste
treatment and  sludge  disposal costs should
be  factored into  the equation as,  you re-
call, we  are going to look at the plating
line  as  a  profit center  and take   into
account the  total  cost of its operation.

     The  least  expensive and the most  cost
effective recovery system is  a simple drag-
out tank.  The first rinse is a  still rinse
which recovers much of the material from the
plating bath which is dragged out.  If the
plating bath is above ambient temperature,
the drag out or dead rinse tank contents can
be used to  restore the plating bath level.
Impurity  control  is  important in
both tanks  so extra makeup water purifica-
tion is essential.

     Ion  exchange  uses  polymeric  resins
which remove metal ions from wastewater by
exchanging  them  for  ions already  in the
resin.   These metal  ions  eventually  sat-
urate  the resins  and they must be regen-
erated usually by  replacing the metal  ions
with  sodium from  brine solutions  or hy-
drogen from acid solutions. Anions can  also
be captured  in  resin  columns of the appro-
priate  material.   They  are  restored  with
caustic.  These recovered solutions may be
added back to the plating tanks,  however the
                                           187

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r
              volume tends to grow which limits its use to
              hot baths or where evaporation can be used
              to further decrease the amount of solution.

                   In  electrodialysis—basically  electro-
              lytic dialysis—ions move  through membranes
              which only allow  the  passage  of only either
              anions or cations.  By  stacking these membrane
              types alternately and  applying a DC current,
              the ions in the waste streams are  forced  to
              migrate from the  dilute-wastewater  so as  to
              form a  series of channels  into  collecting-
              concentrating-channel  , where it is available
              for reuse. The greater the concentration,  the
              greater the efficiency of  the system.   Its
              best applications are  where dragout is high.

                   Reverse osmosis is used for the  removal
              of dissolved organic and  inorganic materials
              and control of such wastewater parameters  as
              soluble metals,  IDS,  and  TOG.   It  separates
              dissolved materials in solution by filtration
              through a semipermeable membrane at a pres-
              sure greater than  the osmotic pressure caused
              by the dissolved materials  in  the wastwater.
              With existing membranes and equipment,  oper-
              ating  pressures  vary  from  atmospheric   to
              1,500 psi.  Products from the process are  (1)
              the permeate or product stream with dissolved
              material removed,  and  (2) concentrate  stream
              containing  all  removed  material.   Removal
              levels obtainable are  dependent  on membrane
              type,  operating  pressure,  and the specific
              pollutant of  concern.   Removal  of  multi-
              charged cations  and anions  is normally very
              high,  while most  low  molecular weight dis-
              solved organics  are not removed or are only
              partially removed.

                  Distillation  is  one  of  the  simplest
             methods  of separating  plating chemicals from
             water.  The distilled water is condensed in a
              chiller.  Distillation  can be accomplished  at
             ambient  temperatures  but is  less likely   to
             destroy  heat sensitive chemicals if  accom-
             plished  under a  vacuum,   i.e.,   at  a lower
             boiling  point.     Fabrication of equipment
             should  be made  with   considerations  of the
             corrosive environment caused by the materials
             being  recovered.7

             Metal  Recovery from Hydroxide Sludges**

                  Treatment of hydroxide  sludges  for metal
             recoveries falls  into two categories: wet and
             dry.  In wet processes, separation reactions
             are  carried  out  usually at  atmospheric tem-
             peratures and pressures.   In dry processes,
             separation reactions take place  at elevated
             temperatures.  The former processes are gen-
 erally classified  as  hydrometallurgy  and  the
 latter as  pyrometallurgy.

      Pyrometallurgical  treatments  for seg-
 regated single metal  sludges  are:

      •    Direct smelting  after dewatering,

      •    Direct alloying  with other  metals.

      For economical feasibility,  the  opera-
 tion  of  pyrometallurgical  processes would
 have to be on a very large scale, and requires
 concentrated  feed  material.   The mixed metal
 hydroxide  sludges  fail to  meet  these   two
 requirements.  But, pyrometallurgical treat-
 ment using the  two above bulleted  processes
 are  presently available.

      Hydrometallurgical treatments  for mixed
 and  segregated  sludges  use aqueous dissolu-
 tion of metals  by  leaching  followed  by  re-
 covery of individual metals or  metal com-
 pounds from this solution.

      There are  certain  advantages  for using
 hydrometallurgical processes.  Metals may be
 removed  directly  from  the  solution by con-
 centration,  electrolysis,   or hydrogen   re-
 duction.  Fuel requirements  are  low  as   the
 processes  are carried  out at  low tempera-
 tures.  Disadvantages are that solution puri-
 fication and  concentration upgrading  may be
 absolutely necessary before metal recoveries
 are  possible.

      The hydrometallurgical treatment of the
 hydroxide  sludges  requires that  the process
 be specific,  reproducible,  and controllable.9
 The  process  should also be  possible  with a
 minimum number of unit operations and/or unit
 processes.  Those needed depend on  the chem-
 ical  state and also on the physical environ-
 ment  of  the metals.   Electroplating wastes,
 after the hydroxide neutralization,  will con-
 sist  mainly of metal  hydroxides  such  as  Cu-
 (OH)2) Ni(OH)2,  Cd(OH)2, Zn(OH)2,  etc.  With
 lime  neutralization,  the  sludge  will  also
 contain calcium salts.

      Solvents for these metallic constituents
 are  sulfuric  acid, ferric  sulfate, ammonia
 and ammonium carbonate,  sulfur dioxide, fer-
 ric  chloride, hydrochloric  acid,  and  nitric
 acid  and are  used  to  solubilize metal ions.
The  order  given  is about  that of  their  im-
 portance.  Metal  recovery from these solu-
 tions by such operations as cementation (co-
precipitation with  or solution  substitution
by another metal)  or electrolysis is most
                                                         188

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commonly  practiced  from  the metal  sulfate
solution.

     Sulfuric  acid   is  the  most  important
leaching reagent.  The main advantages for its
use are  the  cost, minor corrosion problems,
and dissolution of many metal forms.  Its main
disadvantage  is that  it   sulfatizes  every-
thing, which does not provide  any selectiv-
ity.  Ferric sulfate may be obtained cheaply
from spent pickle liquors.  Its primary func-
tion  is  to  provide  a  sulfate solution.   Am-
monia and ammonium carbonate may be suitable
reagents  for  some hydroxide  sludges because
they  possess better  selectivity  for  solu-
bilizing  metal  constituents in  a hydroxide
sludge.  But  the reagent cost is very high and
their recovery  in the process  would be man-
datory from an economical point of view.

     The primary aim for a solvent is to bring
the metal or metals into solution from which
individual separations can provide pure solu-
tions, with major impurities removed.

     Leaching  of  hydroxides by  either  sul-
furic  acid  or  ammonia  will provide  dilute
solutions.  Copper may be  recovered from lean
sulfate  solutions by  cementation with iron,
displacing copper quantitatively  from a solu-
tion.   The  product,  called cement  copper,
although, rich in copper, may be highly contam-
inated with iron so that only a smelter may be
able to handle it.

     A  technique  which is  becoming  widely
accepted  for concentrating solutions  is one
of ion exchange. The  ion  exchange medium may
be  solid or liquid.    Generally speaking,
concentrating  by   solid  organic resins  is
known  as ion  exchange  (IX)  and  by  liquid
organic resins is known  as  solvent extraction
(SX).  Ion  exchange  has tremendous applica-
tions  in uranium metallurgy as  the solvent
extraction technique is becoming accepted in-
copper metallurgy.   Its  acceptance is on such
a  large  scale that the future may  see its
application  in areas where the ore grade has
decreased or residual metallic wastes are to
be treated as in this case.

     For  sulfuric acid  leach solutions, cop-
per may be recovered from  the polymetal solu-
tion by cementation under oxidizing solution.
The cement copper may be  sold  directly  to a
smelter or releached for electrolysis.  Other
metals  are  selectively precipitated  after
iron  removal and may be  recovered  as  pure
metals  or  metal  compounds.    Electrolysis
regenerates  the sulfuric  acid  for  recycle
which is a very important factor in economic
evaluation because  regeneration is  part of
the process requiring no additional or extra
regeneration equipment installation.

     Copper  may  also  be  removed  from  the
polymetal sulfate solution by solvent extrac-
tion  and strip  copper  then  is  removed by
electrolysis.  Other metal recoveries may be
achieved by further solvent extraction or by
cementation with zinc.

     If an ammonia leach is employed, metals
such as copper, nickel,  and  zinc are selec-
tively brought  into  solution as amines  from
the hydroxide sludges.  Other impurities  such
as iron and calcium are left behind as solids.
Copper may  be  removed  from  this  polymetal
solution  by  solvent extraction,  stripping
with sulfuric acid, and electrowinning.   Oth-
er metals are further treated for separation.
Additional reagent recovery equipment is  nec-
essary.

     Generally,  there  are   three   types of
liquid wastes  in  a plating shop:   (1)  rinse
waters, (2) spent baths, and (3) spills.

     Spent baths  are  collected separately.
They  require  only  cyanide  destruction  and
thus  become  concentrated metal   solutions.
Rinse  waters  and  spills  are  treated   con-
ventionally  by  heavy metal  precipitation.
This  presorting provides two  distinct  feed
materials:  (1) a concentrated  solution, and
(2) a hydroxide sludge.   The leach solution
from hydroxide sludge leaching  with sulfuric
acid is mixed with the spent bath solution for
metal extraction.

     Metals  conservation  and  recovery  has
economicj environmental,  and socio- political
benefits.  The recommendations made in  this
paper  will  help  to  alleviate  some of  the
economic  consequences  of waste   treatment,
reduce environmental impacts  from this  in~
dustry, and reduce the rate at which permanent
metal loss occurs.
                                           189

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 REFERENCES

 1.   Mehta, Anil, 1981 Proposal to EPA,
      "Recovery of Metals from Metal Finish-
      ing Waste," Unpublished.

 2.   Ibid.

 3.   Roy, Clarence, "Establishing a Program
      for Pollution Control," excerpted
      from Plating and Surface Finishing,
      Vol. 68, No. 10, October and November
      1981.

 4.   Control and Treatment Technology for
      the Metal Finishing Industry:  In
      Plant Changes, U.S. EPA, January 1982
      and Alternatives;  Economics of Waste-
      water Treatment for the Metal Finish-
      ing Industry, U.S. EPA, June 1979.

 5.   Roy, Clarence, "Establishing a Pro-
      gram for Pollution Control," excerpted
      from Plating and Surface Finishing,
      Vol. 68, No. 10, October and November
      1981.

 6.   Ibid.

 7.   Ibid.

 8.   Excerpted from "Routes to the Recovery
      of Metals from Hydroxide Sludges,"
      Third Conference on Advanced Pollution
      Control from the Metal Finishing
      Industry, U.S. EPA, 1981.

 9.   Ibid.

10.   Ibid.
                                            190

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                                EPA MINING WASTE RESEARCH
                                    S.  JACKSON HUBBARD
                          NONFERROUS METALS AND MINERALS BRANCH
                            ENERGY POLLUTION CONTROL DIVISION
                INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY - CINCINNATI
                                          USEPA
INTRODUCTION

     The mining industry generates an es-
timated 2.3 billion tons of solid waste
each year.  Historically, the total ac-
cumulated solid waste from both active
and inactive mine sites approaches 30
billion tons.  Five segments of the mining
industry generate 85 percent of mine
solid waste: copper, phosphate, iron,
uranium, and coal.

     In recent years, Congress has passed
three acts indicating increasing interest
in the proper disposal of solid waste
generated by the mining industry.  The
Reource Conservation and Recovery Act
(RCRA)  is the most  comprehensive
regulatory authorization.   It was passed
in 1976. RCRA is implemented and enforced
by the Environmental Protection Agency
(EPA) and is intended to: control municipal
and industrial solid wastes.  The passage
of the Surface Mining Control and Re-
clamation Act (SMCRA) of 1977, imple-
mented and enforced by the Department of
Interior, controls coal surface mining
and the surface effects of underground
coal mining.  The Uranium Mill Tailings
Radiation Control Act (UMTRCA) of 1978 is
implemented by EPA and enforced by the
Nuclear Regulatory Commission (NRC) to
control uranium mill tailings disposal.

RCRA

     The Resource Conservation and Recov-
ery Act addresses the disposal of waste
from municipal or industrial sources.
Specific to mining, RCRA recognizes the
special problems associated with this
industry, and requires that a special
study be made.  This study will be dis-
cussed later.  Two types of mining waste
which are exempted from control under
RCRA are uranium mill tailings (covered
by UMTRCA) and overburden intended for
return to the mine site (except when
specifically included by EPA).

     The basic regulatory philosophy
underlying RCRA is that wastes are one of
two types: either hazardous or nonhazardous,
and the regulatory scheme applicable to
each type is different.  Hazardous wastes
are those currently listed by EPA in its
Section 3001 regulations or those which
fail specified tests for toxicity, corro-
sivity, reactivity, and/or ignitability.
Wastes which are not listed by EPA and
which do not fail the tests for these
four characteristics are presumed to be
nonhazardous.

     Hazardous wastes are regulated under
a "cradle-to-grave" approach.  The gener-
ator, transporter, storer, treater and
disposer are all subject to regulation.
The regulations provide a manifest system
to track the waste from the point of
generation to the point of ultimate dis-
posal.  Specific standards are set for
transport, treatment, storage, and dis-
posal.  In addition to the technical
standards, administrative standards cov-
ering recordkeeping, reporting, and fi-
nancial responsibility are also imposed.

   Presently, EPA's RCRA Subtitle C. regu-
lations do not apply to mining wastes.
Congress amended RCRA on October 21, 1980
so that solid waste generated from the
"...extraction, beneficiation, and proc-
essing of ores and minerals..." are ex-
cluded from regulation under Subtitle C.
Subtitle C does however, have important
                                           191

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 implications for the raining industry.
 While no mining wastes are included in
 the RCRA control system now,  EPA may
 eventually bring these wastes under regu-
 lation.  It is important to note that the
 RCRA mining wastes exclusion is not a
 permanent exclusion.  At the same time
 Congress excluded mining waste from RCRA
 subtitle C regulation, Congress directed
 EPA to perform a special study of the
 raining industry and waste generated from
 mining operations.  EPA can,  if it deter-
 mined it necessary, issue RCRA Subtitle C
 regulations for the mining industry six
 months after it completes this study.
 The mining exclusion would end if and
 when EPA issues Subtitle C regulations.
 EPA views mining wastes as "special wastes.
 That is, unlike many low volume,  high
 toxicity waste streams regulated under
 RCRA (and for which Subtitle  C of RCRA
 was designed),  most mining operations
 produce high volume, low toxicity waste
 streams.  Obviously, EPA could never
 apply its existing RCRA Subtitle C regula-
 tions to these waste streams.   If EPA
 decided there was a need to control the
 disposal of mining waste,  the  RCRA regula-
 tions it would issue would be  custom fit
 to  Che raining industry and the unique
 nature of wastes generated from mining
 operations.

 SMCRA

      The Surface Mining Control  and Re-
 clamation Act applies  to coal  surface
 raining and the  surface effects  of under-
 ground coal  mining.   Interim and  permanent
 regulatory programs  have been  promulgated
 by  the Department of the Interior to
 implement the authority of that  law.   The
 regulations  include  specific requirements
 for  the construction and operation of
 mine  waste disposal  sites,  including  both
 mining and processing  wastes.  The re-
 quirements are  intended  to prevent the
 formation of acid mine drainage and other
 adverse environmental  conditions,  and
 assure that  the mine site  is returned  to
 a condition  as good  or better  than before
 raining.  Monitoring  of surface water  and
 groundwater  is provided  in the regu-
 lations.   The Department of the Interior
 requires  the  posting of  a  bond to  provide
 the funds  to  reclaim lands  damaged by
raining operations, and has  the power  to
 shut down mine sites which  do not  comply
with  its regulations.
UMTRCA

     The Uranium Mill Tailings Reclamation
and Control Act requires the promulgation
of standards for the disposal of both
radioactive and nonradioactive mill tail-
ings at both active and inactive sites.
The standards are to be promulgated by
EPA, but the Nuclear Regulatory Com-
mission (NRG) is the enforcement au-
thority, through its permitting procedure
for uranium mining operations.
SPECIAL STUDY - MINING WASTE

Authority

     Section 8002(f) of RCRA requires
that EPA conduct a special study of the
wastes generated by the mining industry.
The requirements of this study are deline-
ated in the following excerpt from RCRA:

     "The Administrator, in consultation
     with the Secretary of the Interior,
     shall conduct a detailed and compre-
     hensive study on the adverse effects
     of solid wastes from active and
     abandoned surface and underground
     mines on the environment, including,
     but not limited to, the effects of
     such wastes on humans, water, air,
     health, welfare, and natural re-
     sources, and on the adequacy of
     means and measures currently employed
   «  by the mining industry, Government
   '  agencies, and others to dispose  of
     and utilize such adverse effects.
     Such study shall include an analysis
     'pf'.-,
          (1)  The sources and volume of
             ,  discarded material
               generated per year from
               mining;
          (2)  present disposal practices;
          (3)  potential dangers to human
 ,    ,         .health and the environment
               from surface runoff of
               leachate and air pollution
               by dust;
          (4)  alternatives to current
               disposal methods;
          ,(5)  the cost of those alter-
               natives in terms of the
               impact on mine product
               costs; and
          (6)  potential for use of dis-
               carded material as
               a secondary source of the
               mine product."
                                           192

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Scope of Study

     EPA's Office of Solid Waste (OSW)
requested that the Office of Research and
Development (ORD) help it conduct the
mining waste study required by Congress.
Due to the time constraints imposed by
Congress and the lack of available data
concerning these wastes, ORD was forced
to approach the problem at two different
levels.  Phase I consisted of an explor^-
atory investigation of 45 mining.sites, to
evaluate the solid waste disposal prac-
tices currently being utilized by the
mining industry.  Phase II is comprised
of a presurvey which included collecting
mine waste samples from 65 active and
abandoned mines and detailed environmental
evaluations at eight of these sites.


Phase I

     Phase I consisted of a survey of cur-
rent solid waste management practices.
The selection of the management practices
to be studied in Phase I was based on the
volume of solid wastes produced and their
potential for causing harm to the envi-
ronment .

     A Mine Solid Waste Coordinating
Committee (MSWCC) was established (con-
sisting of representatives from the EPA
Regions, the Office of Solid Waste,  Efflu-
ent Guidelines Division, the Office of
Research and Development, and other
Federal Agencies including the Bureau of
Mines, Geological Survey, Fish and Wild-
life Service and Soil Conservation Ser-
vice) to assist the Agency in selecting
the management practices to be evaluated
during the entire study.  The American
Mining Congress and the Interstate Mining
Compact Commission  also participated on
the commi'ttee in an advisory capacity.

     This committee nominated candidate
mines that utilized solid waste management
practices that were representative of the
industry.  EPA compiled the list and
selected forty five mines for final review
and selection.

     Based on information obtained from
published literature, interviews with
industry representatives, reports and
research of Federal and state agencies,
onsite visits to the forty five mines,
and information supplied by EPA, a listing
of types of management practices for the
 disposal  of solid  waste from mining and
 beneficiation processes was  derived.
 Management  practices  from the following
 industries  were  considered:

      1.   Metallic ore  mining and  ben-
          eficiation  (e.g.,  copper,  lead,
          zinc,  molybdenum,  gold,  and
          silver).

      2.   Phosphate ore mining and ben-
          eficiation

      3.   Uranium  mining

      The  evaluation of  each  practice was
 based upon  the following criteria:  (1)
 protection  of public  health  and welfare,
 (2) protection of  the quality of ground
 and surface waters from leachates,  (3)
 protection  of the  surface waters from
 runoff, (4)  protection  of air quality,
 e.g., from  fugitive dust,  (5)  and  aesthetr
 ics.

      Evaluation  of each of the practices
 was based on visual observation; dis<-
 cussions with the  mine  operator and regular
 tory  agencies; and  data available  from
 mine  operators,  literature,  and regulatory
 agencies.   No sampling  or analysis  of
 water, air,  or solid  waste was conducted.

      The results from this phase of the
 study provided input  to Phase  II and will
 also  be used in  the preparation of  the
 final report for the  entire  study.

 Phase-II -  Presurey

      Sixty  five mines were visited during
 the presurvey.  These sites  were selected
 from  a list  of candidate  sites suggested
 by the Mine  Solid Waste Coordinating
 Committee and  from  the  results of  the
 Phase I study.

     During  the presurvey, samples were
 collected from active,  inactive, and
 abandoned waste management practices.
 Depending on the specific  site surveyed,
 the following  residuals were  sampled and
 analyzed: mine waste,  which  included
 overburden,   waste rock, and  development
 rock; tailings, including  fresh tailings,
backfilled  tailings,  settled  solids,
water, and dike material  from  tailings
 ponds; low grade ore;  heap leach material;
mine pumpout water  and  settled solids
 from mine pumpout water; and  stockpiled
                                          193

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topsoil.  In addition, when waste mate-
rials of a certain type v?ere segregated
for disposal by separate waste management
practices (e.g., backfilled and surface
impounded tailings), each portion was
sampled separately.  The sampling pro-
tocol and the sampling equipment speci-
fied in the "Sampling and Analysis Manual",
prepared for this study and approved by
EPA, were used.  Over 400 samples were
collected from the 65 mine sites during
this sampling effort.

     A composite sample consisting of
five to ten subsamples and totalling
approximately ten pounds was collected
from each management practice sampled.
The subsamples were collected in a manner
which assured that the most representative
sample was obtained.  Typically, samples
were taken along a transect or from ran-
domly selected areas of the disposal
site.  There were exceptions made to the
sampling protocol due to physically lim-
iting factors such as extremely steep
slopes and flooded or unstable areas
which prevented the safe acquisition of
the samples.  In these instances the
selection of an appropriate sampling
method was left to the discretion of the
sampler. Subsamples were taken using an
aluminum hand scoop from a depth of one
foot; however, when physical limitations,
such a frozen ground, prohibited sampling
at this depth, the sample was taken from
a more shallow excavation. Material that
was too large to sample in this manner
was reduced to a more manageable size
with a crack hammer.  Samples were placed
in appropriately labeled one-gallon poly-
ethylene containers for subsequent ship-
ment.

     Samples of fresh tailings were taken
using a one-liter polyethylene bottle
attached to an extension pole or, if
possible, by filling the one-gallon sample
bottle directly from the mill discharge
or the tailings pond influent.  A minimum
of one gallon of sample was collected.
An additional gallon was collected if the
solids content of the tailings appeared
to be excessively low.

     Liquid samples from tailings ponds
or mine pumpout ponds were obtained by
compositing five to ten subsamples taken
along a transect across the pond when
possible or from the perimeter when a
transect was not possible.  Subsamples
were collected in two one-gallon poly-
ethylene containers and subsequently
homogenized and transferred to appro-
priately labeled smaller sample bottles
and preserved for subsequent analyses.

