&EPA
United States
Environmental Protection
Agency
Center for Environmental
Research Information
Cincinnati OH 45268
Technology Transfer
EPA/625/4-87/017
Publication
Permitting Hazardous
Waste Incinerators
Seminars for Hazardous
Waste Incinerator
Permit Writers,
Inspectors, and
Operators
October 16-17, 1986
Rosemont, Illinois
October 28-29, 1986
Dallas, Texas
November 13-14, 1986
Atlanta, Georgia
November 20-21, 1986
Philadelphia, Pennsylvania
December 4-5, 1986
San Francisco, California
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EPA/625/4-87/017
September 1987
Seminar Publication
Permitting Hazardous
Waste Incinerators
Seminars for Hazardous Waste
Incinerator Permit Writers,
Inspectors, and Operators
October 1 6-17, 1 986
Rosemont, Illinois
October 28-29, 1986
Dallas, Texas
November 13-14, 1986
Atlanta, Georgia
November 20-21, 1986
Philadelphia, Pennsylvania
December 4-5, 1986
San Francisco, California
Center for Environmental Research Information
Office of Reseach and.Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
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Disclaimer
These Proceedings have been reviewed in accordance with the U.S. Environmental
Protection Agency's peer and administrative review policies and approved for
presentation and publication. Mention of trade names or commercial products does
not constitute endorsement or recommendation for use.
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Foreword
An estimated 233 existing incinerators in the U.S. will require RCRA hazardous waste
permits by the statutory deadline of 1989. Although many incinerators have prepared
Part B permit applications, only 25 have been fully permitted under RCRA. The large
majority are continuing to operate under interim status and many new incinerators
will also require permits.
The preparation, review, and approval of incinerator Part B applications is complex,
time consuming, and expensive, averaging 1.2 years for new units and 2 years for
existing ones. The principal obstacle in the Part B review process is the evaluation
of the trial burn plan and data. Approximately 50 percent of the permit review process
is spent evaluating this portion of the application. It is this information that ultimately
demonstrates the ability of the incinerator to adequately destroy hazardous wastes
and which forms the basis for establishing key permit conditions for operation of the
incinerator.
This seminar series was designed to address the problems and issues that affect the
issuance of hazardous waste incineration permits. In particular, the seminars were
designed to improve the overall understanding of trial burn testing.
Papers presented by the seminar speakers are compiled within this Proceedings, and
should be of value to those involved in the design, execution, reporting, and evaluation
of trial burn tests. Those wishing additional information are urged to contact the authors
or the EPA Project Officer, Mr. Norm Kulujian, Center for Environmental Research
Information, Cincinnati, Ohio (513/569-7349).
Calvin O. Lawrence, Director
Center for Environmental Research Information
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Abstract
Five two-day seminars on permitting hazardous waste incinerators were held in cities
geographically central to those parts of the country that generate the most wastes
and have the most existing incinerators. Over 800 people attended the five seminars,
which began on October 16, 1986, arid concluded December 5, 1986. The seminars
reached both federal and State permit writers responsible for reviewing and approving
Part B applications and establishing RCRA permit conditions, and owners/operators
(or their engineering consultants) responsible for designing, conducting, and submitting
trial burn test plans and reports.
The seminars were designed around a number of specific technology transfer objectives.
Specifically, the seminars provided guidance on how to:
• Relate trial burn data to permit conditions.
• Design and execute trial burns and monitoring strategies.
• Ensure that quality assurance of trial burn data sets is conducted adequately.
• Identify deficiencies and their causes in trial burn designs and resulting data sets.
• Recognize variables in trial burn data and understand how to deal with them.
• Organize the trial burn section of a permit application in the most effective manner.
Emphasis was on typical shortcomings in trial-burn plans and how permit writers
can interact with applicants to minimize the likelihood of deficiencies in data and
misunderstandings in requirements.
This document is a compilation of papers written by each of the speakers detailing
the information presented during each of the seminar's.
IV
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Contents
Page
Disclaimer ii
Foreword iii
Abstract iv
Incineration Technology—State-of-the-Art Review
Joseph J. Santoleri, Four Nines, Inc 1
Developing a Trial Burn Plan
Walter S. Smith and Tony Wong,
Entropy Environmentalists 4
Trial Burn Plan Evaluation
John R. Hart, U.S. EPA Region IX 13
Conducting the Trial Burn
Roy Neulicht, Midwest Research Institute 16
Agency Observation of the Trial Burn
Walter S. Smith and Kenneth W. Blankenship,
Entropy Environmentalists 20
Reporting Trial Burn Results
Gary Hinshaw and Andrew R. Trenholm
Midwest Research Institute 25
Translating Trial Burn Test Results into Permit Conditions
C. C. Lee, U.S. EPA-ORD
Carlo Castaldini and S. Torbov, Acurex Corporation.'. 32
Common Deficiencies in RCRA Part B Incinerator Applications
Bruce A. Boomer and Andrew R. Trenholm,
Midwest Research Institute 41
Indicators of Incinerator Performance
Joseph J. Santoleri, Four Nines, Inc 45
Monitoring Equipment and Instrumentation
David R. Taylor, C. Dean Wolbach, and Carlo Castaldini,
Acurex Corporation 46
Carbon Monoxide Monitoring Guidance
Roy Neulicht, Midwest Research Corporation 51
Construction and Retrofit Guidelines for Existing Incinerators
: Joseph J. Santoleri, Four Nines, Inc 56
Case Studies for Trial Burns
Joseph J. Santoleri, Four Nines, Inc 59
Permit Writer's Guide to Test Burn Data
M. Pat Esposito, PEI Associates, Inc 62
RCRA Exemptions, Waivers, and Petitions for Hazardous Waste Incinerators
Gary Gross, U.S. EPA Region III 75
v
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Incineration Technology—State-of-the-Art Review
By
Joseph J. Santoleri
Four Nines, Inc.
Introduction
In the 1960's, much effort was expended on cleaning up
the air and water. Air Quality and Water Quality Acts
were being written and implemented in many States and
communities. New products such as unleaded gasoline
and water base paints were developed to help minimize
pollution. Conversion from oils to natural gas for comfort
and industrial heating was the normal practice.
In the 1970's, there was a sudden concern on how to
safely dispose of hazardous wastes. Indiscriminate
dumping of chemical wastes of all types had been going
on since the birth of the chemical industry in the U.S.A.
Land dumping, inadequate landfills, and dumping into
rivers and oceans were the most economical ways to
dispose of chemical hydrocarbon waste. Methods that
would have eliminated wastes permanently were initially
disregarded as being too costly.
However, many of the major chemical companies
installed incinerator facilities on their own plant sites,
not because it was the most economical method but
because they realized that other methods of disposal
would not be open to them. Now, in the 1980's we
recognize that restrictions on chemical landfills will
eliminate the casual small and underfinanced operator;
ocean dumping will be a thing of the past, and deep well
disposal will ultimately be phased out.
Incineration under proper control and application of the
proper technology will provide the best, and in the long
run, the most economical avenue to the total destruction
of organic hazardous wastes.
Incineration Not a New Technology
Incineration is,not a new technology. It has been used for
many years. Some municipal incineration facilities were
in operation more than 50 years. But because our air
pollution laws were really the first group of
environmental laws to affect the nation, incineration,
especially in the municipal waste area, received a bad
name. Therefore, incinerators, rather than being
purchased and started up during the 1970's, were being
closed because they could not meet current air pollution
regulations. With the closure of many landfills, which
many industry, watchers are certain will occur,
incineration will once again be restored to its rightful
position in hazardous waste management. Industrial
incinerators burning chemical wastes go back to the
1950's. The technologies involved in the incineration
waste included:
1. LIQUID INJECTION systems to burn high heating
value, easily combustible materials, many of which
created acid gases that had to be removed by
downstream scrubbing device.
2. The ROTARY KILN which was an outgrowth of the
cement industry, rotary process driers and later
municipal incineration Was found to be a relatively
simple and forgiving system for the types and
varieties of wastes which it could handle.
3. The FLUID BED system came along in the 1960's and
1970's first to handle papermill wastes, then
certain refinery wastes, and finally some chemical
wastes, but the fluid bed had limitations as did all
the rest. The most important was that it was
expensive like the rotary kiln and economics could
not justify its use. ,
4. The MULTIPLE HEARTH incinerator was not an
incinerator at first; it was a device used for roasting
ore from various metal mining and refining
operations but it was applied to a rapidly growing
market; that is disposal of sewage sludges. The
multiple hearth thrived for a period during the
1960's and 1970's when air pollution regulations
were not that stringent.
5. STARVED AIR or, as it is now called, the
CONTROLLED AIR incinerator came along. It was
basically a hearth-type system with an afterburner
section which burned the incomplete products of
combustion from the first stage. While these
systems were small and modular, they were widely
used during the 1970's for destruction of plant
waste and some hazardous materials.
Liquid injection incinerators are the most common type.
They represent 64% of all the hazardous waste
incinerators in service. Most are off-shoots of liquid fuel
burning design as used in boilers using the same
techniques of atomization, air mixing and burning. These
units may be designed to burn various types of waste
liquors. These are completely organic, an aqueous waste
with organics, or an aqueous waste with organics and
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solids. Solids are usually dissolved in organics contained
in the liquid wastes. |
An organic that is considered most hazardous is one
containing chlorine, often referred to as a chlorinated .
hydrocarbon. Many process industries, such as :
agricultural, pharmaceutical, refineries, etc., generate
these chlorinated hydrocarbons. The chlorine tends to
reduce the combustibility due to the lower heating value
and also creates a fuel more difficult to burn. If
improperly burned, the chlorinated materials tend to form
soot. The products of combustion include hydrochloric
acid gas as well as carbon dioxide, oxygen, nitrogen and
water vapor. The corrosive nature of the fluid causes
problems with nozzles, refractories and the downstream
heat recovery and pollution control devices of an
incinerator system. Systems are operated today which
include the latest technology for the combustion and
incineration systems (including materials of '
construction), as well as the heat recovery devices (waste
heat boilers) and hyproduct recovery (acid recovery
towers). Operating units with steam generation loads of
60,000 Ib per hour are in service today.
For solids, sludges and materials that are not easily
pumped, rotary kiln incinerators are used. Normally,
these do not require pre-treatment of the wastes prior to
feeding to the incinerator. Feed mechanism are belts,
clam shells into a hopper, screw feeders, augers, as well
as ram feeders. The kiln refractory must be able to
withstand the shock of a drum loaded with solids or
sludges sticking to the rotating inner diameter. Certain
sludges, slurries and liquids are fed by positive
displacement pumps to the incinerator chamber. Some
may be injected by nozzles similar to the liquid injection
units.
In the kiln, sufficient air is introduced to provide
combustion of the highly volatile materials that also
provide the energy needed to raise the solids to
volatilization temperatures. Organic compounds that
make up the solids are heated to volatilization !
temperatures releasing hydrocarbon gases, carbon
monoxide, hydrogen, etc. Rotation, length, diameter and
slope of the kiln determine the total residence time for
the solids to permit complete volatilization of the '
hydrocarbon compounds. The inert ash in the waste is all
that remains to be dropped into the ash collection
system. The volatilized gases at temperatures of 1600-
2000°F are exhausted into the afterburner chamber.
Some kilns operate in a slagging mode which permits all
metal compounds (drums, cans, etc.) to reach the molten
stage. All ash is discharged into a hot tap to minimize the
handling problems of distorted steel drums, steel
strapping, etc. i
The afterburner chamber is designed to operate with
sufficient oxygen, temperature and mixing to convert all
the hydrocarbons into carbon dioxide and water vapor.
Halogenated compounds will be converted to the halogen
hydride. Auxiliary fuel is fired into this chamber to
provide the energy necessary to raise the exit
temperatures to levels of 2000-2400°F. This fuel can be
in the form of waste solvents, organics or other fuels ,
with little or no ash content.
Of the other types described above, the starved air/
controlled air incinerator is the only one that is in wider
use for hazardous waste than either the fluid bed or the
multiple hearth. In this case, the starved air is used also
for solid waste materials, sludges and slurries similar to
the rotary kiln applications. A major difference is that the
starved air operates under a reducing atmosphere in the
primary chamber. The solids must be volatilized in the
absence of sufficient oxygen. Typical operations are in
the range of 60-70% of the air necessary for complete
combustion. It is critical that the time in the primary
chamber insures that the ash leaving the chamber has
been devolatilized and is inert. This requires that
sufficient exposure of the materials be accomplished by
the multiple ram feeds that are utilized in this design. In
this unit, the secondary chamber serves the same
purpose as in the kiln secondary, in that complete
oxidation of the volatilized vapors occur. The additional
air required for the volatile gases is introduced at the
juncture between the two chambers. It is important that
turbulence and mixing be achieved in a very short time
so that the residence time in the chambers serves to
completely detoxify and oxidize the hazardous
compounds. Both the fluid bed and multiple hearth have
been used in many sewage sludge treatment plants.
Applications of the fluid bed for hazardous waste have
been few; however, there is a concerted effort to utilize
this technology in the hazardous waste area due to the
advantages of being able to handle the halogenated
compounds, as well as sulfur-bearing compounds, with
the neutralization occurring in the bed by using a
limestone material. Advances to the concept of the fluid
bed are being made and described below.
The multiple hearth has been utilized in the sewage
sludge incineration industry as well as in the roasting
and calcining application.
Emerging Technologies
When reviewing the last 50 years of incineration and
perhaps the last 20 years of hazardous and chemical
waste incineration, one might be tempted to say that we
have made no advances in this time in the basic
technology. To some degree this criticism is true because
these major technologies are primarily used for
incineration of hazardous waste today. It is encouraging,
however, that there are some new ideas emanating from
inquisitive minds throughout the industry. We are
describing here some of these new ideas together with
their advantages and disadvantages.
An off-shoot of the fluid bed technique by GA
Technologies of San Diego, CA, utilizes a circulating fluid
bed claiming higher gas velocites than the conventional
fluid bed system, with the advantage of using lower
calorific value in the waste. Another fluid bed technique
developed by PEDCo Environmental in Cincinnati, OH,
and continued development by Rollins Environmental
Services, is the cascading bed incinerator. This is
essentially a rotary kiln partially filled with a uniform size
sand which is fluidized by the action of the mechanical
lifters on the inside of the kiln's surface. The fluidizing
agent passes through the kiln and is returned to the front
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end through a unique inertial spiral system. Wastes fed
into the kiln at the front end are mixed with the hot sand
from the rear end of the kiln, thus conserving heat and
reducing the amount of fuel required to sustain
combustion. The ROTARY REACTOR as it is now known
is unlined and is limited to a maximum temperature of
about 1600°F.
A third system dependent upon uniform size feed is the
Huber Advanced Electrical Reactor. While not a fluidized
bed system, the incineration process is similar.
Hazardous waste material of uniform size is dropped into
a vertical porous carbon tube which has been heated
externally by electric heaters and the annulus around the
tube is slightly pressurized by nitrogen gas. The nitrogen
gas passing through the porous tube is transparent to the
radiation and prevents the waste particles from collecting
on the tube wall. This system has the advantage of
extremely high temperatures (in excess of 4000°F) and,
therefore, extremely high destruction efficiences. The
residence time; in the Huber system can be extremely
short due to the extremely high temperatures.
Two systems which differ from the fluid bed concept are
the Penberthy Electromelt International System and the
Rockwell International System, both of which use a
molten matrix to achieve destruction. The Penberthy
system is an electric glass furnace into which waste
materials are fed. The high temperature of the glass
furnace (2200°F) gives high ORE values. The resulting
ash is trapped in the glass which is drawn from the
furnace and solidified. The Rockwell system utilizes
sodium carbonate in a molten form and injects both air
and hazardous combustible waste into the melt. It is
especially attractive for chlorianted wastes since the
sodium carbonate reacts with the chlorine or hydrogen
chloride that is formed during combustion. A third system
of similar concept is the Arc Technology Process
currently under development by Chemical Waste
Management. This sealed pyrolytic system utilizes a
direct current electric arc furnace with a molten steel bed
maintained at temperatures near 3000°F into which
hazardous material such as PCB contaminated capacitors
can be fed. At these temperatures, the capacitors melt
immediately and the PCBs pass through the electric arc
plasma at ultra high temperatures and are destroyed. The
gases formed from the destruction of the organic
material pass up through a hollow electrode and then
through a conventional treatment process. Scrubbed
gases containing residual hydrogen are flared using
conventional techniques. Only pilot-plant operations
have been performed to date.
Another electrically heated incineration system is the
Shirco Radiant Furnace. Materials to be incinerated are
introduced on a traveling belt and exposed to the high
temperatures of electric glow bars. The material must be
prepared similar to that which is injected into the fluid
bed. It is critical that the size be such that the depth of
the material on the belt allows heat transfer through the
entire depth. The material is fed through a hopper, screw
feed or ram feed device onto the belt so that the
incoming materials contact the hottest gases leaving the
incineration chamber. As the material travels through the
furnace and the volatile compounds are volatilized, heat
is released from the reaction; the ash is discharged
essentially inert. The gases generated in the incineration
chamber are then drawn into a secondary combustion
chamber where temperatures are increased from
approximately 1500-1600°F up to 2000-2200°F. This is
done either electrically or by using auxiliary fuel or waste
fuels. The volatilized gases at this point are completely
destroyed by incineration with the proper oxygen, mixing
and residence time. The gases then pass through the air
pollution control system and eventually into the induced
draft fan and out the stack.
The last system described here is unique in that while a
thermal system, it does not have any similarities to other
destruction methods. It is deep well where the pressures
and temperatures associated with deep well operation
provide the destruction of the organic materials. It is the
Vertical Tube Reactor supplied by Vertek Treatment
Systems of Colorado. Diluted waste liquid is pumped into
the inner annular space of concentric vertical tubes.
These tubes are suspended in a conventionally drilled
and cased well 5200 ft deep with a tubular heat
exchanger running down the center. The waste stream
and injected air flow down the tube and reach a peak
natural pressure of the 1500 psig at the bottom due to
the height and density of the fluid above. Actual
combustion occurs while the waste substances are in a
liquid state when sufficient air, temperature, pressure
and organic content are present. During this oxidation
process some heat is generated which then may be
removed using the central heat exchanger. This offers
the possibility of recovery of this heat for use at the
surface. The diameter and length of the vertical tubes are
designed to provide sufficient residence time so that the
oxidation reaction can be completed and, in addition, the
high length to diameter ratio allows extremely efficient
counter flow heat exchange and mass transfer. The
reactant products leave through the outer annular space,
then flow into an air separation tank and into a settling
tank. Here it is held for about 30 minutes, allowing time
for the ash to settle out. The settled particles are pumped
to the ash pits and the clarified liquid is returned to the
biological process.
Conclusions
These processes are not all the processes available today
for thermal treatment of hazardous wastes. No attempt
has been made to closely evaluate the economics of
these systems. It is obvious that some might not be
economical under the present cost structure for the
disposal of hazardous waste. This does not mean that
they cannot become economical 5 or 10 years from now.
It is important to recognize that there are other
technologies being pursued which are widely different
from those employed in current practice and one day in
the near future these may be major thermal disposal
methods.
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Developing a Trial Burn Plan
By
Walter S. Smith
and
Tony Wong
The Resource Conservation and Recovery Act (RCRA)
was designed to ensure that incineration facilities which
treat hazardous wastes operate in an environmentally
responsible manner. Under the requirements of RCRA, a
trial burn must be conducted in order to obtain a finalized
operating permit. A trial burn is a test which determines
whether an incinerator is capable of meeting or
exceeding RCRA performance standards. If the standards
are met, then the trial burn should identify the operating
conditions necessary to ensure the incinerator's ability to
meet or exceed the performance standards throughout
the life of the permit.
Development of the trial burn must incorporate interests
of both the permit writer and the applicant. The permit
writer wishes to obtain sufficient data necessary to
establish the permit conditions. The applicant wishes to
obtain a permit which allows the greatest flexibility of
incinerator operating parameters set forth in the final;
permit. The areas of interest to be discussed, which allow
the applicant and permit writer to achieve their goals,
include understanding the problem, selecting a waste:
feed, choosing a principal organic hazardous constituent
(POHC), determining operating conditions, choosing
appropriate sampling methods, and obtaining ;
representative samples (QA/QC). The purpose of the
paper is to give an overview of what is required to
develop a trial burn plan.
Understanding the Problem
The first thing to do before attempting any task is to
identify the problem. For a hazardous waste incinerator,
the problem is obtaining an operating permit by
performing a trial burn which meets or exceeds the
performance standards. These performance standards
are:
1. 99.99% ORE of all designated POHCs,
2. 0.08 gr/DSCF of particulate emissions corrected to
7% oxygen, and
3. 4 Ib/hr of hydrogen chloride emissions or a 99%
removal efficiency. :
A person experienced in the area of incineration must be
available for consultation during the development of a
trial burn plan. Specific incinerator limitations such as
heat capacity, flow capacity, and residence time must be
known. Understanding the incinerator and its limitations
is a major step in the development of a trial burn plan. A
classic example of not knowing an incinerator's
capabilities occurred when a facility hired a consultant to
develop the trial burn plan. A plan with several operating
conditions was designed with the finst condition having
the lowest thermal input. It was determined during
operation that the lowest thermal input was equal to the
thermal capacity of the incinerator. It appears that the
consultant did not have an adequate understanding of
this incinerator and did not develop the trial burn in
conjunction with the incinerator operators. He based his
plan upon theory, not upon the years of experience of
plant personnel.
When a trial burn is designed, decisions must be made
concerning the needs of the facility. If the facility handles
a large amount of wastes, then volume (throughput) may
be important. For a commercial incinerator, the main
objective may be the ability to handle a wide variety of
wastes. If this is the case, then a POHC with one of the
lowest heat of combustion values should be chosen. On
the other hand, the concern could be high chlorine
content, high ash content, or high BTU content.
Whatever the situation, the factors most advantageous to
the facility must be determined.
An important element in understanding the problem is
often planning for the future. There is always the
potential of expansion and the need to incinerate other
waste materials. The need may arise to incinerate a new
waste feed containing a hazardous constituent with a
lower heat of combustion than the designated POHC
used for the trial burn. If this is the case, another trial
burn must be performed or the wastes must be shipped
elsewhere for disposal. Either alternative requires
additional expense. The choice of waste feeds, operating
conditions, and designated POHCs should reflect future
plans.
Selecting a Waste Feed
Three options are available when selecting a waste feed:
using the normal plant waste, spiking the normal plant
waste, or developing a contrived waste.
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Using the normal plant waste during the trial burn offers
a couple of obvious advantages. First of all, normal waste
is readily available. This waste has been incinerated ,«v
during interim status or is expected to be incinerated
once the permit is obtained. This approach is also
indicative of normal operation. Disadvantages include
possible interferences by waste constituents other than
the designated POHCs, which may complicate the
chemical analysis of both the waste feed and the stack
gas. More importantly, when normal plant waste is used,
the facility is limited to testing only for the POHCs
present in the waste. The permit, therefore, will be
limited to burning only those POHCs with heats of
.combustion greater than, or equal to, the most difficult
POHC to be incinerated in the waste.
Spiking a normal waste offers the same advantages of
normal waste, but it also reduces the number of problem
areas. An increase in the concentrations of the
designated POHCs should increase the stack gas
concentrations, therefore reducing the possible
interferences associated with chemical analysis of the
waste feed and stack gas. Another major advantage is
the ability to broaden the number of hazardous
constituents that will be allowed by the permit. For
example, if the waste were spiked with carbon
tetrachloride and a 99.99% ORE is achieved, the permit
would allow the facility to incinerate nearly all of the
Appendix VIII compounds. One potential disadvantage
associated with incinerating normal wastes is the
possible formation of products of incomplete combustion
(PIC), which could be a designated POHC. Unfortunately,
it is impossible to determine the effects of incineration,on
various wastes and the resulting products.
The use of artificial waste may simplify analytical
difficulties by reducing interferences, create a waste
which is difficult to burn, and offer a wide range of
possibilities. A wide range can be interpreted as a large
variation in POHCs, heat content, chlorides, or ash
content. A major deficiency of this approach is that the
artificial waste will not have the same physical
composition as the normal waste. For example, when an
artificial -waste with an ash content comparable to the
normal waste was used during one trial burn, the
particulate results from the trial burn exceeded the
standards by a factor of 10. In contrast, particulate
results from incineration of normal wastes under the
same operating parameters showed concentrations
below the standards. In this situation burning the
contrived waste was not indicative of normal operations.
!
Choosing a POHC
When choosing a POHC for the trial burn, an analysis of
the normal waste feed is performed to determine the
hazardous constituents of significant concentrations. The
present guideline for consideration of a POHC to be of
significant concentration in the waste is 100 ppm.
However, if the compound is highly toxic, a concentration
under 100 ppm can be considered significant.
In addition to identification and quantification of the
hazardous constituents, analyses must be performed to
measure viscosity, heating value, organically bound
chlorine, and ash content. Viscosity measurements
provide the permit writer with information necessary to
judge the adequacy of liquid waste delivery systems.
Heating value of the waste is used to determine and
maintain operating conditions and may be used to
establish permit conditions for allowable variations in
waste content. The ash content is measured to assess
particulate removal requirements of the control system
and.to determine if the ash handling capability of the
system is sufficient.
From the analysis, the designated POHCs can be chosen
by considering two basic factors: (1) the concentrations of
each organic hazardous constituent in the waste feed,
and (2) the rank of incinerability. Generally, the
hazardous constituent of greatest concentration is
chosen as one of the designated POHCs. Another POHC
should be chosen based upon the rank of incinerability.
To select the POHCs for a given waste, the permit writer
should align the hazardous constituents and their
concentrations in order of increasing incinerability. The
constituent with the lowest heat of combustion value
(considered the least incinerable), as well as the most
abundant constituent, should be designated POHCs.
Based upon the rank of incinerability, only one POHC
need be designated. However, the correlation between
the heat of combustion and incinerability is only an
approximation. Presently, there is not sufficient research
in this area to recommend an alternative method to the
heat of combustion approach.
An example of this approach can be seen in Table 1. The
constituents are listed in order of increasing
incinerability. From these values, the tetrachloromethane
and the chlorobenzene should be designated POHCs
based upon the heat of combustion values and
concentrations, respectively. The 1,1,1-trichloroethane
might also be designated a POHC in the event that
99.99% ORE is not achieved for tetrachloromethane.
An important rule to remember is: do not choose a POHC
which is a product of incomplete combustion (PIC).
Currently, regulations do not control the emission of
PICs. There have probably been many situations in which
the PIC produced from a POHC was also a designated
POHC for the same waste feed. As an example,
laboratory studies reveal that the degradation of
chloroform yields carbon tetrachloride and
tetrachloroethylene. A list of selected POHCs and their
PICs are presented in Table 2. The formation and
measurement of PICs as POHCs add complexity to the
interpretation of the ORE results. Based upon the formula
for determination of DREs, 100(Win-W0ut)/Win, the
formation of PICs would cause abnormally low ORE
results. Wm is the mass flow rate of the POHC into the
incinerator, and Wout is the mass flow rate of the POHC
in the stack gas emissions.
The permit writer should also consider limitations of
stack gas sampling and analytical techniques when
designating POHCs. Certain problems associated with
various compounds include water solubility,
contamination, poor recovery, and high reactivity. A list
-------
Table 1. Greatest Concentration and Heat of Combustion
Hazardous
Constituent
Heat of Combustion
% Concentration (kcal/gram)
Totrachloromethane
1,1.1-Trichloroethane
Chlorobenzene
Phenol
1
6
28
9
0.24
1.99
6.60
7.78
Table 2. POHCs and PICs
Designated POHC
Products of Incomplete Combustion
Carbon Tetrachloride
Chloroform
Chlorobenzene
Toluene
Trichlorobenzene
Kepone
Pontachloroethane
PCBs
Tetrachloroethylene
Hexachloroethane
Tetrachloroethylene
Carbon Tetrachloride
Benzene
Benzene
Chlorobenzene
Dichlorobenzenes
Hexachlorobenzene
Tetrachloroethylene
Chlorinated dibenzofurans
of selected problem POHCs is presented in Table 3. For
example, dichloromethane is a solvent commonly used in
laboratory environments. Care should be taken to ensure
that contamination of the samples does not occur. Traces
of formaldehyde, benzene, and chloroform are often
found during the analysis of samples and blanks. Organic
compounds with boiling points between 100 and 140°C
offer a unique situation since these compounds can often
be sampled with either the VOST or the Modified Method
5 (MM5). Laboratory evaluation of the sampling methods
may be necessary to determine which method is
appropriate.
In addition to choosing the designated POHC, the
quantity of the POHC in the waste feed should be
examined. The POHC concentrations should be high
enough to ensure that the analytical detection limits are
achieved. Also, an increase in the quantity, resulting in a
higher sample catch, would reduce the effects of
contamination.
Operating Conditions
The results of the trial burn are the principal basis for
setting the conditions of the operating permit. Data and
information obtained should give an accurate description
of the incinerator's performance. The most important
parameters which dictate the operating condition should,
at a minimum, include POHCs of lowest heat content and
greatest concentration, CO level in the stack gas, waste
feed rate, total thermal input rate, combustion
temperature, and combustion gas flow rate. The permit
writer's evaluation of the trial burn conditions is to
ensure that the data generated is likely to establish the
incinerator's capability of achieving the performance
standards.
