United States
               Environmental Protection
               Agency	
Risk Reduction
Engineering Laboratory
Cincinnati OH 45268
               Research and Development
EPA/600/SR-92/120  Sept. 1992
EPA       Project Summary

               Total  Hydrocarbon  Emission
               Testing  of  Wastewater  Sludge
               Incinerators

               John T. Chehaske, William G. DeWees, and F. Michael Lewis
                 The  U.S. Environmental Protection
               Agency (EPA) is considering a regula-
               tory requirement for continuous moni-
               toring of total hydrocarbon (THC) emis-
               sions from all wastewater sludge incin-
               erators. This study was conducted to
               determine the reliability of total hydro-
               carbon analyzers (THCAs) in this appli-
               cation.
                 Continuous monitors for oxygen (O2),
               carbon monoxide (CO), THC, and tem-
               perature were installed  at two munici-
               pal wastewater sludge incinerators. The
               O2 data were used to  normalize the
               measured THC concentrations to 7%
               O2. CO was measured to determine if it
               could be used as a surrogate for THC
               measurements.
                 The two THCAs performed very well,
               achieving 94% and 90% on-line avail-
               ability  at the two  sampling sites, re-
               spectively. The O2 and CO analyzers
               also worked well. There  were initial
               problems with the sample conditioning
               system that  is necessary for the CO
               and Os monitors, but successful opera-
               tion was achieved after it  was modi-
               fied. The average hourly THC concen-
               trations, normalized to 7% O,, were 108
               and 88 parts per million by volume
               (ppmv) for the two sites.
                 The  corresponding CO  concentra-
               tions were 1,071 and 1,091  ppmv. The
               CO and THC data showed a poor corre-
               lation.  Several short runs were made
               under high turbulence firing conditions,
               and others were made with the use of
               an afterburner. These short runs ranged
               from 13 min to about 5 hr and achieved
               O2 normalized THC concentrations of
               less than 30 ppmv.
  This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
key findings of the research project
that Is fully documented In a separate
report of the same title (see Project
Report ordering information at back).

Introduction
  The EPA Office of Water (OW) drafted
risk-based sludge regulations (for incin-
eration and  a variety of other options)
under  Section 405d of the Clean Water
Act. The proposed regulations were pub-
lished  for public comment in the Federal
Register."  Being  considered for the final
regulation  is a provision for  continuously
monitoring THC emissions as a method of
controlling organic emissions from sludge
incineration.  The monitoring would have
to demonstrate that the THC stack emis-
sions were not exceeding a concentration
limit.
  To evaluate THC monitoring the EPA
Risk Reduction  Engineering Laboratory
(RREL) implemented a study for OW to
operate total hydrocarbon analyzers
(THCAs) over a 3-mo period at two mu-
nicipal wastewater sludge incineration fa-
cilities. Continuous analyzers for THC, CO,
and O2 were installed and operated at  the
two facilities, (Site THC-1 and Site THC-
2) both of which employed multiple-hearth
furnaces (MHFs) to incinerate wastewater
sludge. In addition, EPA requested  an
evaluation of the  use of these monitors to
assist  with  improving incinerator opera-
tion.
 Fed. Reg., 54 (23): 5746-5902, Feb. 6,1989.
                                                               Printed on Recycled Paper