     Samples of settled solids were taken
at the same locations as the liquid sam-
ples from tailings ponds and mine water
pumpout ponds.  Samples were taken with a
core sampler, cork and bottle sampler, or
a scoop, depending on the consistency of
the solids.

     Duplicate samples were provided to
the mine site personnel on request.

Analytical Procedures

     Analyses were performed on the samples
both in the field and the laboratory.  Field
analyses included alkalinity, acidity,
conductivity, temperature, and pH, and
were conducted according to procedures
prescribed in "Methods for Chemical
Analysis of Water and Wastes," U.S.
EPA-600/4-79-020, March 1979.  Samples
for laboratory analysis were shipped to
the contractor's laboratory.  Subsequent-
ly, selected samples and aliquots of
samples were forwarded to subcontractor
laboratories for specific analyses.
Standard chain of custody procedures were
employed in all shipments.

     Solid samples were subjected to
total digestion, RCRA's Extraction Pro-
cedure (EP) toxicity test with acetic
acid, and RCRA's EP using deionized water.
Analyses for radionuclides were performed
on all solid and liquid samples from the
phosphate and uranium industries, on a
selected small population of solid samples
from the metal mining industries, and on
RCRA Extraction Procedure extracts when
the solid sample contained a significant
level of radionuclides.  Quality assurance
procedures approved by EPA were adhered
to for both the field and laboratory
analyses to .ensure both the precision and
accuracy of the results.

Summary of Results

     The results of the Phase II pre-
survey waste characterization study show
several important findings:
                                           194

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 Extraction Procedure Analysis

      •    As expected, a number of the
           waste streams analyzed exhibited
           elevated levels of 'certain
           parameters such as copper,
           lead, cadmium, selenium, and
           mercury.  However, the con-
           centrations of these parameters
           for the majority of the samples
           tested were considerably lower
           (in some cases less than detec-
           tion limits) in both the acid
           and water extracts.  In fact,
           no sample tested exhibited
           toxicity based on the results
           for deionized water extracts,
           and only 12 samples out of 300
           tested (4 percent) were judged
           toxic as a result of lead  con-
           centrations based on the re-
           sults for the acetic acid  ex-
           tract tests.   These results
           suggest  that in  a neutral  or a
           slightly acidic  environment,
          most  of  the mining wastes  tested
          have  a relatively low leacha-
          bility potential.

     •    Of  the 12  samples  tested in
          this  study  which  had  toxic
          extracts  from  the EP  test, 9
          were  tailings, 2 were mine
          waste, and  one was  settled
          solids from a mine water
          settling pond.
Radionuclide Analysis

     •    All liquid and solid samples
          collected from metal mining
          operations exhibit levels of
          radium 226 less than 5 pCi/g
          of solid sample and 50 pCi/1 of
          liquid sample.   Concentrations
          of radium 226 in the acid and
          water extracts  of these samples
          were  less than  1 pCi/1 of the
          extract.

     •    As expected,  levels of radium
          226 in wastes collected from
          phosphate mining operations
          were  higher  than the values
          recorded  for  samples from metal
          mining operations.   The levels,
          however,  were  still relatively
          low with   values  ranging  from
          0.1 to 25 pCi/g  of  the  solid
            samples,
       •    Levels of radium 226  in some of
           the samples collected from the
           uranium industry were elevated.
           Highest values were detected
           for settled solids from mine
           pumpout water ponds (most values
           ranged from 90 to 250 pCi/g)
           and low grade ore (values ranged
           from 37 to 150 pCi/g of sample).
           Samples of overburden and seg-
           regated mine waste exhibited
           much lower concentrations of
           radium 226.   Most values were
           within a range of 1  to 10 pCi/g
           of sample  and  no sample  exceeded
           50 pCi/g.

 Corrosivity  (pH)

      .    Copper  leach liquor was  the
           only sample  type  that  ex-
           hibited  the  characteristic of
           corrosivity.   Three samples of
           this material  were collected
           and the pH values of these
           samples ranged between 2.1 and
           1.9.

Phase  II - Comprehensive Monitoring

     Shortly after the completion of the
sixty  five site visits the comprehensive
monitoring program was initiated.  A
total of eight management practices were
selected for this phase of the study:

    •Florida phosphate combined  mine
     waste and clay slimes disposal—
     Agrico's Fort Green Mine.

    .Southwest copper tailings pond—Cyprus
     Pima's Pima Mine.

    •Southwest copper dump  leach—Kennecott
     Copper's Chino Mine.

    •South  Dakota gold  tailings pond—
     Homestake's Blackhills Mine.

    •Nevada gold tailings pond—Newmont's
     Carlin Mine.

   ..Missouri  lead tailings pond—St.
    Joe's Viburnum Mine.

   •New Mexico uranium mine water pond—
    Kerr McGee's Churchrock #1 Mine.
                                         195

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    •Idaho phosphate waste rock dump—
     Stauffer's Wooley Valley Mine.

     Specific research plans have been
developed for evaluation of each of the
waste management practices at these sites.
The plans include the design of the mon-
itoring system (air, surface water,
groundwater and climatological); sampling
methods, equipment, scheduling, and han-
dling; quality assurance procedures; mine
solid waste evaluation criteria; and data
handling and analysis procedures.

     Monitoring and sampling during this
phase of the study will continue for up
to a 12-month period, and samples will be
collected during four to six separate
sampling periods.  After the initial
sampling period at each site, the sam-
pling program may be modified due to the
absence of specific parameters, inappro-
priate sampling frequency, or other in-
adequacies of the initial site-specific
research plan.  Monitoring at each site
will include several or all of the fol-
lowing activities:

     Surface Runnoff and Seepage:  When
     flow is present, samples will be
     taken prior to exposure to solid
     waste material and after exposure to
     solid waste.  Inflow records will be
     maintained.

     Storm Event Runoff;  During storm
     events, runoff samples will be col-
     lected on an hourly basis.  Contin-
     uous flow measurements will be taken
     during the storm.

     Climatological Data;  A continuous
     record of precipitation, relative
     humidity, temperature, and wind
     direction and magnitude will be
     collected where appropriate.

     Groundwater Samples:  Representative
     samples will be collected from mon-
     itoring wells at a predetermined
     frequency.  A continuous record of
     water level will be obtained when
     appropriate and other tests will be
     performed when it is necessary to
     define groundwater movement.

     Solid Waste Samples:  At several
     sites, representative samples of
     solid waste will be subjected to the
     EPA EP extraction procedures and the
      extract will be analyzed.  Samples
      will be composited from core borings
      at each site and will be analyzed.

      Fish and Wildlife:  At selected
      sites a fish and wildlife-related
      assessment will be made.  This will
      include literature searches, compi-
      lation of properties of toxicity,
      mobility,  and/or bioaccumulation of
      selected materials, or the identifi-
      cation and elaboration of a specific
      situation of interest such as bene-
      ficial effect on fish and wildlife
      resulting from a specific waste
      management practice.
. CURRENT STATUS

      It is anticipated that all  of the
 monitoring stations will be in place  by
 the end of January 1982.   Sampling and
 analysis has been initiated at seven  of
 the sites and will be  completed  during
 the summer of 1982.  At the conclusion  of
 the comprehensive monitoring phase of the
 study,  a detailed final report will be
 prepared describing all the results of
 the mining solid  waste study.  EPA will
 use this data,  as well as  the  results
 from the studies  as  a  part of  a  final
 report  to Congress fulfilling  the  Agency's
 mandate under Section  8002(f)  of RCRA.
                                         196

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                      CHEMICAL TREATMENT OF PCBs IN THE ENVIRONMENT

                              .,.  .          bv •.'   '

                                    Charles J. Rogers
                          U.S. Environmental Protection Agency
                      Industrial Environmental Research Laboratory
                                 .Cincinnati, Ohio 45268


                                        ABSTRACT
      During  the  50  years  that  PCBs were manufactured  and  used  in  this country,  an esti-
 mated 400  million pounds  of 'these chemicals  entered the environment.  The primary sources
 of  PCBs  in the environment are the disposal  of waste  chemicals by consumer  industries
 and of the waste products of municipal treatment plants.   In recent years,  PCBs and
 other hazardous  chemicals have been discovered as contaminants at sites throughout the
 country. Conventional waste management methods cannot be  used,  in many cases, for in-
 situ  treatment of contaminated soils..

      The EPA has initiated studies to determine the efficacy of sodium polyethylene gly.co-
 lates (NaPEG) as reagents for  decomposing PCBs and other  halogenated materials  in the
 environment.  The overall objective of these studies  is to demonstrate that NaPEG, in
 less-than-stoichiometric  proportions, can be applied  as spray-on  reagents for treatment
 of  chemically contaminated areas.  This report summarizes research aimed at development
 of  NaPEG for the detoxification/destruction of halogenated chemicals in the environment.
 INTRODUCTION

     During the past ten years, newspapers
 and scientific journals have reported the
 discovery of discarded hazardous and toxic
 chemicals at sites throughout the country.
 In addition to these, the Environmental
 Protection Agency  (EPA) has identified a
 group of materials that have been manu-
 factured on a large scale during the past
 several years and that are now known to be
 harmful to living organisms, to be resistant
 to biodegradation and to accumulate in the
 food chain.  Because of their toxicity,
 some of these materials have been removed
 from the marketplace.  These materials
must now be detoxified or disposed of in
an environmentally acceptable manner.  A
partial list of priority chemicals
scheduled for detoxification includes
aldrin, kepone, benzidine, DDT, dieldrin,
dioxin-contaminated materials (2,4-D,
2,4,5-T), endrin, and polychlorinated bi-
phenyls (PCBs).  Many of the current dis-
posal methods are not adequate for environ-
mental control of  these chemicals.  Efforts
are  therefore underway to develop effective
treatment methods.
Disposal of PCBs

     PCBs are .among the most widespread
synthetic-chemical contaminants in the
environment.  During the 50 years that PCBs
have been manufactured and used in this
country, more than 400 million pounds of
these chemicals have;entered'the environment.
The primary sources of PCBs in the environ-
ment are the disposal of wastes by consumer
industries and disposal of the products in
municipal treatment plants.  Several dis-
posal practices have contributed to environ-
mental contamination (Figure 1):

•  Open burning,or incomplete incinera-
   tion of municipal and industrial
   waste.
                                          197

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                                 §
                                S
                                o
                                Ji
                                g
                                §
                                S

198

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 «   Discharge of  PCB-containing  fluids
     into waterways with municipal  and
     industrial water effluents.

 •   Dumping of sewage  sludge,  solid waste,
     and sludge spoils  at  sea and into
     sanitary landfills or dumps.  (2)

     There  is general agreement that atmos-
 pheric transport is  the major  mode of
 global dispersal of  chlorinated  aromatic
 compounds  such  as pesticides  and PCBs.
 The compounds are volatilized  into the
 atmosphere and  can be  carried  thousands
 of miles  from the original  source, either
 vaporized  or adsorbed  onto  dust  particles.
 Pesticides and  PCBs  have  been  found in
 ice samples collected  in  Arctic  and Ant-
 arctic regions.  (3)

    Mason and Hanger (4)  report  that vent
 gas from an ordinary landfill  site near
 Chicago contained 3240 ng/m3 of  PCBs.
 Also,  air  samples taken by  the New York
 Department of Environmental Conservation
 from an uncontrolled dumpsite  north of
 Albany showed PCB concentrations of 300,000
 ng/m3.  Studies by Eisenreich,  (5)  Murphy,
 (6)  and Bidleman  (7) have confirmed that
 precipitation events (rain  and snow) are
 the means  of net  transfer of PCBs  from
 the atmosphere to large bodies of  water.
 Volatilization of PCBs is the  principal
 reason for  concern over the use  of land-
 fills  or lagoons  for ultimate  disposal  of
 waste  PCBs or PCB-contaminated materials.

 Current PCB Waste Management Practices

     The chemical stability of PCBs pre-
 cludes their destruction by conventional
 refuse incineration methods. (8)   Most
 municipal  incinerators cannot  achieve the
 high temperatures necessary to destroy
 PCBs in refuse.    The surprisingly  high
 volatilization rates of PCBs and other
 chlorinated aromatic compounds raises
 questions over the use of land disposal
 for  these materials.    Further, many land-
 fill disposed PCBs may be recovered and
 destroyed by chemical  treatment or high
 temperature incineration in the  future.

     Currently,  some commercial chemical
 and physical methods are used  to chemically
 alter or remove PCBs in PCB-contaminated
oils.  These methods include an adsorption
 system developed  by RTE Corporation.  The
chemical methods, developed by Acurex,
Goodyear,  and SunOhio,  involve dispersion
of metallic sodium in oil or the use of
 sodium-biphenyl or  naphthalene mixtures.
 Because of  the reactivity of  sodium with
 water, these  reagents cannot  be  used effi-
 ciently to  decompose PCBs in  soils, sludges,
 and  sediments, and  dredgings.

     Biological treatment of  PCBs and other
 hazardous pollutants is  also  receiving
 attention.  Cytox,  Flow  Laboratories, and
 Sybron Biochemical  are some of the  companies
 marketing strains of bacteria that  report-
 edly degrade  PCBs and other hazardous pollu-
 tants.

     Although it has been demonstrated that
 biological  systems  can decompose phenols,
 fats, waxes and other organics, many skeptics
 remain unconvinced  that  microorganisms can
 reliably decompose  highly chlorinated iso-
 mers of PCBs  or other highly  halogenated
 pollutants.

 New  Dehalogenation  Reactions

     Scientists at  the Franklin Research
 Institute began a'study  3 years ago to
 devise a reaction system that would lead to
 the  cleavage  of carbonhalogen bonds.  Such
 a reaction  must be  rapid, complete, exo-
 thermic, and  self-sustaining.  After exten-
 sive study, the investigators have  identi-
 fied a promising chemical reagent for this
 purpose, prepared from sodium, polyethylene
 glycols, and  oxygen.  The EPA is supporting
 further research, which  has been broadened
 to explore  application of dehalogenation
 reagents for  treatment of soils and lake
 sediments as  well as oils contaminated with
 PCBs or other halogenated compounds.

     Typically, the dehalogenation reagent
 is prepared by reaction of 60 grams of
 sodium with 1.0 liter of polyethylene glycol
with an average molecular weight of 400.
The molar ratio of sodium to solvent should
be 1.1:1.0.   About one-half hour after the
sodium has melted,  the NaPEG reagent prepa-
ration is complete.

     An important feature of the NaPEG
reagent is that dechlorination can be readily
controlled by several parameters:

•    Temperature:  high temperature  favors
     rapid and complete dechlorination.

»    Reactivity:  addition of  water  increases
     reaction  times  and reduces the  degree
     of dechlorination.
                                          199

-------
 •    Concentration of 02:  dehalogenation
     can be stopped at any time by elimi-
     nating 02 from the system.


 •    Quantity of NaPEG reagent:  excess
     sodium or other cation ions must be
     present to react with liberated halo-
     gens.

     Kinetic studies have been conducted on
 the model compound, 1,3,5-trichlorobenzene,
 using  6% by weight of the reagent.   In  all
 cases,  the dechlorination rate was  first
 order  with respect to the chlorinated
 compound.  (9)

     Also, a kinetic study of the dechlori-
 nation of dichlorobiphenyl  (DCS) was carried
 out at a single temperature,  59°C.   When
 DCS was treated with the NaPEG reagent, the
 ficst-order kinetic rate constant was
 0.1396 rain"1, with a correlation coefficient
 of 0.9874.  After 1 hour, the reaction
 ceased completely.  At that point,  approxi-
 mately 30% of the DCS added to the  reaction
 system had been dechlorinated.

     Pytlewski (9)  has proposed mechanisms
 for dechlorination using NaPEG.
MECHANISMS

     The mechanisms proposed by Pytlewski
involve nucleophilic substitution and
oxidative dehalogenation of halo-organic
compounds.  Alkoxides and hydroxides are
potent nucleophiles that can dehalogenate
even the least activated halogenated aro-
DMtic compound.  (10)

     Hydroxide and alkoxide ions displace
halides of  halogenated  aromatics  to yield
phenols and aromatic ethers,  respectively.
The  two reactions  that  take place are  as
follows:
     AR-X   +   OH"  	

  Arylhalide   Hydroxide
     AR-X   +  RO-

          Alkoxide
  AR-OH  +
           X
Arylhydroxide

      +  halide

 AR-OR  +  X~

Arylether
    The displacement of a chloride ion f
a chlorinated aromatic structure  (i.e.,
PCBs)  is rapid only  if the reagent such as
peroxide, hydroxide, alkoxide, or glycoxide
is in  the same phase as the aromatic sub-
strates.  The NaPEG  reagents are miscible
with halogenated aromatics in general and
possess activated nucleophilic groups
(RO~, NaO2> capable of displacement of un-
activated as well as activated halides under
realtively mild conditions.

     The important component   of the  NaPEG
reagent is the sodium salt of long chain
polyethylene glycols.  As proposed, the
sodium cation is complexed by the long chain
polyethylene glycol as shown in  (Figure 2).
Activation of the terminal alkoxide group
is due to the lack of ion pairing and anion
solvation.  The alkoxide group is associated
with electron abstraction from atmospheric
oxygen, and in the generation of nucleo-
philes.  The free radical signals of the
superoxide ion in NaPEG have been measured
by Electron Spin Resonance in concentrations
of 10~3 M.

     Roberts  and  Sawyer  (11)  report the
degradation by superoxide ion of carbon
tetrachloride, chloroform, methylene chlor-
ide, and p,p,-DDT in aprotic media.  They
describe the overall reactions as multi-
step processes and discuss the reactant
product stoichiometry.

     By-products  of the  reaction are  salts
and hydroxylated biphenyl derivatives.
Ongoing NaPEG studies will attempt to demon-
strate that less-than-stoichiometric
proportions of NaPEG can be applied to clean
chemically contaminated facilities, soils,
and other materials.  Specifically, the
studies will attempt to demonstrate that
the removal of one Cl~ is all that is re-
quired for subsequent degradation of the
hydroxylated structure by naturally present
soil microorganisms.

Applications of NaPEG Reagents

     In laboratory studies, NaPEG reagents
reduced PCS concentrations of dielectric
fluid from 1000 ppm to less than 1 ppm and
in soils from 1000 to 481 ppm. (9)  Con-
ceptually, since NaPEG dehalogenation
mechanisms are not based on a dispersed
metallic sodium reaction, the reagent can
be used to treat contaminated soils,  dredg-
ings, sediments,  and low-moisture sludges to
remove organohalogens./
                                           200

-------
     A proposed procedure is being evaluated
 for  treatment of low-moisture 15-20% PCB-
 contaminated waste.   In  two. established
 experimental studies  at  Appleton, Wisconsin
 and  Coventry, Rhode Island, soil contaminated
 with PCBs  (42 to 200  ppm) is spread over a
 heat-adsorbent liner  (PVC)  to a depth of 12
 inches.  The NaPEG reagents, which are very
 viscous,  are diluted  with isopropyl  alco-
 hol, and  sprayed  in less-than-stoichiometric
 proportions  (0.5 M NaPEG/1.0 M PCBs) onto
 the  contaminated  soils.

     Soil samples including controls and a
 standard  (approximately  200 ppm) are taken
 before treatment and  at  intervals of 15,
 30,  60, 90, and 180 days  after treatment.
 The  treated areas are covered with a liner
 throughout the study  to prevent the intro-
 duction of excess water  from rain or snow
 precipitation.   It is hoped that this in-
 vestigation, scheduled for completion in
 June 1982, will prove the method to be more
 cost-effective for PCB control than conven-
 tional decontamination procedures such as
 incineration or containment.
CONCLUSION

     Conventional chemical treatment of halo-
genated compounds necessitates the exclu-
sion of moisture and air from the reaction.
Detoxification of PCB-contaminated soils
and sediments by conventional methods would
be extremely costly and cumbersome, parti-
cularly on a commercial scale.  A new
chemical reagent has been developed in the
laboratory that requires oxygen and toler-
ates low amounts of moisture which could
facilitate treatment.  A reactive reagent
is prepared from sodium, polyethylene gly-
cols, and a continuous supply of oxygen.
In laboratory studies, the NaPEG reagents
have successfully reduced the PCB level of
contamianted oils and soils from 1000 ppm
to less than 1 ppm.  The continued success
of ongoing field and laboratory studies
could lead to a -viable method for destruc-
tion of PCBs, chlorinated pesticides,
dioxins, and other toxic organohalogens
dispersed in the environment.
REFERENCES

1.   Nisbet,  I.D.T.  and A.  F.  Serafim,  "Rates
     and  Routes  of Transport of  PCBs  in the
     Environment," Environmental Health
     Perspectives, Exp. 1,  21-28,  1972.
                                                2.
7.
8.
9.
10.
                                               11.
     Fuller,  B.,  J.  Gordon,  and M.  Korn-
     reiches, "Environmental Assessment of
     PCBs in  the  Atmosphere".  U.  S.
     Environmental Protection Agency,
     Contract No.  68-02-1495, Mitre Corpor-
     ation, April 1976.

     Mackay,  Donald  and  Aaron W. Wolkoff,
     "Rate of Evaporation of Low-Solubility
     Contaminants from Water Bodies to
     Atmosphere",  Environmental Science and
Technology, 7, p. 611  (July 1973).

Mason and Hanger-Silas Mason Co., Inc.,
Lexington, KY.  "Volatilization of PCBs
During Palnned Waukegan Harbor Cleanup
Operations", submitted to U. S. EPA,
Region V, Chicago, IL, May 1981.

Eisenreich, Steven J., Brian B. Looney,
and David Thornton, "Airborne Organic
Contaminants in the Great Lakes Eco-
system" , Environmental Science and
Technology, 15, p. 30  (January 1981).

Murphy, Thomas J. and Charles P.
Rzeszutko, "Eolychlorinated Biphenyls
in Precipitation in the Lake Michigan
Basin".  U.S. EPA, Duluth, Minnesota,
EPA 600/3-78-071 (1978).

Bidleman, T. F., C. P. Sice  and C. E.
Olney, "High Molecular Weight Hydro-
carbon in the Air and Sea:  Rates and
Mechansism of Air/Sea Transfer".
Marine Pollutant Transfer, published
by Lexington Books, D. C. Hearth and
<3o. ,  Lexington, MA.

Gustafson, C. G., "PCBs-Prevalent and
Persistent", Environmental Science and
Technology, £, 10, 814-819, 1970.

Pytlewski, Louis, "A Study of the
Reaction of Molten Sodium and Solvent
with PCBs", EPA Grant R806649, March
1979.

Bunnett, J., "Aromatic-Nucleophilic
Substitution," Chemical Review, 49,
273-412  (1951).