From an operator's standpoint, the trial burn operating
conditions should be designed to ensure the greatest
flexibility in permitted operation. If compliance is shown
at only one operating condition, the resulting permit will
restrict operation only to those parameters, regardless of
changes in waste composition or feed rate. To obtain the
greatest flexibility, testing could be performed at the
maximum thermal input and waste feed rate. Adversely,
this approach would also cause operations to proceed
under worst-case conditions, maximizing the chance of
failure. Therefore, the applicant may consider operating
at the most severe and lenient conditions, in addition to
some intermediate conditions.
The trial burn could also be used as an opportunity to
experiment with the incinerator to determine if operating
costs can be reduced. The operating conditions could be
designed with a lower combustion temperature,
increasing feed rate, or reduced auxiliary fuel.
Appropriate Sampling Methods
Feed Samples
The sampling methods used for waste feed material
depend upon the exact form of the waste (solid, sludge,
liquid, etc.). Sampling for liquid wastes is usually
performed according to the Coliwasa and tap methods.
The. Coliwasa, a composite liquid sampler, is designed to
handle free-flowing liquids and slurries, including
multiphase wastes. To collect a waste, the sampler is
slowly lowered into the waste container and a liquid
sample is removed and transferred to a storage
container. The primary limitation is that the sample depth
cannot exceed 1.5 meters. For depths up to 3.5 meters,
the dipper (popd sampler) may be more appropriate. To
obtain samples from large storage tanks, wells, or other
containers which cannot be adequately sampled with the
other devices, a weighted bottle may be used.
The tap sampling method is appropriate for liquid waste
in pipes or ducts. A sampling line is attached to the tap
and inserted into the sampling bottle. The tap is opened
to allow flow such that the time required to fill the
sample bottle exceeds five minutes. Prior to sampling,
the sample line and bottle should be flushed several
times with the sample material.
For solid waste samples, the grain sampler (thief), the
sampler corer (trier), and the trowel (scoop) are most
suitable. The grain sampler consists of two slotted
6
-------
Table 3. Selected Problem POHCs
Compound
Cause of Problem
Possible Solution
Acetonitrile
Acetyl chloride
Aflatoxins
Aniline
Benzene
Benzenearsonic acid
Bis(chloromethyo)ether
2-Butanone peroxide
2-sec-Butyl-4-6-dinitrophenyl
Chloral
Chloroform
Coal tars
Creosote
Cyanogen
Cyanogen bromide
Cyanogen chloride
Cycasin
Dibutyl Phthalate
Dichloromethane
/V,/V-Diethylhydrazine
1,1 -Dimethylhydrazine
1,2-Dimethylhydrazine
1,4-Dioxane
1,2-Diphenylhydrazine
Diphenylamine
Formaldehyde
Formic acid
Hydrazine
Hydroxydimethylarsine oxide
Iron dextran
Maleic anhydride
Maleic hydrazide
Methyl ethyl ketone
Mustard Gas
Nitroglycerin
Phenylmercury acetate
Phosgene
Phthalic Anhydride
Pyridine
Selenourea
Toluene
Toluene diisocyanate
Vinyl Chloride
water soluble
decomposition
high toxicity
water soluble
contamination
low volatility
decomposition
reactive
acidic-extracts poorly
water soluble
contamination
complex mixture
complex mixture
gas
gas
gas
low volatility
reactive
contamination
unstable
unstable
unstable
water soluble
unstable
basic-extracts poorly
water soluble
water soluble
unstable
low volatility
high molecular weight
unstable
unstable
poor recovery
highly toxic
exposive
low volatility
highly toxic
highly reactive
water soluble
low volatility
contamination
water soluble
poor storage
derivative with HI
sample with MM5 train
derivative to sample
derivative to sample
GPC
derivative with HI
special HPLC column
telescoping tubes, with the outer tube containing a
conical pointed tip on one end which permits the sampler
to penetrate the material. The sampler is opened and
closed by rotating the inner tube.
The sampling corer is usually a long tube with a slot that
almost extends the entire length of the tube. The sampler
is inserted at an inclined angle and withdrawn with the
open portion pointed upwards. This sampler is similar to
the grain sampler but is preferred for moist or sticky
materials. The trowel resembles a small shovel. These
methods are also applicable for the sampling of ash.
Scrubber water samples may be sampled by the dipper or
tap method.
To achieve a representative sample, liquid samples
should be collected every fifteen minutes and composited
for each run. Duplicate samples should be taken in the
event one of the samples is damaged or contaminated.
Solid samples should be collected using the most
practical method for representative samples of each type
of solid waste used in the trial burn. , ,
In certain circumstances, these waste feed sampling
methods may not be appropriate. For example, a large
storage tank containing a nonhomogeneous liquid waste
mixture may cause sampling problems. The weighted
bottle is considered appropriate for depths greater than
3.5 meters, but is not appropriate for multiphase wastes.
The tap method could also be used, but, with a
nonhomogeneous waste, the collected samples may
produce distorted results. This may cause an excessively
high or low POHC feed rate which would bias the ORE
results. As an alternative, measurements of the material
used to make up the waste feed may be used to
determine POHC feed rates. Determining the POHC
-------
concentration from the components of the waste feed \
material may be more appropriate than collecting '
composite samples by conventional methods which may
not bo representative.
Particulate and Hydrogen Chloride
Paniculate and hydrogen chloride (HCI) emissions testing
is performed according to EPA Reference Method 5.
Sampling encompasses EPA Methods 1 through 5 as
defined in the 40 CFR Part 60, Appendix A. Method 1
shall be used for the determination of the sampling
points. Method 2 shall be used for velocity
measurements. Method 3 shall be used for O2 and CO2
measurements. Method 4 shall be used for moisture L
determinations. Method 5 shall be used to determine the
concentration of paniculate matter in the incinerator
effluent gas. The Method 5 train can be modified to
capture chlorides as well. The modification will consist of
replacing the water in the first two impingers with
caustic solution.
i
Each paniculate test run shall be performed in
conjunction with the POHC sampling, and a minimum of
30 dry standard cubic feet of sample gas shall be
collected during each run. The average sampling rate for
each run shall be within ± 10% of 100% isokinetic
conditions. Reference Method 5 analytical procedures
shall be used for the determination of paniculate
emissions. Ion chromatography or EPA Method 325.3,
mecuric nitrate titration, has been used for the
determination of HCI emissions.
POHC Sampling
Stack gas sampling for the designated POHCs is the most
important aspect of the hazardous waste incinerator
permitting process. The two most widely used sampling
methods, the Volatile Organic Sampling Train (VOST) and
Modified Method 5 (MM5), will be discussed.
The VOST is applicable for capturing compounds with
boiling points between 30 and 100°C. For compounds
with boiling points below 30°C or between 100 and
150°C, lab verification of the sampling method is
required. The sensitivity of this method is generally
between 100 ng and 50//g. In certain situations the
lower and upper detection limits can approach values'of
10 ng and 100/ug, respectively. An example of the VOST
can be seen in Figure 1. This design employed by Entropy
makes use of a few basic modifications to the original
sampling protocol. The condensate trap'has been
replaced by a disparger tube and the second condenser
has been removed. Some cases may require analysis of
the aqueous condensate when sampling is performed for
water soluble POHCs. The disparger tube is used to
purge any POHCs which may have been trapped in the
condonsate. The second condenser has been removed
from the train to prevent condensation from flowing into
the tenax/charcoal. Condensation upon the backup
sorbent trap would greatly reduce the capture efficiency
of the charcoal half of the trap. As shown in the figure,
the sampling train is surrounded by an Atmos glove bag.
The purpose of this bag will be discussed in a later
portion of this paper.
The protocol developed for the VOST recommends the
use of 6 pairs of cartridges per run. The purpose for this
approach is to ensure that the detectable range is
achieved by combining samples. From our experience,
the detectable range can be achieved with the use of only
3 pairs of traps. This approach also resduces the sampling
time and analytical costs. Sampling i:> usually performed
at a sampling rate of 1 liter per minute for 20 minutes
with a sample volume for each pair of traps not to exceed
20 liters. For compounds with boiling points below 30°C
and with expected high concentrations, SLOW-VOST, a
smaller sampling volume or slower sampling rate, may
be more desirable. For example, SLOW-VOST could be
either a sample volume of 5 liters with a flow rate of 0.25
liters per minute for 20 minutes or a sample volume of
20 liters with a flow rate of 0.5 liters per minute for 40
minutes.
The analyses of the VOST sorbent traps are performed
according to the purge-trap-desorption followed by GC/
MS. Samples are thermally desorbed with organic-free
nitrogen and passed through a water filled purge column
onto an analytical trap. The trap is heated, and the
effluent gas is directed into the GC/MS.
The Modified Method 5 (MM5) sampling train is designed
to handle vapor phase organic compounds with boiling
points greater than 100°C. This sampling train (See
Figure 2) is adapted from the components typically used
for EPA Method 5 sampling. The basic modifications
include the addition of a sorbent module containing XAD-
2 resin preceded by a condenser used to cool the gas
stream below 20°C. The average sampling rate for each
run shall be within ± 10% of 100% isokinetic conditions.
The sampling period for the MM5 can range from 1 to 6
hours depending upon the analytical detection limit. An
advantage of this sampling method jis the ability to
increase the sampling period to ensure the POHC sample
catch is within the appropriate analytical detection range.
However, a longer sample period increases the'possibility
of stripping the POHCs from the XAD-2 resin. For this
reason, it may be more appropriate to increase the POHC
concentration in the waste feed than to increase the
sampling period. All surfaces that contact the sample,
except the nozzles and probes greater than 7 feet in
length, are constructed of glass or Teflon®. The major
advantage of this system is that paniculate loadings can
also be determined. Sampling can also be modified to
capture hydrogen chloride by replacing the distilled water
in the impingers with caustic solution. To perform the
analyses, the compounds are first extracted by solvent
from the various components of the sample train, then
analyzed by gas chromatography and mass spectrometry.
The lower detection limit for this analytical approach is
typically 10 ng.
Representative Samples
Using the appropriate sampling methods alone will not
ensure quality, representative samples. To determine the
desired sampling .rate and period, the expected stack gas
8
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Charcoal Filter
(for leak checks)
— Squeeze Bulb
(for purging)
Glass Wool
Particulate Filter
Dry Gas
Meter
Vacuum
Pump
Figure 1. Volatile organic sampling train (VOST).
-------
Temperature
Indicator
Thermocouple (behind)
Stack Wall
j f Cooling Water J
u
.
Magnehelic® Gauges
Figure 2. Modified Method 5 (MM5) sampling train.
10
-------
concentration must be calculated. These calculations
should be based upon the POHC feed rate, the stack gas
volumetric flow rate, and the expected ORE results. The
detection range for the various analytical methods
dictates the sample catch required.
Following is an example of how to determine if the VOST
sampling procedures will achieve the appropriate
detection range. Using the information provided, the
emission rate) POHC concentration in the stack gas, and
POHC sample catch can be determined. The emission
rate is based upon the inlet POHC feed rate and 99.99%
destruction and removal efficiency (ORE). The stack gas
concentration is the emission rate divided by the stack
gas.volumetric flow rate. The sample catch is based upon
the normal VOST sample volume of 20 liters. As
displayed in this example, the sample catch of 1.78 fjg
per sample is within the detection range of 100 ng to 50
/ug. Also shown in the example are a decreased and
increased POHC feed rate with sample catches outside
the detection range. For the sample catch below the
detection range, the POHC concentration in the waste
feed must be 'increased or an alternative sampling
method mustbe chosen. The sample volume must not
exceed 20 liters and therefore cannot be increased to
achieve the appropriate detection level. For the sample
catch above the detection range, a smaller sample
volume, obtained from the use of SLOW-VOST, would
lower the sample catch to within the detection range.
Detectable Range:
POHC Feed Rate - 10 Ib/hr
Stack Gas Volume Flow Rate - 3000 dscfm
Expected ORE Results - 99.99%
Detection Range - 100 ng to 50 /ug
Emission Rate:
0.001 Ib * 453.593 g
hr Ib
Stack Gas Concentration:
1 hr = 0.00756 g
60 min min
scf =
0.00756 g * 1 min * 1,000,000/ug * _
min 3000 dscf ~~g 28.317 liter
0.089 /ug
liter
Sample Catch:
0.089 /ug * 20 liter = 1.78 //g
liter
sample
sample
POHC Feed Rate Sample Catch*
0.01 Ib/hr
500 Ib/hr
1.78ng
89.0//g
*Based upon 20 liters of sample volume for
each VOST sample.
A major consideration is the prevention of contamination.
If contamination has occurred, the resulting DREs could
be much lower than desired. For this reason, the use of
field, trip, and laboratory blanks should be incorporated
into the trial burn. Field blanks are prepared at the
sampling location. Field blanks should be treated in the
same manner as a normal sample with the exception of
bypassing the sampling procedures. The VOST field
blanks should be exposed to the atmosphere for the
required amount of time needed to switch;a pair of tubes.
The MM5 field blank should consist of a completely
assembled sampling train. This train will be placed at the
sampling location for the same amount of time which is
necessary to conduct a run. The train will then be
disassembled and cleaned according to the normal
sample recovery procedures.
Trip blanks will be transported and stored on site in the
same manner as the samples. Laboratory blanks will be
stored in the laboratory to determine if contamination
may have occurred during preparation or storage. If
contamination has occurred, the use of the various
blanks should help identify the source of contamination.
The environment around a hazardous waste incinerator
is an undesirable location for Tenax, since POHCs are
present in the ambient air. The objective of the VOST is
to capture the designated POHCs from trie stack gas
without contamination from the ambient air. This is
accomplished most efficiently by surrounding the sample
collection part of the VOST with an atmospheric glove
bag (See Figure 1). All of the tubes needed for the day's
sampling are placed inside the bag. An open dish of
charcoal, designed to capture any hydrocarbons which
cause contamination, is also placed in the glove bag
before sealing. At the end of the testing day, the glove
bag is opened and the sealed cartridges are removed.
Conclusions
The first step to developing a successful trial burn plan is
to identify the problem. This includes understanding
regulations, incineration, and needs of individual
facilities. Each facility will have different needs and will
present different problems. It is the responsibility of the
applicant and permit writer to satisfy those needs and
anticipate those problems.
Cooperation has an important role in the development of
a trial burn plan. The permit writer and applicant have
different duties, but have a common goal (permitting the
incinerator). The permit writer wishes to obtain sufficient
data necessary to establish permit conditions, while the
applicant wishes to obtain a permit which allows the
greatest flexibility of incinerator operating parameters set
forth in the final permit.
In order to understand the problem, competent, qualified
personnel are a necessity. Both the applicant and permit
writer should have an excellent knowledge of RCRA
regulations and incineration. In some cases, a consultant
experienced in these areas may be beneficial. The choice
of sampling methods and obtaining quality.
-------
representative samples should be the responsibility of a
testing firm.
Organization is essential to ensure smooth and efficient
development and implementation of the trial burn plan. A
great deal of planning and research is necessary to !
obtain the most advantageous waste feed, POHCs, and
operating conditions. Once the plan has been developed,
implementing the test plan requires organizing the
efforts of the permit writer, applicant, and testing firm,
towards a common goal.
References
1. U.S. Environmental Protection Agency/Office of
Solid Waste. Guidance Manual for Hazardous
Waste Incinerator Permits, Washington, DC,
September 1982.
2. U.S. Environmental Protection Agency. Practical
Guide - Trial Burns for Hazardous Waste
Incinerators. EPA Contract No. 68-03-3149, April
1986.
3. U.S. Environmental Protection Agency. Permit
Writer's Guidance Document for Hazardous Waste
Incineration, Washington, D.C., November 1982.
4. U.S. Environmental Protection Agency/Industrial
Environmental Research Laboratory. Protocol for
the Collection and Analysis of Volatile POHCs
Using VOST. EPA-600/8-84-007, March 1984.
5. U.S. Environmental Protection Agency/Industrial
Environmental Research Laboratory. Modified
Method 5 Train and Source Assessment Sampling
System Operators Manual. EPA Contract No. 68-
02-3627, August 1983.
6. Dellinger, B. and D. L. Hall. "The Viability of Using
Surrogate Compounds for Monitoring the
Effectiveness of Incineration Systems," Hazardous
Waste Management, Volume 36, No. 2, February
1986.
7. Harris, J., D. Larsen, C. Rechsteiner, and K. Thurn.
Sampling and Analysis Methods for Hazardous
Waste Combustion, First Edition. Prepared for U.S.
Environmental Protection Agency, EPA Contract
No. 68-02-3211 (124) by Arthur D. Little, Inc.,
December 1983.
12
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Trial Burn Plan Evaluation
By
John R. Hart
USEPA, Region IX
Introduction
Alternatives to land disposal of hazardous wastes are
urgently needed. Land disposal leads to complete
evaporation of volatile organic hazardous constituents of
the waste, and to the contamination of ground water and
of surface water.
Combustion of organic hazardous waste is an inherently
good treatment method. However, public concern and
regulations within the Resource, Conservation, and
Recovery Act require that the permitting of hazardous
waste incinerators is done in a technically competent and
comprehensive manner. In order to permit a hazardous
waste incinerator to operate, a demonstration of the
performance of the system must be done. This
demonstration is called a "Trial Burn." The proper
evaluation of a Trial Burn Plan is one of the key issues to
insure the success of a hazardous waste incineration
project.
Evaluation of Completeness of the Trial
Burn Plan
The first step in evaluating a Trial Burn Plan is to
determine if the Plan is complete, with the appropriate
level of detail. The appropriate level of detail is enough
information to design, construct, operate, and maintain
the facility and to conduct the entire Trial Burn and data
reduction. The primary areas which must be included are
the design of the combustor and air pollution control
equipment, a full description of the waste, the detailed
operating protocol, the sampling and analysis protocol,
the continuous monitoring protocol, and a detailed test
schedule and coordination plan.
The description of the design of the facility must be fully
included. The combustion system description must at
minimum include the design or construction drawings,
the piping and instrument diagrams, and the control
systems diagrams with the waste-feed interlock systems.
The specifications and locations of the burners and air
registers must also be included, as well as the complete
mass balance, energy balance, and heat transfer
calculations utilized to design the combustor.
The air pollution control equipment must also be fully
described. The appropriate drawings must be included,
and the full mass balance, absorption, and other
appropriate calculations'must be included.
Full characteristics of the waste must be indicated in the
Trial Burn Plan. The molecular composition must be
included, especially with an identification of any
hazardous organic constituent listed in Title 40 of the
Code of Federal Regulations (C.F.R.) Part 261, Appendix
VIII. Also, an "ultimate" analysis (elemental composition)
of the waste should be included in order to perform the
mass balance calculations for the flue gas composition
and stoichiometric air requirements. The Principal
Organic Hazardous Constituents (POHCs) should be
recommended for each waste stream. The POHCs will be
the constituents for which performance tests, including
Destruction and Removal Efficiencies (DRE's), will be
done during the Trial Burn. The POHCs shall be chosen
on the basis of highest concentration found in the normal
operating waste stream, and on the basis of highest
degree of incinerability. Additionally, the waste feed rate
for each test series should also be specified, as well as
the waste feed rate to each burner.
One area that is often not given full attention is the
detailed operating protocol. All operating parameters and
operating levels must be specified for the entire
combustion system. Some of the primary areas which
must be addressed for the combustor are the waste mass
flow rate and composition, combustion temperature
fields, combustion gas velocity fields (for both residence
time and turbulent mixing considerations), waste burner
atomization pressures, and the key indicators of
stoichiometry and performance: the concentrations of
carbon monoxide, oxygen, and total unburned
hydrocarbons in the combustor exit gas stream. A few of
the key parameters which must be addressed for the air
pollution control equipment are the liquid-to-gas mass
flow ratios, liquid pH, pressure drop and voltage potential
(for electrostatic precipitators).
The sampling and analysis of the waste, combustion exit
gas stream, scrubber and other liquid discharge streams,
and of the ash must be addressed. A detailed protocol
must be developed which includes the schedule,
equipment requirements and backup systems, and
personnel (including contractors). Quality assurance and
quality control programs should be defined in detail. The
exact methods and protocol must be specified in all
aspects of the sampling and analysis of each species,
with the limits of detection listed for each species.
13
-------
Continuous monitoring of the operating parameters and
indicators of stoichiometry and performance must be
defined. The methods and equipment must be specified,
and must meet the performance specifications in 40
C.F.R. 60, Appendix B. The instrument and control
diagrams for the waste feed interlock/cutoff systems
must be included, as well as a description of these
systems. The waste feed cut-off levels for each of the ',
operating and performance parameters must also be
specified.
Finally, the detailed test schedule and coordination plan
must also be enumerated in the Trial Burn Plan. The
proposed dates of the tests and the duration of each test
due to sampling requirements and time to reach steady
state operation must be specified. The test schedule and
protocol must specify and summarize all of the
parameters that are discussed in this section.
Once all of this information is specified in complete :
detail, the Trial Burn Plan must be evaluated for '
adequacy.
Evaluation of Adequacy of Trial Burn
Plan
The evaluation of the adequacy of the Trial Burn Plan is
the evaluation of the adequacy of each item decribed in
the section above {Section II). The primary concerns are if
the technical approach and methods are sound and if the
data will be sound, whether or not the anticipated data
can be translated into permit conditions, and if areas of
public concern are addressed.
For example, in evaluating the design of the combustion
system the calculations indicate that for one of the waste
Streams at the maximum waste flow, the maximum air
delivered will only produce a combustion exit gas oxygen
concentration of 1%. This will probably not be enough air
to achieve the performance requirements, so that this
portion of the Trial Burn Plan (the design of the
combustion system) is not adequate.
The information in the Trial Burn Plan should also be '
adequate to anticipate the type and form of permit
conditions which would be developed from the Trial '
Burn. In essence, this means that a draft of the Permit ;
should be written from the Trial Burn Plan, with the
actual Trial Burn data utilized in confirming the
conditions of the Permit. For example, in one case the ;
Trial Burn Plan requires for a particular test series
several combustion temperatures (one temperature per
test) and all other parameters are required to be held
constant. If the performance standards are achieved for
all of these tests, the permit conditions for that particular
waste stream and waste feed rate would be the
minimum temperature achieved and a corresponding
limit of the other parameters which were held constanti
Perhaps the most difficult question to answer is whether
or not the data developed from the Trial Burn will be
sufficient to satisfy the public. The public is asking
increasingly more difficult questions and wants to know
14
more details than ever before. The primary areas of
public interest are in the areas of heeilth effects from
emissions, levels of emissions, complete molecular
composition of emissions (the identification of all
products of incomplete combustion), and the chances of
explosion, releases, or other catastrophic events. The
Trial Burn Plan should be designed to answer these
questions based on, in part, the data from the Trial Burn.
Data in Lieu of Trial Burn (270.19(c))
Although the submission of data instead of performing a
Trial Burn is not ideal, it has been done and is listed as
an alternative in the regulations. Detailed information
similar to that required for a Trial Burn Plan is required,
and a similarity analysis must be performed on the
combustion and air pollution control systems and on the
wastes from both the proposed system and on the system
on which the data were taken.
The information requirements include detailed waste
analyses, a detailed design decriptiori of both systems as
indicated in Section II, a detailed waste comparison, a
detailed comparison of operating conditions, a detailed
comparison of the combustor and air pollution equipment
design, and the test results in the appropriate form.
An analysis of the similarity of combustion systems is
extremely complex. In order to fully understand a
combustion system, a thorough knowledge of each
fundamental and practical aspect of that system should
be acquired. The systems should be examined in terms of
the local fluid dynamics, combustion chemical kinetics,
heat transfer, mass transfer, and thermodynamics.
Additionally, the practical aspects such as monitoring
devices, fans, burners and burner orientation, and fire
brick should be examined. The data for such an analysis
is usually not readily available for full scale units.
The similarity analyses should be performed with the
data available. The aspects of similarity examined for the
combustor should be geometric, dynamic, chemical, and
thermal similarities. For geometric similarity, the ratio of
all length scales and angles should be proportional.
Dynamic similarity exists when all forces on the gas
streams are proportional. This analysis may be facilitated
by requiring a similarity of Reynold's Numbers. Chemical
similarity exists when chemical concentrations within
the combustion chambers are proportional. Thermal
similarity requires that temperature fields are
proportional.
The similarity of the air pollution control equipment must
also be examined. While every type of device has some
effect on organic, HCI, and particulate emissions, these
devices can be classified into two categories. Gas-liquid
contacting devices primarily remove HCI from the gas
stream. Gas-solid contacting devices primarily remove
particulates from the gas stream.
The primary parameters to evaluate similarity for the gas-
liquid contacting devices are the liquid-to-gas mass ratio,
pressure drop, gas residence time, liquid pH,
temperature, and the contacting area. For the gas-solid
-------
contacting devices the main parameters to examine for
similarity are gas residence time, contacting area,
temperature, and voltage potential (if applicable).
Translating Trial Burn Results into F'ermit
Conditions
The ultimate test to determine if the Trial Bum Plan is
adequate is if the anticipated data can be translated into
permit conditions. Test protocols should be developed
which include all operating parameters. The protocols
should be developed such that the primary operating
parameters are de-coupled, ideally done by the variation
of only one parameter with all other parameters held
constant.
The primary variables which should be examined during
a Trial Burn are derived from a simplified combustion
theory. The effect of residence time, temperature,
turbulence, and stoichiometry on performance should be
examined.
As in any experiment, it is essential to control the
primary parameters during a Trial Burn. This is
sometimes difficult to achieve in many full scale
combustors, primarily because the instrumentation and
controls do not have a high enough resolution. However,
it is important to aim for tight control of the variables
when performing the Trial Burn, and also during
hazardous waste operation.
When examining the effect of one fundamental
parameter on performance during a Trial Burn, it is
essential to hold all other parameters constant. If this is
not done, it is impossible to de-couple the relative
influence each fundamental parameter has on
performance. This is extremely important when setting
permit conditions.
Although this approach appears to be very expensive and
time consuming, it is an ideal which can be utilized in
order to prioritize the data taken during the Trial Burn.
Again, the main conditions of the Draft Permit should be
based on the Trial Burn Plan, with confirmation of these
conditions by actual Trial Burn data.
Summary
When permitting a hazardous waste incineration system
for construction and operation, the Trial Burn Plan must
be carefully evaluated. The Trial Burn Plan must be
complete, it must be technically adequate and must
address public concern, and the Draft Permit should be
written based upon the details of the Plan. Additionally,
utilizing data instead of performing a Trial Burn is an
option which also must be carefully examined. The
comprehensive evaluation of the Trial Burn Plan is a
necessary step in insuring a technically sound
incineration system and in overcoming the hurdle of
public concern which will ultimately determine if the
project proceeds.
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Conducting the Trial Burn
By
Roy Neulicht
Midwest Research Institute
Kansas City, Missouri 64110
Introduction
The trial burn is conducted in order to evaluate an
incinerator's performance with respect to RCRA Part B
requirements. Although the requirements which must be
met are the same for all incinerators, each trial burn is
unique because of the incinerator design, incinerator
operation, waste feed type, and Principal Organic
Hazardous Constituents (POHCs) chosen. The details of
how the trial burn is to be conducted (e.g., POHCs :
chosen, incinerator operating conditions, sampling and
analysis methods) are addressed in the trial burn plan.
The intent of this paper is to present, in a general sense,
guidance on conducting the trial burn. The purpose is to
provide an overview with respect to implementing a trial
burn for those unfamiliar with what is involved. Details
and principles related to preparing a trial burn plan (i.e.,
POHCs to choose) are not addressed. The paper
discusses: '
• Key personnel involved in implementing a trial burn
• Key activities which must be coordinated
• Typical problems
• The trial burn schedule, and
• Improved execution of a trial burn
Planning the Trial Burn - Key Personnel
Prior to conducting the trial burn considerable time will
have (or at least should have) been invested in preparing
a detailed and comprehensive trial burn plan. If a well ,
thought out trial burn plan has been prepared then
conducting the trial burn is a matter of implementing the
plan. Major questions and problems should have been
addressed prior to initiating the trial burn. Hence, the
process of conducting a trial burn is one of planning,
managing, and coordinating in order to implement the
plan. On paper, this sounds easy...in reality the process is
more complex.
Planning, coordinating, and conducting a trial burn
potentially involves a great number of different people-i-
or a "test team." Table 1 identifies the key persons ;
typically involved in conducting a trial burn. Persons from
the facility, emissions testing firm, and agency(s) are
involved. I use the term team, because in order to get the
job done persons in all three sectors (facility, consultant,
agency) must communicate and work together.
Table 1. Test Team
Trial Burn
Coordinator
Operations
Manager
Lead
Operator
Project Leader
Field Crew
Chief
Analytical
Task Leader
Quality
Assurance
Officer
Permit Writer
Technical Leader
for Sampling
Technical Leader
for Analysis
Quality Assurance
Officer
Depending upon the complexity of the test and
organizational structures of the company and agency,
multiple people from each sector usually'are involved.
For example, the company's trial burn coordinator may be
from a corporate environmental group not from the
facility. Obviously, the facility manager also must be
involved, as well as the actual incinerator operator.
Because of the varied expertise required, i.e., sampling,
analysis, regulatory-the agency also may have several
people involved. Obviously, close communication and a
clear understanding of objectives by all persons involved
are necessary in order to coordinate and carry out the
test. Hence, it is important that all parties be involved in
the process as soon as possible, i.e. during planning and
preparation of the trial burn plan.