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Description of Facilities
  Site THC-1 had been previously stud-
ied by the EPA. The results of that study
are contained in EPA report "Emissions of
Metals, Chromium and Nickel Species, and
Organics  From  Municipal Wastewater
Sludge Incinerators, Volume III:  Site  6
Emission Test Report"*. Site THC-2 had
also been previously studied, but different
incinerators were tested in that EPA study.
  She THC-1 is a publicly operated treat-
ment  works (POTW) that processes an
average of 30 million gallons per day (mgd)
of wastewater. The sludge furnace oper-
ates 24 hr per day,  5-3/4 days per week.
Sludge is dewatered before incineration
to reduce sludge-cake water content to
70% to 75% by weight.  A gravity thick-
ener is used to increase the  percentage
of solids in the primary sludge,  and  a
flotation thickener processes the second-
ary sludge. Lime slurry and ferric chloride
solution are used to condition the sludge
drawn from a storage tank. Four recessed-
plate  filter presses  are used  to dewater
tha conditioned sludge before transport to
the furnaces.
  Site THC-1  has two  identical Nichols*
eight-hearth, MHFs; only one  is operated
at a  time. Sludge is screw fed into the
side of Hearth #1. The air pollution control
system consists of an  adjustable-throat
venturi scrubber, followed by  a two-plate
impingement tray scrubber.
  Tha project at Site  THC-1  was  con-
ducted under normal plant and incinerator
operating conditions. During the test pro-
gram, the unit operated a total of 1,690 hr
out of a total of 2,232 possible hr, repre-
senting a 76% on-line operation.
  Site THC-2 is a POTW treating approxi-
mately 40 mgd of primarily domestic waste-
water. Solids processes at the facility are:
gravity thickening of chemically treated (fer-
ric chloride) primary sludge; flotation thick-
ening of waste-activated  sludge;  mixing/
storage of  thickened sludges;  chemical
conditioning/dewatering  of sludge by  a
combination of a vacuum filter, belt press,
and membrane-type filter press; and in-
cineration using multiple hearth incinera-
tors.
  Site THC-2 has  two identical  MHFs,
only one of  which is operated at  a time.
During this study, both furnaces were used.
Tha furnaces are eight-hearth units,  ap-
proximately 22 ft  diameter, built in 1979
by Nichols Engineering.
tEPA 60Q,'R-32/003c. PB 92-151570/AS. March 1992.

'Mention of trado names or commercial products does
 not constitute endorsement or recommendation for
  Throughout most of this study, tests at
Site THC-2 were conducted under normal
plant and incinerator operating conditions.
Because of ongoing plant modifications,
however, several problems were encoun-
tered. These problems related to changes
in the  dewatering  system and modifica-
tions to the burner control circuit. Other
problems at Site THC-2 included the fail-
ure of  an induced draft (ID) fan bearing
and a fire in  the  sludge conveyor and
control wiring. During the test program,
Site THC-2 operated a total of 1,533 hours
out of a possible 2,184 hours, represent-
ing a 70% on-line operation.