Robert, J. L. Jr., Sawyer, D. T.,
(Dept. of Chemistry, University of
California, Riverside, CA), "Facile
Degradation by Superoxide Ion of Carbon
Tetrachloride, Chloroform, Methyl-
chloride, and  ,p-DDT in Aprotic Medic,"
Journal of American Chemical Society,
103: (3):712-714.
                                           201

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                DESTRUCTION OF HAZARDOUS WASTE USING SUPERCRITICAL WATER
     Michael Modell, Gary G. Gaudet, Morris Simson, Glenn T. Hong and Klaus Biemann
                                      MODAR, Inc.
                              Natick, Massachusetts 01760
                                        ABSTRACT
     MODAR has developed a new process that is capable of destroying highly toxic wastes
with efficiencies of greater than 99.99%.  The process uses supercritical water as the
processing medium for oxidation.  The organic components of the waste are converted to
carbon dioxide and water with potential recovery of the heating value; inorganic
components are separated out as solid salts, which can be reused or discarded safely;
water in aqueous waste is recovered in a highly purified form, which can be reused
without further treatment.  The wastes are treated in an enclosed system so that escape
of pollutants to the environment is eliminated.  Furthermore, there is a minimal number
of processing steps so that the capital investment compares very favorably with
alternative processes.  The most significant feature of this new approach is that it can
be cost-effective.  When the organic content of the waste,is 5% or more, the process is
capable of generating sufficient net power to cover the entire cost of waste treatment.
INTRODUCTION
     The MODAR process is based, in part,
on a discovery made in 1975 by Modell and
co-workers at M.I.T.  In the course of
investigating the effects of treating
aqueous solutions of organics at high
temperatures and pressures, it was found
that complex organic substances can be
dissolved and broken down into low
molecular weight products when treated
under conditions where water is
supercritical (i.e., above 374°C and
218 atra).  The discovery is the basis of
U.S. Patent No. 4,113,446 [Modell, ^t
al. (7)J, originally assigned to M.I.T.
and now exclusively licensed to MODAR.

     In 1979, Modell carried this work
one step further.  He proposed a new
method of destroying wastes by dissolving
both organic material and oxygen in
supercritical water (SCW), and then
carrying out the oxidation in the
supercritical water medium.  MODAR was
formed in 1980 to develop and
commercialize this new SCW oxidation
process.  The SCW oxidation process has
been reduced to practice with outstanding
technical results.  In addition,
preliminary economic analyses indicate
that the process is potentially much less
expensive in both capital and operating
costs when compared to high temperature
incineration.
TECHNICAL CONCEPTS
     In the supercritical region, water
exhibits properties that are far
different from normal liquid water  [see,
e.g., Franck (3)].  The density of,
supercritical water (0.05-0.5 g/cm  ) is
low enough and the temperature high
                                            202

-------
enough to essentially eliminate hydrogen
bonding [Franck (4)].  As a result, the
dielectric constant is diminished to
about 3 to 10 and water becomes an
excellent solvent for organic substances
[Connolly (2)].  At somewhat higher
temperatures (above 500°C), the
density of water is reduced to 0.05 - 0.1
g/cm  and the dielectric constant is
less than 2.  Under these conditions,
inorganic salts become only sparingly
soluble [Martynova (6)].  Salts such as
NaCl act as weak electrolytes with
little, if any, dissociation into ions
[Marshall (5)].  Thus, the solubility
characteristics of supercritical water
are the inverse of those of normal  liquid
water.

     Above 350°C, water reacts with
organic materials in a way that leads to
the formation of low molecular weight
products [Amin  (1)].  Whereas many
organic compounds tend to form a high
molecular weight char at temperatures
below 350°C, at supercritical
conditions the  same organics are reformed
to gases (e.g., CO, H   CH,, CO-)
and volatile organic liquids (alcohols,
aldehydes, furans) without producing any
char.

     The products of SCW reforming  can be
subjected to oxidation while still  under
supercritical conditions.  It is well-
known that aqueous solutions of organics
will undergo oxidation at temperatures of
200 to 300°C.   This phenomenon is the
basis of the conventional wet oxidation
or Zimpro process, which is operated
under subcritical conditions [see,  e.g.,
Wilhelmi and Knopp (8)].  The wet
oxidation process requires residence
times of 20 minutes to 1 hour to achieve
destruction efficiencies which are, at
best, mediocre  (70 to 95% reduction in
total organic carbon).  On the other
hand, under supercritical conditions, the
residence time  required for oxidation is—
less  than 1 min, which greatly reduce"!
the volume of the oxidizer vessel.  In
addition, oxygen is completely miscible
with  supercritical water,—-aad"tfie        —
oxidation can be,conducted under
homogeneous  (i.e., single phase)
conditions.  Thus, oxidation under  SCW
conditions is an efficient means of
ultimate disposal of organics.
      When toxic  or hazardous  organic  ,
 chemicals are  subjected to SCW oxidation,
 carbon is converted to CO- and hydrogen
 to H.O.   The chlorine atoms from
 chlorinated organics are liberated as
 chloride  ions.   Similarly, nitro-
 compounds can  be converted to nitrates,
 sulfur to sulfates, phosphorus to
 phosphates, etc.  In other words, hetero-
 atoms form oxy-acid anions.  Upon
 addition  of appropriate cations (e.g.,
 Na  ,  Mg  , Ca   ),  inorganic salts
 can  be formed.

      Finally,  when the concentration  of
 organics  is above 5 wt%, the  heat of
 oxidation is sufficient to bring the
 supercritical  stream to temperatures  in
 excess of 550°C.  At these conditions,
 inorganic salts  have extremely low
 solubilities  in  water.  Inorganic salts
 will be precipitated out and  readily
 separated from the aqueous phase.  After
 removal of inorganics, the resulting
 aqueous phase  is a highly purified stream
 of  water  at high temperature  (>500°C)
 and  high  pressure (3700 psia).  It can  be
 used as a source of high-temperature
 process heat or  fed to conventional
 supercritical  steam turbines  for
 generating power.
 PROCESS DESCRIPTION
      The MODAR system for hazardous waste
 destruction makes use of water in its
 supercritical state (SCW) as the process
 medium for carrying out the destruction
 of organic materials by oxidation.  Key
 to the success of the process is the fact
 that organic substances and gases,
 including oxygen, are completely soluble
 in SCW,  whereas inorganic salts exhibit
 greatly reduced solubilities under
 process conditions.  Thus., it becomes
 conceptually possible to carry out
 "-combustion" reactions by dissolving
 organic substances and oxygen in SCW,
 bringing them into intimate contact in a
_jsiogle-phase "medium.  The temperatures
 and molecular densities allow the
 conventional oxidation reactions to
 proceed rapidly and essentially to
 completion.  In fac.t, one might expect
 these conditions to be more favorable for
 carrying combustion reactions to
                                           203

-------
completion than those of conventional
incineration processes, where
volatilization and mass transport of
reaction species are limiting factors.
Furthermore, the reduced solubility of
salts makes possible the direct removal
of undesirable reaction products through
precipitation.

     A schematic flowsheet for the MODAR
process described above is given in Fig.
1.  The process consists of the following
steps:

(1)  The toxic or hazardous waste is
     slurried with make-up water to
     provide a mixture of about 5 to 10
     wtZ organics.  The slurry is
     pressurized and heated to
     supercritical conditions to avoid
     char formation.  Heating is attained
     by mixing the feed with superheated
     SOW, which is generated in a
     subsequent step.  During a short
     residence time in the tube leading
     to the oxidizer, organics in the
     feed are converted to combustible
     gases, low to intermediate molecular
     weight compounds (furans, furfurals,
     alcohols, aldehydes) and inorganic
     salts.

(2)  Air or oxygen is pressurized and
     mixed with the feed.  Since the
     water is still supercritical, the
     oxidant is completely miscible with
     the solution (i.e., the mixture is a
     single, homogeneous phase).
     Organics are oxidized in a
     controlled but rapid reaction.
     Since the oxidizer operates
     adiabaticallyf the heat released by
     combustion of readily oxidized
     components is sufficient to raise
     the fluid phase to temperatures
     where all organics are oxidized
     rapidly.  For a feed of 5 wt%
     organics, the heat of combustion is
     sufficient to raise the oxidizer
     effluent to at least 550°C.

(3)  The effluent from the oxidizer is
     fed to a salt separator, where
     inorganics originally present in the
     feed are removed as a solid slurry.
     At 500°C and above, the
     solubility of inorganics in SCW is
     extremely low.
 (4)  A portion of the superheated SCW is
     recycled to an eductor upstream of
     the SCW oxidizer.  This operation
     provides for sufficient heating of
     the feed to bring the oxidizer
     influent to supercritical
     conditions.

 (5)  The remainder of the superheated SCW
     (with some CO- and N2) is
     available for power generation or
     use as high-pressure steam.  A
     portion of the available energy is
     used to generate the power required
     to pressurize feed and oxidant.
     Note that the energy required to
     pressurize the oxidant is recovered
     in the expansion of the products of
     combustion in the superheated SCW
     turbine.  Thus, the method of
     oxidation is analogous to that of a
     gas turbine.

     As a waste destruction process, the
MODAR concept has several advantages over
conventional processes.  The chemical
reactions which occur are carried out in
a closed system, making it possible to
maintain total physical control of waste
materials from storage, through the
oxidation process, to the eventual
discharge of the products of combustion,
and any associated wastes.  This feature
provides positive assurance of
environmental protection.  In addition,
bench-scale results indicate essentially
complete destruction of chemically stable
materials (such as PCB's) at projected
costs which are well within those
presently associated with hazardous waste
operations.  Finally, the process can be
adapted to a wide range of feed mixtures
and scales of operation.  Skid-mounted,
transportable systems are being designed
as well as larger-scale stationary units.
EXPERIMENTAL
     Under the joint sponsorship of the
U.S. Army Medical Bioengineering Research
and Development Laboratory (USABMERL) and
EPA's Office of Research and Development,
MODAR conducted a series of experiments
to demonstrate the technical feasibility
of the SCW oxidation process.  A
                                           204

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                                                    to
                                                    o

                                                    Q_

                                                    z
                                                    o


                                                    <
                                                    X
                                                    o
                                                    o
                                                    s:

                                                    LU
                                                    o
                                                    CO
205

-------
continuous flow bench-scale system with
an organic throughput of 1 gallon per day
was used for these tests.  The reactor
was constructed from Hastelloy C-276,
with an i.d. of 0.88 in. and a length of
2 ft.  The reactor effluent was cooled to
room temperature and depressurized to 1
a tin.  Liquid effluents were analyzed for
total organic carbon (TOG), pH, and by
ion-selective electrodes and gas
chromatography/mass spectrometry (GC/MS).
Gaseous effluents were analyzed by gas
chromatography (GC) for low molecular
weight hydrocarbons and permanent gases.
The terminology used to describe the
results is given in Table 1.

     Since the GC/MS analysis of liquid
effluents is of particular importance,
some details will be described.  Liquid
effluent samples were first extracted
with dichlororaethane and then
concentrated in a Kuderna-Danish
apparatus.  One tnicroliter of this
solution was injected into a stand-alone
gas chromatograph and an appropriate
aliquot (1-2 ul, dependent on the
concentration of the solution as judged
from the GC experiment) injected into the
GC/MS system.  A Varian 3700 gas
chromatograph, equipped with flame
ionization detector and automatic
integrator, was used for stand-alone GC
analysis.  Columns were 15 m fused quartz
coated with either SE-30 or SE-52.
Another Varian 3700 gas chromatograph was
coupled to a Varian-mat 212 double
focusing mass spectrometer via an
open-split interface.  The conditions on
the gas chromatograph were the same as on
Che corresponding stand-alone GC run.
The mass spectrometer was scanned from
M/Z of 30 through 500 at cycle times
ranging from 2.0-2.8 seconds.  The
resolution of the mass spectrometer was
set to 1:1000.  The GC/MS was interfaced
to a Varian-mat SS-200 data system.  This
computer contains all the mass
spectrometry data processing and
evaluation programs developed at M.I.T.
over the years.  The data were searched
for compounds of interest either by
inspection of the mass spectra at
GC-peaks in the proper retention areas or
by plotting mass chromatograms of the
characteristic masses of the compounds
(e.g., M/Z of 154, 188, 222, 256, 290,
324, 358, 392 and 426 for biphenyl
through octachlorobiphenyl), followed by
inspection of the mass spectra at these
maxima.

     Alternatively, selected mass spectra
were compared with the NIH/EPA/MSDC mass
spectral library or automatically
microfilmed for easier visual inspection.

     As a search for tetrachlorodioxins
and tetrachlorodibenzofurans, the mass
chromatograms of M/Z 320 and 304,
respectively, were plotted and the mass
spectra at any maximum in the plot were
inspected for the characteristic M/Z 320,
322, 324, 326, 328 pattern (304, 306,
308, 310, 312 for TCDF).  If found, the
entire spectrum would be compared to the
authentic spectra.

     After identification of the
components of interest, their
concentrations were estimated from the
stand-alone GC trace.  Peak heights were
determined and converted to nanograms
using known amounts of naphthalene,
methyl naphthalene and phenanthrene for
the estimation of aromatics and the
phthalates, and 4,4'-dichlorobiphenyl for
the PCB's and other aromatic chlorinated
compounds.
RESULTS AND DISCUSSION
     MODAR has conducted an extensive
series of bench-scale tests to establish
the technical feasibility of SCW
oxidation.  A typical series of tests
with organic chloride feeds is described
herein.

     The feed materials and compositions
for each run in this series are given in
Table 2.  Chronologically, we began this
series with a model compound, DDT, and
progressed to more complex mixtures.

     A summary of the results for this
series is given in Table 3.  Note that
the compounds identified by GC/MS
analysis are identified by letters at the
bottom of Table 3; the structures are
given in Table 4.  Using the methods
described in the prior section, the mass
spectra were searched for each of the
compounds shown in Table 4; only those
found in one experiment or another are
                                            206

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                             TABLE 1.  DEFINITION OF TERMS
Residence Time
Volume of reactor divided by volumetric flow rate of
process fluid.
Organic Carbon In (ppm)
Carbon content of organic/water feed mixture as it
enters the reactor.
Organic Carbon Out (ppm)
Total carbon in liquid effluent after sparging or
total carbon minus inorganic carbon.
Destruction Efficiency
(Organic Carbon In - Organic Carbon Out) x 100
       Organic Carbon In
Combustion Efficiency
[C02/(C02 + CO + CH4)] x 100
concentrations in the effluent vapor, as measured by
GC analysis.
Organic Chloride In (ppm)
Chloride content of organic/water feed mixture, as
it enters the reactor.
Organic Chloride Out (ppm)
Residual organic chloride as determined by GC/MS.
Organic Chloride Conversion
(Organic Chloride In - Organic Chloride Out) x 100
       Organic Chloride In
                                                                             =====3=:=:==:=:=:
                                          207

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TABLE 2.  COMPOSITION OF FEED MIXTURES FOR RUNS 11-15

Run 11
DDT
MEK

Run 12
1,1, 1-trichloroethane
1,2-ethylene dichloride
1,1,2, 2-tetrachlorethylene
o-chlorotoluene
1 ,2,4-trichlorobenzene
biphenyl
o-xylene
MEK

Run 13
hexachlorocyc lohexane
DDT
4,4'-dichlorobiphenyl
hexachlorocyclbpentadiene
MEK

Run 14
PCB 1242
PCB 1254
transformer oil
MEK

Run 15
4,4' -dichlorobiphenyl
MEK

C14H9C15
C H 0
4

C2H3C13
C2H2C12
c2ci4
C7H7C1
C6H3C13
C12H10
C8H10
C H 0
4 8
C6H6C16
G14H9C15
C12HgCl
c5ci6
C,HR0
4- 0
C12HXC14-6
C12HXC15-8
C10-C14
C,HaO
4 8
C12HaCl
C,HQ0
wt %
4.32
95.68
100.0

1.01
1.01
1.01
1.01
1.01
1.01
5.44
88.48
100.0
0.69
1.00
1.57
0.65
96.09
100.0
0.34
2.41
29.26
67.99
100.0
3.02
96.98
wt % Cl
2.133
-
2.133 ,

0.806
0.739
0.866
0.282
0.591
-
-
-
3.284
0.497
0.493
0.495
0.505
-
1.99
0.14
1.30
-
-
1.44
.96
.
                         208

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              TABLE 3.  SUMMARY OF RESULTS:  OXIDATION OF ORGANIC CHLORIDES
Run No.
Residence Time (min)
11

1.1
12.

1.1
13

1.1
14

1.1
15

1.3
Carbon Analysis

Organic Carbon In (ppm)
Organic Carbon Out (ppm)
Destruction Efficiency (%)
Combustion Efficiency (%)

Gas Composition
26,700.
2.0
99.993
100.
25,700.
1.0
99.996
100.
24,500.
6.4
99.975
100.
38,500.
3.5
99.991
100.
33,400
9.4
99.97
100.
                                      25.58
                                      59.02
          32.84
          51.03
          37.10
          46.86
          10.55
          70.89
          19.00
          70.20
Chloride Analysis

Organic Chloride In (ppm)             876.      1266.     748.      775.      481.
Organic Chloride Out (ppm)            .023      .037      <.028     .032      .036
Organic Chloride Conversion (%)       99.997    99.997    99.996    99.996    99.993

GC/MS Effluent Analysis

Compound B (ppb Cl)                   -         -    •     -         -         -
         C                            _____
         E                            -          9        -         14
         F                            18        12        18.       -
         H                            -         -         <4.       -         -
         K                             5        16        <5.        6
         M                            -         -          0.2      -
         N                           '-                    0.3      -         36
         0                                                          12
                                          209

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A:
 B:
 C:
                 TABLE 4.     COMPOUNDS SEARCHED  BY GC/MS ANALYSIS
                                                                CHC1
                                               I:
Cl
                Cl -     \
                            CHO
            CO - CH3
                                               J:
 D:
 Cl
                             COOH
                                              L:
                                                        Isomer of I.
 E:
                    Cl         M:    Cl
   :    Cl
 G:
 H:
                              N:     Cl
                              O:
                              P:
       Notes: p-Isomers are assumed, based on the position
             of the chlorine atoms in the starting materials.
         Compound F - No authentic MS
         Compound G - No MS available in literature
                                        210

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 given in Table 3.  In other words,
 compounds A,D,G,I,J,L and P were not
 present in the test results shown in
 Table 3.  It should be especially noted
 that chlorinated dibenzo-p-dioxins were
 never found in any of our effluents.
 even though the mass spectra were
 specifically searched for them.

      The results of run 11, as shown in
 Table 3, are representative of one of our
 most important findings:  organic
 chlorides can be destroyed by SCW
 oxidation with efficiencies above 99.99%.
 In run 11,  both carbon destruction
 efficiency and organic chloride
 conversion exceed 99.99%.

      The feed for run 12 consisted of a
 mixture  of five organic chlorides (see
 Table 2),  two of which were aromatic
 chlorides  (o-chlorotoluene and
 1,2,4-trichlorobenzene).   Once again,  the
 carbon destruction efficiency  exceeded
 99.99%.   The organic  chloride  conversion
 is  99.997%.

      It  should  be noted that chlorinated
 compound K,  which is  DDE  (see  Table  4),
 was  found  in the  liquid effluent  of  run
 12,  although the  concentration was minute
 (16  ppb).   It is  extremely difficult to
 accept the  hypothesis  that the DDE was
 formed by  reaction or  rearrangement  of
 any  of the  chlorinated  organics in the
 run  12 feed.  We  are more  apt  to  believe
 that  we  had  cross-contamination of
 samples  from the  low pressure,  room
 temperature  portion of  our bench  scale
 system.  To  prevent cross-contamination,
 an acetone wash system was later
 installed.

      The feed for  run 13 was a mixture of
 four  non-volatile  chlorinated  organics,
 including hexachlorocyclohexane (Lindane)
 and 4,4'-dichlorobiphenyl  (a model PCB
 compound), both of  which should be
 relatively stable.  As shown in Table 3,
 the carbon destruction and chlorine
 conversion efficiencies were very good,
 the latter being somewhat  higher  than the
 former.

     The feed for run 14 was a mixture of
 spent transfomer oil,  containing  two
PCB's, which was diluted with MEK.  Once
again, both carbon destruction and
chlorine conversion exceeded 99.99%.
 Note that the residual organic chlorides
 identified by GC/MS  (compounds E,K and 0)
 are all DDT-related  species.  Thus, those
 trace quantities are probably cross-
 contaminants from run 13.  It should also
 be noted that for run 14, mass spectra
 were searched for all chlorinated
 biphenyls.  That is, we specifically
 looked for trace quantities of tri-,
 tetra-, penta- and hexa-chlorobiphenyl,
 in addition to the mono- and di-chloro
 species (compounds M and N in Table 4).
 At the detection limit of < 10 ppb, none
 of these chlorinated biphenyls were
 found.   If we discount compounds E,K and
 0 as cross-contaminants, then the
 chlorinated biphenyl conversion
 efficiency is >99.9994%.

      Run 15 was an experiment with a
 model PCB,  4,4'-dichlorobiphenyl.  The
 results obtained in run 15 were once
 again excellent.
 CONCLUSION
      The  present  results  indicate that
 SCW oxidation gives  essentially complete
 destruction of refractory organic
 compounds in residence  times  on the  order
 of  1  min.  As shown  in  Table  5,  a broad
 spectrum  of organic  materials  have been
 tested; the results  are similar to those
 described above.   In general,  the SCW
 oxidation is non-specific.

      Although not  demonstrated  here, the
 process has  other  advantages which make
 it  an excellent means of  hazardous as
 well  as non-hazardous waste disposal.
 Auxiliary pollution  control equipment  for
 effluent  streams is  unnecessary.   The
 process is  applicable to  wastes  in the
 form  of liquids, solids,  or sludges.   It
 is  particularly applicable to aqueous
 waste streams  containing  mixtures  of
 organic and  inorganic materials, with
 inorganics being recovered as a  solid.
Upon  removal  of inorganic compounds,  the
high  temperature, high  pressure mixture
of  steam  and  gases is available  to be
used  as process heat or for generation of
power.  When  the organic  content of the
waste is greater than 5%,  sufficient net
power may be generated  to cover  the
entire cost of treatment.   The process
                                           211

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cost compares very favorably with
alternative schemes, and is expected to
see wide application in the near
future.
TABLE 5.  MATERIALS TESTED UNDER SOW
                 OXIDATION
Dextrose

Cyclohexane

Biphenyl

Benzene

1,1,1-Trichloroethane

1,2-Ethylene Dichloride

o-Chloro toluene

1,2,4-Trichlorobenzene

o-Xylene

Hexachlorocyclohexane

4,4'-Dichlorobiphenyl

Hexachlorocyclopentad iene

DDT

PGB 1234

PCB 1254

2,4-Dinitrotoluene

Urea

Methyl ethyl ketone
REFERENCES
1.   Amin3 S., R.C. Reid and M. Modell.
1975. Reforming and Decomposition of
Glucose in an Aqueous Phase, Am. Soc.
Mech. Eng., paper no. 75-ENAs-21.