The need for early involvement cannot be stressed
enough. It is foolish for corporate engineering to write a
trial burn plan and think about initiating the trial burn
without involving the lead operator of the incinerator;
after all the operator is most likely to know what the unit
can and can't do. Likewise, problems and the need for
revisions to the trial burn plan usually result if the
consulting firm that will actually conduct the sampling
analysis and reporting is not involved very early in the
process of preparing the trial burn plan. Furthermore, the
more collective experience with conducting trial burns
available to the "team," the better. In other words, if
personnel experienced with conducting trial burns can be
found within the corporate structure, within a consulting
firm, and within the agency, you should use itl
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Key Activities
Table 2 presents a partial list of the key activities to
coordinate during the trial burn. Note that the trial burn
activities are divided into 3 general categories: (a) pretest
activities, (b) activities required during the actual test and
(c) post test activities. When one thinks of a trial burn
there is a tendency to immediately focus on "stack
emissions sampling." True the measurement of the stack
emissions are a key part of conducting the trial burn;
nonetheless, as examination of Table 2 indicates, it is
only one of many parts.
First, in order to avoid unnecessary delays, the trial burn
coordinator, facility manager, and test consultant must
assure that any required site modifications are made well
in advance of the date the trial burn is to begin (several
weeks or months is much preferable to several hours).
Because the trial burn is designed to test performance of
the incinerator under specific operating and waste feed
conditions as specified in the trial burn plan, the facility
must assure that sufficient waste feed with the desired
characteristics is available for the test. Also, since the
trial burn data will be used to establish incinerator
operating limits and monitoring requirements, it is
necessary to assure that the process operation monitors
(e.g. carbon monoxide monitor, waste feed rate monitor)
are properly calibrated prior to initiating testing. Again,
since alot of critical activities will be occurring just prior
to and during the actual burn, these items need to be
addressed well in advance of the burn.
During the actual conduct of the trial burn, the primary
activities which must be closely coordinated include: (a)
process operation and monitoring, (b) emission testing,
and (c) collection of process samples (e.g. waste feed,
scrubber water samples). All three functions are
conducted simultaneously. All are equally important.
Remember that how the incinerator is operated during
the testing will ultimately affect the permit limits. For
Table 2.
Activities to Coordinate
Pretest:
• Site Modifications
• Waste Feed Preparation/Availability
• Process Monitor Calibration
During Test:
Process Operation/Monitoring
Pollution Control System Operation/Monitoring
Emissions Testing
Process Samples Testing
Data Records
Safety
Post Test:
• Sample Transport/Transfer
• Analysis Directive
• Analysis
• Reporting
example, the operating permit generally will require that
the incinerator combustion chamber temperature be
maintained at a level greater than or equal to the
minimum temperature demonstrated during the trial
burn. Hence, it is very important that the facility closely
monitor incinerator operation and coordinate with the
test crew so that testing will not be started and is
discontinued if the desired operating parameters are not
being achieved. Proper understanding of the objectives to
be achieved and good communication among all parties
involved is essential. Similarly, because calculation of
POHC Destruction and Removal Efficiency (ORE) includes
both the input (waste feed) and output (stack gas
emissions) of the chosen POHCsa, the sampling/analysis
of process samples is equally as important as the
sampling/analysis of stack gas emissions. Therefore,
process samples are taken simultaneously with the stack
gas emission testing, usually at 15-30 min intervals.
Depending upon the number of waste feed streams to
the incinerator several people may be required simply to
take process samples. Several different sampling trains
will be required to collect stack gas emissions samples
including, as a minimum, (a) a particulate/HCI sampling
train, (b) an integrated gas sample (oxygen and carbon
dioxide) and (c) volatile and/or semivolatile POHC
sampling trains. It is obvious that the number of activities
and persons to supervise and coordinate for a single test
is significant.
The trial burn does not end when the sampling is
completed. The transfer of samples to the analytical
laboratory and the subsequent sample analysis and
reporting of results constituents a substantial part of the
overall trial burn effort. The number of analyses to be
conducted are numerous and the analytical parameters
and protocols vary depending on the type sample. Hence,
it is essential that a written analyses directive be
prepared and submitted with the samples. In reality, this
must be planned well in advance of the testing. Many
organic samples, especially when analyzing for volatiles,
have specific "holding time" requirements.
Consequently, test samples often are shipped from the
field directly to the laboratory on a daily basis. This
requires that the laboratory knows what samples to
expect, when to expect them, and specifically what
analyses are to be conducted. For a complex trial burn
involving sampling of 3 different waste input streams;
scrubber water influent and effluent; incinerator ash; and
volatile, semivolatile and particulate stack gas emissions,
a three run trial burn can easily generate 50 individual
samples. Most samples will be analyzed using different
methods for multiple analytes (e.g., semivolatiles, ash,
high heat value). In short, proper planning and
coordination is required between the field and laboratory
personnel.
Finally, the field, laboratory, and facility personnel must
coordinate tabulation, interpretation, and reporting of all
results before one can truly say the trial burn is
completed.
_ POHC Input Rate - POHC Output Rate x 100
POHC Input Rate
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Special Concerns and Common
Problems
Some of the more common problems and special
concerns associated with the trial burn are:
1. The incinerator cannot achieve all desired conditions
simultaneously.
2. The incinerator has never been operated at the test
conditions for any length of time.
3. Special preparation of waste feed may be necessary.
4. Process upsets and deviations from protocol.
As previously mentioned, since operating permit limits
will be based on the operating parameters demonstrated
during the trial burn, the chosen trial burn operating
conditions are extremely important. Generally, "worst
case" operating conditions are desired, that is:
• Operating conditions ;
—Maximum heat input rate
—Minimum combustion temperature
—Maximum waste feed rate
—Minimum Oa concentration in stack gas
—Maximum air input rate (maximum gas flowrate to
yield minimum residence time)
—Maximum CO content in stack gas
• Waste characteristics '
—Maximum concentration of selected POHCs
—Maximum Cl content
—Maximum ash content
—Minimum heating value (HHV) of waste feed
It is not always possible to simultaneously achieve all the
worst case conditions. For example, maximum air input
rate (lowest residence time) and minimum 02 ',
concentration may be mutually exclusive. Furthermore,
and perhaps of more concern, is the fact that a facility in
attempting to achieve "worst case" conditions may be
operating at test conditions never before attempted. Not
only may the conditions not be achievable, but potential
problems with operation may appear during the trial
burn. For example, if the ash content of the waste is
significantly increased from the normal level, plugging of
waste feed nozzles during the trial burn may occur.
Similarly, the waste feed system may be prone to failure
if it is operated at or beyond its maximum design level.
Obviously, the wise approach is to determine the desired
operating conditions well in advance of the trial burn and
then proceed through a well designed step by step
"shakedown" to assure the desired operating conditions
can be achieved and to identify potential equipment and
operating problems. During this "shakedown" it may be
desirable to test the performance of the incinerator with
respect to selected RCRA performance criteria. For
example, if the waste feed rate and ash content of the
feed are significantly increased, it is wise to conduct a
paniculate emissions test to assure that the pollution
control system is adequately performing. This approach
of selectively evaluating performance is often referred to
as conducting a "miniburn." Miniburns typically are
conducted to evaluate particulate or HCI performance or
to evaluate ORE under varied operating conditions such
as a lower combustion chamber temperature, increased
feed rate, or different waste type. The concept of a
"miniburn" applies to new and existing facilities. Of
course, in all cases one must assure that during a
miniburn applicable permit limitations (if any) are not
exceeded. In the long run, this approach can be less time
consuming and less expensive than going through a
complete trial burn, failing to meet the particulate
performance standard, and being required to repeat the
trial burn.
As previously mentioned, since worst case conditions are
desired during the trial burn, it generally is necessary to
prepare a special waste feed or modify the normal waste
feed so that the desired waste feed characteristics are
obtained. This can become a logistics problem in terms of
blending and storage of the large quantities needed for
the trial burn. Waste feed homogeniety often is a
problem. Proper planning is required. If there is any
doubt about the success of preparing the desired feed, it
should be attempted and checked out (i.e., sampled and
analyzed) well in advance of the trial burn.
During the actual trial burn, deviations from the
operating, sampling, and analysis protocols established
in the trial burn plan will occur. No matter how well the
trial burn is planned, some deviations generally are
necessary. With regards to handling deviations, a
distinction must be made between major and minor
deviations. A minor deviation would include a minor
change to the test protocol. For example, an extra
impinger might be added to the semivolatile sampling
train because of excessive moisture collection. Minor
changes, should be documented in the test report. A
major deviation is one that will affect permit limitations
or the validity of the test. For example, if the combustion
chamber temperature stipulated in the trial burn plan is
1700°F, the d'ecision to operate at 1500°F is a major
deviation. Agency personnel must be consulted prior to
such a deviation because of the potential adverse impact
on emissions during the trial burn. Similarly, if a decision
is made to operate at 1900°F, the agency should be
informed and the operator must realize that making such
a change will impact on the operating permit conditions.
That is, combustion chamber temperature limits of
greater than 1900°F instead of greater than 1700°F
would be established in the operating permit. The
persons responsible (facility and agency) for making
decisions regarding deviations should be identified before
the trial burn.
Process upsets may occur during the trial burn emissions
testing. The facility operator should be prepared with
regards to handling such situations. Often a quick
decision with respect to stopping an emissions test run
or continuing the run will be required. The decision must
be coordinated with the test consulting firm. It is useful
to establish some general guideline before the trial burn.
The Trial Burn Schedule
Table 3 is an example schedule for conducting a trial
burn. Each trial burn is unique and the schedule will vary
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Table 3.
Schedule
Day 1
Day 2
Day 3
Day 4
Day 5
Day 6
Day 4-8
Day 35-50
Day 35-60
Day 95
Incinerator Shakedown/Site Modifications
"Miniburns"
Monitor(s) Calibration/Evaluation
Preparation of Special Wastes
Pretest Meeting(s)
Arrive On-Site
Set-Up
Sample Solid Wastes
Complete Set-up
Sample Solid Wastes
Preliminary Measurements
Run 1
Run 2, Audits
Run 3
Pack Equipment/Leave Site
Samples Arrive at Laboratory
Sample Analysis Complete
Preliminary Results Reported
Test Report Submitted
according to the number of test runs, as well as, the
sampling/analysis protocol. However, review of a
"typical" schedule is beneficial with regards to reviewing
a few key points. First, note that several items (e.g., site
modifications) are presented in the schedule as being
completed prior to initiating the trial burn. A "pretest
meeting" is identified in the schedule. It is always useful
for the facility, test consultant, and agency personnel to
have a meeting just prior (within a month) to the test to
review the final test protocol and discuss any last minute
changes.
Note that the schedule indicates only one test run per
day. The number of test runs conducted per day will
depend upon the length of each test run and the
complexity of the test protocol. One or two runs per day
is typical. Actual sampling time for a test run usually is 2
to 4 hr. However, additional time is required to set-up the
sampling equipment, conduct leak checks, change test
ports during a run, and recover the sample. Furthermore,
time is required to establish the desired incinerator
operating conditions. Quite a few other additional
activities also are generally required during the testing.
For example, note that the schedule indicates conducting
a field quality assurance audit (e.g. sampling of a volatile
organic cylinder gas) during day 4. Hence, it is generally
impractical to consider conducting more than one test
per day; a 2- to 4-hr test can take from 5- to 10- hr.
The time required to conduct the sample analyses and
data interpretation also is a function of the complexity of
the test. Another important factor is how well the
activities have been coordinated. If the laboratory is
aware that the samples will be arriving, and the samples
arrive on schedule, then analyses will proceed more
smoothly. Delays in the field may have an adverse impact
with regards to timely sample analysis. In general,
because of the numerous activities and persons involved,
any delay tends to have a domino affect on schedule. For
this reason it is best to give careful consideration to the
trial burn schedule during the planning stage. Establish a
realistic schedule. Usually there is a great deal of
pressure to achieve a tight schedule. If a very tight
schedule is necessary, assure that the resources
necessary (plus some) are available. Establishing
unrealistic schedules will only cause delays, confusion
and added costs.
The schedule shows the trial burn report submittal on
day 95. This is 90 days after testing is completed; the
RCRA regulations require report submittal within 90 days
of completion of the test unless otherwise approved by
the administrator.
Improved Execution of a Trial Burn
In summary, although each trial burn is unique, there are
many key items common to conducting all trial burns.
Early identification and involvement of all key personnel
in planning and coordinating the trial burn will facilitate
conducting the trial burn. A well designed trial burn plan
of adequate detail will go a long way towards improving
the execution of the trial burn. Careful attention to
preparing a realistic schedule and identifying critical path
items is necessary. Adequate time for "shakedown" of
the incinerator and conduct of "miniburns" to evaluate
the affect of untried worst case conditions should be
included in the trial burn schedule, when appropriate.
Trial burns are time consuming and expensive...a typical
trial burn can cost from $50,000 to $150,000; it pays to
do it right the first time.
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Agency Observation of the Trial Burn
By
Walter S. Smith
and
Kenneth W. Blankenship
Prior to receiving a permit to operate, the owner/
operator of a hazardous waste incinerator must prove '•
that emissions will be maintained at or below certain
levels, as set forth in applicable standards. This must be
accomplished during a trial burn, in which emissions are
sampled and measured to determine a range of allowable
waste feed compositions and rates amd incinerator
operating conditions.
Observation of the trial burn is the appropriate control
agency's best opportunity to both assess the conditions
considered to be optimal process and control equipment
operating conditions and to compare emissions to the
applicable standards during these operating conditions.
The trial burn observation involves three main objectives.
The first objective is to certify that the testing
methodology is proper and in accordance with the
approved trial burn plan. The second is to develop an
engineering profile of process and control equipment
operating conditions which demonstrates that the test
was conducted under representative conditions. The third
is to establish a set of representative conditions (i.e., '
waste feed rate and composition, carbon monoxide
levels, etc.) under which the incinerator emissions are
within the required limitations. This set of conditions can
then be used during subsequent inspections as an
indication of changes in facility operations, control device
performance, or other parameters that could result in an
increase in emissions.
Incinerator and control equipment operation during the
trial burn is of critical interest to the agency for several
reasons. During the trial burn, the observer can usually
determine the range of process and control equipment
parameters that the facility operator and equipment
supplier consider optimal for achieving compliance with
applicable emission standards. This information is useful
not only for establishing representative operating
conditions during the trial burn, but also for selecting or
evaluating stipulations of operating permits and for
assisting agency inspection personnel in evaluating
future performance of the incinerator. The overall
process of establishing this benchmark set of operating
data is called "baselining."
Establishing a baseline involves documenting all,
pertinent operating parameters as they relate to the '
emission characteristics of the source. This includes both
process and control equipment parameters. The baseline
provides a fixed point of operation or a narrow range of
operating parameters against which other
determinations may be made. Concurrent emission tests
provide documented emission rates that may be
correlated with process and control equipment operating
characteristics.
The purpose of the trial burn observation is to evaluate
the representativeness of the process operations, control
equipment operations, sampling techniques, sample
analysis, and reported results with respect to applicable
requirements. If any one of the above mentioned items is
determined not to be representative, the trial burn results
are invalid.
Planning and Preparation
The initial phase of any trial burn observation is planning
and preparation. During this phase the representative
agency reviews the trial burn plan to determine if all
procedures are acceptable. Typically, the carbon
monoxide continuous emission monitoring system
(CEMS) performance evaluation is conducted
simultaneously with the trial burn. Observation of the
performance specification test (PST) is beyond the scope
of this paper; References 2 and 3 deal with PST
observation.
The trial burn plan is submitted to the agency by the test
consultant or the plant representative and reviewed to
confirm that it meets all agency requirements. In
particular, the agency/observer gives close attention to
any deviations from standard sampling procedures,
available sampling locations, and/or pollutants and
proposed operation of the incinerator during the trial
burn. With the trial burn plan agreed upon, the observer/
inspector prepares for the actual test observation by
further familiarizing himself with the incinerator
operations and gathering any checklists, data sheets,
etc., that he will need on the day of the test.
Prior to the trial burn the observer must be familiar with
the incinerator and control equipment operations. He
may conduct a walkthrough inspection to become
familiar with the facility layout. The agency observer, the
test team leader, and a plant representative with process
20
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control authority should meet to confirm operating
conditions and to coordinate the testing schedule. A
pretest checklist can be used to organize the meeting and
to ensure that all pertinent areas are discussed.
It is the observer's responsibility to be certain that all
details of the test procedures are understood before the
test begins. At the conclusion of the pretest meeting, the
test team supervisor must know the exact sampling
procedures to be used, the minimum data requirements,
and the conditions that constitute an invalid test.
Likewise, the plant representative should know what
process and control equipment parameters must be
recorded, the intervals of data collection, the waste feed
rate that must be achieved, and the conditions that
constitute an invalid test. Execution of the trial burn in
accordance with the agreed upon trial burn plan should
constitute a valid test.
The observer must become familiar with the process to
be sampled. His understanding may be aided by
consulting an agency process control engineer or by
referencing one or more of the many inspection manuals
prepared by the U.S. Environmental Protection Agency.
These manuals generally describe the process, indicate
the methods and devices used in monitoring incinerator
data and address methods of emission control and
control equipment performance evaluation.
The observer should also be prepared to handle any
nonroutine situations that arise during the trial burn.
Before the test begins, he should prepare a written or
mental list of potential problems and possible solutions.
The list should establish limits at which the minimum
requirements for sampling are not met; for example,
sampling may be unacceptable if the sampling train
condenser cannot maintain the sample gas at or below
the maximum temperature of 20°C. If the observer plans
to use checklists, method modifications and anticipated
problems should be noted on these. In preparing to meet
such emergencies in testing, the observer must know
who in his organization is authorized to make decisions
that are beyond his capability or authority.
The number of persons scheduled to observe a trial burn
should be adequate to allow the observation of process
and control equipment operations, the recording of those
observations, and the overseeing of sampling procedures.
The observers' records should allow present and future
evaluations of the representativeness of the test data and
the validity of the testing methodology followed by the
test team.
Trial Burn Observations
The attitude and behavior of the agency observer during
the trial burn are of utmost importance. He should
perform his duties quietly and thoroughly, conversing
with the test team and plant personnel as little as
possible. If test procedures do not follow the established
trial burn plan, the observer should deal solely with the
test supervisor and plant representative. Conversely, he
should refrain from answering questions from the test
team and incinerator operators directly, referring such
inquiries to the appropriate supervisor. The ideal trial
burn is one in which the data gathered is representative
and no discussion of the test procedure is required.
During the trial burn, the observer or observers must
perform a number of tasks to ensure that the test is
representative and to construct a baseline set of data.
These tasks include observation of sampling procedures,
on-site estimation of possible measurement errors,
observation of operational parameters, and confirmation
of normal operations during the test.
The observer must make a number of checks to confirm
the test team's adherence to specified sampling
procedures and appropriate quality assurance measures.
These checks are to ensure that the locations of the
sample ports and sample points will provide samples
representative of the atmospheric emissions and that the
samples collected in the sample train are representative
of the sample points.
In most cases the observer should utilize a checklist or
checklists covering the details of the sampling
procedures to eliminate the possibility of overlooking any
necessary checks. Example checklists for each of the EPA
reference methods can be found in Reference 1. These
checklists contain all the necessary checks for the
standard sampling methods. If the test team is using
modified procedures of any type, the observer should
modify or rewrite his checklists to reflect all
modifications.
The observer must note and gauge the relative
importance of potential measurement errors associated
with the sampling and analytical techniques employed
during the trial burn. Measurement errors can be
classified as three types: bias, blunder, and random
errors.
Bias errors, a deviation of the measured value from the
true value in one direction, are generally caused by the
personnel and equipment used during the sampling. Bias
errors are normally dismissed upon receipt of adequate
equipment calibration documentation, but, the observer
may require a one-point calibration check prior to testing.
Blunder errors occur during sampling procedures and
should be the main concern of the observer. For example,
if the sample nozzle is allowed to touch the inner stack
wall and collects foreign material from the wall, the
resulting error may be extremely large. Such errors are
difficult to observe and the total effect cannot be
calculated. Fortunately, most of these errors can be
dismissed using common sense rationalization.
Random errors, which result from a variety of factors,
cause a measured value to be either higher or lower than
the true value. Such errors are caused by inability of
sampling personnel to read scales precisely, poor
performance of equipment indicators, and lack of
sensitivity in measurement devices. The usual
assumption is that random errors are normally
distributed about a mean or true value and can be
21
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represented statistically in terms of probabilities. ;
Determining the maximum expected error, however, does
not require a strict statistical approach. It can be
estimated by summing the maximum expected errors|for
each factor as explained in Reference 4.
During the trial burn, the agency observer must conduct
an inspection to obtain the operating parameters
necessary for evaluating the test and constructing the
baseline. The only major difference between this and a
routine inspection is the fact that emission testing is
occurring simultaneously. Throughout the test,
incinerator and control equipment parameters and other
pertinent indicators should be checked.
As the initial part of this inspection, the observer should
tour the facility ensuring that all monitoring equipment
and sampling locations are acceptable, functional, and
when necessary, calibrated. In particular, he should
check the following items.
• Sampling port locations.
• Incinerator and control equipment sampling locations
(waste feed, scrubber water discharge, etc.).
• incinerator operations monitors and their calibration
factors.
• Control equipment instrumentation and calibration
factors.
• Continuous emissions monitors and their data
recording equipment.
If any of these items are not acceptable by test time, the
facility contact should be informed that the problem must
be corrected prior to the test.
The primary process parameters monitored as part of the
test include waste feed rate, combustion temperature,
total volumetric air flow rate, and emission levels of
carbon monoxide. Waste feed characteristics that should
be monitored include the chemical composition, the size
distribution of the feed materials (if applicable), and any
feed cycles that are present if the feed is not continuous.
To the extent possible, continuous strip chart recorders
are valuable in providing real-time data and should be
used where available. Otherwise, visits to process
monitoring areas at a reasonable frequency are ;
necessary to provide adequate documentation.
The actual monitoring and recording of the facility
operations is the responsibility of the facility. The
observer's responsibilities are to see that it is conducted ,
in a proper manner and to report any changes that need
to be made to the facility contact. The observer should
never tamper with any equipment or handle or mark on
any operating logs. ;
It is usually advisable during a trial burn to check the
operating parameters on a routine schedule and to note
any sudden changes that occur during the test period.
Specifically the observer must check to see that the
incinerator and control equipment are operating as
prescribed in the trial burn plan and must determine if
any significant shifts in parameters occur during or
between test runs. If shifts do occur, it is the
responsibility of the agency to determine the effect on
emissions and whether the shifts compromise the
representativeness of the test.
The emissions testing will provide the basic data for all
control equipment, including gas volume, composition,
temperature, and pollutant emission rate. For each
control equipment category the final disposition of the
collected material should be determined by the observer.
In addition to monitoring operating parameters, the
observer must also direct his attention to the sampling
team. The observer must ensure that all test procedures
are being performed and all quality assurance measures
implemented in accordance with the approved trial burn
plan. The observer should begin sampling procedure
observation from the time the equipment is being
unpacked and assembled and the sample recovery area is
being readied for use.
Observation of the sampling techniques should confirm
that all procedures are performed correctly and all
samples are representative. Sample contamination is of
primary importance during the trial burn, since ambient
levels of contaminants occasionally are quite high
relative to the concentrations in the sampled gas
streams. Typically, a VOST or Modified Method 5
sampling train (or both) are used during sampling.
Observation of each is briefly discussed in the following
paragraphs.
As with all test observations, data recording activities
must be periodically checked. While it is not necessary
for the observer to watch every move the sampling team
makes, minimum observations must be made (i.e., either
the pretest or post-test leak check should be observed).
Organized observation of the sampling procedures can be
best attained with the use of checklists for the specific
procedures being employed.
Ideally, all components of the VOST should be
constructed of Teflon® or glass. Quality assurance
measures to prevent sample contamination must be
followed at all times. The observer should ensure that a
charcoal tube is attached to the sample probe when not
in use (he., after equipment setup, and during leak
checks and sample recovery procedures). Use of an
atmospheric glove bag equipped with an open dish of
charcoal provides additional assurances against sample
contamination. Exposure of a field blank to the
atmosphere for the same duration as the sample
cartridge will indicate the extent of sample contamination
due to ambient conditions. The observer must ensure
that the field blank is subjected to conditions similar to
those of the sample cartridge.
Observation requirements for Modified Method 5
sampling techniques are similar to those of Method 5;
additional information to be monitored includes the
condenser exit temperature which must be maintained at
or below 20°C. As with the VOST, representative
samples will be obtained only if contamination is
prevented. A Teflon® septum should be used to securely
close the nozzle opening during a leak check, and either
22
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. aluminum foil or a Teflon® cap should cover the nozzle
when the sample train is not in use. Field blanks should
also be used as an indicator of contamination due to
ambient conditions. The observer must ensure that field
blanks are exposed to the same conditions as the sample,
with the exception of not being exposed to the stack
gases. Additionally, the XAD traps must be stored at
temperatures lower than 50°C when not in use.
To reduce the possibility of invalidating the test results,
the responsible person must carefully remove all of the
samples from the sampling train and place them in
sealed, nonreactive, numbered containers. It is
recommended that the samples then be delivered to the
laboratory for analysis on the same day. If this is
impractical, all samples should be placed in a carrying
case (preferably locked), in which they are protected from
breakage, contamination, loss, or deterioration.
The responsible person must also mark the sample
properly to provide positive identification throughout the
test and analysis procedures. The Rules of Evidence
require impeccable identification of samples, analysis of
which may be the basis for future evidence. Positive
identification must also be provided for any filters used in
a test. Generally, particulate filters are identified using
indelible ink, but, due to the possibility of contamination
from the organic constituents of the ink, alternate
identification must be employed when using Modified
Method 5 sampling train. Finally, each container must be
uniquely identified to preclude the possibility of
interchange. The number of each container is recorded
on the analysis data chain of custody sheets associated
with the sample throughout the test and analysis.
While it is often impractical for the analyst to perform the
field test, the Rules of Evidence require that a party be
able to prove the chain of custody of a sample. The use of
standardized data sheets by the tester/analyst as shown
in Reference 5 should assist the tester in meeting these
requirements.
Potential sources of error in analysis lie in the sampling,
the analyzing equipment, the analytical procedures, and
documentation of results. Since analysis is often
performed at a laboratory distant from the test site, the
agency observer usually is not present during analysis.
The best method of checking the accuracy of the
analytical system is through the use of an audit sample.
To ensure proper execution of the required procedures,
the observer may request that the analyst complete the
appropriate analytical checklist contained in Reference 5.
Observation Report
Upon completion of the trial burn, the observer begins
the'final-task of determining the representativeness of
the test data. An observer's report is written for
attachment to the test team report. The facility operation
data from the field checklists and field notes provide the
observer with the information to determine the
representativeness of the process and control equipment
operation and the sample collection. Minimum conditions
must have been met. If the observer suspects a bias in
the results, this bias and its direction should be noted. A
bias that can only produce emission values higher than
the true emissions would not invalidate the results if the
incinerator is determined to be in compliance, but should
still be noted.
The test team supervisor is generally responsible for
compilation of the test report, usually under the
supervision of a senior engineer, who reviews the report
for content and technical accuracy. Uniformity of data
reporting enhances the speed and efficiency of agency
review, hence the recommendation that the agency
provide a report format and other guidelines to the test
team supervisor.
The observer performs the first review of the test report.
He should check all calculations and written material for
validity, noting any errors and providing any necessary
comments. Although the conclusions in the observer's
report do not constitute final authority, they generally
carry great weight in the final decision concerning the
representativeness of the test. Because of the
importance of the observer's report and the likelihood
that it may be used as evidence in court, the observer
should use a standard format that will cover all areas of
representativeness in a logical manner. His report review
form should parallel the report format provided to the test
team leader and may include, if desired, all field notes
and checklists.
In addition to the determination of representativeness of
the test, the observer reports the conditions under which
the facility must operate in the future to maintain their
conditional compliance status. These compliance test
reports and the conditions of compliance acceptance
provide the inspector with sufficient data for conducting
future facility inspections.
References
1. PEDCo Environmental, Inc., Durham, NC. Evaluation
of Stationary Source Performance Tests.
Observation and Evaluation of Performance Test
Series D. Prepared for U. S. Environmental
Protection Agency, Office of Air, Noise, and
Radiation. EPA Series 1-200. July 1982.
2. U.S. Environmental Protection Agency. Guidelines
for the Observation of Performance Specification
Tests of Continuous Emission Monitors. EPA-340/
1-83-009, January 1983.
3. U.S. Environmental Protection Agency. Observer's
Checklist Package for EPA Reference Test Methods
and Continuous Emission Monitor Certification,
(draft), EPA-340/1 -80-009, June 1 980.
4. PEDCo Environmental, Inc., Durham, NC. Evaluation
of Stationary Source Performance Tests. Emission
Testing Concepts and Special Topics. Prepared for
the U. S. Environmental Protection Agency, Office
of Air, Noise, and Radiation. EPA Series 1-100, July
1982.
23
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5. W. G. DeWees, D. J. von Lehmden, and C. Nelsonj
Quality Assurance Handbook for Air Pollution
Measurement Systems, Volume III. Stationary ;
Source Specific Methods. U. S. Environmental
Protection Agency. EPA/600/4-77/027b, August
1977.