Procedures
  Sampling sites at both facilities were
located in a transition section between the
ID fan and the outlet stack, downstream
of the scrubber and demister but upstream
of the shaft cooling air point of entry. De-
tailed descriptions  of each sampling site
are presented in the report.
  Continuous emission monitors (CEMs)
were used to monitor THC, CO, and O in
the sludge  incinerator exhaust gases.  Ex-
haust gas temperature was monitored with
a thermocouple. The analyzer and ther-
mocouple outputs were  recorded on a
computer with the use of  an  electronic
data acquisition system. The analyzer out-
puts were also recorded on strip charts.
  The  THCA sampling  system  for both
sites consisted of  a probe, a three-way
calibration  valve,  and  a heated sample
line. The heated sample line connected
directly to the oven section of the THC as
manufactured by J.U.M. Engineering.  In-
side the  oven, which was maintained at
190°C, was a sample filter, a  pump, a
sample flow control capillary, and a flame
ionization detector.
  The  Og/CO sampling system was more
complex. The initial system had a sintered
stainless steel filter attached to the probe
inlet. This system suffered repeated block-
age of the sintered stainless steel filter.
The redesigned system had a 1/4-in. OD
stainless steel probe that was open at the
inlet.
  At Site THC-1, a Wilkerson compressed
air  line water trap was attached to  the
three-way valve, which was connected to
a Nutech heated filter box and glass filter
holder. The outlet of  the filter holder was
connected to a heated sample line.
  At Site THC-2, a  Cast model  V400G
filter jar  was attached to the three-way
valve, and  the heated line was  attached
to the filter jar. This  water knockout trap
had a 7 oz capacity  whereas the one at
Site THC-1 held 32 oz. The varying com-
plexity  of the two systems demonstrated
how different water knockout/filter designs
can be used, depending on the amount of
contamination  in the sampled gas. The
rest of the Og/CO sample acquisition sys-
tem was the same at both sites, including
a two-pass refrigeration unit.
  A thermocouple was  installed in the re-
frigeration unit outlet line to monitor the
gas stream  temperature. Linearized out-
put from the temperature readout was fed
to the data logger. The THCA unit at Site
THC-1 was a model VE-7AP, and the unit
at Site THC-2 was a model VE-7 with an
add-on autopurge module. The THC ana-
lyzers were calibrated  by using propane
in air standards  prepared by Scott Spe-
cialty Gases.
  Servomex model  1420 O2  analyzers
measured the  O2 content of the exhaust
gas at the THC sampling location. These
analyzers utilize  the paramagnetic  mea-
surement technique.
  Milton Roy Corporation model 3300 ana-
lyzers measured the CO concentration in
the exhaust gases.  These analyzers use
a nondispersive infrared technique to mea-
sure gas concentration. The exhaust gas
temperature was measured with an Omega
Engineering, Inc., model KQ55-14G Type
K thermocouple connected to an Omega
model TAC-30 analog converter. The ther-
mocouple produces a voltage proportional
to temperature, and the analog converter
provides electronic reference junction com-
pensation and  a  linearized output so that
1 millivolt equals 1 degree.
  Outputs from the THC, CO, and O2 ana-
lyzers and the various thermocouples were
recorded on an Odessa model DSM 3260
data acquisition/data reduction  system.
The  Odessa  was connected  to  a
Walkabout 386-SX laptop computer.
  Most  data processing  was  performed
by DEECO, Inc., as DEECO  had  pro-
cessed  continuous monitoring  data from
other EPA test sites. Data from this  study
were recorded  in the same format used in
previous studies  so EPA could  enter the
data into its THC database.  THC concen-
trations, measured on a wet basis, were
converted to a dry basis.
  Columns  were  created  in  the  data
spreadsheets for: THC concentrations cor-
rected to 7% O2; hourly average O2 con-
centrations;  hourly average CO concen-
trations  with off-scale data; hourly  aver-
age CO concentrations with no off-scale
data;  hourly average O2-corrected  THC
concentrations with  off-scale data; and
hourly average O.-corrected THC concen-
trations with no off-scale data.
  A  comprehensive quality assurance/
quality  control (QA/QC) program  was
implemented for this testing  project to as-

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sess the data quality and to establish limi-
tations on the ultimate  use of the data.
The objective of this QA/QC program was
to optimize precision, accuracy, complete-
ness, comparability,  and representative-
ness for each major measurement param-
eter of the test program. Data quality ob-
jectives for the THC, CO, and O2 continu-
ous monitors are presented in Table 1.

Table 1. Summary of Estimated Precision, Ac-
curacy, and Completeness Objectives
 Parameter
Objective
Precision
Accuracy
Completeness
±20%'
±20%f
1 Coefficient of variation (CV) determined from
  periodic analyses of a control sample, where