2.   Connolly, J.F. 1966.  Solubility of
Hydrocarbons in Water Near the Critical
Solution Temperature,  J. Chem. Eng.
Data, 11, 13.

3.   Franck, E.U. 1970.  Water and
Aqueous Solutions at High Pressures and
Temperatures,  Pure Applied Chem., 24,
13.

4.   Franck, E.U. 1976.  Properties of
Water, in  High Temperature, High
Pressure Electrochemistry in Aqueous
Solutions (NACE-4), p. 109.

5.   Marshall, W.L. 1976.  Predicting
Conductance and Equilibrium Behavior of
Aqueous Electrolytes at High Temperatures
and Pressures, in High Temperature, High
Pressure Electrochemistry in Aqueous
Solutions (NACE-4), p. 117.

6.   Martynova, O.I. 1976.  Solubility of
Inorganic Compounds in Subcritical and
Supercritical Water, in High Temperature,
High Pressure Electrochemistry in Aqueous
Solutions (NACE-4), p. 131.

7.   Modell, M., R.C. Reid and S. Amin.
1978.  Gasification Process, U.S. Patent
4,113,446, Sept. 12.

8.   Wilhelmi, A.R. and P.V. Knopp. 1979.
Wet Air Oxidation - An Alternative to
Incineration, Chem. Eng. Progress, 75
(8), 46.
                                           212

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                      THE DESTRUCTION OF VARIOUS ORGANIC SUBSTANCES
                          BY A CATALYZED WET OXIDATION PROCESS
                                    Richard A. Miller
                                 Mark, D. Swientoniewski

                                    IT Enviroscience
                               Knoxville, Tennessee 37923
                                        ABSTRACT

Research was initiated to determine the ability of the catalyzed wet oxidation process to
destroy organic substances that are representative of materials found in hazardous wastes.
Catalyzed wet oxidation uses homogenous catalysts in conventional chemical reaction
equipment to^ultimately oxidize an organic substance to carbon dioxide.  Fifteen organic
compounds were studied in a laboratory-scale batch reaction system.  These compounds were
destroyed with reaction conditions ranging from 165°C to 275°C, 150 psig to 1000 psig and
reaction time from 5 minutes to 420 minutes.  Preliminary designs using a portable 1000
gallon treatment process have been made based on demonstrated destruction rates.  The
cost of treating some organics range from $0.12/lb of organic to $1.04/lb of organic.
INTRODUCTION

The United States is facing a major en-
vironmental problem as it becomes more
aware of the production and handling of
toxic and hazardous wastes.  These wastes
have been produced for many years, but
their disposal has not been controlled.
The recent increase in public awareness
and concern has prompted the United States
Environmental Protection Agency (USEPA) to
evaluate technologies aimed at solving the
problem.  Of particular interest is the
development and application of new tech-
nologies to the problems associated with
abandoned chemical waste disposal sites
such as Love Canal and the Valley of the
Drums.  The estimate of the number of such
sites in the United States and the cost to
clean them up is staggering.  Treatment of
the leachate and ground waters and ulti-
mate disposal of the sludges, soils,
liquids, solids, and containers in the
site are typical disposal problems.

The most desirable technology for dealing
with the problem of chemical disposal
sites is. a process that 1). achieves com-
plete destruction of toxic and hazardous
chemicals and minimizes by-products and
chemical remnants requiring disposal;
2) minimizes the energy required for
disposal, especially supplemental fuels;
3) has few unit operations; 4) has low
chemical usage; 5) has low volume
effluents, so that polishing treatment
to achieve total containment can be
readily implemented; 6) is easily pilot-.
planted; and 7) is transportable to the
landfill sites.

The present study evaluates a new cata-
lytic wet oxidation technology for
the treatment of toxic and hazardous
materials.  It is applicable to both
aqueous wastes and organic residues.
Earlier work resulted in U.S. Patent
3,984,311 (1) and two additional patent
applications that describe catalyst
systems for destruction of various
chemicals.  The data show fast de-
struction rates for compounds such as
nitrated and chlorinated phenols, 2,4-D,
aklylphosphorothioates, and short chain
fatty acids.  On the basis of this
earlier range-finding testing and eco-
nomic evaluation, the technology appears
to have wide-ranging applicability and
potential for alleviating significant
waste disposal problems facing the
                                          213

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United States.  The data on which this
paper was developed was supported by funds
from the USEPA.

CATALYZED WET OXIDATION PROCESS CONCEPT

The catalyzed wet oxidation process is
based on U.S. Patent 3,984,311, originally
assigned to The Dow Chemical Company with
right, title, and interest now owned by
IT Enviroscience for development and com-
mercialization.  The patent teaches the
use of a co-catalyst system consisting of
bromide and nitrate anions in an acidic,
aqueous solution.  Continued research
with the co-catalyst system has led to the
development of a new catalyst mixture
which is more effective for oxidizing
insoluble organics.  The new catalyst
system consists of bromide, nitrate, and
manganese ions in acidic solution.  A
patent for the new catalyst has been
allowed  (U.S. 4,276,198) and assigned to
IT Enviroscience  (2).  The destruction of
most organics by these catalyst systems
is rapid and essentially complete.

The keys to the operation of this catalyst
system are the mechanism of oxygen fix-
ation and the fact that it is a water-
soluble, single-phase catalyst system—
a homogeneous catalyst as contrasted to a
heterogeneous catalyst.  In conventional
wet oxidation, heat and pressure are used
to drive the dissolution of oxygen from
air and the reaction with dissolved or-
ganics in aqueous solution.  In the
bromide-nitrate based catalyst systems
the transfer of oxygen to the dissolved
state is speeded up by using very rapid
gas and  liquid reactions associated with
the catalyst components.  'The importance
of the enhanced oxygen transfer is the
ability  to oxidize organics at much lower
temperatures than uncatalyzed wet oxi-
dation,  165-200°C versus 250-325°C.  The
lower operating temperatures also mean
lower operating pressures which not only
reduces  capital cost but operational
problems.

The second important aspect of the catalyst
system is its homogeneous nature which
permits application to the destruction of
toxic or hazardous organic residues, such
as still bottoms or other organic wastes.
The advantages of a homogeneous catalyst
are best utilized by using a reactor design
which is different from conventional wet
oxidation processes.  In simplest form the
reactor, a continuously stirred tank
reactor (CSTR) contains the catalyst
solution.   Air and the waste are continu-
ously pumped into the reactor and the
organics are oxidized with the heat of
reaction driving off water.  The only
materials to leave the reactor are CO ,
N , water vapor, any volatile organics
and inorganic solids formed. Water is
condensed and returned to the reactor, if
necessary, as are condensable organics.
Any inorganic salts or acids which may be
formed have to be removed by treatment of
a closed loop stream of catalyst solu-
tion.  Such treatment is- individually
designed utilizing conventional tech-
nologies, such as filtration or distil-
lation.  The vent gases from the reactor
are low in volume and may, if necessary,
be .treated by conventional techniques,
such as absorption, adsorption, or
scrubbing.  The most important features
of this process concept are that non-
volatile organics remain in the reactor
until destroyed, and that there is no
aqueous bottoms product.

COMPOUND SELECTION

The study of a process associated with
chemical wastes needs to evaluate a wide
range of chemical compounds to evaluate
the applicability of the process.  In
order to meet this requirement fifteen
compounds were selected from various
chemical groupings of the EPA priority
pollutant list.  The specific compounds
chosen from each grouping were made based
on the likelihood of finding the chemipal
in industrial waste and chemical disposal
sites.  In certain cases a lower toxicity
compound was substituted for a highly
toxic compound, e.g., diphenyl hydrazine
substituted for benzidine, when it pre-
sented an unacceptably high risk to lab-
oratory personnel.  The chemical groups
and the compounds studied were:

 - Halogenated hydrocarbons
     Ethylene dibromide
     Hexachlorobutadiene
     Trichloropropane
 - Pesticides
     Atrazine
     DDT
     Malathion
     Mirex
 - Phenols
     Pentachlorophenol
 - Phthalates
                                           214

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     Di-n-butyl phthalate
   Polynuclear aromatics
     Chloroanthracene
   Nitrogen containing compounds
     Acetonitrile
     Chloroaniline
     Diphenyl hydrazine
     Nitrobenzene
   Aromatic
     o-Xylene
organics), by ion chromatography.  All
of these methods followed quality assur-
ance/quality control  (QA/QC) procedures
as outlined in the IT Enviroscience
Analytical Chemistry Control Manual.
These measurements were used to deter-
mine the completeness of the organic
destruction.

EXPERIMENTAL RESULTS
EXPERIMENTAL METHOD
Summary
The experimental evaluation of catalyzed
wet oxidation was conducted in a 1-liter
agitated titanium autoclave.  The de-,
struction rate of the compounds was
measured at various operating conditions
with batch reactions.  Typical operating
conditions were 165-250°C, 0.5% Br ,  5.0%
NO ~  0.25% Mn+ , 30-120 minutes re-
action time, and 20% excess oxygen over
stoichiometric.  The procedure for con-
ducting the oxidation reactions con-
sisted of loading the reactor with, the
desired quantity of deionized water,  HBr,
and organic to be oxidized.  The reactor
was sealed, purged with oxygen, and
pressurized with sufficient oxygen to
totally oxidize the organic.  The re-
actor was then heated to the desired
operating temperature and the remaining
catalysts, HNO , and MnSO , were added to
the reactor with oxygen pressure.  The
reaction was run for the desired time
period.  At the termination of the re-
action, the reactor was cooled to room
temperature with cooling water.  The
pressure was then vented and any free
bromine was reduced to bromide by the
addition of 10 ml of sodium bisulfite
solution to prevent operator exposure to
toxic bromine vapors.  The reactor was
opened and the aqueous contents were
aspirated from the reactor.  All internal
surfaces of the reactor were rinsed twice
with solvent, methylene chloride.  The
solvent rinsings were aspirated from the
reactor and combined with the aqueous
effluent.  The aqueous phase was extracted
with the solvent rinse and two successive
50-ml portions of solvent to recover
unreacted organics and reaction by-pro-
ducts.  The combined solvent extracts
were analyzed by gas chromatography and
gas chromatography/mass spectrometry
(GC/MS).  The destruction rate of the
organic was also measured by the formation
of CO , by gas chromatography, and the
formation of Cl  (from chlorinated
For the purpose of evaluating the appli-
cability of the process to treat hazard-
ous wastes in chemical landfills, the
results of the individual compound
studies are grouped into two major cate-
gories, fast and slow destruction rate
compounds.  The definition of fast and
slow destruction rates can be set at
any level, but the results of the com-
pounds studied can be split as follows.
Compounds that were destroyed at low
temperatures, less than 200°C, and short
reaction times, less than 60 minutes,
were classified as fast destruction rate
compounds.  This group includes atrazine,
butyl phthalate, chloroaniline, diphenyl'
hydrazine, ethylene dibromide, malathion,
and pentachlorophenol.  Compounds in the
other group (slow destruction rate) were
more difficult to destroy.  These com-
pounds required higher reaction tem-
peratures, up to 250°C, and longer
reaction times.  This group includes the
other compounds studied, acetonitrile,
Chloroanthracene, DDT, hexachlorobuta-
diene, mirex, nitrobenzene, trichloro-
propane, and o-xylene.

Atrazine

The destruction rate for atrazine was
very fast, apparently due to both the
instability of the heterocyclic nitrogen
ring at high .temperatures and the oxi-
dation by the catalysts.  The instability
of the atrazine molecule was observed in
the first experiment without., catalysts.
At a temperature of 163°C, 51.5% of the
atrazine was oxidized with release of a
comparable amount of chloride (58.3%) but
very little CO2 formation.  This cor-
responding release of Cl  with atrazine
decrease suggests an initial C-C1 bond
rupture.  Whether this reaction occurs in
the presence of the catalyst system is
unknown and beyond the scope of this
investigation.   However, the addition of
                                          215

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the Br-NO -Mn catalysts increased the oxi-
dation of atrazine (99.9%) and the forma-
tion of CO, (45.3%) and chloride (83.1%).
A later experiment using only bromide and
nitrate catalysts had a similar oxidation
rate for atrazine  (99.9%) and a formation
rate of chloride (100%) but very little
formation of CO, (0.6%), indicating the
manganese plays a critical role in the
complete oxidation of atrazine to carbon
dioxide.  Because of the demonstrated
importance of manganese in the catalyst
system, the remaining experiments were all
performed with the three-catalyst system,
Br-NO,-Mn.  The experimental variables of
reaction time, temperature, and atrazine
concentration were further evaluated to
determine the maximum destruction rate for
the catalytic oxidation of atrazine.

The rapid oxidation rate of atrazine and
the limited accuracy of the CO, and
chloride analysis made it difficult to
evaluate optimum oxidation conditions.
However, the experimental data can be ex-
amined for trends toward optimum reaction
parameters.  Increasing the reaction tem-
peratures from 165 to 200°C increased the
complete destruction rate to CO2 by ap-
proximately 40%, during a 30 minute re-
action:   The effect of time during these
experiments was minimal, with less than
an 18% increase in formation of C02 with
a four-fold increase in reaction time,
from 30 to 120 minutes.  The effect of
atrazine concentration was determined by
increasing its concentration ten-fold from
0.1% to 1.0%.  The destruction rate
measured by the oxidation of atrazine and
the formation of CO, remained constant,
indicating a first-order kinetic relation-
sip for atrazine concentrations.  The
first-order relationship of concentration,
coupled with the fast oxidation rate,
permits the design of a treatment process
that can destroy large quantities of atra-
zine in relatively small equipment.
Therefore, a waste treatment process with
small equipment  (low capital cost) and
high throughput  (via high destruction
rates) would be a very economical process
to install and operate.  A catalyzed wet
oxidation process offers a technically
and economically viable alternative for
destroying atrazine or similarly
structured compounds.

Butyl Phthalate
The oxidation of butyl phthalate was dif-
ferent from the behavior exhibited by
atrazine.  Butyl phthalate showed con-
siderable resistance to wet oxidation
without the presence of catalysts.  At
164°C only 6% of the initial butyl
phthalate was oxidized in 30 minutes with
1.2% of the initial amount being com-
pletely oxidized to CO..  The addition of
the Br-NO -Mn catalyst increased the
oxidation rate of butyl phthalate to
86.6% in 30 minutes at 163°C with 50.6%
of the initial material being totally
oxidized to CO..  The effect of the in-
creased reaction time increases both the
oxidation of the butyl phthalate and the
formation of CO,.  A four-fold increase
in time, 30 to 120 minutes, increased the
oxidation rate by 13%.  This small effect
on reaction time indicates that the oxi-
dation of butyl phthalate probably
follows a multistep process and that
although the initial steps are fast, the
final oxidation reactions are slow.
Based on earlier catalyzed oxidation
experiments with carboxylic acids, e.g.,
acetic acid, it is postulated that the
early oxidation reactions yield rela-
tively stable by-products which oxidize
at a much slower rate.

The disappearance of butyl phthalate is
first-order, with similar oxidation rates,
96.0% vs. 97.6% for 0.1% and 1.0% butyl
phthalate experiments.  This result is
consistent with early studies of water-
soluble organics and the data from the
study of atrazine.  The effect of various
catalyst mixtures on the oxidation rate
of butyl phthalate and the formation rate
of CO  was similar to the results re-
ported for atrazine.  Although the actual
effects of the catalysts are small, the
trends are Similar.  The removal of
manganese from the mixture decreases the
oxidation rate of butyl phthalate and the
formation of CO,.  Increasing either the
bromide or nitrate concentration slightly
increases the oxidation rate of butyl
phthalate but has little effect on the
formation of CO,.

Analysis of selected experiments by GC/MS
revealed that the extractable by-products
from the oxidation of butyl phthalate
fall into two categories, brominated
organics and phthalic acid.  Brominated
by-products, bromoform and dibromopropane,
were present in the solvent extracts of
                                          216

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all the samples analyzed by GC/MS.
Phthalic acid was identified in the '
extracts of two later experiments, both
high butyl phthalate concentration experi-
ments.                             •_  •   ,

Chloroaniline

The oxidation of chloroaniline was similar
to the oxidation of atrazine in that
chloroaniline.was partially oxidized with
no catalyst present.  Two experiments
were conducted with no catalyst at tem-
peratures of 165 and 199°C.  It is not
known whether the. uncatalyzed reaction was
due to a wet oxidation reaction or to a
rearrangement reaction.  However, the ease
of oxidizing chloroaniline without cata-
lysts usually results, as in the case with
atrazine, in rapid and essentially com-
plete oxidation with the Br-NO -Mn
catalyst system.  The solvent-extracted
effluent from the third experiment was
analyzed by GC/MS for reaction by-products.
The compounds identified were small
amounts of dibromochloromethane, bromoform,
tetrabromoethane, and various brominated
chlorobenzenes.  These by-products are
consistent with other analyses of reactor
effluents.  The by-products or partially
oxidized compounds are ultimately oxidized
to CO , HC1, and HO.
     ^            ^         .   '    . '
Chloroanthracene
The oxidation of Chloroanthracene was very
different from any of the earlier com-
pounds studied.  The initial experiment
with no catalysts showed very little oxi-
dation.  However, the rest of the ex-
periments showed very high destruction
rates by disappearance of Chloroanthracene
and by the limited formation of CO  arid
Cl .  Analysis of the reactor effluent by
gas chromatography showed the presence of
a major reaction by-product, which was
identified by GC/MS as chloroanthra-
cenedione with smaller amount of bromo-
form, tetrabromoethane, and'dibromochloro-
benzene.  The significance of the chloro-
anthracenedione by-product is that it is
the first major by-product identified
which was not brominated.  Later'experi-
ments show that chloroanthracenedione is
oxidized further at longer reaction times
or under more stringent conditions.  The
similar destruction rates as measured by
CO  and Cl  formation indicate that the
chloroanthracenedione can be completely
oxidized.
 Ethylene Dibromide

 The oxidation of ethylene dibromide (EDB)
 follows a multistep sequence that
 initially results'in the'disappearance
 of EDB with very little CO  formation.
 This occurred in the first and third
 experiments when no catalysts were used
 at a reactor temperature of 164°C.  The
 mechanism which causes this reaction is
 not known, but the addition of the
 Br-NO -Mn catalyst to the reactor re-
 sults in the oxidation of the organics
 to CO .  The excess formation of CO» is
 attributed to an analytical error as-
 sociated with the CO  analysis rather
 than to the complete oxidation of all
 the EDB placed in the reactor.  The only
 identified by-product of the oxidation
 reaction was bromoform in the second
 experiment.

 Hexachlorobutadiene

 The oxidation of hexachlorobutadiene was
 more difficult than for any of the com-
'pounds tested earlier.   Wet oxidation at
 165°C without catalysts was ineffective
 in destroying hexachlorobutadiene.  Even
 the addition of the Br-NO -Mn catalyst
 did not improve the oxidation rate at
 165°C.  The resistance of hexachloro-
 butadiene to oxidation required a higher
 reaction temperature and a longer re-
 action time to achieve destruction.
 After two hours at 250°C,  25% of the
 hexachlorobutadiene was oxidized to CO'
 and Cl .   Although this destruction rate
 is relatively slow, the catalyst system
 successfully destroyed hexachlorobuta-
 diene.  Further experiments with longer
 reaction times increased the destruction
 rate but the overall rate, 45% de-
 struction in 7 hours,  was  still too slow
 to effectively destroy large quantities
 of hexachlorobutadiene.  However,  ex-
 periments with higher concentrations of
 hexachlorobutadiene yielded much higher
 destruction rates.   A later experiment
 had the greatest destruction of hexa-
 chlorobutadiene, 91% in 2  hours'at
 242°C.• 'It'is unknown whether the high
 destruction rate was due to the presence
 of greater quantities of chloride or to
 an insoluble'organic phase..  The reason
 for the improved destruction rate could
 be the subject of future laboratory
 studies.   Analysis of the  reactor ef-
 fluent from the hexachlorobutadiene
 experiments by GC/MS revealed the
                                          217

-------
presence of hexachloroethane, an impurity
of hexachlorobutadiene, and bromoforra, a
by-product of the oxidation.

Malathion
Malathion was so unstable at temperatures
higher than 165°C that none could be de-
tected in the reactor effluent.  The
affect of temperatures was isolated by
running an uncatalyzed oxidation at room
temperature.  Greater than 91% of the
malathion was recovered from the reactor.
This experiment demonstrated that mala-
thion is thermally unstable.  The only
significant experimental difference ob-
served was that uncatalyzed oxidation gave
limited CO , indicating only partial oxi-
dation of malathion.

In the presence of the catalyst, malathion
was oxidized completely to CO .  The high
CO_ formation results, 105% to 113%, indi-
cate complete oxidation.  A few trace
organics were identified in the reactor
effluent by GC/MS.  These were methylene
bromide and bromoform, which could be
final remnants from the oxidation of
malathion.

Hirex

Of the fifteen organics studies, mirex was
the most resistant to oxidation.  The
first experiment, no catalysts, showed no
oxidation of mirex and greater than 99%
recovery at 199°C.  The addition of the
standard Br-NO_-Mn mixture only increased
the oxidation rate to 8.5% in 65 minutes.
With the apparent high resistance to oxi-
dation later experiments utilized much
higher reaction temperatures to attempt
mirex oxidation.  At temperatures as high
as 274°C, only 15.9% of the mirex could
be oxidized.  No extra compounds were
indicated by analysis of the reactor ef-
fluent, so no analyses by GC/MS were
performed.

Nitrobenzene
Nitrobenzene was the first compound evalu-
ated during this study and the experi-
mental results are difficult to interpret.
The uncatalyzed oxidation of nitrobenzene
was evaluated at 200°C with reaction times
from 4 to 60 minutes.  The loss of nitro-
benzene in these runs ranged from 18 to
31% with no apparent relationship between
loss of nitrobenzene and reaction time.
Inconsistent data were attributed to
start-up problems associated with a new
operator.  The formation of CO  in the
uncatalyzed oxidations was low, 0.2 to
8.2%, indicating that very little nitro-
benzene was being totally oxidized.  The
addition of catalysts to the experiments
at 200°C had little effect on the partial
oxidation, or loss, of nitrobenzene.
When the reaction temperature was raised
to 250°C, the oxidation rate increased
to 46% in 60 minutes with 12.2% of the
nitrobenzene being completely oxidized
to CO.  Although the results of the
nitrobenzene experiments are too varied
for detailed analysis, the overall re-
sult of the evaluation is that nitro-
benzene can be oxidized by the Br-NO -Mn
system at slow rates.