6. U.S. Environmental Protection Agency, Code of
Federal Regulations. Title 40, Part 264. Standards
for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities, revised
as of July 1. 1985.
7. U.S. Environmental Protection Agency/Industrial
Environmental Research Laboratory. Protocol for
the Collection and Analysis of Volatile POHCs
Using VOST. EPA/600/8-84/007, March 1984.
8. U.S. Environmental Protection Agency/Industrial |
Environmental Research Laboratory. Modified
Method 5 Train and Source Assessment Sampling
System Operators Manual. EPA Contract No. 68-
02-3627, August 1983.
24
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Reporting Trial Burn Results
By
Gary Hinshaw
and
Andrew R. Trenholm
Midwest Research Institute
Kansas City, Missouri 64110
Introduction
This paper discusses the importance of uniform reporting
of information relating to performance of hazardous
waste incinerators. The EPA or state permit writer is
charged with the responsibility of reviewing all submitted
incinerator design, operating and trial burn data and
translating this information into enforceable permit
conditions. The review of relevant information is often
complicated by the lack of forrnats and incomplete
information. Required information may be either lacking
or it may be buried in a trial burn report in an
inappropriate location. Furthermore, inclusion of
redundant or nonimportant information may also delay
the review and permit-writing process.
The permit reviewer/writer may face a variety of
problems. For example:
It is not always clear which data are used in calculating
the end results.
Treatment of blank corrections is not uniformly done.
Not all relevant operating conditions are reported.
Departures from standard sampling and analysis
methodologies are not well documented.
Quality assurance data are inadequate.
Significant departures have been taken from the Trial
Burn Plan, which may have been written several
months previous to the trial burn.
Clearly, there is a need for uniformity both in terms of
extent of information and in the logical organization of
the information in a manner which makes the permit
writer's job easier. This will help to speed up the entire
permitting process, thus serving the needs of the
regulatory agency, the facility, and the public to make
available soundly demonstrated technology to dispose of
hazardous waste.
There are several types of reporting needs. First, the
permit writer needs the results of performance and
operation during the trial burn itself. Additional design
data may also be required to perform an engineering
analysis to support permit conditions. Finally, the EPA
needs both design and performance results for
incorporation in its national data base for hazardous
waste treatment, the Hazardous Waste Control
Technology Data Base (HWCTDB). This data base
explores the universe of hazardous waste incinerators in
order to judge how well existing technology and
regulations are serving the environmental, health, and
economic needs of all parties.
It is difficult to develop a single uniform reporting format
which will apply to all situations. Indeed, to require such
a rigorous format could create unnecessary burdens on
incinerator owners and operators and their contractors.
However, strong guidance is needed to assure some
degree of uniformity. Many times availability of good
examples will provide the best guide for a reporting
format. Example forms will be available in an EPA
guidance document to be released in Spring 1987.
Overview of Trial Burn Data
The trial burn is the key focal point of the entire
permitting process for hazardous waste incinerators. The
trial burn is actually a series of tests designed to
determine if the performance of the incinerator meets
applicable standards and to demonstrate that the facility
is capable of reliable operations that pose minimal threat
to health or environment. The permitting process is
generally broken up into three distinct phases: pretrial
burn, trial burn, and post-trial burn.
In the first phase, the Part B permit application is written,
generally incorporating the Trial Burn Plan. The Trial
Burn Plan should reflect careful planning and
forethought as to anticipated conditions during the trial
burn. The Trial Burn Plan or permit application also
provides design data on the facility and other relevant
information needed to determine if the unit can be safely
operated during the trial burn.
The trial burn is normally the shortest part of the
permitting process, but also the most intensive. Over an
interval that usually ranges from several days to several
weeks, hundreds of samples are taken and an exhaustive
25
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amount of data are collected. Following the trial burn,
several weeks or months are needed to analyze all
samples and to report data. The manner in which these
data are reported is critical to ensure that the permit
writer is able to write the best permit conditions for long-
term facility operation.
The amount and variety of information that should be
included in a Trial Burn Report is extensive. An example
format for the main body of a Trial Burn Report is shown
in Table 1. This ordering of information represents a
logical sequence of results that can be easily followed by
the permit reviewer. Other organizational techniques
could also be acceptable, however, it is very important
that all results needed for permitting be presented clearly
and not have unnecessary information interspersed. This
is an overview of all information that might be require^
or otherwise included in trial burn reports; not any one
incinerator would have all of the components covered in
this matrix. Trial burn data which are normally appended
to the main report are shown in Table 2. Additional data
may be required in specialized cases.
• The applicant must submit to the Director a certification
that the trial burn has been carried out in accordance
with the approved trial burn plan, and must submit the
results'of all the determinations required [above]....
This submission shall be made within 90 days of
completion of the trial burn, or later if approved by the
Director. i
• All data collected during any trial burn must be
submitted to the Director following the completion of
the trial burn.
• All submissions required [above]... must be certified on
behalf of the applicant by the signature of a person
authorized to sign a permit application or a report....
The reporting requirements include a mixture of facility
operation results, sampling and analysis results, and
performance results. Certain quality assurance and
quality control (QA/QC) results will also be required
according to EPA policy.
Some of the data and information reported is specifically
required by regulation. Regulations for hazardous waste
incinerator permits are found in 40 CFR 270.62. Specific
information required in the Trial Burn Report is covered
in § 270.62(b)(6) - 270.62(b)(9). These requirements are
listed below:
• A quantitative analysis of the trial POHCs in the waste
feed to the incinerator.
• A quantitative analysis of the exhaust gas for the
concentration and mass emissions of the trial POHCs,
oxygen (Oz), and hydrogen chloride (HCI).
• A quantitative analysis of the scrubber water (if any),
ash residues, and other residues, for the purpose of
estimating the fate of the trial POHCs.
• A computation of destruction and removal efficiency
(ORE)....
• If the HCI emission rate exceeds 1.8 kilograms of HCI per
hour (4 Ib/hr), a computation of HCI removal efficiency
• A computation of paniculate emissions.
• An identification of sources of fugitive emissions and
their means of control.
• A measurement of average, maximum, and minimum
temperatures and combustion gas velocity.
• A continuous measurement of carbon monoxide (CO) in
the exhaust gas.
• Such other information as the Director may specify as
necessary to ensure that the trial burn will determine
compliance with the performance standards ... and to
establish the operating conditions required ... as
necessary to meet that performance standard.
Data Processing
Permit conditions for a hazardous waste incinerator
should assure that the unit always meets the
performance standards. The trial burn is a performance
test of the system to demonstrate that the performance
standards are met under specified operational conditions.
Ideally, measuring an incinerator's performance would
be done on a real-time basis, however, a certain amount
of time averaging must be used in evaluating and
reporting trial burn data.
Most of the trial burn data fall into two categories: (1)
data representing an average over the test period or
portion of the test period, and (2) data recorded
continuously or semicontinuously. Data that by necessity
represent an average include most of the analytical
results (e.g., waste characterization results for a
composited sample of waste feed or POHC results for a
sampling period of minutes to hours). Data taken
continuously (or as continuously as practicable) include
both process data and continuous emission monitor
(CEM) data. This section discusses primarily how
continuously monitored data are processed and reported.
Regulations relating to trial burn reporting require
determination of "a measurement of average, maximum
and minimum temperatures and combustion gas
velocity" and "a continuous measurement of carbon
monoxide (CO) in the exhaust gas" [40 CFR
270.62(b)(6)(viii,ix)]. These are the only regulations
specifying either statistical measures or frequency of
measurement for trial burns. However, other regulations
pertaining to monitoring of incinerators require the
continuous monitoring of combustion temperature, waste
feedrate, the indicator of combustion gas velocity, and
CO [40 CFR 264.347(a)(1,2)]. In practice, minimum,
maximum, and average values are often reported for
other process and CEM data.
26
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Generally, in reporting continuous data, problem areas
involve how the data are recorded. Because of the
requirements for automatic waste feed cutoff described
in 40 CFR 264.345, key process data such as CO, waste
feedrate, temperature, velocity, APCE parameters, and
draft should be monitored automatically. Newer
incinerators tend to be equipped with advanced enough
technology so that most instrumental data can be
recorded automatically and processed as needed by data
loggers and computers. However, many existing facilities
rely upon manual recording of data at frequent intervals
in the facility operating log. For an operating condition
not specifically required to be recorded continuously,
manual reading at 15-min intervals is typical.
The frequency at which data measurements are taken
and recorded is a primary concern. If automated data
logging equipment is used, data which can be
continuously monitored should have measurements
taken at least every 15 sec and generate an updated
value at least every minute. The use of rolling averages
over a longer interval (i.e., 5 to 15 min) may be useful.
CO is a special case that requires careful attention.
Most process instruments produce nearly instantaneous
electrical signals that may be read on a gauge or
processed in a data logging system. CEM data, however,
are generally not as responsive to changing conditions.
This is due to delays caused by a sample of the gas
stream physically moving through a probe line and also
instrumental delays caused by a sensor which must
adapt to changing gas composition. For a given gas, one
type of instrument may be inherently more responsive
than another. For example, paramagnetic oxygen
monitors are much more responsive than
electrochemical types.
Combined delays for sample lines, conditioning systems,
and instruments may range from several seconds to
several minutes. The CEM system may be responsive in
"tracking" a small change in concentration, but not be
responsive to a large peak or dip. Differences in delay
times and responsiveness must be accounted for in
comparing data on different parameters. ,
Another general data quality problem common to most.
Trial Burn tests involves correlating the performance
results with the operating conditions. Different kinds of
results cover different time periods throughout the
overall Trial Burn test, which may span 6 to 8 hr. The
incinerator operating conditions should, of course, be
maintained as steady as possible throughout the test
period, but unavoidable variations in waste properties
and other factors may cause the unit to show some
variability throughout the test. An example trial burn test
timeline is shown in Figure 1 to illustrate these
correlation problems.
For all process and CEM data, the average (arithmetic
mean), maximum, and minimum values should be
reported for the trial burn test period, as easily read
graphical displays can be included for these parameters,
with time and units clearly indicated. This will enable the
permit writer to assess the variability of the data more
easily. The use of rolling averages may also be of value
for certain key parameters, particularly CO.
Table 1. Trial Burn Reporting Format
Recommended Report Organization
Specific Information
Preliminary
Preface
Table of contents/lists of tables and figures
1.0 Summary of Test Results
• Process operation
• Emissions performance
Certification letter
Facility name/location
Name of company performing testing
Test dates
Residence times
Combustion temperatures
Heat input (firing) rate
Summary of APCE parameters
Stack height
Stack exit velocity
Stack temperature
Stack excess Oa
Test dates
DREs
Paniculate emissions
HCI emissions
CIREs
Stack gas flow rates
02
CO2
CO
27
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Table 1. (Continued)
Recommended Report Organization
Specific Information
2.0 Introduction
• Background
• Non-standard practices/events
3.0 Porformanee Results
3.1 POHCs
3.2 Chlorine
3.3 Particulate
4.0 Process Operating Conditions
4.1 Process Overview
4.2 Incinerator Operating
Conditions
• Combustion temperature
• Waste feed/auxiliary fuel data
• Waste burner data
• Airflow data
• Residue generation rates
• Other operating conditions
4.3 APCE Operating Conditions
• Wet processes
—Quench
—Venturi scrubber
—Packed tower scrubber
(adsorber)
—Ionized wet scrubber
28
Brief discussion of incinerator type and design
Objectives for trial burn
Planned test matrix and deviations
Description of wastes/fuels
Description of any unusual test methodologies
Discussion of any special problems encountered
Input rates
Emission rates
DREs
Input rates
Emission rates
REs
Concentrations
Brief description
Process diagram
PCC temperature
SCC temperature
Brief descriptions/firing locations
Feed rates
Firing rates
Ash loading rates
PCC atomization/burner pressures
SCC atomization/burner pressures
Flow rates/velocities from MM5
Flow rates/velocity indications from process monitors
Blower data
Draft measurements
Bottom ash
Fly ash
Scrubber mud/solid residue
Kiln rotational speed
Other conditions deemed important
Exit temperature
Water flowrate
Pressure drop
Water/liquor flowrate
Pressure drop
Liquor flowrate
Effluent pH
Voltage (AC, DC)
Current (AC, DC)
Sparking rate
-------
Table 1. (Continued)
Recommended Report Organization
Specific Information
—Mist eliminator
Dry processes
—Cyclone
—Dry scrubber
—Baghouse
—Electrostatic
Precipitator
Pressure drop
Pressure drop
Reagent f low/rate
Atomizer rotational speed or nozzle pressure
Inlet/exit temperatures
Pressure drop
Voltage
Current
Sparking rate
5.0 Sampling and Analysis Results
5.1 Methods Description
5.2 Waste Feed and Fuel Characteristics
• Physical characteristics
• Chemical characteristics
Summary table
Diagram of sampling locations
Moisture
Ash
Volatile matter
HHV
Specific gravity
Viscosity
Chlorine
POHCs
Other App. VIII compounds
Metals
5.3 Stack Gas Concentration Data
• Gases
—CEMs
—Orsat
POHCs
Other
CO
CO2
02
SO2
NO,
TUHC
CO2
02
Volatiles, semivolatiles, other analytes
Moisture
Chloride
Paniculate
Metals
PICs/other App. VIII compounds
5.4 APCE Aqueous Streams
5.5 Ash and APCE Residues
POHCs
Chloride
IDS
pH
Metals
EP toxicity test results
POHCs
Metals
29
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Table 1. (Continued)
ORE = Destruction and removal efficiency
RE « Removal efficiency
POHC = Principal organic hazardous constituent
PIC = Product of incomplete combustion
APCE = Air pollution control equipment
PCC = Primary combustion chamber
SCC « Secondary combustion chamber
CEM = Continuous emission monitor
Oz = Oxygen
CO2 = Carbon dioxide
CO = Carbon monoxide
SOz = Sulfur dioxide
NOx = Nitrogen oxides
TUHC = Total unburned hydrocarbon
TDS = Tota 1 dissolved solids
EP = Extraction procedure
Table 2. Trial Burn Reporting Format—Appended Information
Typical appendix format
Contents
Detailed S&A Results
• POHCs
• Chloride
• Particulate
• All analytical test results
Raw Data Logs
• Process data
• CEM data
• Stack sampling data
QA Results
S&A Methods
Chromntograms
Concentration in each sample
Sampling durations
Trip and field blank values ;
Averages
Concentration
Impinger volumes
Blank values
Filter weights
GC/MS or other printouts
Log sheets, strip charts
Strip charts, printouts
Field data forms
Surrogate recoveries :
Blind audit samples
Standard method writeup
Description of any deviations
"Nonstandard" methods
Waste analysis
Emissions analysis '•.
30
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VOST
(Volatile POHCs)
MM5 Train No. 1
(Cl, Paniculate) ,
MM5 Train No. 2
(Cl, SV POHCs)
Grab Sampling:
Waste •
APCE Liquids!
Bottom Ash A
Logging of Process
and CEM Data
Process Parameter
(e.g.. Temperature)
Sample 1 Sample 2 Sample 3
-> Port t_
Change
_, Port
Change
Process Upset
1000 1100 1200
Figure 1. Example trial burn test timelirm
1300 1400 1500
Military Time
1600
1700
1800 1900
31
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Translating Trial Burn Test Results into Permit Conditions
By
C. C. Lee (EPA/HWERL)
C. Castaldini (ACUREX)3
S. Torbov (ACUREX)
Background
RCRA regulations require that owners and operators of
hazardous waste incinerators demonstrate compliance
with performance standards specified in 40 CFR
264.343. Trial burn test results are the official
demonstration of compliance with POHC ORE, particulate
and HCI emissions standards. Existing incinerators are
permitted by Regional EPA Administrators, or State
Environmental Agencies with jurisdiction over hazardous
waste management (HWM) facilities, following the
completion of the trial burn or submittal of data-in-lieu of
trial burn. The permits must specify operating '•
requirements that are aimed at guaranteeing continue^
compliance plus various general operating conditions.
Although limitations for specific operating parameters j
are required under the regulations (40 CFR 264.345), the
Regional and State permit writers must use professional
judgement in specifying operational limits for a variety of
trial burn test cases. Clearly, this task is difficult
considering the complexity of incinerator systems and
their operation, the variety of wastes and trial burn
cases, and the associated responsibility of issuing
permits that safeguard the public's health and protect the
environment. Consequently, translation of trial burn data
into permit conditions has been laborious and lacking the
desired consistency and uniformity among permit !
writers.
Objectives and Uses
This paper discusses the development of guidance on
translating trial burn test results into operating permits
lor hazardous waste incinerators. The information is
preliminary because it is based on an ongoing study toi
develop a guidance manual on trial burn reporting format
and setting permit conditions. This manual will be a
companion to other guidance manuals, each addressing
specific requirements of the RCRA Part B process ',
Including trial burn planning and execution, incineration
measurements, and quality assurance/quality control
(QA/QC). This paper focuses on the specific steps in the
permit condition setting process and the operational
limits required to ensure continued incinerator :
compliance demonstrated during the trial burn.
'Principal author and speaker
Admittedly, RCRA requires only regulatory compliance
with gas emissions. However, this paper also discusses
preliminary guidance to minimize incinerator residual
waste emissions in light of anticipated regulations on
incinerator residue quality.
Preliminary draft guidance is discussed for selection of
key operating parameters, monitoring requirements, and
respective operational limits for typical incinerator
system components. The selection of key parameters is
based on best engineering judgement and sound
engineering principles. Graphical presentations of
relevant energy and material balance algorithms are also
included. Proposed guidance is also given for routine
inspection and maintenance of system's components and
safety interlock requirements. The information in the
final guidance will also be amenable to use by permit
applicants to formulate trial burn test plans and by permit
writers to provide preliminary feedback to applicants on
. anticipated permit conditions resulting from proposed
test plans. Treatment of trial burn test cases which result
in performance failures is not included in this interim
presentation but will be available in the final draft of the
manual.
Facility Description
The current state-of-the-art in incineration of hazardous
waste relies on a well-defined number of thermal
treatment and air pollution cpntrol equipment options.
Thermal treatment equipment usually consists of
refractory furnaces capable of incinerating gaseous,
liquid, and solid waste in high temperature oxidizing
environments. The particular furnace design and waste
feed mechanism depend primarily on the physical state
of waste incinerated (solids or liquids). The destruction
and removal efficiency of principal organic hazardous
constituents (POHC ORE), like fossil fuel combustion
efficiency (CE), is dominated by temperature, turbulence
(mixing), residence time at temperature, and
stoichiometry (excess air). Typically, in furnaces where
the waste is well mixed with primary fuel and air, the
excess air and residence time requirements are lower in
order to achieve a given DRE. However, for furnaces
incinerating bulk and containerized solids, such as in
rotary kilns, the reduced mixing must often be
compensated with higher temperature and excess air or
32
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longer residence time. Consequently, combustion
products from rotary kilns are virtually always thermally
treated with afterburners or secondary combustion
chambers (SCC). Waste destruction in incinerators is a
very complex process that is well beyond the capabilities
of current analytical predictive models.
Figure 1 illustrates typical incinerator facility layouts. The
combustion equipment consists of a primary combustion
chamber (PCC), such as rotary kiln or liquid injection
incinerators, followed in most cases by SCC equipment.
Refractory-lined transition ducting between PCC and SCC
units minimizes heat loss. Containerized solids in fiber
pack/drums or steel drums are always introduced in the
PCC unit (kiln). Steel drums containing solid wastes or
other bulk solids are often shredded prior to incineration.
Fiber packs or drums are mostly used for containerized
sludges, slurries or other semisolid wastes (e.g., gels,
resins). Pumpable and atomizable liquid wastes are
introduced in both' PCC and SCC. Fossil fuels can also be
-used in both PCC and SCC for initial refractory heatup,
combustion stability, and supplemental heat.
Occasionally, a steam generator is used to recover the
heat. The heat recovery steam generator does not impact
the permit approach unless it is also supplementary fired.
For this case, the steam generator can be considered as a
tertiary combustion chamber to be treated as a SCC. All
commercial and most onsite incinerator facilities treat
the gas effluents with air pollution control equipment
(APCE). Wet APCE systems are predominant among
existing facilities. Operating conditions for these systems
are discussed in greater detail in this paper. Figure 2
illustrates a typical wet APCE layout. The gases are
cooled in the quench chamber to saturation temperature
prior to paniculate and acid control in scrubbers and
absorption towers. Several scrubber and absorption
equipment designs are used. Their performance is
governed by a common set of key operating parameters.
Permit Conditions
Figure 3 illustrates the principal steps involved in
formulating permit conditions for the operation of the
^-
Primary
chamber
(PCC)
II
/
^
%.
K
— '>
^X
^,
Secondary
chamber
(SCC)
K
k
APCE
Stack
Pumpable
Solids/sjudge
A
F
Pumpable
Ash
Primary
liquid
chamber
(PCC)
Pumpable
A
F
-*>
-*•
-*•
Primary
kiln
chamber
(PCC)
fcl
— N
— •
r
Secondary
chamber
(SCC)
K
APCE
Stack
Pumpable
Solids
sludge
slurries
A - Combustion air
F - Primary fuel
Ash
Figure 1. Incinerator equipment arrangements.
-------
incinerator using trial burn test results. The following
sections discuss these individual steps in more detail.
Select Appropriate Parameters
Step 1 of the process involves the selection of
appropriate parameters that define the system and its
intended operation. Key design features of each major
system component should be summarized. The particular
design features of the system will be used in conjunction
with trial burn results to specify operational limits and to
perform recommended energy and material balance
calculations. Table 1 summarizes the required design
information. In general, the information specifies the
design capacity of major system components and the
design features which impact key process parameters
such as gas temperature, residence time, and
stoichiometry.
In addition, the permit writer selects appropriate
operational, waste, and emission parameters that will
form the basis of the operating permit. Test data on each
of these parameters should be available in the trial burn
report. Table 2 lists possible parameters and their
selection criteria. As indicated, specification of some
parameters is required under current RCRA regulations
while others are recommended for possible inclusion in
the permit conditions on the basis of their potential
impact on incinerator performance. Since trial burns are
typically designed to demonstrate compliance over a
range of operating conditions, several settings for each
parameter are likely to be available in the report. A
particular complication of trial burn results evaluation is
that all maximum and minimum settings specified in
Table 2 do not always occur during one test condition.
For example, the minimum temperature condition may
not correspond with the maximum waste feedrate tested
thus affecting the specific limitations imposed in the
Waste
pond
Makeup water
and caustic
Figure 2. APCE schematic (wet system)..
Monitoring:
L
Q
T
PH
AP
- Tank level
- Liquid flow
- Temperature
- Acidity
- Pressure drop
Trial burn
report:
Design
Emissions
Waste
Compliance
Others
fc
Step 1 :
Select
appropriate
parameters:
• Design
• Operation
• Waste
• Emissions
Step 2:
Set appropriate
and meaningful
permit
• Operation
• Monitoring
—t*-
Step 3:
Verify
consistency
and
• Engineering
analysis
Step 4:
Specify safety and
maintenance
requirements
(» Routine
inspection
-------
Table 1. Identify Appropriate Design Parameters
Incinerator design (PCC and SCC)
—Arrangement
—Capacity (MBtu/hr)
—Internal dimensions, volume (including transition)
—Primary fuel type, capacity (MBtu/hr)
—Refractory area, thickness and conductivity
—Kiln inclination, rotational speed
—Waste injection locations
—Burner and atomization design
—Combustion air capacity (scfm)
—Design chamber draft (in W.C.)
Air pollution control equipment
—Types and arrangement
—Gas capacity (scfm)
—HCI capacity (Ib/hr)
—Inlet temperature (°F)
—Design pressure drop
Ancillary equipment
—Primary gas mover capacity (scfm, AP, motor amps)
—Quench, scrubber, absorber water capacity and temperature
(gpm, °F)
permit. Furthermore, process settings are often not
constant requiring that more than one average setting be
specified in the permit. For example, continuously
monitored and recorded CO emissions, as with gas
temperature, are likely to vary over the duration of a trial
burn test, requiring specification of rolling time averages
as well as appropriate minimum or maximum levels. The
POHC concentration in the waste and the waste heating
value are not usually considered for permit specification
because performance data to date do not support such
approach. Furthermore, as long as combustion chamber
temperature, residence time, and stoichiometry are
maintained at permit specifications with appropriate air
and supplementary fuel, the impact on POHC ORE is
considered negligible. Limitation on waste heating value,
however, may result from incinerator design limitations.
Total ash and organic halides feedrates and APCE
operating pararneters can be selected primarily on the
basis of potential impacts on particulate and HCI
emissions.
Set Permit Conditions
!
Tables 3 through 5 summarize the monitoring methods
and permit guidelines for process parameters identified
in Table 1. For the most part, the tables are self
explanatory however, the following sections discuss in
more detail some proposed permit guidelines for selected
key parameters.
Minimum Temperature
Combustion chamber temperature is a critical process
operating parameter. Relatively high temperatures are
required for thermal decomposition and oxidation
reactions of hazardous organic molecules. The higher the
temperature the faster are the decomposition and
reaction rates. The maximum' combustion chamber
temperature is constrained by design considerations
such as heat input capacity and refractory limits. The
design heat input capacity should not be exceeded to
minimize equipment problems. Typically, this is not an
important consideration since facilities are not subjected
to operation outside manufacturer design specifications.
More importantly, the permit writer has to specify a •
minimum temperature for each combustion chamber
outlet. Continuous traces of gas temperatures are
reported for each test in a trial burn. Typically, these
traces show relatively steady (±2 percent) gas
temperatures because of the high thermal capacity of the
refractory material. However, some cases of higher
temperature fluctuations during a trial burn may also be
encountered. The permit condition should address both
these cases.
For relatively constant temperature traces the permit
writer should specify a time-average temperature. The
minimum SCC temperature should be the one recorded
during maximum waste feed injection into the chamber
(worst case). The permit writer should verify that this
minimum temperature can be maintained regardless of
waste heating value. For example, if the water content of
the waste increases dramatically the total heat input
capacity should be such to compensate for the quenching
effect of increased water feedrate. If the waste
constitutes the primary fuel to the SCC, a minimum low
heating value (LHV) of 7000 Btu/lb should also be
mandated to guarantee combustion stability. If the
minimum average temperature for the SCC is at or below
1650°F (900°C) then automatic waste cutoff to both PCC
and SCC limits should be required when the
instantaneous SCC temperature falls below the set limit.
The rationale is based on thermal,decomposition data for
oxidative environments which indicate potential ORE
failure for several hazardous organic compounds when
exposed to lower temperatures for <2 seconds
(Reference 1). For SCC temperatures of 1740°F (950°C)
or higher, a waste cutoff requirement should be set at 98
percent of the average value.
For unsteady temperature traces where the standard
deviation exceeds 4 percent of the time-weighted mean,
the permit writer should specify an absolute minimum
temperature and the length of time permitted at that
temperature. This approach is designed to maintain some
flexibility consistent with the typical operation of the
facility. The automatic waste cutoff is triggered when the
temperature falls below the absolute minimum or when
the specified times are exceeded for temperatures below
time-weighted average or at absolute limits.
Maximum Combustion Gas Flow rate
The permit writer'should specify the maximum gas
flowrate demonstrated in the trial burn as the operating
permit condition. Limits on maximum combustion gas
flowrate are aimed at maintaining gas residence time in
35
-------
Table 2. Selection of Appropriate Process Parameters
Process Parameter
Section Rationale
Combustion Chambers:
Minimum temperature, each chamber
Maximum combustion gas flowrate
Combustion chamber draft; primary chamber
Minimum ash retention time; kiln only
Maximum total waste feedrate; each chamber
Minimum Og each chamber exit, and at the
stack
Maximum waste burner turndown and
minimum waste and atomization fluid
pressures
Emissions and Waste Characteristics:
Maximum CO; corrected at the stack
Maximum halides input rate
Maximum volatile content of waste solids;
kiln only
Maximum viscosity of pumpable waste;
secondary chamber only
Maximum ash feedrate; each chamber
Lowest POHC heating value; each chamber
APCE:
Liquor pH
Liquor/water flowrate
Pressure drop; venturi; baghouse
Electrical settings; ionizing wet scrubber,
ESP
Water/liquor temperature
Temperature is kinetically tied to molecular dissociation and thermal destruction.
Required under RCRA.
Indicator of gas velocity is required under RCRA.
Control of fugitive emissions is required under RCRA.
Affects mixing and residence time with potential impact on residue quality.
Affects heat and air requirements and potential impact on residue quality; required
under RCRA.
Indicator of oxygen availability for thermal oxidation. Required to calculate combustion
gas flowrates and residence time.
Indicator of atomization quality. Waste atomization is critical to evaporation and mixing
rates and destruction efficiency.
Best indicator of mixing, combustion efficiency and PIC emissions; CO monitoring
required under RCRA.
Halides are known flame retardants with potential impact on ORE; impacts acid burden
to APCE.
Prevents localized air-deficient zones in the kiln having potential impacts on DRE and
byproduct emissions.
Impacts waste atomization and burner operation.
Impacts paniculate emissions and waste atomization in SCC.
RCRA does 'not permit POHCs that are less incinerable than trial burn POHC. Heat
of combustion is current measure of incinerability.
Acid scrubbing capability
Impacts L/G and gas temperature for acid and paniculate scrubbing; important for
venturi paniculate collection performance.