    % CV= Stand Deviation x 100
                   Mean
f Relative accuracy (RA) determined from the
  difference between the known concentration
  of the cylinder gases and the concentrations
  indicated by the CEMs, where RA = /differ-
  ence/actual concentration x 1001
f Valid data percentage of total hours sampled.
  Four-point  calibration  error (linearity)
checks were  made at the beginning and
end of the study and each time a new or
modified analyzer was installed. Collected
data show that the analyzers were rou-
tinely well  within the allowable  ±3%  of
span. The  maximum  error observed for
any of the  linearity checks was 1.6% for
CO, 0.87% for O2, and 1.0% for THC.
  Bias checks were conducted at the be-
ginning and end of the study and periodi-
cally during the study when the sampling
line was disassembled to ensure that the
sampling system was not leaking. All bias
checks were below the allowable ±5% of
the control gas value. The maximum bias
check error observed was 1.6%.
  Zero and span drift checks were per-
formed throughout  the study. The allow-
able  zero and span drift error, calculated
as a percentage of the  span,  was ±5%.
The  maximum zero  and span drift ob-
served were 0.6% and 2.0%, respectively.
  Because different  coefficient of varia-
tion had to be calculated for each span
gas used during the study, there was more
than  one value for each analyzer. All  of
the coefficient of variation  results were
well below the maximum allowable ±20%.
  The relative accuracy of the continuous
monitors was determined from the analy-
sis of special audit  gases.  The  results
were all well  below the  ±20% maximum
allowable.  The largest relative accuracy
error was 2.35%.
Results
  At Site THC-1, data collection began on
June 8, 1991, and ended on September
9, 1991. At Site THC-2, monitoring  ran
from June 11,  1991, to September  10,
1991.
  During the study, the various analyzers
worked  well with a minimum of mainte-
nance under a wide range  of operating
conditions. Concentrations of THC and  CO
were, however,  often much  higher than
anticipated.
  Significant problems occurred at the be-
ginning of the study with the  sample con-
ditioning system for the O2 and  CO ana-
lyzers. The initial sample conditioning sys-
tem design  was  prone to plugging,  but
after the system was redesigned, satisfac-
tory operation was achieved.
  In  future  applications,  it appears  that
problems associated  with particulate and
liquid water  removal  can be solved with
relatively simple water  knockouts and fil-
ters.  Water  vapor removal, however,  re-
quires  more complicated  mechanical
equipment that will increase maintenance
requirements by plant personnel.
  The EPA criteria for determining THCA
analyzer reliability was  on-line availability
of the analyzers. These results  are pre-
sented in Table 2.

Table 2.  THCA On-Line Availability
Site
THC-1
THC-2
Furnace
Operating
Hours
1,681
1,508
THCA
Operating
Hours
1,579
1,355
THCA
Availability
(%)
94
90
               The target of having the THCAs operat-
             ing at least 90% of the time that the plant
             was operating was achieved at both sites.
             At Site THC-1,  94%  availability was
             achieved and at Site THC-2, 90%.
               A THCA failed to reignite on nine occa-
             sions after an automatic backpurge cycle.
             Six of these occurrences, at Site THC-1
             during August, resulted in 53  hr of lost
             data. The problem was corrected by ad-
             justing the flame-out potentiometer inside
             the analyzer. The  THCA failed to reignite
             three times at Site THC-2, and 184 hr of
             data were lost.  These failures occurred in
             July, August, and September.
               Had the flameout been  noticed sooner
             during  routine  inspection, the analyzer
             could have been  repaired more quickly,
             and Site THC-2's  availability would have
             been considerably better. No other repairs
             or maintenance had to be performed other
             than the flame-out potentiometer adjust-
             ment and a sample line clean out. A total
 of 3 hr and 15 min were spent maintaining
 the two THCAs.
   THC concentrations were  initially  sig-
 nificantly higher than had been anticipated
 and resulted in stack gas concentrations
 that exceeded the  designated  range of
 the  THCAs.  Operating  ranges  of  the
 THCAs were  subsequently expanded to
 compensate for this problem. THC con-
 centrations were normalized  to 7% O2.
 Daily averages were calculated for those
 days that had  13 or more hours of data.
   Neither plant achieved a O2-normalized
 THC  concentration  of  30 ppmv or less.
 Most were considerably  higher. At  Site
 THC-1, concentrations of less than 30
 ppmv or less were achieved for only  100
 hr and at Site  THC-2 for 51 hr.
   The overall average hourly concentra-
 tion at THC-1 was  £108 ppmv  and at
 THC-2, >88 ppmv. The average daily con-
 centration: (1)  for days with  all data on
 scale was 81  ppmv for THC-1 (10 days)
 and 74 ppmv for THC-2 (29 days); (2) for
 days with off-scale data was  >117 ppmv
 for THC-1 (25  days) and >118  ppmv for
 THC-2  (5 days); and  (3) as an  overall
 average was >107 ppmv for  THC-1  and
 >81 ppmv for THC-2. The maximum daily
 concentration for THC-1 was  5272 ppmv
 and for THC-2 >188; the minimum daily
 concentration for THC-1 was 40 ppmv and
 for THC-2, 44. For periods with off-scale
 values, the maximum scale reading was
 used  for calculation of these averages,
 yielding equal-to-or-greater-than values.
   The CO monitors worked very well dur-
 ing the study,  and there was one serious
 problem and two minor problems with the
 O monitors. The O2 monitor at Site THC-
 1 had a loose output connector that caused
 lost data in July, and in September,  the
 analyzer failed completely. A replacement
 analyzer was obtained, and the failed  unit
 was returned for repair.
  Another minor problem was encountered
 with the Site THC-2 O2 monitor, when the
 dumbbell inside the  unit became stuck.
 The dumbell deflects in a varing  magnetic
 field to  provide a reading proportional to
 O2 concentration. Tapping the side of the
 case released  the stuck dumbell, and no
 other problems occurred.
  The CO data from both sites had  fre-
 quent off-scale excursions.  The concen-
trations were higher than  had been  en-
 countered on previous EPA tests. Thus,
expanded-range analyzers were installed
 at Site THC-1  on August 15 and at Site
THC-2 on August 5. Even with the higher
 range, both sites still had a number of off-
scale excursions.  The overall  average
 hourly  concentration for the THC-1  was
 1,071  ppmv and for THC-2, 1,091 ppmv.