Pentachlorophenol

The oxidation of pentachlorophenol was
evaluated in a series of six experiments.
The oxidation rate with no catalysts was
measured at reaction temperatures of 165
and 194°C.  The results indicate that
pentachlorophenol is oxidized by wet
oxidation at moderate rates and that the
oxidation is complete, as measured by
CO .  However, the addition of the Br-
NO_-Mn catalyst drastically increased the
oxidation rate by all three methods of
measurement, loss of pentachlorophenol
and formation of CO  and Cl .  The
initial catalyst reactions with penta-
chlorophenol were so fast that after 30
minutes at 165°C more than 99% of the
pentachlorophenol was partially oxidized.
Total oxidation can be achieved with
either increased reaction time or in-
creased reaction temperature.  The re-
action by-products from later experiments
were analyzed by GC/MS to identify the
partial oxidation products of penta-
chlorophenol.  The only compounds present
were dibromochloromethane and bromoform.
Such short chained organics are usually
the oxidation products prior to the final
oxidation to CO .

Trichloropropane

The oxidation of trichloropropane was
evaluated at a few experimental con-
ditions.  The first experiment was an
uncatalyzed oxidation at 163°C for 30
minutes.  At these conditions, 14.5% of
the trichloropropane was oxidized, 5.3%
completely to chloride.  The next experi-
                                          218

-------
 merits evaluated the effect of adding the
 catalysts and increasing the reaction
 temperature.  The addition of the Br-
 NO -Mn catalyst doubled the destruction
 rate by loss of trichloropropane and by
 formation of CO  and Cl~.  These de-
 struction rates were doubled again by in-
 creasing the reaction temperature from
 165 to 200°C.  The ability to oxidize tri-
 chloropropane was demonstrated during
 these 30-minute reactions.  The by-
 products of the reaction were analyzed by
 GC/MS and identified as debromochloro-
 methane, bromoform, and dichlorobromo-
 propane.

 o-Xylene

 The oxidation experiments with xylene
 generated some interesting data.   The
 uncatalyzed oxidation at 165°C destroyed
 more than half the xylene, 54.3%,  but
 generated only 0.3% of CO .   The  wide
 difference in destruction rates may be
 attributable to partial recovery  of un-
 reacted xylene with the solvent ex-
 traction procedures used,  but this was
 not verified during the xylene oxidation
 experiments.   The  destruction rates were
 increased by the addition of  the Br-NO -
 Mn catalysts but not by increasing the
 reaction temperature.

 The most surprising result was  the in-
 crease  in  destruction rates caused by
 increasing the  initial  concentration of
 xylene.  During these  experiments  the
 destruction  rate by loss of xylene was
 greater than  98% with  almost  half  the
 xylene  being  totally oxidized to CO .
 This result was  also observed with Hexa-
 chlorobutadiene  but  the reason  for the
 increase was  beyond  the scope of this '
 project and was  not  studied.  However,
 this observation would indicate a
 slightly higher overall order of reaction
 for xylene than  the  first-order rate of
 reaction observed for the other compounds.
 Keeping in mind the complexity and number
 of reactions occurring in the liquid and
 vapor phases, this slight increase in
 order may indicate a different reaction
 mechanism during the destruction process
 of this compound.  The by-products of
 xylene oxidation were identified by GC/MS
 as bromoxylene and dibromoxylene.   The
presence of the brominated by-products
 reinforces the hypothesis that bromine
 species are the major oxidant in this
 catalyst system.

 Diphenyl Hydrazine

 The oxidation of diphenyl hydrazine is
 fast and comparable to the oxidation of
 butyl phthalate.  Diphenyl hydrazine was
 oxidized slowly without catalysts.  At
 164°c, 19.3% of the initial diphenyl
 hydrazine was oxidized in 30 minutes and
 only 3.6% of the initial amount was
 completely oxidized to CO . . Addition of
 the Br-NO3-Mn catalysts increased the
 destruction of diphenyl hydrazine to
 73.3% in 30 minutes at 164°C, and 44.5%
 of the initial amount was totally oxi-
 dized to CO2.  Increasing the reaction
 temperature from 164°C to 200°C caused
 destruction of 97.9% of the initial
 diphenyl hydrazine in 30 minutes and
 69.8% of this initial amount was oxi-
 dized completely to CO .

 Surprisingly, when the initial diphenyl
 hydrazine concentration was increased
 from 0.1% to 1.0% the destruction de-
 creased to  57.9% vs.  97.9% by disap-
 pearance of organic and 39.5% vs.  69.8%
 by conformation.   The reason for this •
 sharp decrease was not studied nor was
 the experiment repeated to confirm this
 result.   The trace by-products of oxi-
 dation of diphenyl hydrazine  were
 identified  by GC/MS as tribromomethane,
 various  bromobenzenes,  and bromodiphenyl
 hydrazine.
 DDT                       .   .  :

 The oxidation of DDT without catalyst is
 slow.  At  166°C only 9.6% of the initial
 DDT oxidized in 60 minutes and 2.8% of
 the initial amount oxidized to CO  and
 5.6% by Cl  formation.  The addition of
 the Br-NO3-Mn catalyst raised the de-
 struction of DDT to 59.8% in 60 minutes
 at 165°C and 5.4% of the initial material
 oxidized to C02, 19.9% to Cl~ ions.  In-
 creasing the temperature- to 249°C in-
 creased the destruction to 93.5% but
 did not significantly change the CO  or
 Cl  destruction numbers.  Also, an in-
 crease in time from 30 to 60 minutes
 increased the destruction by only 10.2%.
As in the case of butyl phthalate oxi-
dation, the small effect of reaction
 time on destruction indicates that the
oxidation of DDT follows a multistep
process.
                                          219

-------
The destruction of DDT is first-order
with respect to initial DDT concentration.
Destruction was 100% vs. 98.4% for 0.1%
and 1.0% DDT concentration experiments.
Experimental conditions were 150°C for
120 minutes for these experiments.

As in the case of butyl phthalate, the
actual effects of various catalyst mix-
tures on the destruction of DDT is minor.
The removal of manganese from the catalyst
mixture decreases the destruction of DDT
and the formation of CO  and Cl  ions.
Increasing either bromide or nitrate
slightly increases the destruction of
DDT as measured by the formation of CO2
and Cl  ions.

Analysis of the extractable by-products
by GC/MS revealed a variety of materials.
By-products formed in an early experiment
include bromoform, dibromochloromethane ,
dichlorobenzene , bromochlorobenzene ,
dibromochlorobenzene , dichlorophenyl
chlorophenyl ketone, chlorophenyl ketone,
bromochlorophenyl chlorophenyl ketone,
and l,l-dichloro-2,2-bis (p-chlorophenyl)
ethylene.  Later experiments include
toluene, benzaldehyde,  tetrachlorobenzene ,
dichloroacetophenone , pentachTorobehzene ,
trichlorobenzaldehyde,  and hexachloro-
benzene.  This  variety  of by-products
from  the oxidation of DDT is supportive
of the  fact that initial experiments
supported a multi-path  decomposition as
indicated by a  large disappearance_of  DDT
but a low appearance of CO2  and  Cl  ions.
Although these  by-products are somewhat
more  stable toward oxidation than the
original DDT molecule these  materials
are ultimately  oxidized to CO2/  HC1, and
 Acetonitrile
 Acetonitrile is resistant to wet oxi-
 dation.   Without catalyst only 5.4% of
 the initial material oxidized in 30
 minutes at 165°C.  When the catalyst
 mixture was added, 89.9% of the acetoni-
 trile disappeared at the same reaction
 conditions.  An increase in temperature
 to 200°C and initial acetonitrile con-
 centration from 0.1% to 1.0% resulted in
 destruction increasing to 96.3% and 99.3%
 respectively.  An increase in reaction
 time from 30 minutes to 60 minutes had
 no effect on the destruction of acetoni-
 trile.
PROCESS DESIGN AND ECONOMICS

With data generated from the batch oxi-
dation reactions of the 15 compounds
preliminary capital and operating costs
can be estimated for a full-scale con-
tinuous process to destroy these com-
pounds.  Two processes were designed to
destroy aqueous wastes or organic resi-
dues.

Process Description;  Organic Residues

A continuous large-scale system for the
destruction of organic residues by
catalyzed wet oxidation is based on the
use of a conventional continuous stirred
tank reactor  (CSTR).  The organic resi-
due and compressed  air enter the pres-
sure vessel continuously.  A reflux
condenser returns condensate to the
reactor.  Noncondensables are scrubbed
with caustic and passed through a carbon
adsorber.  For chlorinated residues it
is also necessary to remove HC1 from the
reactor, which is accomplished through a
distillation of the reactor contents and
a return of the catalysts to the reactor.
Makeup catalysts are also added to the
reactor to compensate for losses through
the reactor vent.

A CSTR in this system has the advantage
of requiring the relatively insoluble
and nonvolatile organic to remain in the
reactor until it is oxidized to CO2 or a
volatile organic.   However these vola-
tile organics are condensed and returned
to the reactor through the condensate
accumulator.  This  advantage is more
important to  a  "real world" waste stream
composed of easily  oxidized or more dif-
ficult to oxidize organic compounds.
Therefore a CSTR-based wet oxidation
system allows for the destruction of the
complete range of organics  if the design
is based on the most difficult to oxi-
dize organic  compound.

Process Description:  Aqueous Wastes

A large-scale system  for the destruction
of an  aqueous organic waste by  catalyzed
wet oxidation has the  same  major compo-
nents  and  functions as  the  organic  resi-
 due oxidation system.   The  major dif-
 ference in  these two  systems is that any
 feed water entering the oxidation re-
 actor can  only exit the reactor as  water
                                           220

-------
 vapor.   The heat required to boil up this
 incoming water could be supplied by the
 heat of combustion of the organic if the
 organic is at a high enough concentration.
 The water vapor leaving the reactor is
 then condensed.  The condensate may re-
 quire subsequent treatment, depending on
 the particular waste profile being oxi--
 dized.   All other equipment units function
 the same as the organic residue process
 previously described.

 Economics
 Capital  and operating costs were estimated
 for several catalyzed oxidation processes
 using the experimental destruction rates
 obtained in this  study.   The processes
 were designed for compounds with dif-
 ferent destruction rates  to show the
 impact of destruction rates on  the process
 design and economics.   The  design basis is
 a  1000-gal reactor system for destroying
 a  pure compound in water.  'By fixing the
 system design at  1000-gal,  the  major
 factor affecting  the  cost of the treat-
 ment system is the destruction  rate of
 the organic substance.  For example the
 feed rate of organic  for  a  pentachloro-
 phenol treatment  system is  2.3  times the
 feed rate for a butyl  phthalate treatment
 system.   Therefore the corresponding
 treatment cost per pound  of organic would
 be greater for the butyl  phthalate  treat-
 ment system.   However,  due  to the  added
 constraint of removing hydrochloric acid
 from the  pentachlorophenol  system, .the
 operating cost of  this  system is almost
 twice the cost of  the  butyl phthalate
 system.   Therefore, the cost per pound :
 of organic of ..the  pentachlorophenol treat-
 ment  system is correspondingly  higher and
 approaches the cost of the butyl
 phthalate  treatment system*  Other minor
 factors affecting  the treatment costs
 include air  compressor duty, condenser
 size,  cooling water requirements,
 neutralization or  scrubbing requirements,
 and catalyst  losses.

 The cost  for  treating waste organic resi-
 dues  similar  to the compounds evaluated
 in this program ranged from $0.12/lb of
organic for compounds with fast de1-
 struction rates,  such as pentachlorophenol
to $1.04/lb  for compounds with slow de-
 struction rates such as hexachlorobuta-
diene. 'A  second type of process was
designed to permit the treatment of  •
aqueous waste contamined with high levels
of a soluble organic compound.  This
process assumes the destruction rate of
acetonitrile in a 7.25% aqueous solution
and results in costs of $0.45/lb of
organic or $0.27/gal of waste.

Funds for this research came from the
program budget of the former Solid and
Hazardous Waste Division of the USEPA
Minicipal Environmental Research
Laboratory, with that program responsi-
bility now part of the Industrial Envi-
ronmental Research Laboratory in
Cincinnati, Ohio, Contract No. 68-03-2568,
Work Directive T-7016.

REFERENCES        .

1.  Diesen, R.  W. and J.  R. Moyer, "Wet
    Combustion of Organics," U.S.  Patent
    3,984,311 (October 5,  1972).

2.  Miller, R.  A.,  "Destruction Method
    for the Wet Combustion of Organics,"
    U.S.  Patent 4,276,198  (June 30,
    1981).          ,
                                          221

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                   SHIPBOARD INCINERATION OF HAZARDOUS CHEMICAL WASTE

                               Routine Disposal  of Liquids
                                           and
                            Experimental  Destruction of Solids
                                   Gerald 0.  Chapman
                          U.S. Environmental  Protection Agency
                                 Washington,  D.C.  20460

                                   Robert J.  Johnson
                              TRW Environmental  Division
                               Redondo Beach, CA 90278

                                  Daniel W. Leubecker
                                Maritime Administration
                                 Washington,  D.C. 20590

                                   Donald A.  Oberacker
                          U.S. Environmental  Protection Agency
                                 Cincinnati,  Ohio 45268
                                        ABSTRACT

     In February 1980, an interagency work group undertook a study of at-sea incineration
and the alternatives available to the Federal Government for encouraging the design,
construction, and operation of U.S. flag incinerator ships.  The group examined previous
incineration operations, various federal assistance programs, safety and control  measures,
Incinerator ship conceptual designs, environmental impacts, and waterfront facilities.   In
September 1980, the work group concluded that chemical waste incineration at sea aboard
specially designed and equipped vessels is a cost-effective, technically efficient, and
environmentally acceptable technology for destroying many combustible hazardous wastes.

     The work group was expanded in October 1980, designated the Interagency Review Board
for the Chemical Waste Incinerator Ship Program, and now coordinates and expedites all _
Federal Government activities related to developing an incineration at sea capability in
the United States.

     This paper presents the findings of the work group and the work program which the
Interagency Review Board has initiated.  Important ship design factors, such as the regu-
latory requirements, incinerator technologies, and incinerator system research recommenda-
tions, are explained.  A conceptual design for a dual-mission ship, that can incinerate
both liquid and solid wastes is presented.  Anticipated operations permits, environmental
monitoring, vessel design requirements, and waterfront facilities are discussed.
 INTRODUCTION

      The United  States currently confronts
 a serious  and massive hazardous materials
 disposal problem.  The public  health and
 the nation's environment  are being
threatened by ever increasing volumes of
hazardous wastes.  The Environmental
Protection Agency (EPA) has estimated that
tens of millions of tons of hazardous waste
are generated annually across the nation.
Furthermore, there are thousands of disposal
                                           222

-------
 sites throughout the country being improp-
 erly maintained, and a large number may
 pose health problems.  (1-6)

      These environmental  and public health
 problems  have prompted federal  agencies to
 examine various  technologies for treatment
 and destruction  of waste  materials.   Con-
 trolled high  temperature  incineration,
 whether on- land or  at sea,  is the
 most effective method  available for
 the destruction  of  combustible  hazardous
 wastes.   Incineration at  sea  removes  the
 destruction site  from populated areas and
 the vulnerable freshwater  environment,
 which  is  of special  importance  when in-
 cinerating  the most toxic  wastes.

     The U. S. faces  a deficiency in
 incineration capacity  for  chlorinated
wastes as well as a  difficulty  in siting
 new or expanded incinerators for certain
 high toxicity or problem wastes.  Incin-
 eration at  sea could provide a  significant
 portion of  the needed disposal  capacity
 for short-term as well as a continued
 long-term disposal option over  the next
 15 to 30 years. '

     Several foreign  flag  incinerator
 ships have  been operating  in Western Europe
 for about a decade.   In 1974, 1975 and  1977
 three officially sanctioned U.S. at-sea
 incineration operations were successfully
 conducted on the foreign incinerator ship,
 M/T Vulcanus.  (The  Vulcanus was purchased
 by a U.S. firm, Chemical Waste  Management,
 Inc., in 1980).  Eight shiploads of indus-
 trial organochlorine wastes and three
 shiploads of Air Force.Herbicide Orange
were destroyed under  research,  special,
and interim permits  issued by EPA.  These  -
operations and those  in Europe  have demon-
 strated incineration at sea of  liquid com-
 bustible chemical wastes to be an available
 industrial operation which can  be implemen-
ted in the U.S. without much of the pre-
 liminary testing that other ultimate dis-
posal alternatives may require.  (7-16)

     In February 1980, an interagency work
group (including EPA, Maritime Administra-
tion, Coast Guard, and National Bureau of
Standards) undertook a study of at-sea in-
cineration technology and the alternatives
available to the Federal Government for  •
encouraging the design, construction, and
operation of U.S. flag incinerator ships.
The work group examined previous incinera-
tion operations,  various federal assistance
 programs,  safety  and  control measures,  in-
 cinerator  ship  conceptual  designs,  environ-
 mental  impacts, and waterfront  facilities.
 In  September  1980, the work group issued its
 report  (17) concluding that chemical waste
 incineration  at sea aboard specially
 designed and  equipped ships is  a cost-
 effective, technically efficient, and en-
 vironmentally acceptable technology for the
 destruction of  many types  of combustible
 hazardous  waste.
 INCINERATOR SYSTEMS AND RELATED RESEARCH

     The  EnvironmentaLProtection Agency
 and  its predecessor organization have con-
 ducted federally supported incineration
 studies for some 15 years, including 7
 years of  engineering and scientific studies
 of hazardous waste incineration technolo-
 gies, both on land and at sea.  These
 studies have supported increasingly strin-
 gent incineration performance and emissions
 standards of federal, state, and local
 agencies.  Such standards have helped
 eliminate unsafe incineration practices and
 have encouraged the development and use of
 improved  technologies to protect public
 health and the environment.

     EPA's work on incineration at sea be-
 gan in 1974 and continued in 1977, when the
 Agency permitted and monitored the burning
 of U.S. industrial and military wastes
 aboard the incinerator ship M/T Vulcanus.
 These organochlorine wastes were incinera-
 ted at sea with no detectable impact on the
 environment.  The liquid  injection  incinera-
 tion equipment on board the ship is simi-
 lar in basic design to the best available
 land-based incineration equipment.  The
 major difference between the two technolo-
 gies is that land-based incinerators for
 chlorinated materials must have scrubbers
 to remove effluent acid gases, whereas the
 marine environment neutralizes the acidic;  .
 stack emissions from the at-sea incinera-
 tion process.

 Applicable Hazardous Waste

     Orie advantage of incineration is that
 the energy content of the chemical  wastes
 can be used to maintain combustion, so that
wastes assist the destruction process.  High.
 energy wastes  can even be destroyed with-
out using supplemental  fuel..   The  EPA has
 studied hazardous waste types and  incinera-
tors which can handle different wastes.
                                           223

-------
 Chemical waste streams suitable  for thermal
 destruction fall into four classes:

   1.   C-H and C-H-0 compounds, yielding
       C02 and HgO

   2.   C-H-N and C-H-O-N compounds,  yielding
       COgj HpO, and nitrogen oxides
   3.   C-H-C1 and C-H-0-C1 compounds, yield-
       ing COp. HgO, and HC1 (gas)
   4.   Other wastes including organic com-
       pounds containing both nitrogen  and
       chlorine; compounds containing sul-
       fur, bromine, fluorine, phosphorus,
       or silicon; and varied wastes not
       included in the first three major
       classes

     The candidate wastes for incineration
 at sea may be either pumpable liquids  or
 slurries,  sludges, tars, or discrete solids.
 The liquids and slurries are highly vari-
 able mixtures, with specific gravities  as
 low as .85 or as high as 1.5.   The  solid
 wastes also have highly variable physical
 properties, but they must be suitable  for
 a  screw feed or a waste container.  A  ship
 that has both liquid injection and  rotary
 kiln incinerators could destroy virtually
 any organic waste stream, except those "con-
 taining more than "trace quantities" of
 heavy  metals or other nonincinerable
 materials  which would not be permitted  for
 incineration at sea without appropriate
 air pollution control devices  installed.

 Incineration Equipment

     Available marine liquid injection  in-
 cinerators  (Figure 1) can safely and effec-
 tively dispose of combustible  liquid or-
 ganic  chemical  wastes.   Similar units are
 used in land-based operations  and on the
M/T Vulcanus and the K/B Vesta.   Although
fluidized  bed,  multiple chamber, and molten
salt incinerators are also available today,
these  designs are not as well  developed,
proven,  or  widely used  as is liquid injec-
tion technology.

     The EPA seeks to advance  at-sea incin-
eration by  investigating the thermal de-
struction of certain types of  solid hazard-
ous wastes  including dry flowable granules,
containerized wastes,  and nonpumpable
slurries or semi-solid  materials.  For
destroying  these materials,  rotary kiln
incinerators (Figure 2)  have been used for
decades  in  land-based applications.  .How-
ever,  at-sea applications would  constitute
   WASTE TYPES

      PUMPABLE LIQUIDS

      SLURRIES. SLUDGES

      TARS

      SOLIDS:

      — GRANULAR

      — IRREGULAR

      — CONTAINERIZED


   MAXIMUM OPERATING
   TEMPERATURE. C


   MAINTENANCE


   COMMERCIAL APPLICATIONS
     VES

     NO


     NO




     NO

     NO

     NO


     1600



     LOW
                       WIDELY USED FOR LIQUID WASTES
                       CURRENTLY USED FOR AT-SEA
                       [INCINERATION
  Figure 1.  Liquid injection incinerator.
a unique mobile  environment for these units,
and a research or  demonstration period
would be necessary.   Also,  unlike the
relatively  "ash-free" or "clean-burning"
incineration  of  liquid wastes, many solid
wastes contain significant  amounts of
uncombustible ash  materials which must be
retained on board  and properly disposed of
after incineration in the rotary kiln.  A
stack scrubber might also be needed to pre-
vent particulates  from being released with
the flue gases.
WASTE TYPES

   PUMPASLE LIQUIDS

   SLURRIES SLUDGES

   TARS

   SOI IDS:

    — GRANULAR

    — IRREGULAR

    — CONTAINERIZED


MAXIMUM OPERATING
TEMPERATURE. C


MAINTENANCE


COMMERCIAL APPLICATIONS
VES

VES

VES




VES

VES

VES


1600
MEDIUM

WIDELY USED ON LAND FOR ALL WASTES
    Figure  2.   Rotary kiln incinerator.
                                             224

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Recommended  Research

A U.S. flag  incinerator ship would pro-
vide a safe  facility to research hazardous
waste incineration.  To advance shipboard
incineration at sea, as well as other
vital technology development, the following
needs have been identified:

  1.  Demonstrate full-scale rotary  kiln
      incineration of solid hazardous waste
      aboard ship;

  2.  Develop  seawater scrubber technology
      for shipboard incinerators; and

  3.  Investigate shipboard use of emerging
      technologies at pilot-scale, such as
      fluidized bed, molten salt, and'
      oxygen-blown incineration and  various
      air pollution control devices.