Direct impact on paniculate collection; controlled with gas throughput or scrubber throat
venturi.
Affects paniculate collection efficiency.
Combustion' gas temperature control; together with flowrate impacts paniculate
collection.
the combustion chambers at or above those
demonstrated in the trial burn. Furthermore, limitations
on gas flowrate also impose limits on maximum
combustion excess air for a given temperature and
maximum waste feedrate. Continuous recording of gas
flowrate should be required in the permit using dirpct gas
velocity measurement or indirect ID fan amperage. Direct
velocity measurements consist of pilot tube, annubar or
venturi tube. The pitot tube and annubar offer a marginal
degree of accuracy and are generally plagued by
maintenance problems. The retrofit of a venturi tube
requires a significant capital investment. Alternative
indirect velocity measurements are combustion air
flowrate and oxygen level. Combustion air flowrate
represents the bulk of the mass throughput in an
incinerator especially at high excess 02 levels. Thus,
36
-------
Table 3. Monitoring and Permit Setting Guidelines—Operating Parameters
Process Parameter
Monitoring Method
Potential Permit Guidelines
1. Minimum temperature at each
chamber exit
2. Maximum combustion gas flow/rate
(SCC or Stack) ,
3. Combustion chamber draft
4. Minimum ash retention time in the
kiln.
5. Maximum total waste feedrate to
each chamber
6. Minimum Oa at each chamber exit
Shielded Type K or R thermocouple
inserted at least 3 in. in the gas flow.
Continuous monitoring with recording tied
to automatic waste cutoff.
Pilot tube, annubar, venturi tube, ID fan
amperage or combustion air blower with
continuous recording tied to automatic
waste cutoff
Magnehelic or pressure differential gauge
tied to automatic waste cutoff
Kiln rotational speed meter
Batch and continuous waste feedrate
monitoring using appropriate meters,
recorders, or operational logs
Oz continuous recording meter tied to
automatic waste cutoff
1. Minimum time-average temperature
demonstrated in the trial burn.
2. Foraverage SCC temperature <1650°F,
automatic waste cutoff when minimum
is exceeded. For average temperature
>1740°F automatic waste cutoff when
below 98 percent of average.
3. For unsteady temperature traces also
define time below average and absolute
minimum temperature and time at that
temperature. Waste cutoff when limits
are exceeded.
1. Do not exceed maximum trial burn gas
flowrate or APCE capacity whichever is
lower. ;
2. Automatic waste cutoff when exceeded
for 5 min.
1. Maintain negative pressure in the
primary chamber.
2. Automatic waste cutoff in affected
chamber if positive pressure for 15 sec.
1. Do not exceed rotational speed
demonstrated in the trial burn when
burning solid waste.
2. Do not exceed trial burn maximum solid
waste loading.
1. Do not exceed total maximum feedrate
as demonstrated in the trial burn.
1. Maintain Oz levels above those
demonstrated during the trial burn
maximum waste input test.
2. Automatic waste cutoff for lower Oz
levels for over five continuous min. '
Table 4. Monitoring and Permit Setting Guidelines—Emission/Waste Parameters
Process Parameter
Monitoring Method
Potential Permit Guidelines
1. Maximum CO
Continuous monitoring at the stack with
recording tied to automatic waste cutoff
1. Maximum 5-min rolling average CO
measured during trial burn or 100 ppm
(corrected to 7 percent Oa) whichever
is higher.
2. Maximum average not to exceed 500
ppm.
3. Solid waste feedrate cutoff when
average CO is exceeded. All waste
cutoff if CO remains above average for
5 min. Waste feed is renewed after CO
is stabilized below average for
minimum of 15 min.
4. Automatic cutoff of all wasteload when
instantaneous CO exceeds maximum
recorded during trial burn
37
-------
Table 4. (continued)
Process Parameter
Monitoring Method
Potential Permit Guidelines
2. Maximum organic halides feedrate
3. Maximum volatile content of bulk
and containerized waste
4. Maximum viscosity of pumpable
waste to SCC
Perform halides analyses using ASTM
D808-81
Perform volatile analyses using ASTM
D1888-78
Perform analyses for viscosity of SCC
wastes ASTM D445
5. Maximum ash feedrate to each Perform inorganic ash analyses using
chamber ASTM D482-80forsolid and liquid streams
to each chamber
6. Lowest POHC heating value to either Perform volatile (organic analyses per SW-
chambsr 846 appropriate methods
1. Do not exceed total halides feedrate in
each chamber demonstrated during the
trial burn.
2. Blend the waste streams or reduce
feedrate as appropriate for higher halide
concentrationss.
1. Do not exceed total volatile content in
the solids as demonstrated in the trial
burn.
1. Do not exceed kinematic viscosity and
waste feed turndown as required by
atomization type. Automatic waste feed
cutoff for feed pressure below set limits
or loss of automation.
1. Do not exceed maximum ash feedrate
for which particulate emissions
standards were demonstrated during
the trial burn.
2. Reduce feedrate of waste as appropriate
to maintain inorganic ash feedrate to
each chamber below trial burn
maximum.
1. Do not incinerate waste having a lower
heating value POHC (>100 ppm) than
trial burn selected POHC.
Table 5. Monitoring and Permit Parameters—APCE Parameters3
APCD
Monitoring Method
Potential Permit Guidelines
A. Vonturi Scrubber
1. Inlet gas temperature
2. Pressure drop
3. Scrubber liquor pH
4. Scrubbing water/liquor flowrate
B. Absorber
1. Water/liquor flowrate and pH
2. Alkaline tank pH
Type K thermocouple inserted at least 3
in. in the gas flow. Signal tied to alarm.
Differential pressure meter with
continuous recorder and signal tied to
alarm
pH meter with continuous recording and
signal tied to alarm
Rotameter, venturi, orifice meters. Signal
tied to alarm
Rotameter, venturi, orifice meters. Signal
tied to alarm.
pH meter and tank level recorder. Signal
tied to alarm.
1. Maximum temperature of 500°F with
alarm when exceeded.
2. Minimum temperature at 220°F with
alarm for lower temperature.
1. Minimum pressure drop demonstrated
during trial burn with alarm for lower
pressure drop.
1. Minimum pH demonstrated during trial
burn. Alarm activated when pH falls
below set point.
1. Minimum liquid flowrate demonstrated
in the trial burn. Alarm tied with
measured stack flowrate.
1. Minimum demonstrated during trial
burn. Monitoring signal tied to alarm.
2. Minimum pH of return flow interlocked
with increase in makeup water flow
, for lower pH.
1. Minimum pH demonstrated during trial
burn
"Additional information on key parameters for these and otherwet and dry control devices can be found in References 2, 3, 4,
and 5. .
38
-------
measuring the combustion airflow to each chamber, or
the excess O2, can in some cases be satisfactory
alternatives to flue gas flowrate. For constant speed ID
fans, the electric motor amps can also be used in lieu of
gas velocity measurements. Since pressure differential
changes with gas flowrate the permit writer should
determine the relative accuracy of the ID fan amps as an
indicator of gas flowrate. This can be done using actual
data generated in the trial burn. The trial burn data
should also be reviewed to ensure that the maximum gas
flowrate specified does not conflict with the ability to
maintain negative pressure in the combustion chambers.
Automatic waste cutoff should be required when limits
set on gas velocity or fan amperage are exceeded for 5
min.
Maximum CO Emissions
During incinerator trial burn tests, CO emissions are
likely to show drastically different levels and are also
likely to fluctuate significantly over the duration of the
test. This poses a particular problem for the permit writer
in that CO emissions and DRE performance may be
seemingly inconsistent (e.g., high CO and acceptable
DRE). However, because CO is measure of combustion
efficiency and because high CO is typically associated
with higher PIC emissions a relatively low CO limit is
recommended for the operating permit. A maximum 5-
min rolling average of 100 ppm corrected to 7 percent O2
when measured at the stack should guarantee continued
DRE compliance and low PIC emissions.
Notwithstanding, the permit writer may want to consider
a higher CO level on the basis of the results for the
"worst case" lowest temperature, highest waste feedrate
and lowest excess Oz. For example, if the "worst case"
test shows 5-min rolling average CO of 140 ppm with
performance in excess of the standard (DRE >99.999
percent) than this limit should be considered. However,
an average of greater than 500 ppm should not be
allowed in any full operating permit. Two stages of
automatic waste cutoff should be set. Under the first
stage, the solid and containerized waste to the PCC is
automatically cutoff if the 5-min rolling average is
exceeded. The wastefeed should not resume until the CO
has remained below the limit for 15 min. This stage is
especially recommended if during the trial burn higher
CO emissions resulted with higher PCC solid waste
feedrate. All waste feed will be cutoff if the 1 -hour
average limit is exceeded for more than 5 min. The
second stage will call for automatic waste cutoff if the
instantaneous CO concentration exceeds the maximum
level recorded during the "worst case" test condition.
Engineering Analysis
The third step in setting permit conditions involves the
engineering evaluation of pertinent design and operating
data. The primary objective of this activity is to ensure
that operational limits set by the permit writer are
internally consistent and not overly constraining thus
preventing unnecessary interruptions in waste feedrate
and facility operation. The evaluation relies on relatively
straightforward calculations using energy and material
balance algorithms. The EPA/HWERL in conducting an
Engineering Analysis program intended to provide permit
writers with the technical tools to perform these
computational checks on a routine basis. • •
Inspection and Maintenance Requirements
A regular inspection and maintenance (I&M) program is
critical to the successful operation of the incinerator
facility since its objective is to ensure equipment
reliability and safety, accurate monitoring, and regulatory
compliance. Any hazardous waste incinerator facility is
required to adhere to an I&M schedule. The permit
applicant has to submit this schedule with the Part B
application (40 CFR 264.347). In turn, the permit writer
specifies the I&M schedule in the operating permit. Table
6 summarizes a recommended permit approach to the
I&M schedule. Incineration equipment and APCE are
inspected daily or weekly to verify the operational status.
Performance monitoring equipment is subjected to both
inspection and calibration. Inspection is most often done
on a continuous basis because most are online monitors
with continuous response records. Daily inspection of
monitors and instrumentation is also recommended.
Equipment service should be performed on the basis of
manufacturer recommendation. The permit applicant
should specify the manufacturer service
recommendations for review by the permit writer. The
operating permit should also specify that all alarm, waste
cutoff and emergency shutdown interlock systems be
tested on a weekly basis. Records of compliance with
I&M schedules should be maintained in the facility
operational daily log. , ,
Authors Note
Future guidance discussed in this paper is meant to
assist permit writers in developing meaningful and
defensible incinerator permit conditions on the basis of
successful trial burn results. The information is not
intended to be rigidly applied for all trial burn cases. The
authors recognize that permit writers will occasionally
face additional test cases and trial burn results which
warrant guidance not provided in this paper. The final
version of the guidance manual will expand on the
information of this paper to provide a more complete
approach to permit setting.
Acknowledgements
This study was performed for the Office of Solid Waste
(OSW) .under the overall direction of Ms. R. Anderson and
the technical review of Dr. C. C. Lee of EPA/HWERL in
Cincinnati. The results presented were developed with
the technical inputs from C. Castaldini and S. Torbov of
the Acurex Corporation in Mountain View, California and
Dr. R. Seeker of EERC in Irvine, California. Comments
and suggestions should be directed to Dr. C. C. Lee in
preparation for the manual.
39
-------
Toblo 6. Recommended Inspection and Maintenance (ISiM) Frequency
Equipmont/Parameter
Incinerator Equipment
Wastefed/Fuel Systems
PCC and SCO Outlet gas
temperature
Oa and CO Monitors
Gas Flow Monitors:
• Direct gas velocity
• Indirect fan amps
Other incinerator
monitoring equipment
(Homo scanners, air
blowers, etc.)
APCE
APCE Support Systems
APCE Performance
Instrumentation
Conditions
Operational
Operational
and Accuracy
Operational
arid Accuracy
Operational
and Accuracy
Operational
and Accuracy
Accuracy
Operational
Operational
Operational
Operational
and Accuracy
Operation and Monitoring
i
Calibration Inspection
Daily
2 Daily
Weekly Continuous
Daily Continuous
Weekly Continuous
6 Months Continuous
Daily
Weekly
-- Daily
Weekly Daily
I&M Frequency
Equipment
Service
1
1
1
1
1
—
1
1
1
1
Emergency
Alarms
—
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
—
Weekly
Weekly
Systems
Waste
Cutoff
—
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
—
Weekly
Weekly
1—Equipment manufacturer recommendation.
2—Equipment manufacturer recommendation or no less than monthly.
References :
1. Dellinger, B., et al., "Factors Affecting the Gas-Phase
Thermal Decomposition of Chlorinated Aromatic
Hydrocarbons," Proceedings of the Ninth Annual
Research Symposium on Incineration and
Treatment of Hazardous Waste, EPA/600/9-84/
015, July 1984.
2. Theodore, L, and A. J. Buonincore, Air Pollution
Control Equipment — Selection, Design, Operation,
and Maintenance, Prentice-Hall, 1983.
3. Air Pollution Engineering Manual, Environmental
Protection Agency, Office of Air Quality Planning
and Standards, 1973. :
4. U.S. Environmental Protection Agency, Industrial
Environmental Research Laboratory, Cincinnati,!
Ohio. Engineering Handbook for Hazardous Waste
Incineration, SW 889, September 1981. '
5. Schifftner, K. C., "Correcting Problems in the
Operation of Wet Scrubbers on Hazardous Waste
40
Incinerators," 77th Annual Meeting of the Air
Pollution Control Association, San Francisco, CA,
June 1984.
-------
Common Deficiencies in RCRA Part B
Incinerator Applications
By
Bruce A. Boomer
and
Andrew R.Trenholm
Midwest Research Institute
Kansas City, Missouri 64110
Introduction
This paper presents information on common deficiencies
in RCRA Part B incinerator applications, based on
extensive experience at Midwest Research Institute (MRI)
in evaluating hazardous waste incinerators and
reviewing Part B applications under contract to the
USE PA and state agencies. The views expressed in this
paper are those of the authors and do not necessarily
reflect those of the E PA. Although requirements are
listed in the regulations (federal1 or applicable state) and
guidance is provided by E PA,2"3 certain types of
information often are deficient in the applications. The
missing information results in deficiency notices and
delays in the permitting process.
A major step in obtaining a hazardous waste facility
permit is filing a permit application, either a federal " Part
B" application sent to the USE PA or an application sent
to an authorized state agency. The permit application is a
major document containing hundreds to thousands of
pages, depending on the complexity of the facility and the
number and type of hazardous waste units to be
permitted.
In addition to documenting general facility requirements,
a hazardous waste incinerator application will include a
detailed engineering description of the incinerator and
typically a detailed trial burn plan for evaluating the
performance of the incinerator. The application will be
reviewed by an E PA or state agency permit writer who
will issue a "Notice of Deficiencies" with comments on
any inadequacies of the permit application. The typical
review process may require submittal of one or more
revisions of the permit application before all of the permit
writers' requirements are satisfied.
A "totally complete" incinerator application is virtually
impossible to compile for the initial submittal due to the
nature of the permit application review process. With
flexibility in the regulations to request all necessary
documentation and operating conditions, both to meet
the performance standards and to protect the public/
environment,4 the permit reviewer is "grading" each
permit application on a case-by-case basis with best
engineering judgment. In addition to the specific
regulatory requirements and federal, regional, or state
policy issues, the case-by-case judgment of individual
reviewers makes prediction of all details of information
necessary for a complete application very difficult.
Questions Asked by the Permit Reviewer
Even if the exact requirements for an incinerator permit
application vary with the agency office and the individual
case, the permit applicant can compile a high quality
package for the initial submittal by predicting the
concerns and needs of the reviewer. In general, the
permit reviewer will be asking the following questions:
1. Does the application provide a thorough
understanding of how the incinerator works and
how it is operated?
2. Is the incinerator safe to test and will it most likely
meet the performance standards?
3. Will the proposed test accurately measure the
performance of the incinerator for "worst case"
operations or over the. range of expected operating
conditions?
4. Will the proposed test generate the information
needed to establish permit conditions for the
incinerator?
5. Are the operating protocol and process monitoring
equipment adequate on a continuing basis to
guarantee operation of the incinerator within the
regulatory limits and within the conditions to be
specified in the permit?
To answer these questions, the applicant must provide
information with an appropriate level of detail in the
application.
In addition, the state of the knowledge related to
incineration and associated permitting/testing activities
is changing as new information becomes available. New
41
-------
studies continue to provide additional insight into the
operation, testing, and performance of hazardous waste
incinerators, which creates changes in a permit
reviewer's requirements.
The remainder of this paper identifies common
deficiencies in recent incinerator applications and
suggests an appropriate level of detail for these problem
areas based on the authors' experience. The goal is a
permit application that receives a "good grade" from the
permit reviewer after the first round of review.
Common Deficiencies
1. Engineering description: Common deficiencies in
this section of the permit application include the
following: :
a. Burner/nozzle design—Design specifications of
primary importance are: (1) design range of waste
feed rate, (2) design range of waste viscosity, and
(3) design range of atomization pressure. A
comparison of normal/expected conditions and
the design specifications is appropriate in the
permit application.
b. Fugitive emission control—The method to control
fugitive emissions from the incineration facility
and the method(s) used to monitor the control of
fugitive emissions must be described in the permit
application.
2. Process monitoring: During the trial burn, key
process parameters must be monitored to
characterize the operation of the incinerator. In
subsequent regular operations, certain process
parameters must be monitored as specified in the
permit. The key parameters may include waste feed
rate{s), temperature(s), pressure(s), combustion gas
velocity or equivalent, carbon monoxide (discussed
in more detail below), auxiliary fuel rate(s), waste
atomization pressure(s), kiln speed, critical air
pollution control device parameters (venturi
pressure drop, liquid flow, pH, charging voltage/
amperage, etc.), or other parameters depending on
the specific facility. Permit applications should
contain the following:
a. A compilation of key process parameters with the
type of measuring device, location of device,
output (i.e., gauge, digital readout, strip chart,
computer, etc.), instrument range and accuracyt
expected range, and calibration (method and
frequency). A simplified instrumentation diagram
may be appropriate.
b. A list of the process parameters to be monitored
during the proposed trial burn, the frequency of
readings, and the results to be reported.
3. Gaseous emission monitoring: CO must be
monitored continuously during the trial burn and
during subsequent operation. The adequacy of the
CO monitor is an important issue in the permit
42
application. Documentation should include the
model and type of monitor; sampling location; type
of output; preconditioning system; design and
operating range; manufacturers' specifications on
accuracy, precision, and sensitivity; and calibration
procedures (frequency and method including
specification of calibration gases). A diagram of the
sampling location and preconditioning system is
helpful. (Note: If Oa monitoring is selected as an
alternative to combustion gas velocity monitoring,
the above information is also needed for the 02
monitor.)
4. Automatic waste feed cutoff system: The applicant
must describe the automatic waste feed cutoff
system required in the federal regulations.5 The
permit reviewer expects to find the following
information in a permit application:
a. A general description of the cutoff system including
sensing device and action mechanism.
b. A summary table of parameters monitored in the
system and proposed set points.
c. Discussion and schedule of calibration/testing of
the system.
In addition to the parameters specified in the
regulations,6 automatic waste feed cutoff may be
required for additional key parameters on a case-by-case
basis. Automatic cutoff may be appropriate for low waste
feed atomizing pressure; low scrubber water flow,
pressure drop, or pH; or other operating conditions
posing special performance or safety concerns.
5. Waste characterization: To answer the five major
questions discussed earlier, the permit reviewer
must have complete waste characterization data.
Specific needs include content of the Appendix VIII
hazardous organic constituents in the waste,
chlorine and ash content, heating value, and
viscosity (if applicable). This information is
particularly important to the reviewer for an
understanding of incineration operations, a
preliminary evaluation of system performance, and
the selection/approval of principal organic
hazardous constituents (POHCs) for the trial burn.
The applicant must distinguish any differences in
waste characterization between the wastes
proposed for the trial burn and the wastes
incinerated during normal continued operation.
6. Sampling and analysis: Some of the most
complicated technical questions associated with
the permitting of a hazardous waste incinerator are
related to sampling and analysis for the trial burn.
In most cases, the applicant will require the
services of experts who understand the special
needs and problems to be addressed in a trial burn
sampling and analysis plan. Permit reviewers look
for the following items in an application:
-------
a. A detailed summary of the sampling and analysis
protocol (i.e., number of samples, sampling
locations, sampling intervals/duration).
b. Sampling and analysis of all input and output
streams associated with the incinerator. (A trial
burn test is, amongst other things, a
determination of the fate of selected hazardous
organic constituents in the incineration facility.)
c. The use of appropriate and proven sampling and
analysis procedures. Certain facilities, conditions,
or constituents may create special sampling and
analysis problems. Documentation of each
procedure to be used is necessary in the permit
application.
d. Although not required in the regulations, sample
calculations are desired to indicate that the
proposed'Sampling methods, sample volume, and
analytical detection limits are adequate to
determine a destruction and removal efficiency
(ORE) of at least 99.99%.
e. A summary of results to be reported and the units.
7. Quality assurance/quality control: QA/QC is an
essential component of any sampling/analysis
activity. A site-specific QA/QC plan typically is
required in a trial burn plan. Since the required
level of QA/QC will vary with the specific agency or
permit reviewer, a preliminary discussion of QA/
QC requirements with the reviewing agency is
advisable prior to submittal of the permit
application.
The combustion sampling manual prepared by A. D.
Little7 includes a discussion of QA/QC procedures. Also,
three E PA reports8'10 provide guidelines on QA/QC
plans, but the level of effort discussed may be more
detailed than necessary for most incinerator trial burn
tests. Table 1 presents a checklist of the contents of a
typical QA/QC plan; Table 2 summarizes some of the
practical concerns of incinerator testing that are
appropriate for a QA/QC plan.
General Considerations
Submitting an incinerator permit application is similar in
some ways to turning in a term paper to a college
professor. Organization, clarity, and logic may be as
important as content. Many of the deficiency comments
contained in a Notice of Deficiencies are the result of
misunderstandings due to vague or conflicting
information presented by the applicant, an expression of
the reviewer's frustration of failing to find essential
information among thick volumes and appendices of
superfluous information, or simply a note of failure to
understand the .applicant's reasoning for selecting a
particular operating scenario. Common sense in
compiling a complete and concise permit application can
result in fewer deficiency comments and a quicker
review process.
Table 1.
QA/QC Checklist*
Sampling Analysis Reporting
Technical responsibility • • •
QA responsibility 9 • 0
Quality objectives • •
Quality control procedures
Equipment calibration • •
Sample traceability/
custody. • O '
Blanks » •
Control checks •
Internal standards •
Surrogates •
Replicates O • ;
Data review • • •
Quality assurance procedures
System audits O O O
Performance audits o *
Written SOP • • •
Documentation • • •
Corrective action
Responsibility • • •
Action levels • • •
*R. M. Neulicht, Midwest Research Institute, Personal
Communication, November 1985.
O = Optional.
Table 2.
Practical Concerns for a Trial Burn QA Plan0
All equipment used in S&A activities should have written
calibration procedures. Procedures amd documentation of
the most recent calibration should be available.
Traceability procedures (not necessarily chain-of-custody)
should be established to ensure sample integrity.
A GC/MS performance check sample should be analyzed each
day prior to sample analysis. If results are outside acceptable
limits, samples should not be run.
All samples from at least one run should be analyzed in
triplicate to assess precision.
43
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• A minimum frequency of check standards (5% is suggested)
should be used with each sample batch. Analysis of actual
samples should be suspended if check standards are outside
of the desired range.
• Blank samples should be analyzed to assess possible
contamination and corrective measures should be taken as
necessary. Blank samples include:
—Fieldblanks—These blank samples are exposed to field and
sampling conditions and analyzed to assess possible
contamination from the field (a minimum of one for each
type of sample preparation or the number specified by the
appropriate method).
—Method blanks—These blank samples are prepared in the
laboratory and are analyzed to assess possible laboratory
contamination (one for each lot of samples analyzed).
—Reagent and solvent blanks—These blanks are prepared in
the laboratory and analyzed to determine the background
of each of the reagents or solvents used in an analysis
(one for each new lot number of solvent or reagent used).
• Field audits and laboratory performance and systems audits
may be included in some cases. Cylinders of audit gases for
volatile POHCs are available from E PA.
• A minimal level of calculation checks (e.g., 10%) should be
established.
"Gorman, Paul G., et al.. Practical Guide - Trial Burns for
Hazardous Waste Incinerators. Prepared by Midwest Research
Institute for USE PA Contract No. 68-03-3149, Work
Assignment 12-7, Rnal Report, June 1985.
7. Sampling and Analysis Methods for Hazardous
Waste Combustion, Prepared for U.S. EPA/IERL-
RTP by A. D. Little, Inc., December 1983.
8. U.S. EPA, Quality Assurance Handbook for Air
Pollution Measurement Systems ("The Red
Book"), Office of Research and Development,
Environmental Monitoring Systems Laboratory,
EPA/600/9-76/005, March 1976.
9. U.S. EPA, Interim Guidelines and Specifications for
Preparing Quality Assurance Project Plans, Office
of Monitoring Systems and Quality Assurance,
Office of Research and Development, QAMS-
005/80, December 1980.
10. Jayanty, R. K. M-, Performance Audit Results for
POHC: VOST and Bag Measurement Methods,
Prepared for U.S. EPA Environmental Monitoring
Systems Laboratory by Research Triangle
Institute, January 1984.
Summary
By understanding the technical and regulatory concerns
of regulatory agencies in the permitting of hazardous
waste incinerators, an incinerator permit applicant can
compile a permit application that requires only minimal
follow-up review. Practical considerations can reduce
the expense and delays often associated with the permit
application review and revision process.
References
1. 40 CFR 270.62.
2. U.S. Environmental Protection Agency, Guidance
Manual for Hazardous Waste Incinerator
Permits, Office of Solid Wastes, Washington, DC,
SW-966, July 1983.
3. RCRA Part B Model Permit Application for Existing
Incinerators, Prepared for U.S. E PA by A. T.
Kearney, Inc., and Battelle Columbus Labs,
February 1983.
4. 40 CFR 270.62
5. 40 CFR 264.345(e).
6. 40 CFR 264.345(b).
44
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Indicators of Incinerator Performance
By
Joseph J. Santoleri
Four Nines, Inc.
Background
Incineration systems are required to meet the
performance as established by the State and the U.S.
Environmental Protection Agency (E PA) regulations.
Basically for a hazardous waste incinerator, these
include the ability of the unit to meet 99.99% destruction
and removal efficiency (ORE); the ability to reduce HCI
emissions by 99% or a maximum of 4 Ib/hr in the
smaller units; and the ability to reduce the particulate
emissions to 0.08 gr/dscf corrected to 7% oxygen in the
stack. Based on the types of waste, the type of
incinerator and the type of controls, there are variables in
the conditions under which the units operate which will
affect the ability of the incinerator to perform to the
requirements above.
The major variables in the performance of an incinerator
are the following:
Temperature
Pressure
Flow
Flue-Gas Composition
Waste Analysis
Ash Analysis
Listed in the handouts provided at the meetings are the
variables as listed above, locations for measurement and
the means of measuring. The minor incinerator variables
are as follows:
Atomizing Fluid Temperature
Amperage
Viscosity
Humidity
Ambient Temperature
Barometric Pressure
pH of Scrubber Discharge
Flame Appearance
The various items listed are covered on separate sheets
to show the location of the measurement of the variable,
the means of measurement and the effect on the variable
whether it is below or above the set point.
incinerator operation have been covered. In some cases,
these may swing from a minor to a major depending on
the type of installation or the type of incinerator system.
The above are meant to assist in the review of an
incinerator permit or Trial Burn to determine which
should be looked at carefully when determining whether
an incinerator is operating to reach the conditions
required by the regulations.
Summary
The selected variables for either major or minor
conditions within the incinerator which affect the
45
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Monitoring Equipment and Instrumentation
By
David R. Taylor, C. Dean Wolbach, and Carlo Castaldini
Acurex Corporation
Mountain View, California 94039
Introduction
One of the most important aspects to consider in
conducting a trial burn is the selection of the
instruments, equipment, and methods used to obtain the
data on which a regulatory decision is made. Without
accurate and reliable data, a decision is impossible. In
this paper in the workshop, the key factors that must be
considered in selecting equipment and methods are
discussed. Also included is a listing of those instruments,
equipment, and methods that are commonly used in test
burn sampling and analysis. The purposes of each
instrument is briefly outlined as well as possible
alternatives. The tables that summarize the information
also include a brief overview of information describing
advantages and disadvantages of each piece of
equipment. A detailed description of each type of
measurement and its associated equipment is not
possible in this brief paper, but the paper attempts to
highlight key areas to be considered in a selection of the
various alternatives. Finally, the paper concludes with a
brief overview of Quality Assurance/Quality Control
(QA/QC) considerations that should be factored in
whenever a sampling and analysis or test plan is
evaluated.
A list of acronyms and abbreviations used in the paper
can be found at its conclusion.
Factors Affecting Instrument and
Equipment Selection
Several factors determine the choice of sampling and
analysis methods, instruments, and equipment. The
primary ones include (1) regulatory requirements, (2)
monitoring purpose, (3) unit operating range, (4) waste
composition, (5) available sampling methods, (6)
analytical sensitivity, (7) QA/QC needs, and (8)
economics. These eight factors all play a role in the
decision process and, depending upon the particular burn
in question, may assume greater or less importance.