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  In comments to EPA, CO was suggested
as a surrogate for THC  measurements.
This led to a  second objective  of the
proJQCt-^o determine correlations between
THC and CO  concentrations. Data from
August were chosen for  these analyses
because both the analyzers and  the fur-
naces performed best during that time pe-
riod. For meaningful analysis, it is  also
important that the correlation be deter-
mined for values near the expected emis-
sion standard.  Results of the linear re-
gression analyses for data ranging from
10 to 50 ppmv are shown in Table 3. The
correlations developed for both sites do
not appear to support the use of CO con-
centrations for estimating THC concentra-
tions.
  The use  of breaching temperature as a
possible surrogate for THC concentrations
was also  suggested.  These correlation
analyses were also performed with Au-
gust data. Results  of the analyses for Sites
THC-1 and THC-2 (Table 4) do not reflect
a strong correlation between THC and
breaching temperature.
  Several operations test runs were con-
ducted at Site THC-2 during the weeks of
August 5 and August  12, 1991, to deter-
mine if  tower  THC emissions could be
obtained with relatively minor changes in
furnace  hardware  or operating conditions,
or both.  Two different scenarios were tried.
One involved  inducing more turbulence
within the hearths  with special air-fuel mix-
ing valves (i.e., a high turbulence  [HT]
run). In addition to this analysis, several
runs were  made using the afterburner to
evaluate THC  and CO reduction at differ-
ent afterburner temperatures.
  The HT run was achieved during a 5-hr
period between August 8 and August 9,
1991. THC concentrations were shown to
vary between 10 and 25 ppmv normalized
to 7%  O2 during  this  5-hr test, with the
exceptions of  a spike condition resulting
in a value of approximately 65 ppmv (nor-
malized). The spike condition was caused
by  a momentary  stoppage  in the sludge
feed.
  A second series of runs, on August 14,
1991, evaluated the use of an afterburner
to achieve desired emission limits. These
tests were at an  afterburner temperature
of 1400°F. During this series of runs, THC
emissions  decreased  from an observed
value of approximately 50 ppmv before
starting afterburner to approximately 5 to
10  ppmv  whenever the  afterburner was
on.
  On August 16,1991, a second analysis
of afterburner effectiveness was conducted
at  temperatures  between  1100°F and
1400°F. These test runs showed an  in-
Table 3.  Correlation of THC and CO
Site
THC-1
THC-2
Linear Regression
Equation
CO = (20.4)(THC) + 247
CO = (22.0)(THC) -i- 232
Number of
Observations
3,028
8,190
R*
0.525
0.455
 Table 4.  Correlation of THC and Breaching Temperature
Site
THC-1
THC-2
Linear Regression
Equation
Temp. = (-1.102)(THC) + 929
Temp. = (-1.316)(THC) + 867
Number of
Observations
3,028
8,190
R2
0.012
0.085
verse relationship of afterburner tempera-
ture to THC emissions.  Under these re-
duced afterburner temperatures, emissions
varied between 7 to 21 ppmv.