     These studies would take advantage of
available space on an incinerator ship
along with supplies of wastes and other
facilities.  A rotary kiln demonstration
program would cost approximately $1.5
million with its associated construction,
installation, and engineering evaluation
studies.  A pilot-scale seawater scrubber
program would cost $500 thousand or more.
Both programs conducted concurrently would
be completed .in 12 to 18 months.
INCINERATION AT SEA PERMITS AND
  ENVIRONMENTAL MONITORING REQUIREMENTS

Permits for Incineration at Sea

     The Environmental Protection Agency
has permit granting authority for all ocean
dumping except dredged material; this
authority includes incineration at sea.
Ocean Dumping Regulations (18) describe
the criteria for permit application and
procedures for issuing or denying permits
for ocean dumping.  EPA regulates incin-
eration at sea according to the Marine
Protection, Research and Sanctuaries Act
(MPRSA) (19) and the London Dumping Con-
vention (20), applying the Intergovern-
mental Maritime Consultative Organization
(IMCO) mandatory regulations (21) and tak-
ing full account of the IMCO technical
guidelines (22).  A Research Permit is
granted for the initial burn of a particu-
lar waste and requires extensive monitor-
ing.  Special permits, for more routine
incineration operations, are granted for
a maximum of three years with an option for
renewal.
     A current  revision of the Ocean Dump-
 ing  Regulations (18)  is progressing which
 will align  these rules more closely with the
 needs of the  Chemical Waste Incinerator
 Ship Program.   In addition, further revi-
 sions are under discussion which will lead
 to the development and implementation of
 policies and  procedures for the mixing,
 blending, and treating of multiple waste
 streams.  It  is also  acknowledged that the
 present permit  system is time-consuming,
 costly, and inflexible.  A solution to this
 regulatory  problem in support of incinera-
 tion at sea is  of prime concern to EPA.

     Under  the  present system, a permit
 application must describe specified chemi-
 cal and physical characteristics of the
 waste and the results of specified tests
 done on the waste.  The method of incinera-
 tion, the proposed incineration location,
 and any special  considerations regarding
 probable impacts of the disposal must also
 be included.  A permit application is re-
 viewed in consultation with other federal,
 state, and  local agencies.  After a tenta-
 tive determination is reached, time is
 allowed for public comments, which may
 include a public hearing.  When all infor-
 mation has been  collected and evaluated,
 a final determination is made and announced.
 Administrative  appeal procedures and re-
 source to legal  authority are available if
 anyone objects  to the action of the per-
 mitting authority.

     The design  and operation requirements
 for land-based  and shipboard incineration
 systems are divided into three main cate-
 gories:  regulatory, technical, and safety.
 (23)  The regulatory requirements include
 the ocean dumping permit requirements, the
 Resource Conservation and Recovery Act (24)
 requirements which regulate the land-based
 portion of the  integrated system, and the
 pertinent Coast Guard and IMCO requirements.
 IMCO mandatory  regulations and technical
 guidelines are considered as technical  re-
 quirements,  and all  may appear in the per-
 mit.

     Open ocean sites for at-sea incinera-
 tion are selected to minimize the inter-
 ference of waste disposal  activities on
 the marine environment.   Disposal  site
 evaluations  are based on EPA criteria.   The
 results of these studies are presented as
 an environmental assessment of,the impact
of using the site for disposal.   An environ-
mental  impact statement is subsequently
 prepared for each site designation.  (8,25)
                                           225

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A site has been designated in the Gulf of
Mexico and one has been proposed and evalu-
ated for the North Atlantic.

Environmental Monitoring

     Environmental monitoring during at-sea
incineration is imposed by the MPRSA regu-
lations and the IMCO mandatory regulations
adopted under the London Dumping Conven-
tion.  The IMCO mandatory regulations,
which went into effect in the United States
in March 1979, impose minimum operational
monitoring requirements for protection of
the marine environment.  Additional re-
quirements may be in the permit for at-sea
•incineration.  For example, specific per-
mit monitoring requirements were imposed
on the at-sea disposal actions for organo-
chlorine waste and Herbicide Orange.  Two
general cases involving different degrees
of environmental monitoring are discussed
below.

Initial Incineration Monitoring—

     The London Dumping Convention and the
MPRSA require a survey during the first
use of an at-sea incineration facility to
determine compliance with the regulations.
The survey requires stack gas sampling and
analysis; monitoring of the stack gas for
CO, C0£» 02, total hydrocarbons, and halo-
enated organics; and combustion and de-
struction efficiencies of at least 99.9
percent.  The survey must be repeated every
two years.

     Monitoring in excess of the minimum
regulatory requirements would be performed,
for example, under the following conditions:

  1.  An unusually hazardous waste (e.g.,
      PCBs, which may contain TCDFs) or a
      waste containing an unusually hazard-
      ous substance (e.g., Herbicide Orange
      and its 2,3,7,8-TCDD contaminant) is
      to be incinerated.
  2.  A new type of waste is to be incin-
      erated, unless it is deemed similar
      to a previously tested waste.
  3.  A new incinerator or a new type of
      incinerator is used, or extensive
      system component changes are made.

     When any of these three situations
occur, it is expected that detailed stack
sampling followed by shipboard or land-
based analysis of the samples will be
required.  Additionally, monitoring of
solid residue from a rotary kiln incinera-
tor and influent and effluent from a
scrubber would be required.

     When waste containing appreciable
amounts of sulfur and/or nitrogen (e.g.,
greater than 5 percent) are incinerated,
stack gases should be monitored for oxides
of sulfur and/or nitrogen.  Additionally,
during any research phase, oxides of
nitrogen should be monitored to establish
baseline values.  In some cases, seawater
sampling could be required to determine
actual impacts of incinerator effluents
on the sea and on marine organisms.  For
example, marine water and organism samp-
ling was performed during several Research
Permit burns of organochlorine waste in the
Gulf of Mexico, and marine waste samples
were taken during the Research Permit burn
of Herbicide Orange in the Pacific Ocean.

Routine Incineration Monitoring—

     The MPRSA regulations and London Dump-
ing Convention mandatory regulations do not
require environmental  monitoring during
routine operations.   These regulations do,
however, require operational  monitoring.
The operational monitoring requirements are:

  1.  Flame temperature not less than
      1250°C, unless studies on the incin-
      erator have shown that a lower tem-
      perature will  achieve the required
      combustion and destruction efficien-
      cies.
  2.  Combustion efficiency is at least
      99.95 + 0.05%, based on
      Combustion
      Efficiency
= 100 x
:co2  -  cco

   CC00
      Mhere CGO? and Cco are, respectively,
      concentrations of carbon dioxide and
      carbon monoxide in the stack gas.

  3.  No black smoke or flame extension
      above the exit plane of the stack.

     The London Dumping Convention .manda-
tory regulations also direct that Contrac-
ting Parties "take full account of the
technical guidelines."  The IMCO technical
guidelines establish additional operational
standards.  Several relevant guidelines are:
                                           226

-------
  1.  Minimum 3 percent oxygen in stack gas
      near the exit plane of the stack.

  2.  Incinerator wall temperature should
      be not less than 1200°C (unless tests
      on the unit have shown that adequate
      waste destruction can be achieved at
      lower wall temperatures).
  3.  Residence time of all wastes in the
      incinerator should be of the order
      of one second or longer at a flame
      temperature of 1250°C.
  4.  Waste type and rate of input to the
      incinerator should be recorded.
WATERFRONT SUPPORT FACILITIES

     Waterfront integrated hazardous waste
management facilities are necessary to
support incinerator ships.  Such a facility
would include waterfront storage tanks;
waste receiving, processing, and handling
equipment; a laboratory for waste analysis,
an'd a transfer terminal 'for loading wastes
aboard ship.  In addition, an inland trans-
portation system is required to safely
haul wastes to the waterfront facility.
(16,17)

     The waterfront facility must:

  1.  Receive liquid and solid hazardous
      wastes either by land or by water-
      borne barge transport;

  2.  Analyze, blend, shred, and process
      the materials as appropriate for in-'
      cineration at sea;

  3.  Load the waste aboard ship in a safe
      and efficient manner; and

  4.  Remove and receive residues from the
      incinerator ship for analysis and
      disposal either on land or at sea, in
      the case of incineration of wastes
      producing a collectable residue dur-
      ing disposal.

     The facility will accommodate waste in
almost any physical form and in several
types of containers, some of which may be
older, corroded, and possibly leaking.
Ideally, the facility would service three
transportation modes for delivery of
wastes:  truck, rail, and barge.  It should
consecutively accommodate at least two in-
cinerator ships, each on a 10 to 14 day
cycle.  Figure 3 presents a conceptual
layout of the facility.
      Liquid waste, solid waste, and ash
 residue from  incineration will be pro-
 cessed and stored separately.  Liquid waste
 in drums and  other containers will be sent
 through a shredder Tn the dedrumming facil-
 ity.  Liquid  from both the containers and
 the decontamination of the containers will
 be blended to optimize transfer and combus-
 tion  processes and pumped to storage tanks.
 Liquid waste  arriving in tank trucks or
 tank  cars, along with the tanker decontami-
 nation rinse, will also be blended and
 pumped to the storage tanks.

      Solid waste arriving at the site will
 be unloaded at the unloading rack, prepared
 for incineration by shredding, and placed
 in bulk material containers to be loaded
 on the ship.  Any ash residue from the at-
 sea burn will be returned to the waterfront
 facility and  kept in the residue storage
 area  until removed for ultimate disposal,
 probably in a landfill approved for hazard-
 ous waste disposal.
DUAL-MISSION INCINERATOR SHIP

Design Alternatives and Operating Scenario

     In addition to a conventional ship,
several alternative marine technologies
may be viable for an incineration at sea
system capable of destroying solid as well
as liquid waste, including:

  1.  Integrated tug/barge unit.(a ship-
      shaped barge propelled by a specially
      designed pushing tug that.is mechani-
      cally linked to the barge stern).

  2.  A towed tug/barge combination (a
      traditional tug and tethered incin-
      erator barge).

  3.  A ship conversion (an existing tanker
      may be the most easily converted
      ship).

  4.  A tug/supply vessel (using  either
      existing vessels or new vessels).

     A conventional  new ship design was
selected, -based on the following  operating
scenario:

  1.  Two week operating cycle, with ten
      days  "on-site;"

 -2.  Both  liquid and solid wastes accepted;

  3.  Three liquid incinerators operated
      continuously at full  capacity for ten
                                            227

-------
                    i	TANKER UNLOADING— •
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260 M
tBOOFT)
                                           SOLID AND
                                           CONTAINERIZED
                                           LIQUID STORAGE
                                                  !R.R.
                       EXPANSION
                                                                                       FENCE
O




O
DIKE
RESIDUE
RECEIVING
AND
LOADING
RAMP
	 n 	
                          Figure 3.  Waterfront facility layout.
      days for routine destruction of
      large volumes of liquid wastes;
      One solid waste incinerator operated
      for research purposes;
      No "abandoned site" wastes accepted
      without prior analyses;
      Solid waste containerized before
      loading onto ship;
      Wastes loaded at terminal by auto-
      matic equipment;
      Drifting or slow steaming during
      incineration operations; and

      Heading into wind maintained by bow
      thruster during incineration.
     Adopting a dual-mission  scenario  has
resulted in a conservative conceptual
design that exceeds the needs of  a  vessel
built only for routine liquid incineration.
A first-generation U.S. flag  commercial
incinerator vessel need not incorporate  all
the features of this design.

Incinerator Ship Conceptual Design

     A typical mild steel tankship  hull,
as shown in Figure 4, has been  equipped
with extensive auxiliary processing sys-
tems to handle and incinerate liquid and
solid hazardous chemical waste.   The incin-
eration-plant, liquid cargo pumps,  and
                                            228

-------
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 unattended electric propulsion  motors  arle
 located aft,  with the deckhouse,  labora-'
 tory,  and  attended propulsion diesel-gen-
 erator machinery spaces  located forward.
 This arrangement locates  personnel  living
 and working spaces as far as possible  from
 the incinerator plume, heat, and  potential
 chemical contamination.   Design specifica-
 tions  of the  dual-mission incinerator  ship
 are presented in Table 1.

     Liquid waste tanks and solid waste
 container  storage are midships.  The'four
 center!ine tanks provide  IMCO Type  I cargo
 protection.   The eight port and starboard
 tanks, which  are protected by wing  ballast
 tanks, are ample for  Type  II cargo  protec-
 tion.  Type I chemicals are products that
 require maximum preventive measures to pre-
 clude  escape  of such  cargo; Type I  pro-
 ducts  require significant preventive mea-
 sures  to preclude  escape.  (26,27)  The
 large  amount  of ballast tankage can be
 sequentially  filled to help the ship main-
 tain a constant draft and uniform ship
 motions as wastes  are incinerated.  Solid
 waste  containers are stored on  deck,
 directly above  the liquid waste tanks, but
 separated  from  those tanks by a three foot
 high inert  gas-filled void across the full
width of the  cargo area.

     The rotary/kiln liquid injection in-
 cinerator combination is  on the ship center-
 line, with the  two liquid injection incin-
erators located out-board of the kiln's
 forward end.  The rotary kiln is an experi-
mental  facility and the problems of safely
            loading,  handling,  and  incinerating  the
            solid  wastes  have  influenced  the overall
            design in several  respects.   The kiln axis
            on  the ship center!ine  minimizes the effect
            of  ship's roll  on  the waste residence time.
            The estimated maximum ship pitch angle of
            about  2 1/2 degrees  is  unlikely to disrupt
            the rotary kiln's  operation.  The ship's
            vibrations and  roll  motions impose loads on
            the kiln's external  rotary drive, but two
            major  induced vibration sources, the pro-
            pulsion motors  and  the  propeller, would be
            idle much of  the time that the rotary kiln
            is  operating.   The diesel generators,
            another major source of induced vibration*
            are forward,  remote  from the  incinerators.
            Therefore, ship source vibrations should
            not disrupt the rotary kiln.  Isolation
            mountings  and a modified rotary drive can
            be  provided to  alleviate the  effect of
            vibration  and roll.

                The  ship is powered by a diesel elec-
            tric propulsion plant, providing a service
            speed  of  12 Kts.  The propulsion motors
            must be located aft, but the  diesel  gen-
            erators are below the forward deckhouse,
            so  that the machinery space, where the
            engineers will work most of the voyage, is
            separated from  both the incineration sys-
            tem and the waste cargo.  The same diese!
            generators power the incineration plant
            when the propulsion plant is idle or opera-
            ting at reduced speeds.   This "power pool"
            arrangement makes possible a single  instal-
            lation, rather  than separate ship's  propul-
            sion and ship's service generator installa-
            tions.
                    TABLE 1.  INCINERATOR SHIP DESIGN SPECIFICATIONS
  Length Overall
  Beam, Molded
  Draft, Full Load
  Range
  Liquid Waste Capacity
  Solid Waste Capacity
  Incinerator Specifications

    Number
    Flame Temperature
    Capacity
    Residence Time
Up to 1600°C
10 mt/hr (each)
1  to 1.5 sec
129.5m (425'-0")
 23.8m  (78'-0")
  7.5m  (24'-7")

5000 Nautical  miles

7200 mt (7088  long tons)
 360 mt  (355  long tons)


       Solid

         1
     Up to  1600°C
     1.5 mt/hr
     Minutes to hours
                                           230

-------
            TABLE 2.  ESTIMATED SHIP CONSTRUCTION AND OPERATING COSTS
       Contract Drawings
       Construction Contract
                                (1)
       Plan Approval, Inspection, and Spares
$ 1 million
$50- million

$ 1 million
       Projected Ship Cost ^ '
                      fo\
       Operating Cost ^ '

       Ship Related Disposal Cost
                                              Total        $52  million

                                                           $75  million

                                                           $  1.1  million/14  day  voyage
                                                           $145/metric  ton of waste
(1)  Includes $14 million for subcontracted incineration systems.

(2)  Based on October 1982 contract award and March 1985 vessel  delivery,  assuming
    1no/ annual  inflation rate.
                                                   U.S.-flag incinerator ship  de-
                                                   velopment;

                                               2-   Establishment  of a  coordinated
                                                   certification  and permitting  pro-
                                                   gram for  an  applicant who wishes
                                                   to  establish a commercial incin-
                                                   eration at sea service;

                                               3.   Encouraging  and assisting state and
                                                   local authorities to  develop  water-
                                                   front integrated hazardous  waste
                                                   management facilities  to support in-
                                                   cinerator ships;

                                               4.   Development  of technical requirements
                                                   based on  existing international
                                                   standards and  national regulations
                                                   for the design and  operation  of in-
                                                   cinerator ship systems;

                                               5.   Planning and conducting research to
                                                   advance the  state-of-the-art  of in-
                                                   cineration at  sea,  e.g., polymeric
                                                   liner materials  for containment of
                                                   hazardous wastes, kinetics  of the in-
                                                   cineration process, 'and incineration
                                                   of  solid wastes at  sea;

                                               6.   Evaluation of  loan  guarantee appli-
                                                   cations from private industry for
                                                   U.S.-flag incinerator ship  develop-
                                                   ment; and

                                               7-   Environmental  assessment and desig-
                                                   nation of ocean incineration sites.

                                                  Early in 1981,  the National  Advisory
                                             Committee on  Oceans  and Atmosphere (NACOA)
   (3)  Based on  1985  start of operations.

 Estimated  Costs and  Schedule

     Ship  construction cost is conserva-
 tively estimated at  $75 million for vessel
 delivery in 1985 (Table 2).  Thirty months
 total  construction time is required.
 Operating  cost  includes ship capital cost
 depreciated over 15 years, but does not
 include waterfront terminal operations or
 waste  land transportation costs.
CONCLUSION

     Incineration at sea aboard specially
designed and equipped ships has been deter-
mined to be a cost-effective, technically
efficient, and environmentally acceptable
technology for the destruction of many
types of combustible hazardous waste, in-
cluding chlorinated organic chemical and
petrochemical wastes (17).  An Interagency
Review Board for the Chemical Waste Incin-
erator Ship Program has been formed to co-
ordinate and expedite all Federal Govern-
ment activities related to incineration at
sea.  (28)  Principal participants at this
time are the Environmental Protection
Agency, Maritime Administration, Coast
Guard,  and National-Bureau of Standards.
The work program of the Interagency Review
Board includes the following projects:

  1.  Investigation and pursuit of viable
      legislative amendments to provide
      additional  federal  assistance for
                                        231

-------
released a Report to the President and
Congress entitled, "The Role of the Ocean
In a Waste Management Strategy."  (29)
This special report is the culmination of
a two-year effort by NACOA to formulate
recommendations on use of the ocean as a
waste disposal medium.  NACOA is firmly
convinced that the United States must
reexamine present national policies and
regulations concerning waste disposal in
the oceans, and notes a high probability
that land, deepwell, and atmospheric waste
disposal activities will be reduced during
the 1980's in favor of ocean waste dis-
posal .  NACOA recommends that ocean dis-
posal of industrial wastes should continue
at sites where evidence indicates no un-
reasonable environmental degradation and
when human health, environmental, and
economic considerations indicate this is
the preferable option.  It is the opinibn
of this paper's authors that chemical
waste incineration at sea, when properly
regulated and control!edj thoroughly
satisfies these NACOA criteria and will be
a preferred, readily available, disposal
option for many hazardous wastes.
ACKNOWLEDGEMENTS

     The authors wish to express their
sincere gratitide to the members of the
Interagency Review Board for the Chemical
Waste  Incinerator Ship Program ahd its
predecessor, the Interagency Ad Hoc Work
Group, for their contributions to this
program.
REFERENCES

1.  ,  U.S.  Environmental  Protection  Agency.
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      Sheet,  Volume 5,  Number 2,  February
      1979,  page 12.

2.    U.S.  EPA.   Information  prepared for
      the U.S.  Senate Subcommittee  on Health
      and Scientific Research, June  6, 1980.

3.    U.S.  EPA.   EPA Activities Under the
      Resource  Conservation and Recovery
      Act of 1976,  Annual  Report to  the
      President and the Congress for Fiscal
      Year  1978, SW-755,  March 1979.

4.    U.S.  EPA.   Everybody's  Problem -
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5.   ILS.  EPA.   EPA Journal,  Cleaning Up
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6.   U.S.  EPA.   Siting of Hazardous  Waste
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7.   Wastler, T.A., C.K.  Offutt,  C.K.
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     014,  July 1975.

8.   U.S.  EPA.   Final Environmental  Impact
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     76X-054, July 8, 1976.

9i   Clausen, J.F., H.J.  Fisher,  R.J.
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     board the M/T Vulcanus.   EPA-600/2-
     77-196, September 1977.

10.  Ackerman,  D.G., H.J. Fisher', R.J.
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     Matthews,  E.L. Moon, K.H. Scheyer,
     C.C.  Shih, and R.F.  Tobias,  At-Sea
     Incineration of Herbicide Orange
     Onboard the M/T Vulcanus.  EPA-600/
     2-76-086,  April 1978.

11.  Paige, S.F., L.B. Baboolal,  H.J.
     Fisher, K.H. Scheyer, A.M. Shaug, R.L.
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     Assessment:  At-Sea  and  Land-Based
     Incineration of Organochlorine  Wastes.
     EPA-600/2-78-087, April  1978.

12.  Shih, C.C.j J.E. Cotter, D.  Dean,
     S.F.  Paige, E.P. Pulaski, and C.F.
     Thorne, Comparative  Cost Analysis
     and Environmental Assessment for
     Disposal of Organochlorine Wastes.
     EPA-600/2-78-190, August 1978.

13.  U.S.  Environmental Protection Agency,
     U.S.  Department of State, Final
     Environmental Impact Statement  for  the
     Incineration of Wastes at Sea Under
     the 1972 Ocean Dumping Convention,
     February 9, 1979.

14.  U.S.  Department of Commerce/Maritime
     Administration Chemical  Waste Incinera-
     tor Ship Project, MA-EIS-7302-76-
     041F, July 2, 1976.
                                           232

-------
15.  Halebsky, M., A Study .of the Economics
     and Environmental Viability of a U.S.
     Flag Toxic Chemical Incinerator :Ship.
     MarAd Report No. 04068-002, NTIS Report
     No. PB 291932to4, December 1978.

16.  Martinez, L.A., Hazardous Chemical In-
     cineration at Sea:  A Disposal Alter-
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     Thesis at the Massachusetts institute
     of Technology), February 1980.

17.  U.S. Environmental Protection Agency,,
     U.S. Department of Commerce/Maritime
     Administration, U.S. Department 'of
     Transportation/Coast Guard, U-.S.
     Department of Commerce/National Bureau
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     Work Group for the Chemical.Waste
     Incinerator Ship Program, NTIS Report
     No. PB-81-112849, September 1980. '

18.  U.S. EPA.  Code of Federal Regulations,
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19.  Marine Protection, Research, and
     Sanctuaries Act, 1972, (Public Law
     92-532), as amended by Public Law
     93-254.                •.:

20.  International Convention on the,
     Prevention of Marine Pollution by
     Dumping of Waste and Other Matter,
     1972, as amended.