Clearly, many of these factors are interrelated.
Regulatory requirements are the prime factors which
dictate the choice of the sampling and analytical
methods. These determine what measurements must be
made, since it is the purpose of the test burn to obtain
regulatory approval of the use of the incinerator. Based
on objectives which are established by the permit
applicant, the monitoring purposes can be determined.
The operating range of the unit and the composition of
the waste fed to it during the test burn influences the
specific choice of instruments or monitoring methods.
Given that a particular type of measurement must be
made, there may be several alternative ways of obtaining
this information. The composition of the waste and unit
operating range are two of the more significant factors in
determining what instruments are chosen. Especially
when the E PA is involved, it is preferable that either IE PA
standard or equivalent methods be utilized if possible.
The analytical sensitivity of the instruments and QA/QC
needs also should play a factor in the decisions with
respect to methods. If the required measurements cannot
be made with the necessary quantitation limits needed to
establish the effectiveness of the combustor, the type of
sampling may need to be changed or perhaps the existing
methods modified so that a different size sample may be
collected. A final consideration is that of economics.
Conducting a test burn is an expensive proposition; the
sampling and analysis aspects of the burn are not
insignificant contributors to the total cost.
Many questions have to be addressed before a test burn
plan can be evaluated. Normally these are considered in
the sequence shown in Figure 1. Figure 1 indicates those
points in the process where monitoring and
instrumentation requirements should be specified and
also indicates those points where monitoring and
instrumentation equipment are used. It is not crucial that
these areas be covered in initial permit applications;
however, prior to permit approval, this information must
be made available by the permit applicant.
This information would be typically presented in the test
plan for the burn. In the test plan the applicant should
discuss how the regulatory requirements determine the
emission limits and analyte selection for the burn. The
description of the system should result in an
identification of sampling locations, sample types, and
the sample matrix. A discussion of waste and fuel
characteristics should dictate what analytes are to be
sampled and measured, determine the instrumentation
to be used, and dictate the methodology chosen. The test
matrix itself should dictate the range of operating
conditions. The section on sampling and analysis should
46
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Conduct site survey
i
Prepare test plan3
Prepare equipment
Conduct field test
Conduct analyses
Carry out data reduction
i
Conduct compliance monitoring
"The task where monitoring and instrumentation requirements
are specified.
'The tasks where monitoring and instrumentation equipment is
used.
Figure 1.
Flow diagram for testing a hazardous waste thermal
destruction device.
identify the species to be measured, the methods to be
used to sample or monitor these species, and the
analytical methods to be used to characterize the
samples obtained. A discussion of QA/QC should include
a description of the sampling and monitoring frequency
within an individual test, as well as the number of tests
to be replicated if this is to occur. It also should include a
description of analytical repetition, blanks, standards, and
spiking considerations. Finally, the QA/QC section
should also specify the calibration and maintenance
procedures to be followed for all the instruments. If
samples are not to be analyzed onsite, then the QA/QC
section should also include consideration of such factors
as chain of custody, recordkeeping, and possibly sample
transportation and storage. It is usually desirable,
although not necessarily essential, that the QA/QC
section or the test plan include some description of data
validation and review procedures.
Description of Monitoring and Sampling
Instrumentation and Equipment
For the purposes of this discussion, equipment and
instrumentation are divided into three categories:
continuous monitoring instruments; sampling equipment;
and analytical instrumentation. All three of these may be
used onsite, while analytical instrumentation may also be
used at an offsite laboratory.
Table 1 contains a description of continuous monitoring
instrumentation. These types of instruments normally
monitor for the parameters CO, C02, Oa, TUHC (total
unburned hydrocarbons), S02, and NOX. Only CO and Oa
are required to be monitored under the Resource
Conservation and Recovery Act (RCRA) although,
generally, information on the other species is desirable.
As can be seen from Table 1, there are several
alternatives for the measurement of each of these gases.
All are designed to operate on a real-time basis
approximately over the range that is presented in Table 1.
In Table 2 are several brief comments with respect to the
properties of these instruments that may influence their
choice for measurement purposes. This discussion is
based on instrument type rather than each specific
analyte and instrument.
In Table 3, a listing of typical source sampling methods is
presented. In most cases these involve stack sampling
trains which collect multiple samples. For instance, a'
particulate sample may be collected at the same time an
impinger is collecting a volatile gas. A resin cartridge
may collect a sample at the same time as some other
factor is being monitored. Most, but not all, of these
methods are E PA standard methods; but, unlike the
continuous monitors, there is not a lot of choice between
them. This is especially true in the case of volatile
organics, where the volatile organic sampling train
(VOST) is presently the method of choice or, in the case
of the Modified Method 5 (MM5), for semivolatile organic
compounds and particulate matter.
Once a sample is collected, it is necessary to have it
analyzed. The relationship between the samples
described in Table 3 and the analytical methods is shown
in Table 4. In Table 4 the method is identified, as well as
the type of sample that is collected from it. The specific
analyte that may be associated with that substrate is
indicated. In general there is usually more than one way
to quantify a given analyte. This is shown more
specifically in Table 5 where a comparison of the most
common analytical instruments and/or detector systems
are described. For the organic area especially, there is a
large range of possible methods or instruments that can
47
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Table 1. Continuous Monitoring Instrumentation
Analyto
CO
COj
Oa
TUHC
SOz, NO,
Method
NDIR
Differential
adsorption
Polarographic
Spectrometric
NDIR
Polarographic
Spectrometric
Polarographic
Electrocatalytio
Paramagnetic
Spectrometric
FID
NDIR
NDIR
Polarographic
Differential
adsorption
Spectrometric
ppm
0.5
1
0.01
1
0.5
0.1
1
0.01
0.1
0.1
1
0.1
10
0.5
0.01
1
1
Range
Percent
50
100
20
50
50
0.1
50
20
25
100
50
1
10
50
20
100
50
be used. A detailed discussion of the capabilities of all of
these instruments is beyond the scope of this paper;
however. Table 5 does summarize some of the
advantages and disadvantages of them. In a review of a
test burn sampling and analysis plan, the permit
applicant must give some consideration to the
parameters to be measured and the means by which
these measurements are to take place in the laboratory.
An additional area where measurements are required is
in the area of waste characterization. The type of waste
fed to the combustor dictates the nature of the
measurements that are made. The same instruments
that are discussed in Table 5 are also those that are used
to characterize the waste fed to the incinerator. The
major problem ordinarily is the waste is of a higher
concentration than the samples received from the
sampling effort. The result is additional analytical steps
may be necessary to provide an accurate analysis.
Quality Assurance Considerations
All sampling analysis plans or test plans should contain a
section that discusses quality assurance. Preferably, a
detailed quality assurance project plan will be prepared
for the test burn; however, this is not a requirement. It is
key that the plan contains some mechanism to estimate
data quality. Typically, the Agency prefers to see some
discussion of precision, accuracy, representativeness,
completeness, and comparability; although the latter two
are not always necessary. It is also key that there is some
independent cross-checking of the results that are
obtained.
Typically, a quality assurance plan should contain some
discussion of chain-of-custody and reporting
requirements during all phases of the test. Second, it is a
good idea if it contains a discussion for data quality goals
because it is these that establish the measurement
criteria and equipment decisions. Failure to meet goals
impacts the regulatory approval of the future use of the
combustor. There should be a discussion of quality
control activities as they relate to the sampling and
analysis activities of the project. A discussion of data
quality assessment and how the data are to be validated
is appropriate. Data review procedures, corrective action
procedures, and preventative maintenance procedures
should also be discussed. Finally, it is desirable, although
not essential, that a separate section be included in the
final report that discusses QA and QC. In reviewing a
proposed test burn plan, or the results of a test burn, it
should be kept in mind that quality assurance
considerations influence the choice of instruments and
Table 2, Comments on Different Continuous Monitoring Instruments
Advantages
Disadvantages
NDIR instruments
Polarographic
analyzers
Electrocatalytic
Oa analyzer
Paramagnetic
Oa analyzer
Moderate cost; can
be used several
gases
Can be used for several
gases
Both extractive in
situ designs
Separate instruments for each gas
Subject to interferences
Not good with corrosive gases
May have limited sensitivity
Sample gas must be conditioned
Electrochemical cell must be
replaced every 6 months
CO, hydrocarbons will burn at
device operating temperature
Requires stable temperature
, Needs stable gas composition,
UHC may react
HaO and participate matter must
be removed
NO and NOa may interfere
48
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Table 3. Typical Source Sampling Methods
Generic
Name
Analytes
Time/
Sample
(min)
Volume
(1)
Compound
Boiling
Detection Point
Limits (°C)
Comments
Table 4. Relationship Between Sampling and Analytical Methods
Sampling
Method
Substrate
Source
Analyte
Method
(instrument)
Method 5
Modified
Method 5
SASS
Filter
Impingers
Filter
Resin
Filter
Cyclones
Resin
Impingers
Metals
Weight of paniculate matter
Volatile metals
Anions
pH
Metals
Weight of paniculate matter
Semivolatile organic
compounds
Metals
Weight of paniculate matter
Semivolatile organic
compounds
Volatile metals
Anions
pH
AA, I CAP
Balance
AA, 1CAP
Ion chromatography
pH meter
AA, ICAP
Balance
GC/MSorGC
(various detectors)
AA, ICAP
Balance
GC/MSorGC
(various detectors)
AA, ICAP
Ion chromatography
pH meter
VOST
VOC (M25A)
Bag
Cryotrap
Andersen
Resin
Gas
Condensate
Gas
Condensate
Filters
Volatile organic
compounds
(VOCs)
Hydrocarbons
Hydrocarbons
Semivolatile organics
VOCs
Semivolatile organics
VOCs
Size fractionated
Paniculate
Metals
Anions
GC/MSorGC
(various detectors)
GC
GC
GC/MS, GC
(various detectors)
GC/MS, GC
(various detectors)
Balance
AA, ICAP
1C
equipment used for sampling and analysis. The
requirements for calibration and the standards that are
used for the test also influence the quality of data from
the test burn. The number of tests, the number of
replicates of each test or burn condition, and the number
of replicates of analyses to be made from the samples
obtained are dictated by QA/QC considerations. When
there is too little QA/QC information, the decision
making process is hindered. It should be noted that each
test burn is a dynamic situation in which the acquisition
of an exact duplicate is never possible; however, it is
possible to repeat operating conditions and get some idea
of the range of performance of the unit. In some cases, it
is also possible to split samples for analyses purposes,
even though the sample itself is unique. For example, an
XAD resin once extracted may yield an extract which can
be analyzed by a gas chromatograph/mass spectrometer
more than once.
Summary
As can be seen from the brief discussion of this paper, a
permit applicant has a number of things to consider in
his or her choice of sampling and monitoring equipment
for analytical instrumentation. First, there are the factors
that flow from the test burn itself such as the regulatory
requirements, the operating range, and the objectives of
the burn. Second, there are the limitations or
characteristics of the sampling and monitoring
49
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Table 6. Comparison of Analytical Instruments/Techniques
System
Advantages
Disadvantages
GC/FID
GC/ECD
GC/HALL
GC/PID
GC/TCD
GC/MSD
GC/MS
HPLC/UV/
FLUOR/RI
HPLC/MS
AA
ICAP
1C
Universal, fair
sensitivity, wide range
Selective for RCL and RN,
excellent sensitivity
Selective for RCL, moderate
range good sensitivity
Selective for arornatics,
moderate range, good
sensitivity !
Universal, wide range
Universal, high
identification confidence
Universal, excellent
identification, moderate
range
Selective/moderate
specificity, heavier
compounds
Universal, heavier
compounds, identification
Good sensitivity, specific
Fast, multielement, can
handle oils and other
difficult samples
Fast, multi-analyfe
Many interferences, poor
sensitivity for RCL and RN,
requires specific standards
Easily upset, water sensitive,
narrow range
Unstable, water sensitive
Limited selectivity, poor
sensitivity for RCL
Not sensitive, requires specific
standards
Labor intensive, limited
selectivity, moderately expensive
Difficult to maintain, expensive,
slow, identification range must
be sacrificed for sensitivity
Few established methods, labor
intensive, moderate cost
Labor intensive, expensive,
experimental
Labor intensive, slow, subject to
interferences
Subject to interferences
Columns need frequent
replacement
equipment used. Third, there are the limitations of the
laboratory instrumentation used. All of these areas must
be considered in evaluating a permit or the results from a
test burn, for it is on them that the ultimate decision
considering the granting of a permit must rely.
List of Acronyms and Abbreviations
AA Atomic absorption
ECD Electron capture detector
FID Flame ionization detector
Fluor Fluorescence
GC Gas chromatography
HPLC High performance liquid chromatography
1C Ion chromatography
ICAP Inductivity coupled argon plasma
spectrometry
MS Method 5
MM5 Modified Method 5
MS Mass spectrometry
MSD Mass selective detector
NDIR Nondispersive infrared spectrometry
PID Photoionization detector
QA Quality assurance
QC Quality control
Rl Refractive index
RCL Organic compound containing chlorine
RN Organic compound containing nitrogen
SASS Source assessment sampling system
TUHC Total unburned hydrocarbons
TCD Thermal conductivity detector
UHC Unburned hydrocarbons
UV Ultraviolet
VOST Volatile organic sampling train
VOC Volatile organic compound
50
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Carbon Monoxide Monitoring Guidance
By
Roy Neulicht
Midwest Research Institute
Introduction
As an indicator of combustion performance, continuous
monitoring of the carbon monoxide (CO) level in the stack
exhaust gas is required for all RCRA permitted hazardous
waste incinerators. Furthermore, RCRA requirements
stipulate that the permit specify an operating limit for the
CO in the stack gas. However, RCRA regulations do not
provide specific guidance on monitoring system
requirements nor on establishing permit limitations. This
paper discusses several aspects of continuous
monitoring for CO including (a) system design
performance criteria and evaluation, (b) operation/
maintenance, (c) data handling, and (d) data evaluation
with regards to permit conditions.
Currently, a guidance manual entitled "Guideline for
Continuous Emission Monitoring of Carbon Monoxide at
Hazardous Waste Incinerators" is being prepared for the
E PA Office of Solid Waste (OSWf by Pacific
Environmental Services ( PES). This document which is
expected to be completed in the spring of 1987 will
provide specific guidance for many of the issues
discussed in a general sense in this paper.
infrared (NDIR) analyzer directly mounted on the stack or
duct. The NDIR source is transmitted across the stack,
and the amount of NDIR attenuation due to the CO
concentration in the gas is measured by a detector. An
extractive system removes a gas sample and transports it
to a remote analyzer. Each type of system has its
advantages and disadvantages. Figure 1 schematically
shows the two types of systems. Table 1 presents some
of the advantages and disadvantages of each system
type.
Extractive
Stack
Probe
System Design
The RCRA regulations do not specify any design
requirements for the continuous emission monitoring
system. Consequently, system design is entirely up to the
owner/operator.
In fact, "continuous" is not actually defined in the
regulation and has been a point of discussion. Although
some systems continuously take a sample, most (if not
all) "analyze" the sample and transmit the signal at
discreet intervals; this interval may vary from less than a
second to minutes. The current agency guidance is that
an acceptable system will continuously sample the gas
and will analyze and transmit a signal every few seconds.
That is, a system which analyzes the stack gas every 5
min is not acceptable.
Two general types of systems are available and both have
been used on hazardous waste incinerators; these are in
situ and extractive systems. An in situ system actually
measures the carbon monoxide concentration in the duct
or stack without removing a sample. Typically, an in situ
carbon monoxide monitor consists of a nondispersive
Source Detector
x-Detector Cell
Electronics
Figure 1. In situ and extractive monitors.
The concept of a continuous monitoring system is
stressed because the monitoring of carbon ^monoxide
levels incorporates an entire system and not just an
"analyzer." A monitoring system includes the following
subsystems:
a. Sample interface/transport
b. Sample conditioning
c. Analyzer
d. Data recording
e. Calibration
All aspects of the system are important and must
function properly if accurate results are to be obtained.
Figure 2 is a schematic of an example extractive CO
monitoring system.
Several factors to keep in mind when designing a system
are:
51
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Tnbla 1. Some Advantages and Disadvantages of In Situ and
Extractive Monitors
Advantages
Disadvantages
In Situ
Extractive
Very rapid response
time
No conditioning
system
Measures entire
stack traverse
Susceptible to
problems from
vibration on stack
General inability to
directly audit
calibration with
cylinder gases
Inaccessibility for
maintenance
Analyzer ban
be located in
a remote
clean area
Complex
sample
conditioning
maybe
necessary
1. Sampling/measurement location. Obviously, a
representative sample must be obtained in order to
achieve meaningful results. A sample may be taken
from the "hot zone" or following the combustion
chamber in the stack or at a location anywhere in
between. The advantages of sampling from the hot
zone are few. First, since the sample is taken right
after the combustion chamber, information on the
combustion process is more readily obtained, i.e.,
the lag time for the emissions to reach the stack is
eliminated. Second, the effect of excess air in-
leakage into the system downstream of the
combustion chamber is minimized. The main
disadvantage of hot zone sampling is that the
sampling environment is very adverse, i.e., the
monitor must sample a hot, corrosive, and dirty gas.
This presents serious problems and, in my opinion,
a location downstream of the pollution control
system is preferable. A single point sample
generally is adequate unless the sample is taken
immediately following a source of air in-leakage
where stratification in the gas stream may occur.
2. Locate the monitoring system parts which require
routine maintenance (e.g., filters) in an easily
accessible location.
3. Design a data recording/logging system which is
useful to the operator.
Stack or Duct
Nitrogen
I
i
Reheat
Permeation
Dryer
Line
Analyzer
Vent
J
Microprocessor
Data Logger
Zero
Figure 2. Example extractive system.
52
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4. Establish a calibration procedure that assures
accurate results and is easy to use.
5. Keep the system as simple as possible.
Performance Criteria and Evaluation
RCRA regulations do not specify performance criteria for
monitoring systems. Recently, regulators have been
referring to E PA's regulations under New Source
Performance Standards (NS PS) for guidance on CO
monitoring performance criteria. E PA's New Source
Performance Standard (NS PS) regulations (40 CFR 60,
Appendix A) include Reference Method 1O for
determination of carbon monoxide. Although this method
is intended specifically for compliance testing of
Petroleum Catalytic Cracking Unit Catalyst Regenerators,
Agency personnel often cite the method and refer to it in
relation to CO monitoring of hazardous waste incinerator
emissions. Table 2 summarizes the design and
performance criteria established in Method 10. The
criteria are a good starting point, but one should not be
tied to them; this is further discussed in the following
paragraphs. '
Table 2. Criteria Established in EPA Method 10 for CO
• Lufttype NDIR ;
• Minimum 20 ppm sensitivity
• 1,000 ppm range
• Zero drift—10% in 8 hr
• Span drift—10% in 8 hr
• Precision—± 2% of full scale .
• Linearity—2%:of full scale :
• Rejection ratio—CO2: 1,000 to 1
H2O: 500to;1
, Table 3. Requirements of Performance Specification 4 for CO
Monitoring3
Performance Specification 4 for continuous monitoring
of carbon monoxide emissions (40 CFR 60, Appendix B)
was developed for evaluating CO monitors required
under NS PS regulations. Table 3 summarizes the;
performance requirements. Performance Specification 4
involves conducting a zero/span drift test to evaluate
performance and "certify" the monitor. Note that ;
Performance Specification 4, as written, is desigried only
for the initial evaluation and "certification" of the
monitor; it does not include provisions'for continued
evaluation of the monitoring system (e.g., daily
calibration checks). •
What performance criteria make sense for a CO
monitoring system at a hazardous waste incinerator?
First, performance criteria should be established for both
! 24-hr zero/span drift
! Relative accuracy
(Method 10 NDIR exempt)
< 5% of span
< 10% of Reference Method
a40 CFR 60,.Appendix B.
a pretrial burn performance evaluation andior an
ongoing evaluation during operation.
Items which require consideration prior to the test
include:
a. Instrument range (span)
b. Initial calibration procedure
c. Calibration drift check procedure and frequency
d. Accuracy
f.
Instrument Range. Instrument operating range is
specified by the manufacturer. Typical ranges are 0 to
1%, Oto 1,000 ppm, or Oto 500 ppm. For a hazardous
waste incinerator, a range of no more than 0 to 1,OOO
ppm or 0 to 500 ppm generally is desirable.
Instrument Calibration. The level at which calibration will
be conducted, as well as the procedures used and the
frequency, should be evaluated and established. It may
be desirable to calibrate the instrument at a point less
than full scale. Figure 3 is an example of the relationship
between instrument span, calibration level, and normal
operating level. Typically, calibration is conducted at a
point somewhere between the normal operating level
and the full scale span. For example, if a source normally
; operates at 50 ppm, and full scale span is 1000 ppm,
• calibration might be conducted at 200 ppm. During an
initial evaluation, it is desirable to check the instrument
calibration at more than one level. In the example above,
an additional calibration check during initial evaluation at
50 ppm is desirable using multipoint calibration checks
across the entire operating range of the instrument. The
procedure used for calibration must be specified and
should include as much of the entire monitoring system
as possible (i.e., sample conditioning system, sample line,
etc.). Sometimes it is not practical to include the entire
sample transport system (i.e., the sample line from the
. stack) in the calibration. In such cases, the transport
system must, as a minimum, be checked for leaks.
o 1— i
Normal
Operation
SF
Permit
Level
Zero
Instrument
Range
o
Initial and Daily
Calibration
Check
Initial
Calibration
Initial
Calibration
Figure 3. Instrument calibration.
53
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Calibration Drift Check Procedure. How well the
instrument will hold calibration over a period of time
must be evaluated. The criteria of Performance
Specification 4 are recommended, i.e., a 24-hr drift
check. Calibration drift is checked at 24-hr intervals for 1
week. The 24-hr drift must not exceed 5% of instrument
span. Note that a tighter drift requirement may be
desirable in some cases. For example, for an instrument
with full scale span of 1,000 ppm, the allowable drift (by
Performance Specification 4) is 50 ppm. If the facility's
emission level is normally 40 ppm, allowing a 50-ppm
drift really is not desirable. A 20-ppm drift is more
desirable and is reasonable since most manufacturers
will specify a drift of ^ 2% of full scale (2% of 1,000 ppm
= 20 ppm). Also note that had the same facility installed a
monitor having a full scale span of only 500 ppm,
Performance Specification 4 would stipulate an
allowable drift of only 25 ppm. It is obvious that simply
specifying use of Performance Specification 4 criteria
may not be equitable in all cases or even make sense. In
fact, a more reasonable approach is to look at the
particular situation and the instrument specifications to
establish reasonable drift requirements and then
establish drift requirements in terms of ppm rather than
percent of full scale. The procedure used and the
concentration level at which the calibration drift check is
conducted should be stipulated.
Accuracy. It is desirable, but not necessary, to
independently check monitor accuracy prior to the triaj
burn. For extractive monitoring systems, this may be
done by entering an "audit gas" into the sampling system
or by actually measuring the stack gas with an
independent measurement system, i.e., another monitor.
For an in situ system, an independent measurement of
the stack gas generally is required if monitor accuracyls
to be verified. Note that since no criteria exist for defining
an acceptable accuracy, judgment must be exercised ih
determining if results are acceptable. ',
The pretest evaluation is necessary to assure the
monitoring system is performing properly prior to the trial
burn. Continual evaluation of the monitoring system
performance is required to assure that monitor I
performance is acceptable on a continuous basis during
normal operation. The primary means of evaluating
performance is a daily zero drift and span drift calibration
check. This check is conducted daily in the same manner
as the pretest calibration drift checks. Criteria should be
established for the amount of drift which is unacceptable,
consequently requiring a calibration adjustment or
instrument recalibration.
An independent performance audit of the system
accuracy is another means of checking continued
performance. For example, an annual audit using a
cylinder gas that has been independently certified can be
conducted to evaluate monitor performance.
Operation and Maintenance
Routine preventative maintenance of any monitoring
system is important if the system is expected to operate
54
in a reliable manner. Each system is different and
therefore will require different maintenance.
Nonetheless, a maintenance program should be
developed for each monitoring system. The permit should
stipulate that a written maintenance schedule be
prepared and followed and that a maintenance record log
be maintained. The manufacturer's specifications provide
an excellent starting point for developing an operation
and maintenance program.
Data Recording Frequency and Record
Keeping
One cannot assume that because a continuous CO
monitor is installed that the data recording system is
adequate. The type of data recording system (i.e., 2-in.
strip chart, 12-in. strip chart, or data logger) should be
specified. The frequency of measurement (how often the
analyzer measures the gas) and the frequency of
recording the data (i.e., "continuously," every 10 sec, 3-
min averages) also should be specified. Use of both a
strip chart and data logger is desirable, but not
necessary. The strip chart allows the^operator to see
what is happening on a real time basis and to evaluate
trends. The strip chart should be locajted in the control
room. The data logger allows a convenient method for
summarizing and evaluating data over a longer period of
time. For example, minimum and maximum values for
each hour or each 24-hr period can be recorded and
stored. The number of times an alarm has been activated
can be tabulated. Daily calibration results can be
conveniently recorded and compared to previous records
for evaluating instrument drift.
Data Evaluation and Establishing Permit
Conditions
The data obtained during a trial burn will be used to
establish permit conditions for the allowable CO level in
the stack gas during routine operation. When the permit
limits are exceeded, the waste feed must be cut off.
Several factors related to evaluating data and
establishing limits must be considered; these are briefly
discussed in the following paragraphs. How does the
permit writer handle brief "excursions" or "upsets"
which result in brief but significant increases in CO?
Should the permit allow a time delay before waste feed
shutoff or is an immediate shutdown required? If CO
excursions are noted during the trial burn (and the feed is
not shut off), then the permit writer can base time delays
allowed in the permit on the actual trial burn data.
However, if.no excursions were observed during the trial
burn, a time delay for waste feed shutdown still makes
sense. For any monitoring system there is a lag in the
measurement of an event; consequently, it makes sense
to take the response (lag) time into consideration before
initiating a shutdown. For example, for a brief excursion
lasting only 30 sec, by the time the event is monitored
and the waste feed shut off, the event will likely be over.
A shutdown and startup of the waste feed may actually
result in more emissions than the event itself.
-------
How does the permit writer handle a case where the
emissions are very low (< 20 ppm) throughout the test
and a very high ORE is obtained (> 99.9999). Is the limit
set at not to exceed 19.5 ppm even though the stated
(and demonstrated) monitor precision is ±20 ppm?
When the CO level varies widely (e.g., varies over a range
of 50 to 100 ppm) during a trial burn but does not include
obvious excursions (e.g., 300-ppm peak) is the standard
set at the maximum level during the burn (e.g., 100 ppm)
or some mean level (70 ppm for 2 min) or both.
Currently, there are two types of permit limits being
written:
a. Single level standards
b. Double level standards
Single Level Limit. The simplest type of permit limitation
is a single level standard, i.e., a single emission limit is
set. This type emission limit would only be applicable to
an incinerator for which the CO levels are very steady.
The limit does not generally allow for excursions. The
limit can take the following forms:
a. Not to exceed Y ppm (where Y = 70 ppm, for example).
This standard does not allow for any time delay for
instrument response time nor for brief excursions.
b. Not to exceed Y ppm (where Y = 70 ppm, for example)
for greater than 30 sec. This limit allows a brief time
delay prior to shutdown for response time lag and for
very brief excursions.
c. Y ppm (where Y = 70 ppm, for example) for 5-min
average. Use of a time averaged emission level
allows the limit to be set at a lower level than the
"not to exceed" limit. However, use of a time
averaged standard can diminish the ability to quickly
identify excursions, depending upon the time
averaging period. The longer the averaging period,
the more difficult identification of excursions
becomes.
Dual Level Limit. A dual level limit incorporates all the
options of a single level limit and allows additional
flexibility in establishing permit conditions. This type of
limit can be used where significant CO emissions
excursions are noted during the trial burn; for example,
when brief but distinct CO peaks are noted during
charging of solids to a rotary kiln or fixed hearth
incinerator. Two examples of this type of permit condition
are:
Example 1:
• Level 1: Not to exceed 50 ppm for greater than
3 min
• Level 2: Never to exceed 1,000 ppm
Example 2:
• Level 1: 5,0 ppm for a 5-min average
• Level 2: Never to exceed 1,000 ppm
The advantage of this type of limit is that a time delay is
provided for brief excursions before waste feed shutdown
is initiated. However, a maximum limit also is provided to
quickly identify major upset conditions. There are many
other combinations of never to exceed values, limits with
a time delay, and average limit's that can be considered.
Proposed Guidance on Establishing CO
Limits
As previously mentioned, USE PA currently is developing
specific guidelines for the monitoring of CO from
hazardous waste incinerators. This guidance is expected
to be established in the spring/summer of 1987. Initial
indications are that the guidance will include
establishing dual level permit limits for a facility. Limits,
based on average CO values for specified time periods,
i.e., time weighted rolling averages are being considered.
The guidance being considered is for the CO measured at.
the stack, normalized to a standard oxygen concentration
of 7%. Use of the oxygen normalized CO value will adjust
for changes in dilution air (air in-leakage) and
combustion excess air rates. Use of this format if adopted
as guidance would require that facilities also .monitor
oxygen and that real time integrators be installed to
calculate rolling averages.