Conclusions
  In  terms of equipment operation, the
two J.U.M. Engineering THCAs  worked
reliably at both MHF wastewater sludge
incinerators, ft is believed that the  suc-
cess of these analyzers was significantly
affected by the unique sample filtering and
backpurging system used by J.U.M. The
CO analyzers also performed very  well.
No downtime was caused by analyzer fail-
ure;  rather all downtime was caused by
failures  of the sample acquisition/condi-
tioning system, which was external to the
analyzers. The Servomex O2  analyzers
performed well, despite two  analyzer-re-
lated problems.
  Based on the data collected in this study,
there was poor correlation between  THC
and  CO concentrations, and there was
essentially  no correlation between  THC
concentration and breaching temperature.
As indicated in this summary, sample con-
ditioning systems are critical to acquisition
of reliable CO and O  data when  using
extractive monitors. If not  properly de-
signed, or  maintained,  or  both,  such
sample  conditioning systems can cause
significant  operating  problems.  For O2
monitors, the sample conditioning system
can be eliminated by using an in-situ moni-
tor rather than an extractive monitor.
  On a  limited basis, the study examined
operating  the incinerator afterburner  at
lower temperatures and also  examined
two  potentially less expensive process
modifications (that might offer an alterna-
tive to afterburners). External afterburners
are effective  in  reducing CO  and THC
emissions, and it appeared that  emissions
less than 30  ppmv  may be  achieved at
temperatures  less than 1,400°F. Only a
short demonstration of this was possible
during this study, however. A limited test
program also demonstrated that lower THC
emissions may be achieved by increasing
the gas phase turbulence within the
hearths  while simultaneously raising the
exhaust temperature by firing most of the
auxiliary fuel above the combustion hearth.
It was beyond  the  scope of this study,
however, to demonstrate that these tech-
niques are viable for long-term operation.
  The test program reverified  that an MHF
is inherently unstable. The extremely wide
variation in CO and THC emissions shown
in  this  study  indicates  that substantial
changes in operating procedures probably
will be required  to comply with the new
regulations. For many plants, equipment
modifications  may also be necessary.

Acknowledgments
  The full reports were submitted in fulfill-
ment  of Contract  No.  68-CO-0027 by
James M. Montgomery Engineers under
subcontract to'Pacific Environmental Ser-
vices, Inc.,  DEECO, Inc., and F. Michael
Lewis, Consultant, under the sponsorship
of the  U.S.  Environmental Protection
Agency. Papers containing data summa-
ries have also been presented at the 1992
annual meeting of the Air and Waste Man-
agement Association and the 1992 sludge
specialty conference of  the  Water Envi-
ronment Federation.
                                                                                     •U.S. Government Printing Office: 1992— 648-080/60065

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John T. Chehaske is with Pacific Environmental Services, Inc., Herndon, VA;
  William G. DeWees is with DEECO, Inc., Gary, NC; and F. Michael Lewis is a
  private consultant In El Segundo, CA.
Harry E Bosttan is the EPA Project Officer (see below).
The complete report, entitled "Total Hydrocarbon Emission Testing of Wastewater
  Sludge Incinerators," (Order No.  PB92-197086/AS; Cost: $19.00; subject to
  change) will be available only from:
        National Technical Information Service
        5285 Port Royal Road
        Springf^, VA 22161
        Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
        Risk Reduction Engineering Laboratory
        U.S. Environmental Protection Agency
        Cincinnati OH, 45268
     United States
     Environmental Protection Agency
     Center for Environmental Research Information
     Cincinnati, OH 45268

     Official Business
     Penalty for Private Use
     $300
     BULK RATE
POSTAGE & FEES PAID
         EPA
   PERMIT No. G-35
     EPA/600/SR-92/120

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