21.  IMCO Mandatory Regulations for the
    • Control  of Incineration of Wastes
     and other Matter at,Sea, 1978,
     (Addendum to Annex I of the London
     Dumping Convention).

22.  IMCO technical Guidelines on the Con-
     trol of  Incineration of Wastes' and
     Other Matter at Sea, 1979.  '',

23.  Johnson, R.J., D.G. Aekermanv,and
     L.L. Scinto, Preliminary Criteria for
     Evaluation of At-Sea Incineration
     Activities, Volumes I and II.  EPA
     Contract No. 68-02-3174, Work
     Assignment No. 61, November 1981.

24.  Resource Conservation and Recovery
     Act, 1976, (Public Law 94-580).'

25.  U.S. Environmental Protection Agency,
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     Incineration Site Designation,
     October 1980.
26.  IMCO' Code for the Construction and
     Equipment of Ships Carrying Danger-
     ous Chemicals in Bulk, as amended,  '
  -   (IMCO Resolution A212 (VII)).

27.  U.S... Coast Guard.  Code of Federal   ;
     Regulations, Title 46, Part 153•-  ;;.
     Safety Rules for .Selt-Propelled
     Vessels Carrying Hazardous Liquids.

28.  Interagency Memorandum of Agreement
 ... .  from the Administrator, U.S. Environ-
    mental. Protection Agency., and the ,  .
     Assistant Secretary for Maritime    '
     Affairs, U.S-. Department of Commerce,
     Report .of the Interagency Ad Hoc Work
     Group for the Chemical Waste Incinera-
     tor Ship Program, October 8, 1980.

29.-  National Advisory Committee on Oceans;
     and Atmosphere, A Special Report to the
     President and Congress - The Role of
     the Ocean in a Waste Management
     Strategy, January; 1981.
                                           233

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                          ELIMINATION OF HAZARDOUS WASTES BY THE
                              MOLTEN SALT DESTRUCTION PROCESS
            James 6. Johanson, Samuel J. Yosim, Larry G. Kellogg, Seymour Sudar
                       Rockwell International, Energy Systems Group
                              Canoga Park, California 91304


                                         ABSTRACT

The Resource Conservation and Recovery Act (RCRA) imposes strict regulations on the
management of hazardous wastes.  Disposal of the wastes by any means that does not
result in conversion of the waste matter to ecologically harmless materials sets up a
continuing responsibility for prevention of damage to public health and to property.
Under RCRA, the waste generator must bear this continuing responsibility with its con-
comitant liability potential.  The generator's responsibility, however, can be terminated
by destruction of the waste material in conformance with RCRA regulations, which require
at least 99.99% destruction and removal efficiency (ORE) of all principal organic
hazardous constituents (POHC).  An exception to this rule is polychlorinated biphenyls
(PCBs) for which a minimum of 99.9999% ORE is required.  To meet these stringent require-
ments, much attention is being given to high-temperature combustion systems for hazardous
waste treatment.  This paper describes the Rockwell Molten Salt Destruction (MSD) process
and recent experimental results which demonstrate the high degree of destruction achieva-
ble with the MSD process.  These experiments were conducted with the support of the EPA,
Incineration Research Branch, Contract 68-03-3014, TMS II, Task 21, Subtask 1.  These
tests emphasized the treatment of chlorinated hydrocarbons with MSD.  Results of prior
MSD tests performed with a variety of hazardous waste materials are also described herein.
MOLTEN SALT DESTRUCTION PROCESS

     This process is based on the use of a
molten salt, such as sodium carbonate, as
a heat transfer and reaction medium.  In
the process, combustible waste and air are
continuously introduced beneath the surface
of a sodium carbonate-based salt at 1450 to
1850°F.  Figure 1 shows the molten salt
combustor schematically.  The combustible
material is added in such a manner that any
gas formed during combustion is forced to
pass through the melt before it is emitted
into the atmosphere.  The off-gas contain-
ing carbon dioxide, steam, nitrogen, and
unreacted oxygen is cleaned of particulates
in commercial applications by passing it
through a baghouse.

     Acidic gases, such as HC1 and S02,
produced from halogenated organic compounds
and sulfur-containing organic compounds,
                 STACK

                  f C02.H2O.H2.02
                        REMOVED PARTICULATES
Figure 1.   Schematic of molten salt
           waste combustion system.
                                           234

-------
  respectively, are neutralized and absorbed
  by  the alkaline Na2C03-  The ash intro-
  duced with the combustible waste is also
  retained  in the melt.  The char from the
  fixed carbon is consumed in the salt.  The
  temperatures of oxidation are too low to
  permit a  significant amount of NOX to be
  formed by fixation of the nitrogen in the
  air.

      The scrubbing function of the sodium
  carbonate leads to the formation of other
  sodium salts.  Ash, introduced by the waste,
 must be removed when it becomes excessive
  to preserve the fluidity of the melt.  An
 ash concentration of about 20 wt % provides
 an ample margin of safety for the melt
 fluidity.  In some applications, the melt
 can be removed batchwise.  In other applica-
 tions, a side stream of the melt is with-
 drawn either batchwise or continuously and
 is processed.   If desired,  the melt may be
 quenched in water, the solution filtered to
 remove the ash,  and  processed to recover
 the carbonate  which  is then recycled to the
 combustor.

      Sodium carbonate  is  used because  it is
 compatible with  combustion  products,  C02
 and H20,  and because  it reacts with  acidic
 gases  such as  HC1  (produced  from organic
 chloride  compounds).   It  is  stable,  non-
 volatile,  inexpensive, and nontoxic.

      Data  are  reported from  tests conducted
 in  two different-sized systems.  One system
 is  a  6-in.-diameter bench-scale  unit for
 feasibility and optimization tests (up to
 approximately 3 Ib/h).  The other system
 is a pilot-scale unit (up to approximately
 250 Ib/h)  for obtaining engineering data
 for the design of an actual plant.
DESTRUCTION OF HEXACHLOROBENZENE AND
  CHLORINE

     A program to test the destruction of
solid hexachlorobenzene (HCB) and liquid
chlordane by the MSD process was completed
for the Environmental Protection Agency
under Contract 68-03-3014, Task 21, Sub-
task 1.  The HCB was selected as a stand-in
for PCBs; chlordane was selected as an
example of a liquid organic chlorinated
waste.  The experimental .portion of the
program consisted of bench-scale tests
and pilot-scale tests.
 Bench-Scale  Tests

 Test Apparatus  and  Waste  Streams

      The  overall objective of  the bench-
 scale tests  was to  provide a data base
 for the pilot-plant tests.  A  schematic
 of the bench-scale  combustor is provided
 in Figure 2.

      The  hexachlorobenzene, mixed with
 coke (70  wt  % HCB - 30% coke)  to increase
 the heating  value,  contained (on a weight
 basis) 98% HCB  and  2% inerts.  The chlor-
 dane,  mixed  with kerosene (60  wt %
 chlordane, as received -40% kerosene),
 contained 61.1% carbon, 27.8%  chlorine,
 and 8.7%  hydrogen.

      HCB-coke feed  rates varied from 1.7
 to 3.2 Ib/h, and chlordane-kerosene feed
 rates  varied from 0.9 to 1.4 Ib/h.  The
INJECTOR TUBE
AIR IN

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ATTACHED HERE)
^sL— STAINLESS-STEEL

RETAINER VESSEL
^- 3.7 cm ID ALUMINA
FEED TUBE
*. MARSHALL FURNACE
^^15 cm ID
ALUMINA
TUBE
—-15 cm DEPTH OF
MOLTEN SALT
   Figure  2.   Bench-scale molten  salt
              combustor  schematic.
                                          235

-------
air feed rate was 2.5 scfm.  The super-
ficial air velocity through the melt was
I ft/s.  The NaCl content of the melt
increased with the amount of waste proc-
essed.  It reached 88 wt % in the case of
HCB and 55 wt % in the case of chlordane.

Sampling and Analysis Procedures

     Portions of the off-gas were sampled
with a sampling line consisting of:
(1) a heated glass fiber filter which re-
moved particulates, (2) a heat exchanger
which cooled the gas to a proper absorption
temperature, and (3) polyurethane foam
plug(s) which capture the HCB or chlordane
in the off-gas followed by toluene-contain-
ing impingers to trap any material which
escaped the polyurethane foam plug.  These
samples, along with samples of the melt,
were analyzed for undestroyed HCB and
chlordane.  The sampling and chemical
analyses for HCB and chlordane were done
in accordance with EPA-appr6ved modifica-
tions to EPA Methods 612 and 608, respec-
tively.  A gas chromatograph equipped with
an electron capture detector was used in
this analysis.  A schematic of the sampling
:rain for capturing undestroyed HCB and
chlordane is shown in Figure 3.

     The analytical procedures described
below follow the methods recommended in
EPA Methods 608 and 612 for organochloride
pesticides.

Sample Extraction and Connection.  The
polyurethane plug and glass fiber filter
were placed in Soxhlet extractors and
extracted with methylene chloride for
about 10 h.  Melt samples were dissolved
in water.  The resulting solutions were
then extracted with methylene chloride
using a separatory funnel.  The extracts
were quantitatively transferred to Kuderna-
Danish (K-D) evaporators.  When the apparent
volumes of each extract reached 1 to 2 ml,
the K-D apparatus was moved and allowed to
drain while cooling.  Fifty (50) ml of
hexane was added to each extract, and the
resulting solutions were then concentrated
to a final known volume of 1 to 5 ml.  Known
aliquots of impinger solutions and probe
washings were directly injected into the
gas chromatograph for analysis.
Gas Chromotographic Analyses.   Analyses
of hexachTorobenzene and chlordane were
conducted using a chromatograph with an
electron capture detector.   The chromato-
graphic column was a 6-ft x 4-mm-ID glass
column packed with 100/120 Supelcoport
coated with 1.5% SP2250 and 1.95% SP2401.
This column is recommended in  EPA Method
608 for organochlorine pesticides and PCS
analyses.  Confirmation of hexachloroben-
zene or chlordane was done on  selected
samples by a gas chromatograph-mass spec-
trometer (6C-MS) using characteristic ions
at m/e 284 for HCB and m/e 373 for chlor-
dane.  Only the electron impact mode was
used in this GC-MS work.  Degradation pro-
ducts were also analyzed, and  their mass
spectra was searched and compared to EPA/
NIH or special priority pollutant libraries
to identify the most probable  chemical
compounds.  The GC-MS analysis of the
samples has shown mainly the presence of
unburned hydrocarbons anthracene and
other polynuclears along with  some chlor-
inated derivatives (during off-spec
conditions).  Furans and dioxins were not
detected using conventional GC-MS analysis.

HCB Results

     The results of the HCB destruction
tests are shown in Table 1 and include
the concentration of HCB in the off-gas
and in the melt as well as the destruc-
tion removal efficiency.  The  destruction
removal efficiency is defined  as 100%
minus the percent of HCB in the feed
emitted to the atmosphere and  thus does
not include the contribution from the
melt.  No HCB was detected in  any of the
melt samples, despite the very low detec-
tion limits (less than 1 ppb)  for HCB.

     Excellent destruction was obtained
in all cases.  The best destruction
removal efficiency, greater than 7/9's
(>99.9999986%), was obtained at 1839°F
with 118% of stoichiometric air.  Excel-
lent destruction removal efficiencies
were also obtained at 127% stoichiometric
air and 1656°F (>99.999974%) and at 70%
stoichiometric air and 1848°F (>99.999982%)
The last result indicates excellent
destruction even when excess air is not
used.
                                           236

-------
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                        237

-------
                              TABLE 1.  SUMMARY.OF HCB RESULTS
Temp
(°F)
1839
1848
1656
% stoich
air
118
70
127
Cone of HCB
in off-gas
ppmv
<0. 00017
<0.0031
<0.0028
mg/m3
<0.0019
<0.037
<0.033
Destruction
Cone of HCB removal
in melt efficiency
(ppmw) («)
<0. 00100
<0. 00040
<0. 00110
>99. 9999986
>99. 999982
>99. 999974
  No HCB was detected in any melt sample
even though melt samples were taken while
HCB was being fed.  Thus, the concentration
of HCB in the melt was, at most, ,1 ppb in
spite of the short residence time of the
feed in the expanded melt (^3/4 s).  This
is an excellent indication that the spent
melt is nontoxic.

  The concentration of HCB. in the off-
gas was extremely low in all cases.  In
the 1839°F test with excess air, the con-
centration of HCB was only 0.00017 ppmv or
0.0019 mg/m3.  In the 1656°F test and in
the test with 70% of stoichiometric air,
the concentrations were higher by an order
of magnitude but still extremely low
(0.003 ppmv or 0.03 mg/m3).

Chlordane Results

  The results of the chlordane destruc-
tion tests are shown in Table 2.

  The sensitivity of the electron capture
detector is significantly less for chlordane
(60 ng/ml) than for HCB (1 ng/ml) due to the
relative chlorine contents of the molecules
and the number of different chlordane com-
pounds in the feed. Thus, the detection
limits were considerably higher than those
of HCB.
  Excellent-chlordane destruction was
obtained in the excess air tests.  In
these tests, two peaks with the same
elution times as two of the four charac-
teristic chlordane peaks were present.
These peaks were assumed to be chlordane
for the calculation of destruction removal
efficiencies.  With this conservative
assumption, the destruction removal
efficiencies were greater than 99.9999%.

  In the test with 81% of stoichiomet-
ric air, in which larger peaks were found,
three peaks with the same elution time as
three of the four characteristic chlordane
peaks were present in all samples except
the impinger and the melt sample.  How-
ever, when the first plug was examined
by gas chromatograph-mass spectrometry,
the three peaks with elution times similar
to chlordane were identified as not due
to chlordane isomers.  Thus, the~cFflordane
destruction efficiencies were probably
much greater than 99.99%, which was
calculated assuming the three "chlordane"
peaks were actually due to chlordane.

  No chlordane was detected in any
melt sample even though melt samples were
taken while the chlordane was being fed.
Thus, the concentration of chlordane in
the melt was, at most, 12 ppb.
                           TABLE 2. SUMMARY OF CHLORDANE RESULTS
Temo
1930
1836
1648
% stoich
air
121
81
118
Cone of chlordane
in off-gas
ppmv mg/nv-'
<0. 00132 <0.0447
O.243 <4.08
<0. 00267 <0.0220
Cone of chlordane
in melt
(ppmw)
<0.0090
<0.0120
<0.0080
Destruction
removal
efficiency
(*)
>99. 9999951
>99.9934
>99. 999903
                                           238

-------
      The  concentration  of  chlordane  in  the
 off-gas was  very  low.   In  the  183QOF test
 and  in the 16480F tests (both  with excess
 air), the concentration of chlordane was
 <0.001 and <0.003 ppm,  respectively.  The
 concentration  of  chlordane in  the test
 with 81%  of  stoichiometric air was
 <0.243 ppm.  However, the  fact that  the
 peaks (at least in the  plug) could not  be
 confirmed as chlordane  by  the  GC-MS  indi-
 cates that the chlordane concentration  is
 much less than this value.

 Pollutant Concentrations from  HCB
  and Chlordane Tests

      No chlorine  or phosgene was detected
 in the off-gas.   The limits of detection
 of chlorine and phosgene are 0.2 and
 0.3  ppmv, respectively.  The HC1 concentra-
 tions were <100 ppm.  No H2 or CH4 was
 detected  except with less  than 100%  of
 stoichiometric air.  As  expected, the NOX
 levels were very  low (<50  ppm).  The CO
 levels were higher than  desired (up  to
 2.4%) in  the excess, air  tests.  Such high
 values have been  noted  before  in this lab-
 oratory when chlorinated aromatic compounds
 were destroyed in  NagCOs melts  containing
 large amounts  of  NaCl.   However, the CO
 concentrations decreased markedly with
 increasing melt temperature and with in-
 creasing  percent  stoichiometric air.
 While destruction  efficiency and destruc-
 tion removal  efficiencies  of 99.9999% and
 better can be  achieved with excess air  at
 1830QF and at  16480F, a  temperature of
 1830QF is preferred over 16480F since CO
 emissions are much lower at the higher
 temperature.

 Pilot-Scale Tests


     The Molten Salt Test  Facility (MSTF)
was operated for a total of 96  h to provide
five data points each for demonstrating
destruction of HCB and chlordane.   A
 schematic of.the MSTF, including the two
 sample locations used for these experi-
ments, is shown in Figure 3.  Sample Loca-
tion 1 was immediately after the molten
salt destructor, i.e., just upstream of the
particulate drop box.   Sample  Location 2
was just downstream of the baghouse.   The
feed rates of HCB and chlordane were as
 high as 269 and 72 Ib/h, respectively,  in
 these  tests.  The  tests were conducted at
 melt temperatures  from 1645 to  18160F and
 from 78  to  151% of stoichiometric air.
 Sampling for unreacted HCB and  chlordane
 was done in the exhaust of the  molten
 salt combustor, in the exhaust  of the
 particulate baghouse downstream of the
 combustor,  in- the  residual baghouse salt
 bottoms, and in the salt melt overflow
 from the combustor.


     The maximum total air feed rate
 corresponded to a  2.7-ft/s superficial
 velocity in the bed.  Testing was done
 in 0.5-  to 2.0-h test periods with a
 minimum  1 h of vessel purging and up to
 3 h of process stabilization between
 sampling periods.   Destruction  gas
 sampling was done  during each sampling
 period.  Auxiliary coke fuel was used
 throughout the various waste burn periods
 as required to maintain nominal operating
 conditions.  Between burn periods, coke
 or diesel oil was  the only combustible
 material fed to the vessel.  The salt bed
 composition in all  cases was maintained
 at 50 wt % sodium  chloride and  50 wt %
 sodium carbonate to simulate nominal
 steady-state bed compositions for organor-
 chloride waste destruction.


 HCB Test Results


     The HCB feed  rate varied from 46 to
 269 Ib/h.  Coke was used as auxiliary
 fuel  in all  tests  except 3B, where no
 auxiliary fuel  was needed.  Bed tempera-
 tures varied from  1685 to 18050F.


     The test results are summarized in
 Table 3.  Runs 1 and 2A were conducted
essentially under  the same test conditions.
An HCB concentration of 0.27 yg/m3 was
determined in the combustor exhaust
 (Sample Location 1) on Run 1 using a plug
 sampler.  On Run 2A, no HCB was detected
 in the combustor exhaust using an impinger
 sampler  (HCB  0.8 yg/m3).  " No HCB was
detected in the exhaust from the baghouse
 (Sample Location 2) for Run 1.   Based on
the HCB detection  limit and the size of
the baghouse gas sample,  this resulted in
an HCB concentration in the final  system
exhaust of less than 0.006 yg/m3.   An HCB
sample was  not taken in the baghouse
                                           239

-------
                                                                              GAS
                                                                             VENT
SPENT
MELT
OVERFLOW
INTO
DRUMS
         LIQUIDS
         FEED
   n ' [^.Iffi-iffi
jpjL^^w^^
                 MOLTEN SALT
                 DESTRUCTOR
           Figure 4.  Molten Salt Test Facility including sample  locations.
                    TABLE 3....SUMMARY QF  PILOT-SCALE TEST RESULTS

Combustor off -gas
ppmv
Baghouse
mg/m3
ppmv
Spent melt, ppmw
NOX, ppmv
HC, ppmv
3
Parti cul ate, mg/m
ORE, %
Note: The pH of the
line remained
HC1 emission.

2.7
2.3
<6
<5.2



liquid
basic

x 10
x 10
x 10
x 10

<6.2

HCB
-4 ?
-5-6!
-6-l.
-7-l.
0.001
x 10"3
11-9's
in a small
throughout
Chlordane
1 x
1 x
6 x
4 x
—
ID'2
ID"3
io-4
io-5
0.104
70 - 125
35 - 110
-0.107
—
9-9's
sampling
the test
5.3
3.2
<3.6
<2.1

4.1
x
x
x
x

x
10
10
10
10

10
-3 _
-4 _
-4 _
-5 _
0
-3 _
6.8 X
4.1 x
<4.4 X
<2.6 X
io-2
io-3
10"3
io-4
.0044 - 1.2
0.5 -630
0.4 - 60
1.75 x IO"2
8-9's. -7-9's
scrubber
indicating
in the off-gas
essentially no
                                       240

-------
exhaust (Sample Location 2) for Runs 2A or
3A, and the DRE values reported for these
two runs are based on the Sample 1 HCB
values.  The DREs for Runs 1 and 2A were
greater than 10/9's (99.99999999) and
8/9's, respectively.

     Run 2B was made at 75.8 Ib/h HCB feed
(approximately 30% of the total thermal
load).  Measurements for HCB showed
22.0 yg/m3 at Sample Location 1 and less
than 0.027 yg/m3 at Sample Location 2.
The molten salt bed temperature was held
at 1685°F during the run.  The DRE was
>9/9's.

     Run 3A was made at 112 Ib/h HCB feed.
An impinger measurement of less than
1.3 yg/m3 in the vessel exhaust corre-
sponded to a calculated DRE of greater
than 8/9's.

     Run 3B was the last run of the test
series, and since results up to then were
so promising, it was decided to test the
molten salt unit with 100% HCB feed,
i.e., no auxiliary fuel coke was used.  A
feed rate of 269 Ib/h HCB was used to main-
tain the vessel at a temperature of 1805°F
The HCB in the off-gas was 71 yg/m3 down-
stream of the combustor and 0.16 yg/m3
downstream of the baghouse.  Note that
this was the only run in which HCB was
actually detected in the system's ex-
haust to the atmosphere.  The 71
yg/m3 and 0.16 yg/m3 figures imply a
baghouse removal efficiency of 99.77%.
Post-test inspection of baghouse filters
verified the presence of tears in the
fabric.

     Measured residual HCB in the molten
salt overflow is shown in Table 3 for
Tests 2B and 3B.  The measured HCB con-
centration in the molten salt overflow
was only 0.001 yg/g of melt in Test 2B
but was 0.1 yg/g of melt in Test 3B.  It
may be that the last value was a result
of contamination.

     The salt dust from the baghouse
contained <0.001 yg/g of dust; it could
be recycled continuously back to the
combustor if the HCB concentrations in
the dust were of concern.  Otherwise,
this residual material would be disposed
of as nonhazardous waste, as would the
melt overflow.
TEST CONCLUSIONS

     Bench-scale testing of HCB and chlor-
dane was performed to optimize process
parameters and verify analytical techniques
to be utilized in pilot-scale tests which
followed.  For HCB destruction at a nomi-
nal salt bed temperature of 1839°F, a
stoichiometry of 118%,and a residence time
of 2-3/4 s, a destruction removal efficiency
of _>99.9999986%  was achieved.  Concentra-
tion of HCB in the off-gas and the salt
bed, sampled during HCB feed, was
<0.000017 ppmv and <0.00100 ppmw, respec-
tively.  For chlordane destruction, at a
lower salt bed temperature of 1648°F and
similar stoichiometry and residence time,
a destruction removal efficiency of
>99.999903% was achieved.  Concentrations
of chlordane in the off-gas and salt bed
were <0.00267 ppmv and <0.0080 ppmv,
respectively.  Additionally, no chlorine
or phosgene was detected within the ana-
lytical limits.  HC1 and NO^ were deter-
mined to be <100 ppm and <50 ppm, respec-
tively.  Monitoring, sampling, and analyti-
cal techniques to ensure conformance to
EPA standards were verified.  Additionally,
a data base was established and subsequent-
ly verified for correlation of bench-scale
and pilot-scale tests.