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Construction and Retrofit Guidelines for
Existing Incinerators
By
Joseph J. Santoleri
Four Nines, Inc.
Introduction
The proper and continuous operation of an incineration
system for hazardous wastes has become a major
responsibility of the Plant Engineer. Owners and
operators of incinerators have had to submit completed
applications for the Part "B" operating permit on existing
incinerators by November, 1986. As part of the Part B
permit, a Trial Burn Plan is needed. The Trial Burn Plan
spells out the conditions under which the incinerator will
be operated to determine the permit conditions to be
established between the permitting agency and the
operator. Many incinerators for which there has been
application for the Part B permit have had interim status
for at least 6 to 8 years, having received this in 1978.
Now that the Trial Burn Plans have been submitted arid
the equipment needed to operate the unit permanently
has to be installed and in operational -condition prior to
the Trial Burn, many organizations are taking a hard look
at whether they have a unit capable of meeting these
conditions. The permit and the Trial Burn have
established the recording and monitoring procedures
necessary to ensure that the incinerator operation is .
within approved parameters. It has been found through
Mini-Burns that many incinerators do not meet the
conditions necessary to be approved in the final trial
Burn. As a result, many installations are going through) a
retrofit program to bring the incinerator to the point
where it has an excellent opportunity of passing the Trjal
Burn conditions.
To determine the potential for an incinerator to meet the
Trial Burn conditions, Mini-Burns are recommended. I
These burns will provide the incinerator owner a better
understanding of what his equipment can do in its
present condition and what changes may be required to
bring the system up to the performance necessary for the
Trial Burn. Although this discussion focuses on the
problems related to the pumpable liquid wastes burned in
liquid injection units, the concepts developed can be
applied to other incineration units such as rotary kilns,,
fluid bed combustors, two-stage combustors, and other
incineration systems.
Materials Handling Problems
In transporting liquid wastes or slurries to the
incinerator, the key elements are the storage facility,
transfer and heat pumps, metering, control and shutoff
valves, and the atomizers. Wastes vary from highly
aqueous materials with organics and ash (typical of
pharmaceutical and agricultural process wastes) to
viscous tars such as toluene diisocynate with a viscosity
of 4500 ssu at 300°F.
The transport system should be designed to prevent
blockage in the lines due to waste shutoff to the
incinerator, pump failure or inadvertent shutoff to the
waste system. It is important that then following waste
data be analyzed to determine whether the system as
designed can properly transport and feed the waste into
the incinerator, create no problems with refractory
construction and eliminate problems in the waste heat
recovery and air pollution control systems downstream.
These waste data are:
1. Chemical composition
2. Heat of combustion
3. Physical data (if not liquid)
4. Viscosity
5. Corrosivity
6. Reactivity
7. Polymerization
8. Ash/lnerts content
9. Fusion temperature of ash
10. Combustion product analysis
11. Nitrogen composition
Design Details of the Incinerator
Incinerator systems should be reviewed and include but
not be limited to the following:
Physical dimensions
56
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Materials of construction
Feed device
Injection method
Auxiliary fuel system
Combustion air system
Quench system
Scrubber system
Controls, Monitors and Alarms
Knowing information about the waste, the flow rates of
the waste, and the compositions as well as heating
values, one can determine the ability for the system to
reach these capacities. We have found systems that were
designed for one set of conditions initially when the
system was installed; however, the process plant
changes created new waste streams that are now being
handled by the incineration system. A closer review of
the capacity of the system to handle these new wastes
should be made. This will include the capacity and the
composition of the waste regarding the air available
which determines the overall capacity of the system and
the downstream scrubber system, depending upon the
concentration of the waste and what acid gases are
generated. In some cases, the system has been modified
for the type of solids injected into the incinerator. The
physical data for the solids may affect the type of
scrubber that has been installed.
To determine the capability of the system to meet the
conditions for operating in the Trial Burn, a Mini-Burn or
test program should be set up. The waste streams should
be defined with the feed rates, compositions, heating
values, water content and ash content; next, the
operating temperatures of the various components of the
system, such as the primary or kiln and the secondary
chamber. In a liquid injection incinerator, this would be
the primary chamber only. A review should be made of
the air rates, and methods of determining the
measurements of these rates. In case of the induced
draft fan systems, this may be done only through stack
discharge of the induced draft fan with a balance made
with the air supply through the forced draft fans.
Measurements can be made of all streams and tests
should be conducted to determine these rates.
It is important that a sampling procedure be established
to monitor the combustion efficiency and ORE of the
selected POHCs. If ash is contained in the waste, the
particulate emission should also be measured. If
chlorinated hydrocarbons are injected into the system, a
means should be developed for measuring the overall
efficiency of the scrubber. In other words, the HCI
entering and leaving the scrubber should be sampled so
that the efficiency of the scrubber can be determined.
Prior to formal Mini-Burn, observation of the unit should
be made while the unit is in normal operating conditions.
It is sometimes feasible to make interim modifications
prior to the Mini-Burn based on the preliminary
observations. This is often done to provide better feed
conditions, better atomization if liquid waste, better
control on draft, improvement to pH control system, also
improvements to the venturi pressure drop control, etc.
Normally, these modifications are minor in nature and
should not require much of a design effort nor an
installation effort. Once the test program is set up and
the information is obtained as a result of the testing, the
real involvement in retrofit design begins; however, it is
important to know that the Mini-Burn should basically
cover the variety of wastes to be handled in the Trial
Burn. Sufficient data should be taken on the rates of the
waste streams, the composition of the waste streams,
and the resulting emissions from the stack, scrubber
discharge and ash discharge.
The advantages of the Mini-Burn are that it provides a
complete run-through of all the systems involved in
. operating the incinerator. The problems that have
occurred in these Mini-Burn tests are covered in more
detail in the papers enclosed with the handouts at the
meeting. The paper, "Trouble Shooting and Upgrading for
Incineration Systems," covers several types of
incinerators and the problems related to the operation of
those units. A second paper entitled, "Design and
Operating Problems of Hazardous Waste Incinerator,"
also goes into the many areas that should be looked at
during the Mini-Burn. Once these problems have been
found, the next phase of the project involves interim
modifications with subsequent testing. These may again
be minor modifications without major revisions or design
effort. Tests should still be conducted to prove the
adequacy of these changes. Based on the results of these
Mini-Burns, a final design is started. In most cases this
begins with a conceptual design and budget costs
covering the changes needed and the importance of
these changes. These are reviewed with the owner of the
incinerator and his engineering staff; in some cases,
some of this work can be handled directly by in-house
engineering and fabrication departments. In other cases,
the entire project is assigned to the consultant with
detailed design and purchasimg assistance provided. This
will include specifications for all equipment that has to
be purchased, selection of vendors, review of bids, and
assistance in placing the purchase orders for these
items.
The next phase of the retrofit includes the overall
program management which includes the following:
Purchasing
Fabrication and Inspection
Shutdown and Installation
Pretest Checks
Again, this phase is one that can be handled by internal
personnel of the incinerator owner with assistance from
the consultant, or it can be done completely by an outside
consulting and engineering firm. In any case, it is not
much different than programs involved in the initial
purchase and installation of the equipment; however,
57
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since it does include a retrofit, it does include much more
careful investigation of the existing equipment since
modifications may have been made from the original
drawings to the final installation. Changes to the
instrumentation and hardware from the original
installation may have been made; therefore, these must
be carefully checked to be sure that whatever design
changes are incorporated will fit into the final unit.
Scheduling of the shutdown must be carefully planned to
ensure that no problems will occur with storage or
buildup of the waste materials during the time the retrofit
is completed. This requires liaison between the plant
operations, the incinerator operations, the vendors who
are supplying the equipment, and the installation '
contractors. Since it is a high temperature furnace, the
other areas that must be carefully observed are the cool-
down needed for the refractory linings and the complete
purging of all acid gases and ash-containing substances
throughout the entire incinerator system. This will
include the incinerator refractories and the scrubber
system to purge out any build-up of salts or any other
ash-containing materials. Shutdown will allow inspection
of the entire system including the piping, valves, nozzles,
refractories, pumps, operating linkages on valve arms;
and damper controls. It also permits inspection and
maintenance of all instrumentation including the '.
temperature, gas analysis and pH controls.
After installation, tests should be scheduled prior to the
first full-scale Mini-Burn test. Pretest should be made of
all the new equipment that has been installed. This
includes all rotating machinery, motor drives, belt drives,
etc. All automatically controlled valves should he checked
for the stroke of the valve through its full range. All
instrumentation should be fine tuned by instrumentation
mechanics. If new refractory has been installed, this ,
should be placed through a proper curing cycle and this
scheduled with the incinerator operations department.
Once the pretests have been completed, the unit should
be brought on-line utilizing fossil fuels such as natural
gas, No. 2 oil, to allow the unit to go through its operating
temperature range and total flow range. This will also
permit complete fine tuning of all instrumentation and
controls.
Next,'the waste burning test should be scheduled. This
will be a duplication of the Mini-Burn test to ensure that
all the modifications that have been designed into the ;
retrofit will meet the conditions necessary for the final!
Trial Burn. Scheduling should be basically the same as;
the final Trial Burn except it may not be necessary to go
through the entire range of wastes or cases as one would
in the final Trial Burn. The main purpose of this is to
ensure that modifications will meet the conditions for
which they were designed.
Upon completing the final Mini-Burn tests and reviewing
the process and sampling data, determination of the
readiness of the incineration system for the final Trial
Burn should be made. If all the conditions of ORE, HCI
removal and particulate levels in the stack emissions
have been met, the unit is now ready for the final Trial'
Burn. Prior to this all modifications which affect the Trial
Burn plan should he included in the Trial Burn plan.
These should then be submitted to the inspection agency.
Meetings will then be held to review the conditions for
the Trial Burn and hopefully at this point all NODs will
have been eliminated. Following these meetings the final
Trial Burn schedule will be set up and arranged.
In the past two to three years, many systems have
undergone the procedures outlined above in bringing a
unit up to the conditions necessary to meet and pass the
Trial Burn. I have tried to outline here the steps that are
required. There are variations depending on the
installation and the type of equipment but basically the
procedures will follow the outlines as indicated above.
58
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Case Studies for Trial Burns
By
Joseph J. Santoleri
Four Nines, Inc.
Background
A questionnaire was developed to generate information
that could be used in this portion of the program. A total
of 36 questions were asked regarding all phases of the
Trial Burn Plan. This included the information as
prepared in the Trial Burn Plan including any comments
or reviews by the inspection agency, whether it be the
State or the E PA; the follow-up by the incinerator owner
with the inspection agency, and the most important
section, that of the Trial Burn itself. These questionnaires
were forwarded to four locations with different types of
incinerators. The one that responded with the most
detailed information was from a rotary kiln chemical
process plant. This facility was the Eastman Kodak
Company in Rochester, New York. Kodak Park is the
central location for Eastman Kodak Company for
producing film. As a result, a fairly large chemical
complex is located at this facility. Due to the chemical
processes involved, many wastes are generated in the
forms of solids, sludges and liquids.
The present incineration system handles these particular
wastes on a day-to-day operation. The schematic shows
the entire incineration plant which involves a rotary kiln
followed by an afterburner: then a quench chamber
followed by a venturi scrubber, packed tower, two
induced draft fans in series, and finally the stack, 250 ft.
high. The wastes are brought into the plant in tank trucks
and delivered to storage tanks. These tanks are designed
with internal mixers so that a homogeneous mixture can
be maintained in the tank. The liquids are then pumped
out and fed directly to the kiln burners or into the
auxiliary burner firing the afterburner chamber. Many
locations exist for feeding liquids both at the front end of
the kiln or in the auxiliary burner firing at the base of the
afterburner chamber. This burner provides the heat
necessary to maintain the afterburner temperature. The
sludges are brought in tote boxes, again pumped by
diaphragm pumps over to the storage tank where they
are mixed and fed into the sludge burners located in the
front of the kiln. Any wastes that contain inorganic
materials are also fed into the kiln. The storage and
handling of these wastes are such to prevent any ash-
containing waste from being fed directly into the auxiliary
burner. However, high aqueous materials containing
organics and inert ash are fed into a series of nozzles
located on the periphery of the auxiliary burner in the
afterburner. Combustion air is supplied through forced
draft fans providing air to the burners at the front end of
the kiln .and also through forced draft fans to the auxiliary
burner. The induced draft fans at the exit of the
scrubbers are used to induce air in through the front end
of the kiln through an automatically controlled damper.
The total volume of gases traveling through the kiln are
generated by the forced draft fans feeding the burners at
the front end of the kiln as well as the air through the
inlet duct of the kiln. The bulk of the gas flow through the
kiln or through the entire incinerator system is
determined by the total stack gas flow. At Kodak the
amperage of the motors used to drive the induced draft
fans was used as a means of measuring the total volume
flow through the system. This provides a measurement of
the volume of gases in the afterburner chamber which
permits calculation of the residence time in this chamber.
The afterburner is constructed as two vertical chambers
with the gases traveling vertically up after leaving the
kiln and making a 180° turn through a vertical down
chamber. The auxiliary burner is firing at the bottom of
the first chamber into the gases as they exit the kiln. This
provides good contact of these gases with the flame
surface and ensures that all gases leaving the kiln pass
through the flame front. The high intensity of this burner
ensures that all gases are brought up to the secondary
chamber temperature and maintained at that
temperature throughout the full length of the two vertical
chambers. After the gases leave the second vertical
down chamber, they enter the quench tower. Water is
sprayed in through the top of the tower contacting the
gases in a counterflow arrangement. This permits the
gases to be completely saturated prior to entering the
venturi scrubber. This ensures high efficiency on the
scrubber by having the gases fully saturated prior to
entering the throat of the scrubber. The excess water
sprayed into the quench tower drops to the bottom of the
vertical quench chamber and is recycled into the spray
nozzles. The venturi scrubber is used to scrub the ash
generated in the incineration process which includes the
ash carryover from the kiln into the secondary chamber
and any ash generated by the aqueous wastes introduced
into the secondary chamber. After these particulates are
scrubbed through the high energy venturi, the gases then
travel through a packed tower absorber where they are
contacted by a caustic solution to scrub out the HCI gases
generated from the chlorinated wastes. At this point the
gas temperature is approximately 150° F. After passing
through the packed tower, the gases enter the induced
draft fans and are then forced up through the stack. The
system includes two induced draft fans to provide a total
pressure drop across the venturi and packed towers of
59
-------
approximately 78". This level of pressure drop is required
due to the particulates generated in the incinerator. yVith
only a single fan operating, the pressure drop provided is
in the range of 45-50". When solids are not burned and
most of the waste being burned is solvents containing
very little ash, the system can be operated with only a
single fan, thereby reducing horsepower. In order to
assure complete scrubbing of the HCI, caustic is
introduced into the pH control system. As the gases pass
through the venturi and eventually into the packed tower,
they are contacted by recycled liquids from the pH
control. The pH is maintained at a level of 6-7. This
insures that the HCI is scrubbed out and the liquid used
in recycle is neutral or slightly above neutral. Due torthe
reaction time of the pH control system and the spikes
that can occur due to the introduction of high chloride
wastes, the pH control system will vary and allow the
recycled liquid to go to the acid side. The number of times
the pH will spike down determines how well the system
can handle the chloride load. Minimum pH allowable for
alarm and shutdown is 1.5.
The total heat capacity generated in this incineraton
system is approximately 120 MM Btu/hr. Note that the
system does not contain a waste heat boiler. At the time
the system was installed, waste heat recovery from this
type of waste burning was not designed with waste heat
recovery in mind. The main purpose of the system was a
means of waste disposal by incineration. However, with
the quantity of heat that is generated, consideration may
• be given in the future to add waste heat recovery. This
should generate about 80,000-90,000 Ib/hr. of steam.
Information regarding the schedule of the Trial Burns,
the modes in which the Trial Burns were planned, the
schedule of the daily testing, and the results of the Trial
Burn which includes the DREs, the paniculate removal
and the HCI removal are all shown in the handouts
provided. One thing that should be particularly pointed
out for this case study is the Mini-Burns that were
conducted by Kodak to ensure that all systems were
optimized. This included all the existing control functions
as well as all the instrumentation, monitors and safeties.
It is recommended that any system go through a Mini-
Burn before a final Trial Burn is scheduled. Kodak went
through a period of 3-4 years of various tests. A
concentrated test period took place over about 4 months
proper to the final Trial Burn. This permitted complete
debugging of all the problems that would have occurred
during the Trial Burn which may have caused a
shutdown and increased the expense of the Trial Burn
operations. Some items that were changed were the flow
meters for measuring liquid flows, nozzles in the burners
and aqueous waste injection, refractory design, CO and
Oz monitors; also improvement in the sampling trains for
the CO and O2 monitors to prevent the nuisance
shutdowns that had been occurring.
One of the most important areas reported by Kodak
personnel was the good communications between Kodak
and the regulatory agency. In the case of Kodak, it was
necessary to deal with the regional U.S. Environmental
Protection Agency (EPA) office as well as the New York
State Department of Environmental Quality (DEQ). Before
the final Trial Burn was submitted, discussions were held
and various areas of the Trial Burn Plan were revised
before the Final Plan was submitted. A good line of
communications between the agency and the incinerator
operating team is necessary. It is important that the
permitting agency know exactly what your plans are; they
can make recommendations on problems that occurred at
other facilities in your area or pass on information
regarding Trial Burn Plans in other regions that they are
aware of. In the case of Kodak, the Trial Burn Plan with
specifics including permit limits and rationale for
establishing those limits was established early in the
game. The EPA came back with recommendations that
were reviewed and discussed with Kodak.
One of the conditions that was established for this Trial
Burn was a worst case scenario so that these conditions
would all be tested during a Trial Burn. As you will note
from the schedule, it was not a single day of testing; it
was a series of days.
It was decided that the test basis for the Trial Burn
include the worst case scenarios. This included the
maximum heat release rate, maximum combustion gas
volume, minimum kiln incineration temperature,
minimum afterburner incineration te.mperature,
minimum oxygen level, maximum ash load, maximum
chloride level, minimum venturi pressure drop, minimum
pH level, and maximum amperage on the I.D. fan. Some
of these are interrelated but these were the goals for the
Trial Burn testing.
One of the major items that had to be considered in the
Trial Burn Plan was the selection of POHC. Dayton
Research Institute laboratory assisted in determining
POHCs selection. Various methods of ranking POHCs
are available. At present, heat of combustion is a method
of ranking. The compounds havintj the lowest heat of
combustion, which are considered the most difficult to
burn, are those that are normally selected as a POHC.
This can be considered as a surrogate or as a compound
contained in the actual waste generated at the facility. A
second means of ranking is the auto-ignition
temperature. This has been discussed at great length
concerning whether it should be used as the means of
determining POHCs based on the difficulty of ignition
and combiistion. The third column which is headed,
Flameless Oxidation, is that temperature at which the
vapors generated achieve a 99.99% destruction
efficiency with a 2-second residence time. This assumes
that a portion of the material does not go directly through
a flame front. The ability of the incinerator to reach the
99.99% ORE of the material in this situation determines
the difficulty of oxidation. Note that acetonitrile ranks No.
1 with a temperature of 951 °C necessary to reach the
ORE. In the ranking under Heat of Combustion this is
ranked No. 10. Tetrachloromethane which ranks No. 1 in
both heat of combustion and auto-ignition temperature is
ranked No. 3 in the flameless oxidation method of
ranking. As a result, both acetonitrile and
tetrachloromethane were selected as the POHCs for the
Trial Burn.
In the Test Schedule five separate operating modes were
selected and the dates of tests were one week apart. The
reason was the quantity of surrogate compounds that
6O
-------
had to be put together for each daily run. Kodak allowed
a week between tests to collect enough materials. They
had the advantage that all of the stack emission testing"'"
as well as the ash and waste analysis testing were done
by Kodak's in-house testing group. Therefore, this
eliminated the problem in having to bring in an outside
sampling firm to the site on five separate weeks.
In the Daily Test Plan four tests were set up for the daily
schedule. This was done to insure that if one of the tests
failed due to an outside influence, that is, a process
problem, equipment problem, etc., sufficient data would
be available for ORE, HCI and particulate calculations. By
allowing time for four separate runs each day, they could
eliminate one due to a failure problem.
One item which could have been considered another
sample point was the make-up water or the fresh water
inlet to the quench chamber. Since chlorides are
balanced throughout the system, the analysis of this
water for chlorides would have added another means of a
material balance to the system. In some areas where the
chloride content of water is high, this would add an error
into the incoming stream which may not be considered.
Note that the stack gases were sampled at two locations,
one directly beyond the silencer in the Location 7. This
was used for the monitors measuring oxygen and carbon
dioxide with portable monitors. CO is also analyzed at
this location using a continuous recorder. At Location 8
the flow rate was measured as needed by a stack
emission test as well as the Orsat for measuring
moisture. Method 5 tests were also run to measure
particulates and HCI levels. It is recommended that a
schematic such as this be included with any Trial Burn
Plan. This ensures not only that the sampling contractor
understands what is required with regard to the sampling
program, both for wastes, ash: scrubber discharge and
stack emissions, but also ensures that the process data
are obtained for all flow measurements, temperature
measurements, pressure measurements, etc. It serves as
a good check tool for the consultant supervising the Trial
Burn. It also provides the inspection agency with
information so that they will have it available during the
Trial Burn proper.
The Eastman Kodak report includes the results of ORE,
HCI removal and particulates. The final permit limit
summaries include the limits of temperature for both the
kiln and secondary chamber with the waste feed cut-off
points necessary based on the temperature drops in
either chamber. This waste feed cut-off establishes when
the liquid waste is cut and when the solid wastes are cut.
The permit limit also sets a maximum amperage on the
combustion gas flow based on the horsepower level of
the I.D. fan. The carbon monoxide level which had
initially been established with a permit limit of 120 ppm
was later changed to a level of 90 ppm where the
average condition of 128 ppm indicated a ORE level of
99.98995% for acetonitrile. It was decided between the
Eastman Kodak people and the New York DEQ that 90
ppm be established as the limit for carbon monoxide.
Note that two stages of hazardous waste feed shutdown
should occur based on the rolling 1 hr average limit of 90
ppm. If the rolling average CO exceeds 90 ppm at any
time, the containerized solid waste system shall shut
down automatically and remain shut down until the
average rolling CO has dropped below 90 ppm for 15
minutes. All hazardous wastes should automatically shut
down if the rolling average CO exceeds 90 ppm for 15
minutes. This includes not only the solid wastes but also
the liquid wastes. However, once the rolling hour CO has
dropped below 90 ppm for at least 15 minutes, the liquid
hazardous waste feed may then be resumed. Solid waste
may then be resumed 15 minutes later providing the CO
level remains below 90 ppm. An instantaneous level of
1000 ppm was established as a condition which would
automatically prevent feeding any containerized solid
waste.
With regard to the particulate load to the scrubber, a
maximum ash content in the liquid waste was
established at 3%. The solid waste loading limit was
variable depending on the type of solid waste. In the
event of a finely divided inorganic solids such as
diatomaceous earth and sodium chloride salt, no more
than 20 packs per hour could be fed to the incinerator.
The normal rate of containerized solid waste allowed has
been 45 packs per hour; however, with the finely divided
inorganic solids, a high particulate loading can be
generated since the ash can be airborne.
Summary
The above case study covers in detail the results of the
installation at the Eastman Kodak Plant in Rochester, NY.
It points out the importance of good communications
between the incinerator operator and the regulatory
agency. It also points out the importance of a
concentrated Mini-Burn schedule to ensure that all
problems that can occur during a Trial Burn can be
minimized by proper design of the Trial Burn and also
proper selection, maintenance and calibration of the
equipment. The total elapsed time for the Part "B" permit
approval was about 29 months. After the Trial Burn was
completed, about 3 months was needed to get a report
from the analytical firm on all of the analyses taken
during the Trial Burn. This was submitted to the agency
and about 14 months later the final permit for the Part
"B" was issued. Delays occurred due to the review of the
Trial Burn reports and modifications of the permit
conditions by the permitting agency. This, of course,
required negotiations between the two parties to come to
a final decision. One of the problems that did occur was
the change of permit writers during this overall submittal
period.
The major result of the entire review of this case study
points out the need for communications right from the
start in the planning stages with the incinerator operator
and the agency. Also important is that communications
continue throughout the program between the supervisor
of the Trial Burn, the operating department of the plant,
the maintenance and instrumentation sections of the
plant, as well as the sampling personnel. Good
coordination is required by all parties and again,
continued communications with the permitting agency.
61
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Permit Writer's Guide to Test Burn Data
By
M. Pat Esposito
PEI Associates, Inc.
Cincinnati, Ohio
Abstract
The PERMIT WRITER'S GUIDE TO TEST BURN DATA is a
new guidance document prepared by the Environmental
Protection Agency's (EPA) Center for Environmental (
Research Information for use in the permitting and
testing of hazardous waste incinerators regulated under
the Resource Conservation and Recovery Act (RCRA).'
Results from hazardous waste test burns conducted in
the U.S. at 23 full-scale stationary incinerators are j
summarized.1"3 In addition to the incinerator test burn
data, the book also contains results of test burns at 11
U.S. lime, cement, and aggregate kilns, and 9 industrial
boilers/'17
This is the first time that a data book containing results
from a wide variety of combustion tests has been
assembled. The document is a beneficial source of
information for those involved in the planning, execution,
and evaluation of hazardous waste trial/test burns, and
should be used in conjunction with other E PA guidance
documents on hazardous waste incineration.
Introduction
The Resource Conservation and Recovery Act (RCRA)
requires that hazardous waste incinerators adequately
destroy hazardous organic compounds while maintaining
acceptable levels of particulate and chloride (HCI)
emissions. Owners and operators of these incinerators
must demonstrate the acceptable performance of the
facility by means of a trial burn. Consequently, industry
and control agency personnel have become involved in
planning for, conducting, and interpreting the results
from trial burns as an integral part of the RCRA
permitting process.
In an effort to assist the RCRA permitting process, the
E PA has prepared this test burn data book as a reference
document for use in reviewing trial burn plans for
hazardous waste incinerators and other thermal
treatment devices that are now or may soon be regulated
under RCRA. The book summarizes the results from
hazardous waste test burns conducted at 23 full-scale
stationary incinerators in the United States. Nine of these
test burns were designed and conducted by the E PA and
its contractors as part of E PA's Regulatory Impact
Analysis of the RCRA incinerator regulations. The other
14 were conducted separately and individually by private
industrial concerns and their contractors as part of their
Part B application requirements for obtaining full
operating permits under RCRA.
In addition to the incinerator data, the book also contains
data from hazardous waste test burns at 11 lime,
cement, and aggregate kilns and 9 industrial boilers in
the United States. The E PA conducted these tests as part
of an overall research program aimed at determining the
efficiency of these thermal units for cofiring (and thereby
destroying) hazardous wastes as fuel supplements or
replacements. The practice of substituting hazardous
wastes for fossil fuels in kilns and boilers is currently
exempt from RCRA regulation, but this situation may
change as more is learned about the overall effect of
typical kiln and boiler operating conditions on various
waste-oriented performance parameters, such as waste
destruction and removal efficiencies, chloride and
particulate emissions, and the formation of unwanted
byproducts of combustion.
Basic data derived from each completed test burn
involving the burning of hazardous wastes are presented
on summary forms similar to that shown in Figure 1. The
forms include information on the type of thermal unit
tested, composition of the waste feed, operating
conditions during each run, monitoring methods, and
emission results. Baseline tests in which only auxiliary
fuels or nonhazardous wastes were burned are not
reported. Also, test runs which were aborted due to
operational or sampling problems are not reported.
Summary and Analysis of Incinerator
Performance Data
Analysis of available test data from 23 separate
incinerators located throughout the United States yielded .
data on 57 different POHCs tested during 126 different
runs for a total of 534 POHC/test run combinations. A
complete tabulation of key data from these 534 POHC/
test runs can be found in Table 1. This table can be used
to quickly identify POHC ORE results, POHC
concentrations tested, temperatures tested, and
questionable test data. When used in combination with
other tables presented in the report, this listing can be
useful in studying performance relative to various types
62
-------
Incinerator Trial Burn Summary
Date of Trial Burn:
Run No.:
Incinerator Information:
Type of unit: __
Capacity:
Pollution control system:
Waste feed system:
Residence time:
Commercial: ;D
Trial Burn Conditions:
Waste feed data:
Type of waste(s) burned:
Private/industrial: D
Length of burn:
Total amount of waste burned:
Waste feed rate:
POHC's selected and concentration in waste feed:
Name Concentration
Btu content:
Ash content:
Operating Conditions:
Temperature: Range .
Auxiliary fuel used:
Chlorine content:
Moisture content:
Average _
Excess air:
Other:
Monitoring Methods:
POHC's:
Cl: ! _
Particulate:
Other:
Emission and ORE Results:
POHC's:
Cl:
Particulate:
THC:
CO:
Other:
PIC's:
Reference(s):
Comments:
Figure 1. Example data summary form.
cif incinerators, various types of wastes, or controlled/
uncontrolled conditions.
DREs for all of the incinerators tested were generally
above 99.99 percent. Since the operating conditions
monitored during the majority of the E PA tests were
those selected by the plants as their normal conditions, it
can be concluded that operating incinerators will
generally obtain an overall performance level of 99.99
percent ORE or better.