     Pilot-scale tests of the same materials
under similar process conditions  produced
similar or better destruction efficiencies.
Typically, destruction efficiencies were
>99.99999%.  Improved performance charac-
teristics in the pilot-scale units were
attributed to greater salt inventory and
greater residence times, the latter
approaching 2 s.  System limits were
challenged by deliberate introduction of
plant upset conditions.  Stoichiometry
was reduced to 0.78% from the nominal
120%; bed temperature was reduced'over
115°F from the nominal operating tempera-
ture of 1830°F; superficial air velocity
was increased from 2.0 fps to 2.7 fps;
feed throughput was more than doubled; and
auxiliary fuel was cut off in one case.
None of these conditions resulted in off-
gas emissions or POHCs in the spent melt
which.would be considered hazardous by
RCRA criteria.  Under these upset condi-
tions, maximum concentrations of feed
material in the combustor off-gas and
spent melt was <0.0061 ppmw and <1.2 ppmw,
respectively.  Stack emissions were
                                           241

-------
<640 ppmv NOX and <110 ppmy hydrocarbons.
A small sampling scrubber in the off-gas
remained basic throughout the test series,
indicating essentially no HC1 carryover.

     In summary, these tests provided quan-
titative data on the performance of the
Molten Salt Process in the destruction of
hazardous waste.  The data indicates more
than adequate destruction  efficiencies in
accordance with RCRA criteria.  These
efficiencies were obtained with stack
emissions and process spent melt residue
characteristics v/ell below minimum
criteria for environmentally acceptable
discharges.  The data supports considera-
tion of the Molten Salt Process as an
environmentally acceptable alternative
technology for the destruction of hazard-
ous waste.
ENGINEERING STATUS

Reference Commercial System Design

     Energy Systems Group has completed
conceptual design of an MSD plant capable
of 2000-lb/h throughput for liquid PCB.
The plant is also capable of destroying
other liquid and solid wastes.  Design
modifications may be needed on a case-by-
case basis after evaluation of performance
requirements.  Figure 5'is a schematic of
this plant and Figure 6 is an artist's
concept.
                                          COMBUSTORS
                                                        SALT DISPOSAL
                          Figure 5.  Simplified plant schematic.
               Figure 6.   Molten salt destruction plant for hazardous wastes.

                                           242

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                         EVALUATION OF HAZARDOUS WASTE
                   INCINERATION IN A .DRY PROCESS CEMENT KILN
                             Gregory M.  Higgins and
                           Arthur J. Helmstetter,  P.E.
                               SYSTECH Corporation
                                Xenia,  OH  45385
                                    ABSTRACT
     This  report  presents  the preliminary results of a test program  conducted
by  SYSTECH Corporation  at  the Marquette Cement  Plant  in  Oglesby,  Illinois.
The objective  of  this program was  to compare the emissions resulting from  co-
firing  low chlorine, high  Btu liquid waste and coal in a  dry  process  cement
kiln with  the  emissions resulting  from firing coal only.

     The characteristics of  the liquid waste burned during the test were exam-
ined by performance of  standard analytical methods, with  particular  emphasis
on  organic composition. Destruction  and  removal  efficiencies  (DREs)  were
calculated for four principal organic hazardous constituents  (POHCs)   of  the
fuel:   methylene  chloride; methyl   ethyl  ketone;   1,1,1-trichloroethane;  and
toluene.   Additional analyses were conducted on the stack gases  to  determine
particulate loading, S02,  NOX,  total gaseous  nonmethane  organics  (TGNMO),
HC1, and metals emissions.   The kiln dust was also sampled  and  analyzed  for
metals  and Extraction Procedure (EP)  toxicity.

     The results  of these  tests indicate that the cement kiln may be an  ideal
method  of  disposal for  low chlorine,  high Btu liquid wastes.  The  burning of
liquid  wastes  in  the kiln  did not  lead to any significant increase in particu-
late loading,  S02, NOX,  TGNMO,  or  HC1 over the levels observed during   base-
line coal-only test periods.   Among the metals examined,  only lead  was  found
to  significantly  increase  in emission rate during the liquid waste firing.  No
significant differences were observed in the EP toxicity  of  the  kiln  dusts
sampled during the liquid waste and baseline tests,  and only the concentration
of  lead was found to significantly increase in  the  kiln  dust.    Within  the
detection  limits  of the test method employed,  the  four  POHCs  measured  were
completely destroyed in the  kiln.
INTRODUCTION

     Marquette Company operates a ce-
ment plant in Oglesby, Illinois, which
produces approximately 450,000 tons
of cement yearly.  Pulverized coal
has been the primary fuel for this
facility.  Marquette  proposes  to
                                         243

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construct and operate  a liquid  waste fuels
resource recovery  system  at  the   Oglesby
plant  to  facilitate   the  use   of   select
combustible  liquid waste materials  such as
high Btu (10,000 to  14,000  Btu/lb),   low
chlorine (2  to  5 percent)   waste solvents
as supplemental fuel   in  the  kiln.    The
primary fuel will remain coal with  an
estimated 25 to 40 percent  of the  heat
required  by the  manufacturing   process
supplied by  the energy content   of   liquid
waste  materials*   In order to  assess   the
environmental effects   of   burning   liquid
wastes in the   kiln,   Marquette,  in  con-
junction with the  U.S. Environmental  Pro-
tection Agency  (EPA),  the   Illinois Envi-
ronmental Protection   Agency  (IEPA),   and
SY.STECH Corporation performed a series  of
tests  on the cement  kiln   at  Oglesby  on
October 26 through 31, 1981.

     The liquid waste  fuels burned  at   the
Oglesby facility were  low  chlorine,  rela-
tively high  Btu waste   solvents from   ink
and paint manufacturing and  solvent   re-
covery processes.  Wastes  of  this type are
classified as hazardous under the Resource
Conservation and Recovery  Act (RCRA) regu-
lations primarily  because  of  their  ignita-
bility, and  have generally been considered
unsuitable for  recycling   or	reclaiming.
Materials of this  type have  traditionally
been disposed in landfill   or  incinerated
without  recovering  their useful   energy
content*  Incineration of  such  wastes  in a
ceaent kiln  has the potential of minimiz-
ing any environmental   damage  from their
disposal by  destroying their  combustibles
while  simultaneously    recovering   their
useful energy content. Because  of the  high
temperatures (2700° to 3000°F),  long   gas
retention times (approaching  10 seconds),
and high alkalinity in cement kilns,   even
highly toxic wastes such as PCBs have  been
demonstrated to be effectively   destroyed.
Earlier tests have  demonstrated destruc-
tion and removal   efficiencies   (DREs)   of
such compounds  exceeding 99.99  percent.1»2

     The primary objective of   the tests
conducted in this  program  was  to   charac-
terize the   baseline   emissions from   the
process when only  coal was fired   and  to
compare the  results  from   this situation
with those obtained when a combination  of
liquid waste and coal  was  being fired  in
the kiln.  Specific emphasis was placed on
characterizing  the DREs of four principal
organic hazardous constituents (POHCs)  of
the  liquid  wastes:  methylene  chloride;
methyl  ethyl   ketone;   1,1,1-trichloro-
ethane;  and  toluene.   The  experimental
design and test methods used were develop-
ed to permit a comparison to be  made  be-
tween these two conditions rather than  to
accomplish  a   definitive   environmental
assessment of the burning of liquid wastes
in a cement kiln.  Therefore, it should be
emphasized that the main purpose  of  this
program was to determine whether co-firing
liquid wastes increased the emissions over
those normally  observed  during  baseline
conditions.  The only statistically  valid
conclusions which can be derived from this
test program  fall  into  two  categories:
either the  emissions  were  significantly
increased or else no significant  increase
was observed.  Although the mean values of
the data collected  may  at  first  glance
seem  to  indicate  differences,  only  by
considering the numbers of  samples  taken
and the calculated sample standard  devia-
tions can statistically valid  conclusions
be reached.  This summary  report  focuses
on system emissions while  the  final  EPA
report will include information  regarding
any effects that the liquid waste may have
had on the characteristics of  the  cement
product.  These effects are expected to' be
negligible and should not impact  the  en-
vironmental considerations regarding  this
project.

METHODS

     The test  program  conducted  at  the
Oglesby facility was designed  to  collect
2 days of samples and data during both the
baseline and liquid waste burns.   Because
of difficulties encountered  in  receiving
and delivering a  sufficient  quantity  of
liquid waste and periodic unscheduled kiln
down times, however, only 1 day of testing
was accomplished  with  liquid  waste  and
only 1 1/2  days  during  baseline  condi-
tions.

     Figure 1 shows a schematic flow  dia-
gram of the dry process cement kiln tested
at Oglesby.  Samples and  data  were  col-
lected from the sites labeled A through E.
Liquid waste was  pumped  -from  a  storage
                                           244

-------
 tanker  into  the  flame of the kiln  through
 a   specially  designed  delivery   nozzle.

     The  liquid  waste burned in  the  test
 program was  sampled  at Site A and analyzed
 for heating  value, chlorine,  sulfur,   ni-
 trogen, and  water  content by standard  ASTM
 reference methods.   Method  8.01  (SW   846
 Test Methods for Evaluating  Solid  Waste;
 Physical/Chemical  Methods) was employed to
 identify  the concentrations  of  methylene
 chloride;  methyl ethyl ketone;   1,1,1-tri-
 chloroethane;  and  toluene.  Other organics
 were qualitatively identified by a general
 scanning  procedure employing  gas  chroma-
 tography  with flame   ionization  detection
 (FID).    Metals  were  identified  by   in-
 ductively coupled  plasma  emission spec-
 troscopy  (ICP).  Atomic  absorption spec-
 troscopy  (AA)  was   employed  for  mercury
 analysis.

     .Stack   emissions  were   sampled  at
 Site C  and examined  for total gaseous  non-
 methane organics (TGNMO)  by EPA Method 25.
 Integrated bag samples of stack gases  were
 analyzed  by  gas  chromatography  with   FID
 according to EPA Method 23  for  methylene
 chloride;  methyl ethyl ketone;   1,1,1-tri-
 chloroethane;  and   toluene  (see  Federal
 Register,  June 11, 1980,  and EPA 600/4-80-
 003).  Particulate emissions were measured
 by  EPA Method 5, and S02  was measured   by
 a modified EPA Method 8 procedure  employ-
 ing 3 percent H202 in the  impingers  to
 collect S02  and  sulfuric  acid mist.  Metals
 emissions  were determined from an analysis
 of  the Method 5  filters  and  the  acetone
 probe rinses  by  ICP  spectroscopy.  Mercury
 emissions  were determined by AA  spectros-
 copy.  Emission  of   nitrogen  oxides   was
 determined by  EPA   Method  7.    A  midget
 impinger  train containing sodium hydroxide
was  used  to  collect  hydrochloric  acid
 emissions.  Analysis of the impinger  con-
 tents was  accomplished  by a  mercuric   ni-
 trate titration.

     The kiln dust   collected  at  Site D
 from the  last two banks   of  the  electro-
 static precipitator  (ESP_)  was  analyzed for
metals by  ICP spectroscopy.   Mercury   was
analyzed by AA spectroscopy.    The  poten-
 tial for  leaching of metals  from this  dust
was  assessed  by  conducting  EP  toxicity
 tests.
RESULTS AND DISCUSSION

     Figure  2  illustrates  the    testing
and process operating  log  for  the   test
period.  It is evident that the  kiln  ex-
perienced several  periods  of  down   time
during the  tests.   Three  tests,  desig-
nated Test Nos. 1, 2,  and  3,  were   con-
ducted during the liquid  waste  burns  on
October 28, 1981.  Test Nos. 4, 5,  and  6
were conducted during  baseline  burns  on
October 30 and 31, 1981.  Each  test   con-
sisted of  approximately  2  hours  during
which samples  and  data  were  collected.

     The liquid waste used for  this   test
was typical of that which would be  speci-
fied for a permanent  facility  operation.
The liquid waste was  sampled  every   hour
during the  test  period,  and  composites
were made of the hourly samples to  repre-
sent the material  fired  during  each  of
the three co-firing conditions.   The  re-
sults of these analyses are  presented  in
Table 1.  The  liquid  waste  had   a  mean
heating value of 12,350 Btu/lb and  a  mean
chloride content  of  4.54  percent.   The
primary metallic constituent of the waste
was lead, with  a  mean  concentration  of
1,800 ppm.  No PCBs were detected   in  the
waste and the POHCs designated  for these
tests comprised an average of 24.7  percent
of the liquid waste.   The  other   organic
constituents listed in Table 1 were quali-
tatively identified by retention  time  in
the GC analysis.

     It  is  anticipated  that  in  normal
operation a substitution  rate  of  25  to
40 percent liquid  waste  would  be used;
however, during the test  period  a limi-
tation on the  quantity  of  liquid waste
available precluded firing  the  waste  at
these rates.  The substitution  rates  for
the liquid waste expressed as a percent of
the total heat input of the combined  coal
and liquid waste stream were 14.0   percent
for Test No.  1,  11.2  percent  for  Test
No. 2, and 12.8 percent for  Test   No.  3.

     Stack emissions measured  during  the
test program are shown in Table  2.   None
of the POHCs measured were detected In the
stack gas samples during either  co-firing
or coal-only combustion.   Table  3 shows
                                           245

-------
the DREs of the kiln for the  POHCs  meas-
ured during the liquid waste tests.  Since
none of the POHCs  were  detected  at   the
minimum detection limit of  the  test method
(nominally 0.1 ppra),  the   DREs  expressed
can be  considered  minimum values.    The
efficiency of combustion of organic  com-
pounds is also supported by the results of
the Method 25 tests which show no signifi-
cant increase at a 95  percent  confidence
level in TGNMO emissions during  co-firing
when compared with baseline results. These
results indicate that there is no  measur-
able contribution to the hydrocarbon emis-
sions from the stack due to the  addition
of liquid waste to the kiln.

     In addition to hydrocarbons, Table 2
also presents the particulate,  S02,  NOX,
and HC1 emissions under the co-firing con-
dition for Test Nos. 1, 2,  and  3  versus
the coal condition during Test Nos. 4,  5,
and 6.  Although unstable   operating  con-
ditions  contributed  considerable  varia-
bility within the data sets, there was  no
significant increase at a 95 percent  con-
fidence level over baseline conditions  in
particulate, S02,  NOx, or  HC1  emissions
while cofiring liquid waste.

     Table 4 shows the results  of  metals
analyses  of  .stack  particulates  sampled
during this test.  A  slight  increase  in
lead emissions  over  baseline  conditions
(from .04 to .072 Ib/hr) was observed dur-
ing the  co-firing  tests.   Other  metals
examined did not increase significantly at
a 95 percent  confidence  level  with   the
burning of the  liquid  wastes.   Table 4
also shows the results of metals  analyses
of the kiln dust sampled during this test.
An increase in the lead  concentration  in
the kiln  dust  was  observed  during   the
liquid waste firing.   This  increase   was
from  approximately  .02  percent   during
coal-only conditions to .05  percent  dur-
ing the co-firing conditions.   The  other
metals present in the  liquid  waste  were
not observed to significantly increase  in
concentration at a 95  percent  confidence
level in the kiln  dust  when  the  liquid
waste was co-fired in the kiln.   Further,
the leachability of metals  from  the  kiln
dust did not  increase  significantly   and
remained orders  of  magnitude  below   the
allowable limits  specified by  the  EPA.
     The inclusion of metals in the liquid
waste burned in the cement kiln appears to
have had a minimal impact on the discharge
of metals from the stack or on the  amount
occurring in the kiln dust.  This may  in-
dicate that many metals are  deposited  in
the cement clinker and become incorporated
in the crystalline structure of the cement
product.

CONCLUSIONS

     The general conclusion  that  can  be
drawn from this test program regarding the
the environmental impacts of firing liquid
wastes in a cement kiln is that the liquid
waste does not significantly increase  the
emissions of particles, hydrocarbons, S02,
NOX, or HC1 from the  stack.   Within  the
detection limits of the test  methods  em-
ployed, the four POHCs examined were  com-
pletely destroyed in the kiln.   A  slight
increase in lead in  the  particulate  and
kiln dust was observed, but  other  metals
examined did not show  a  significant  in-
crease either in stack emission or in  the
process   collected  kiln  dust  with  the
burning of the  liquid  waste.   The  kiln
dust was determined  by  the  EP  toxicity
test to be nonhazardous and could be land-
filled even when  liquid  wastes  are  co-
fired.  In  general,  the  use  of  liquid
waste in this  test  produced  only  minor
changes in the emissions from the kiln and
revealed that the kiln may provide a prom-
ising waste disposal method for high  Btu,
low chlorine wastes.

REFERENCES

1.  Ahling,  B.,  "Combustion  Test   with
    Chlorinated Hydrocarbons in  a  Cement
    Kiln at  Stora  Vika   Test   Center,"
    Swedish Water and  Air  Pollution  Re-
    search Institute, Stockholm, March 16,
    1978.

2'.  Knut Trovaag, "Hazardous Waste  Incin-
    eration  in  a  Cement  Kiln,"  Inter-
    national  NATO/CCMS  Hazardous   Waste
    Symposium, October 5, 1981.
                                            246

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                     TABLE  1.   WASTE FUEL ANALYSIS

Heat content (Btu/lb)
Ash (%)*
Chloride (%)
Sulfur (%)
Nitrogen (%)
Water (%)
Metals (ppm)
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Quantified organics (%)
Methylene chloride
1,1, 1— trichloroethane
Methyl ethyl ketone
Toluene
PCBst '
Other organics (%)§
Methanol
Ethanol
2-Propanol
Acetone
Methyl acetate
Ethylene chloride
2-ethoxy-ethyl acetate
Methyl isobutyl ketone
Butyl acetate
4-hydroxy-4-methyl-2-pentanone
Benzene
Ethyl benzene
Styrene
Cg Alkyl benzenes
Paraffins (Cg-C]^)
Xylene
Unidentified
(2 compounds)
Test 1
12,210
12.13
3.56
.09
.13
10.70

3
725
195
2520
47
.076
52
1770
23.88
2.72"
1.86
7.51
11.79
N.D.
53.29


















Test 2
13,012
7.82
4.28
.09
- .10
10.3

2
565
. 167
1820
35
.104
42
1290
22.01
2.94
1.63
8.90
8.54
N.D.
59.87


















Test 3
11,823
6.85
5.80
.06
.20
' -11.80

1
446
177
1050
42
<.032
107
905
28.26
6.27
1.97
8.18
11.84
N.D.
53.09


















* All (%) are weight percent.

t None detected at a detection limit of  .005  percent.

§ Weight percent of other organics = 100 percent  -  ash - water —'quanti-
  fied organics.  Compounds listed in  this  category were not  quantified.'
                                    247

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              TABLE  3.  DREs  CALCULATED FOR THE CO-FIRING TESTS
Test
numbers
1
2
3
Average

Methylene
chloride
99.869
99.851
99.917
99.879
Minimum
Methyl ethyl • >
ketone l.lj
99.960 , /,.;
99.959
99.961
99.960
DREs*
, 1-trichloroethane
;99.718 '
99.604 :
99.7,10
99.677
, :(
Toluene
99,968
99.947 ;
99.968 ;
99.961 '
* The DREs indicated have been adjusted by  a  sensitivity analysis        '
  approach to include the impact of random  measurement  errors  oil the ORE
  calculations.  The stated values therefore  actually represent the
  minimum DREs observable in ;the cement kiln  by  employing the  test methods
  described in this report. '•
                                     249

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TABLE 4.  METALS TEST RESULTS


Element
Cd
Cr
Cu
Pb
Mn
NI
Hg
Zn




As
Ba
Cd
Cr
Pb
Hg
Se
Ag




Cd
Cr
Cu
Pb
Mn
Hg
Ni
Zn
Kiln Dust Analysis (ppm)
Liquid waste Coal only
Run
No. 1 2 3 Avg. 456
18 16 15 16 19 22 30
23 24 31 26 23 28 24
26 24 25 25 24 30 30
524 511 488 507 173 186 167
632 656 795 694 681 759 655
25 31 31 29 22 27 29
.22 .30 .40 .31 .40 .22 .26
71 66 70 69 49 57 75
Kiln Dust EP Toxicity Test Results (mg/Jl)
Liquid waste Coal only
Run
No. 123 Avg. 4 5 6
<.003 <.003 <.003 <.003 .006 .004 .003
.593 1.020 .685 .766 .753 .649 1.020
.004 .481 <.003 .167 .073 .017 .897
<.020 .088 .032 .047 <.020 .020 .035
<.043 .919 <.043 .335 <.043 <.043 .713
<.0008 <.0008 <.0008 <.0003 <.0008 <.0008 <.0008
.215 .343 .179 .246 .350 .414 .502
•C.007 <.007 <.007 <.007 <.007 .013 <.007
Metals Emissions On Particulates (Ib/hr)
Liquid waste Coal only
Run
No. 1 23 Avg. 456
.003 .001 .001 .002 .002 .003 .002
.075 .030 .054 .053 .020
— — — — — — —
.105 .060 .052 .072 .042 .036 .043
.007 .004 .003 .005 .003 .002 .003
.0002 .0002 .0001 .002 .0003 .0003 .0003
.160 .061 .065 .095 .044 .018 .032
.049 .005 .001 .018 .002 .002


Avg.
24
25
28
175
698
26
.29
60



Avg.
<.005
.807
.329
.025
.266
<.0008
.422
<.009



Avg.
.002
.020
—
.040
.003
.003
.031
.002
             250

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                                  FEED
                                MATERIALS
                                                    STACK
                                                    GASES
COAL
LIQUID
             B
                         KILN
                CEMENT
                CLINKER
 ESP
                                         DUST  RETURN
  DUST
DISPOSAL
          Figure 1. Marquette-Oglesby cement kiln schematic.
                             251

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Hour
Date


10/27



10/28




10/29



10/30




10/31
0   2    4   6
                                       10    12   14    16    18   20    22   Ik
Coal
Co-firing
Downtime
                       Test  1    Test  2     Test 3

                       Test 4      Test 5
                       Test 6
                                                    Y/////////////:
                         Figure 2.  Process  operations  log.
                                       252
                                                               *U.S. GOVERNMENT PRINTING OFFICE 1fl83-659-095/1930

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