Although all of the sites reported ORE successes, nine
also reported periodic ORE failures. Though almost all
POHCs were tested successfully (i.e., greater than or
equal to 99.99 percent ORE) in one or more tests, more
than one-third of the POHCs also had some unsuccessful
tests (less than 99.99 percent ORE). The principal
reasons believed responsible for these ORE failures are
low POHC concentrations in the waste feed (i.e., <1000
pprn) and detection limitatipns inherent in the sampling
and analysis methods. Such limitations often precluded
the mathematical calculation and demonstration of 4-9's
ORE, even though in reality such a level of destruction
and removal may have been achieved. Low temperature
also may have been a significant factor in some ORE
failures. Overall, the data show that about 80 percent of
the failures occurred when the POHC concentration in
the waste feed was less than 0.1 percent (less than 1000
ppm) or the temperature was less than 2000°F.
Another factor identified as having negative impact on
ORE involves choosing as POHCs those compounds that
are also likely to be present as PICs in the stack gases.
Several compounds have been previously identified as
PICs; examples include chloromethanes, toluene,
benzene, chlorobenzenes, and napthalene. The formation
of these compounds during the incineration process
would tend to increase their concentration in the stack
gas, resulting in apparently lower DREs. In fact, many of
the failures noted in Table 1 occurred when these types
of compounds were chosen as POHCs.
Eight of the E PA tests and at least one of the trial burn
tests investigated POHC levels in scrubber water and
ash; the results show that POHC levels in these media
are generally very low or nondetectable. These data
suggest that the majority of POHCs are destroyed rather
than merely transferred to another media in the
incineration process.
Some Appendix VIII compounds detected in the stack
(primarily trihalomethanes) appear to be stripped from
the scrubber water by the hot stack gas. In the E PA tests,
trihalomethanes detected in the scrubber inlet waters
frequently were not detected in the effluent waters.
Often, compounds of this type are used in scrubber
waters to control microbial growth. When such
compounds are chosen as POHCs, the result can be
lower measured/calculated DREs even though the
destruction mechanisms may not have been affected.
Recent guidance from E PA-HQ states that all POHCs in
the exhaust gases, including any POHCs that may be
stripped from the scrubber, should be included in ORE
calculations.17
63
-------
Table 1. Summary Tabulation of Incinerator Test Results by POHC
SITE
MCDONNELL DGLS
MCDONNELL DGLS
MCDONNELL DGLS
MCDONNELL DGLS
STAUFFER CHEMICAL
STAUFFER CHEMICAL
STAUFFER CHEMICAL
STAUFFER CHEMICAL
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
DOW CHEMICAL
DOW CHEMICAL
TWI
DUPONT-LA
TWI
TWI
TWI
TWI
TWI
TWI
TWI
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
3M
3M
3M
3M
3M
3M
3M
3M
3M
3M
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UPJOHN
UPJOHN
UPJOHN
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
AMERICAN CYANAMID
AMERICAN CYANAMID
AMERICAN CYANAMID
AMERICAN CYANAMID
UPJOHN
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
UPJOHN
UPJOHN
STAUFFER CHEMICAL
STAUFFER CHEMICAL
STAUFFER CHEMICAL
STAUFFER CHEMICAL
POHC
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1, ,1 trichloroethane
1,1,1 trichloroethane
1,1,1 trichloroethane
1,1,1 trichloroethane
1,1,1 trichloroethane
1,1,1 trichloroethane9
1,1,1 trichloroethane8
1,1.1 trichloroethane8'11
1.1.1 trichloroethane8'"
1,1,1 trichloroethane0
1,1,1 trichloroethane*"
1,1,1 trichloroethane0
1.1,1 trichloroethane8
1.1,1 trichloroethane8'11
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,1, 2 trichloroethane
1,1,2 trichloroethane
1,1,2 trichloroethane
1,2 dichlorobenzena
1,2 dichlorobenzene
1,2 dichlorobenzena
1,2 dichlorobenzene
1,2 dichlorobenzene
1,2 'dichlorobenzene
1,2 dichlorobenzene
1,2 dichlorobenzene
1,2 dichlorobenzene
1,2 dichlorobenzene
1,2 dichlorobenzene
1,2 dichlorobenzene
1,2,4 trichlorobenzene
1,2,4 trichlorobenzene
1,2,4 Trichlorobenzene
2,4 dimethylphenol
2,4 dimethylphenol
2.4 dimethylphenol
aniline"
aniline0'*
anilinec>*
aniline0-*
aniline0
aniline
aniline
aniline
aniline0
aniline0
benzene
benzene
benzene
benzene
POHC
CONC,%*
71
70
62
59
0.88
0.87
0.82
0.83
2.55
0.91
0.58
0.00792
0.001
0.016
0.0123
0.0105
0.0087
0.0051
0.011
0.0162
0.038
0.035
0.028
1.631
1.566
1.304
1.066
0.937
1.771
1.3
1.225
0.548
1.239
24
1.6
1.7
1.5
1.4
1.4
2.2
2/1
1.3
1.4
5
1.2
0.027
0.039
0.029
0.071
0.02
0.02
60
53
' 55
0.8
c
0.026
0.026
0.021
c
c
4.68
4.53
4.47
4.65
DRE,%*
99.99999
99.99999
99.99999
99.99999
99.99998
99.99998
99.99998
99.99998
99.99952
99.999
99.999
99.998
99.996
99.966
99.932
99.88
99.87
99.86
99.84
99.82
99.81
99.47
99.99999
99.99999
99.99999
99.999
99.999
99.999
99.999
99.999
99.998
99.998
99.998
99.994
99.99
99.99994
99.99992
99.9999
99.9999
99.9999
99.99986
99.99985
99.99985
99.99957
99.99933
99.99923
99.99921
99.65
99.75
98.6
99.9994
99.9992
99.999
99.99999
99.99999
99.99999
99.9997
99.9988
99.998
99.998
99.998
99.9988
99.981
100
100
100
99.99999
TEMP,
°F
1800
1800
1800
1800
1830
1830
1830
1830
2110
2090
2040
1810
1820
2080
2640
2230
2140
2070
2050
1810
2030
2120
2040
2110
2090
1890
1985
1905
1885
1915
1930
1925
2030
1985
1950
1600
1800
1600
1600
1800
1800
1600
1600
1800
1800
1600
1800
2040
2040
2040
2040
2110
2090
1198
1198
1240
1254
2040
2110
2040
2090
2040
2040
1830
1830
1830
1830
HCL,
Ib/h
0.8
0.74
1.64
1.67
99.9
99.9
99.9
99.9
0.1
0.3
0.3
99.9
99.9
0.3
0.5
h
h
0.6
h
0.2
0.4
h
0.3
0.1
0.3
0.8
0.2
0.3
0.4
0.5
1.2
0.7
0.44
0.9
0.48
98.9
98.2
98.6
98.1
98.4
97.9
98.9
98.5
98.3
98.2
98.2
98.5
0.9
1.7
1.2
0.3
0.1
0.3
0.007
0.007
0.004
0.007
1.2
0.1
0.3
0.3
1.2
1.7
99.9
99.9
99.9
99.9
YSP,
gr/dsdb
6.632
0.032
0.044
0.047
0.001
0.00:2
0.0009
0.003
0.061
0.077
0.061
0.075
0.0115
h
h
0.048
h
0.044
0.127
h
0.061
0.061
0.077
0.08
0.091
0.047
0.0413
0.047
0.154
0.070
0.084,3
0.0623
0.112
0.066
0.075
O.OSii
0.073
0.064
0.07
0.04U
0.057
0.061
0.071
0.094
0.05(5
0.09-1
0.013
0.08
0.061
0.061
0.077
0.069
0.17J5
0.07J5
0.007
0.08
0.061
0.061
0.077
0.08
0.013
0.003
0.002
0.001
0.0009
"TEST
No.
2
4
3
1
7
6
4
5
1
2
3
10212-2
10212-1
1
1
6
SB
3
7
4
2
8A
3
1
2
10
4
6
7
5
8
9
3
1
2
7
6
11
2
12
3
8
9
5
4
1
10
2
4
3
3
1
2
3
5
2
4
3
1
3
2
3
4
5
6
7
4
SPONSOR
Private
Private
Private
Private
Private
Private
Private
Private
EPA
EPA
EPA
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
64
-------
Table 1. (continued)
SITE
TWl
TW1
TWl
TWl
TWl
TWl
TWl
MITCHELL SYSTEMS
TWl
MITCHELL SYSTEMS
DUPONT-LA
DUPONT-LA
DUPONT-LA
MITCHELL SYSTEMS
MITCHELL SYSTEMS
MITCHELL SYSTEMS
TWl
TWl
TWl
TWl
UPJOHN
UPJOHN
UPJOHN
CINCINNATI MSD
CINCINNATI MSD
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
MITCHELL SYSTEMS
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
MITCHELL SYSTEMS
MITCHELL SYSTEMS
CONFIDENTIAL SITE B
STAUFFER CHEMICAL
MCDONNELL DGLS
STAUFFER CHEMICAL
STAUFFER CHEMICAL
STAUFFER CHEMICAL
MCDONNELL DGLS
MCDONNELL DGLS
DUPONT-DE
DUPONT-DE
DUPONT-DE
MCDONNELL DGLS
DUPONT-DE
DUPONT-DE
DUPONT-DE
CINCINNATI MSD
DUPONT-LA
DUPONT-LA
DUPONT-LA
DUPONT-DE !
ZAPATA INDUSTRIES
TWI ;
3M
3M
3M
3M
3M
3M
ZAPATA INDUSTRIES
3M
3M
CINCINNATI MSD
DOW CHEMICAL
POHC
benzene11
benzene11
benzene
benzene11
benzene1*
benzene
benzene
benzene"
benzene
benzene8
benzyl chloride
benzyl chloride
benzyl chloride
bis(etnyl hexyiphthalate'
bisjethyl hexyiphthalate0
bisjethyl hexy)phthalatec
bisjethyl hexyiphthalate0'8
bisjethyl hexy)phthalatec'a
bisjethyl hexyjphthalate0'0
bis(ethyl hexylphthalate"'8
bis(ethyl hexy)phthalatec
bis(ethyl hexy)phthalatec
bis(ethy) hexyjphthalate0
bromodichloromethane
bromodichloromethane
butyl benzyl phthalate
butyl benzyl phthalate
butyl benzyl phthalate0
butyl benzyl phthalate
butyl benzyl phthalate8
butyl benzyl phthalate9
butyl benzyl phthalate0
butyl benzyl phthalate8
butyl benzyl phthalate8
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride c
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
POHCvi
CONC,%*
2.91
3.24
1.52
2.54
2.52
1.18
0.889
0.0116
1.43
0.0067
0.233
0.211
0.219
0.192
0.416
0.169
0.0051 1
0.00429
0.00574
0.00261
0.05
0.13
0.05
0.4
0.28
0.1
0.027
0.017
0.169
0.0227
0.0149
0.00758
0.0064
0.00416
0.89
8.9
0.82
0.85
0.84
7.5
8.1
9.4
9.2
9.3
8.9
8.7
7.5
8.8
0.26
5.38
6.16
5.27
7.7
0.73
0.379
1.068
1.031
1.021
0.99
0.868
0.623
0.61
0.596
0.482
0.16
DRE.%*'
99.99979
99.99952
99.9983
99.995
99.99
99.989
99.988
99.986
99.984
99.82
99.9996
99.9996
99.9994
99.9985
99.996
99.993
99.96
99.951
99.94
99.88
99.98
99.98
99.95
99.995
99.97
99.9996
99.999
99.998
99.995
99.9938
99.9923
99.992
99.973
99.92
99.99998
99.99998
99.99998
99.99998
99.99998
99.99997
99.99996
99.99994
99.99994
99.99993
99.99992
99.99992
99.99992
99.99991
99.9999
99.99988
99.99986
99.99981
99.9994
99.99911
99.99903
99.999
99.999
99.999
99.999
99.999
99.999
99.999
99.999
99.999
99.999
99.999
TEMP,
°F
2140
2120
2080
2050
2230
2030
1810
2000
2070
2050
2640
2640
2640
1930
1975
2000
2030
2080
2070
1810
2040
2040
2040
2400
1650
2110
2040
2090
2000
1952
1952
1930
1975
1952
1830
1800
1830
1830
1830
1800
1800
1831
1842
1864
1800
1833
1906
1826
2400
2640
2640
2640
1857
1600
1810
1985
1950
1890
1930
2030
1905
1550
1885
1915
1650
1860
HCL,
lb/hb
h
h
0.3
h
h
0.4
0.2
4.9
0.6
f
0.6
0.5
0.9
4.1
3.8
4.9
0.4
0.3
0.6
0.2
0.9
1.7
1.2
60.9
5
0.1
0.3
0.3
4.9
0.64
4.47
4.1
3.8
1.83
99.9
1.64
99.9
99.9
99.9
0.8
1.67
2.6
1.3
1.2
0.74
0.6
0.1
1.7
6.1
0.6
0.5
0.9
1.1
1.4
0.2
0.2
0.48
0.8
1.2
0.44
0.3
2.8
0.4
0.5
3.7
99.4
TSP.
gr/dscf
h
h
0.075
h
h
0.127
0.044
0.313
0.048
1
0.004
0.015
0.011
0.491
0.378
0.313
0.127
0.075
0.048
0.044
0.094
0.013
0.08
0.444
0.107
0.061
0.061
0.077
0.313
f
0.161
0.491
0.378
0.187
0.002
0.044
0.0009
0.001
0.003
0.032
0.047
i
f
0.079
0.032
0.08
0.055
1
f
0.004
0.015
0.011
0.071
0.022
0.044
0.091
0.112
0.08
0.154
0.0848
0.047
0.036
0.048
0.047
i
"TEST
No.
8B
8A
1
7
6
2
4
2
3
3
2
1
3
1
4
2
2
1
3
4
2
4
3
9
7
1
3
2
2
1
3
1
4
2
6
3
4
7
5
2
1
3
7
6
4
4
2
5
3
2
1
3
1
2
4
4
2
10
8
3
6
3
7
5
4
11302-2
SPONSOR
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
EPA
EPA
EPA
Private
EPA '
EPA
Private
Private
Private
Private
Private
Private
EPA
Private
Private
EPA
Private
65
-------
Table 1. (continued)
SITE
TO!
TWI
MITCHELL SYSTEMS
TWI
TWl
MITCHELL SYSTEMS
3M
3M
ZAPATA INDUSTRIES
MITCHELL SYSTEMS
TWI
ROSS INCINERATION
ROSS INCINERATION
DOW CHEMICAL
ROSS INCINERATION
UPJOHN
TWI
CINCINNATI MSD
UPJOHN
UPJOHN
CONFIDENTIAL SITE B
TWI
MITCHELL SYSTEMS
CONFIDENTIAL SITE B
ZAPATA INDUSTRIES
CONFIDENTIAL SITE B
CINCINNATI MSD
CONFIDENTIArsriFB
CINCINNATI MSD
CONFIDENTIAL SITE B
TWI
TWI
TWI
UNION CARBIDE
UNION CARBIDE
CI8A-GEIGY
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
CIBA-GEIGY
UNION CARBIDE
CIBA-GEIGY
UNION CARBIDE
CIBA-GEIGY
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
ZAPATA INDUSTRIES
CIBA-GEIGY
ZAPATA INDUSTRIES
ZAPATA INDUSTRIES
ZAPATA INDUSTRIES
TWI
TWI
TWI
TWI
TWI
UPJOHN
UPJOHN
TWI
TWI
TWI
SMITH KLINE CHEM
SMITH KLINE CHEM
SMITH KLINE CHEM
POHC
carbon tetrachloride0'"
carbon tetrachloride0
carbon tetrachloride0
carbon tetrachloride0
carbon tetrachloride0
carbon tetrachloride0
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride0
carbon tetrachloride'1'1'
carbon tetrachloride
carbon tetrachloride
carbon letrachlorido
carbon tetrachloride
carbon tetrachloride
carbon tetrachloride0'1'
carbon tetrachloride
carbon tetrachlorido
carbon tetrachloride
carbon tetrachlorido0
carbon tetrachloride0'11
carbon tetrachlorido0
carbon tetrachloride0
carbon tetrachlorida
carbon tetrachlorida0
carbon tetrachloride
carbon tetrachloride0''
carbon tetrachloride
carbon tetrachloride0'1
chlordane
chlordane
chlordane
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene
chlorobenzene01''
chlorobenzene0111
chlorobenzene0
chlorobenzene0
chlorobenzene0
chlorobenzene
chlorobenzene
chlorobenzena0il<
chlorobenzene0
chlorobenzene0'1*
chloroform
chloroform
chloroform
POHC
CONC.%"
0.377
0.277
0.243
0.198
0.228
0.263
0.881
0.524
0.28
0.242
0.53
0.16
0.21
0.2
4.4
0.44
0.22
3.6
4.4
0.132
0.209
0.223
0.163
1>2
0.142
0.11
0.12
0.23
0.118
0.736
0.66
0.462
1.8
1,7
29.52
1.9
1.4
2
1r8
29.52
1t6
29;52
1.6
29.52
2,7
2.7
2.6
i[s
0.4
29^52
0.79
0.78
0.76
0.0167
0.0184
0.0047
0.00858
0.00956
0.68
0.41
0.0152
0.0102
0.0174
1.21
1,1
0.93
DRE,%'
99.9987
99.9987
99.9984
99.9984
99.9983
99.9981
99.998
99.998
99.9972
99.997
99.9966
99.9964
99.9961
99.996
99.9959
99.9954
99.9951
99.995
99.994
99.9931
99.9928
99.9926
99.984
99.984
99.978
99.976
99.96
99.949
99.9
99.63
99.9999
99.9999
99.9998
99.99979
99.99979
99.9997
99.99962
99.99961
99.99959
99.99952
99.9995
99.99949
99.9994
99.99935
99.9992
99.99907
99.99907
99.9988
99.9987
99.9983
99.998
99.9974
99.9956
99.9953
99.9949
99.978
99.966
99.965
99.956
99.945
99.86
99.73
99.7
99.6
99.99999
99.99999
99.99999
IfcMP.
°F
2050
2070
1975
2080
2030
2000
1925
1985
1660
1930
2120
2110
2090
1830
2040
2040
2140
1650
2040
2040
1952
2230
2050
1952
1570
1952
2000
1776
2400
2070
2030
2080
1800
1800
1800
1600
1600
1600
1800
1800
1800
1800
1800
1800
1600
1600
1600
1800
1660
1800
1550
1570
1600
2140
2120
1810
2080
2070
2040
2040
2050
2030
2230
1640
1620
1710
HCL.
lb/hb
h
0.6
3.8
0.3
0.4
4.9
0.7
0.86
3.3
4.1
h
0.1
0.3
99.7
0.3
1.7
h
1.9
0.9
1.2
1.83
h
f
0.64
2.2
4.47
7.8
h
89.7
h
0.6
0.4
0.3
97.9
98.4
99.9
98.1
98.2
98.6
98.2
99.9
98.2
99.9
98.3
99.9
98.9
98.9
98.5
98.5
3.3
99.9
2.8
2.2
1.4
h
h
0.2
0.3
0.6
1.7
1.2
h
0.4
h
0.6
0.2
0.6
TSP,
gr/dsd
h
0.048
0.378
0.075
0.127
0.313
0.078
0.0623
0.017
0.491
h
0.061
0.077
0.061
0.013
h
f
0.094
0.00
0.187
h
f
f
0.03
0.161
0.056
h
»
h
0.048
0.127
0.075
0.07
0.064
0.21
0.073
0.094
0.055
0.071
0.14
0.075
0.2
0.061
0.1SJ
0.066
0.048
0.057
0.056
0.017
0.14
0.036
0.03
0.022
h
h
0.044
0.075
0.048
0.013
0.0(11
h
0.127
h
0.057
0.027
0.03
TESt
No.
7
3
4
1
2
2
9
1
4
1
8A
1
2
11302-3
3
4
8B
1
2
3
2
6
3
1
1
3
5
4
6
5
3
2
1
3
12
1
2
1
11
4
3
6
2
5
4
7
8
9
10
4
5
3
1
2
8B
8A
4
1
3
4
3
7
2
6
6
7
8
SPONSOR
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
EPA
EPA
EPA
EPA
EPA
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
66
-------
Table 1. (continued)
SITE
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
DUPONT-LA
DUPONT-LA
DUPONT-LA
TWI
TWI
TWI
CONFIDENTIAL SITE B
TWI
TWI
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
TWI
TWI :
TWI
CONFIDENTIAL SITE B
UPJOHN
UPJOHN
UPJOHN
UPJOHN
DUPONT-LA
DUPONT-LA
DUPONT-LA
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
TWI
TWI
TWI
TWI
TWI
TWI
TWI
TWI
OLIN
ODN
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
PENNWALT
PENNWALT
PENNWALT
PENNWALT
PENNWALT
PENNWALT
PENNWALT
DUPONT-DE
DUPONT-DE
DUPONT-OE
DUPONT-DE
DUPONT-DE
DUPONT-DE
DUPONT-LA
DUPONT-LA
DUPONT-DE
DUPONT-LA
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
TWI
ZAPATA INDUSTRIES
TWI
POHC
chloroform
chloroform
chloroform
chloroform
chloroform
chloroform
chloroform
chloroform
chloroform0'"
chloroform0'8-"
chloroform0'8'"
chloroform0'"
chloroform0'"
chloroform0'"
chloroform0'"
chloroform0'"''
chloroform0'*
chloroform0'"-"
chloroform0'8'"
chloroform0'8
chloroform0'8-'
chloromethane0
chloromethane0
chloromethane0
chlorophenyl isocyanata
cis-dichlorobutene
cis-dichlorobutene
cis-dichlorobutene
cresol(s)
cresol(s)
cresol(s)
dibromomethane"
dibromomethane"
dibromomethane
dibromomethanek
dibromomethane
dibromomethane"
dibromomethane
dibromomethane
dichlordiflucrmethane
dichlordifluormethane
dichlorobenzene
dichlorobenzene
dichlorobenzene
dichlorofluoroethane
dichlorofluoroethane
dichlorofluoroethane
dichlorofluoroethane
dichlorofluoroethane
dichlorofluoroethane
dichlorofluoroethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane
dichloromethane0
dichloromethane0
dichloromethane0
dichloromethane0
dichloromethane
dichloromethane8'"
HOHC .
CONC,%"
1.32
1.72
1.09
1.8
1.2
0.33
0.404
0.229
0.00224
0.00476
0.00443
0.0074
0.00201
0.00654
0.0154
0.00428
0.0102
0.0082
0.00478
0.00283
0.00725
>0.2
>0.19
>0.12
2.8
1.76
1.39
1.63
0.12
0.091
0.074
0.326
0.292
0.0244
0.319
0.159
0.322
0.172
0.126
5
5
0.11-0.17
0.09-0.15
0.05-0.15
17.6
15.1
15
14.5
9.2
3.9
10.2
6.7
6.1
8
7.1
5.6
4.6
1.71
1.61
7.7
1.89
0.67
0.36
0.23
0.00627
0.017
0.00881
DRE,%'
99.9997
99.9995
99.9989
99.998
99.998
99.9938
99.9914
99.987
99.944
99.92
99.88
99.86
99.8
99.78
99.7
99.69
99.66
99.1
99.02
98.2
97.9
99.9986
99.9975
99.9952
99.9991
99.99998
99.99998
99.9999
99.9993
99.9991
99.999
99.99992
99.99981
99.9987
99.9936
99.982
99.974
99.964
99.956
99.99
99.99
99.998
99.996
99.99
99.999
99.999
99.999
99.999
99.999
99.997
99.995
99.9999
99.9998
99.9997
99.9997
99.9997
99.9997
99.99941
99.9991
99.999
99.9988
99.989
99.978
99.968
99.918
99.906
99.9
ItMP,
°F
" 1650
2400
2000
2400
1650
2640
2640
2640
2080
2140
2120
1952
2070
1810
1952
1776
1952
2230
2050
2030
2040
2040
2040
2040
2640
2640
2640
2110
2040
2090
2140
2120
2080
2050
1810
2230
2070
2030
2088
2095
2400
1650
2000
2320
2370
2260
2340
2380
2340
2350
1864
1826
1833
1831
1906
1842
2640
2640
1857
2640
2090
2040
2110
2080
1600
2140
HCL,
Ib7hb
3.7
6.1
7.8
89.7
1.9
0.5
0.9
0.6
0.3
h
h
1.83
0.6
0.2
0.64
h
4.47
h
h
0.4
h
0.9
1.7
1.2
1.7
0.9
0.6
0.5
0.1
0.3
0.3
h
h
0.3
h
0.2
h
0.6
0.4
0.7
1.2
60.9
5
16
1.3
1.4
0.72
1
0.9
1.1
1
1.2
1.7
0.6
2.6
0.1
1.3
0.5
0.6
1.1
0.9
0.3
0.3
0.1
0.3
1.4
h
TSP,
gr/dscf
f
0.123
0.056
f
f
0.015
0.011
0.004
0.075
h
h
0.187
0.048
0.044
f
h
0.161
h
h
0.127
h
0.094
0.013
0.08
0.013
0.011
0.004
0.015
0.061
0.061
0.077
h
h
0.075
h
0.044
h
0.048
0.127
0.052
0.031
0.444
0.107
0.68
0.006
0.006
0.044
0.007
0.005
0.036
0.014
0.079
f
0.08
f
0.055
f
0.015
0.004
0.071
0.011
0.077
0.061
0.061
0.075
0.022
h
Itiil
No.
4
3
5
6
1
1
3
2
1
8B
8A
2
3
4
1
4
3
6
7
2
5
2
4
3
4
3
2
1
1
3
2
8B
8A
1
7
4
6
3
2
2a.b,c
3a,b.c
9
7
8
22-3
23-2
22-4
23-3
23-1
22-1
22-2
6
5
4
3
2
7
1
2
1
3
2
3
1
1
2
88
SPONSOR
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private .
Private
EPA
EPA
EPA
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
EPA
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
67
-------
Table 1. (continued)
SITE
TW1
TWI
TWI
TW1
TWI
TWI
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
AMERICAN CYANAMID
AMERICAN CYANAMID
AMERICAN CYANAMID
AKZO CHEMICAL
DUPONT-WV
DUPONT-WV
AKZO CHEMICAL
AKZO CHEMICAL
DUPONT-WV
AKZO CHEMICAL
AKZO CHEMICAL
AKZO CHEMICAL
AKZO CHEMICAL
AKZO CHEMICAL
AKZO CHEMICAL
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
TWI
TWI
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
TWI
TWI
TWI
CINCINNATI MSD
CINCINNATI MSD
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CIBA-GEIGY
CIBA-GEIGY
CIBA-GEIGY
CIBA-GEIGY
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
CIBA-GEIGY
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
POHC
dichloromethane
dichloromethane8'"
dichloromethane0
dichloromethane9
dichloromethane0'11
dichIoromethaneB>
diethyl phlhalate
dielhyl phthalate
diethyl phthalate
diphenyl amine*
diphenyl amine*
diphenyl amine*
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
formaldehyde
hexachlorobenzena8
hexachlorobenzene8
hexachlorobenzene9
hexachlorobenzene0
hexachlorobenzena0
hexachlorobenzena0
hexachlorobutadiene"
hexachlorocyclopentadiene
hexachlorocyclopentadiene
hexachlorocyclopentadiene
hexachlorocyclopentadiene
hexachlorocyclopentadiene
hexachlorocyclopentadiene0
hoxachlorocyclopentadiene0
hexachlorocyclopentadiene0
hexachlorocyclopentadiene0
hexachlorocyclopentadiene0
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroelhane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroelhane
hexachloroethane
hexachloroethane
hexachloroelhane
hexachloroethane
hexachloroethane
hexachloroethane
hexachloroethaneo
hexachloroethane"
hexachloroelhane0
hexachloroethane
hexachloroolhane
hexachloroethane"
hexachlorpelhane9
POHC
CONC.%'
0.021
0.00832
0.00762
0.0116
0.0109
0.013
0.0572
0.0524
0.037
0.58
0.54
0.62
10.'03
9.7
10
10.01
10J24
7J5
10.2
10.14
10J01
10J09
10:09
10:05
<0.01 -0.016
<0.01-0.01
<0.0140.016
0.01-0.026.
0.01
0.01
0.0144
0.693
0.37-0.56
0.24-1.6
• 0.25^0.71
0.069-0.76
0.00956
0.00786
0.0066
0.01-1.2
0.009-0.31
6.4
2.8
2.7
2.7
2J1
2
2
1.8
1.8
1.7
1.6
1.5
0.21^0.47
0.22-0.77
0.14^0.75
4.87
4.87
4.87
4.87
0.01-0.023
0.01-0.019
0.01-6.014
4.87
0.011^0.020
0.01-6.018
0.01-0.015
DRE,%"
99.88
99.83
99.71
99.63
99.53
99.51
99.974
99.962
99.943
99.9992
99.9992
99.999
99.998
99.998
99.997
99.996
99,995
99.995
99.993
99.993
99.993
99.992
99.992
99.992
99.993
99.993
99.99
99.99
99.99
99.99
99.98
99.9996
99.999
99.998
99.996
99.996
99.99
99.99
99.99
99.97
99.96
99.99997
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999
99.9999-
99.9997
99.9996
99.999
99.998
99.997
99.997
99.995
99.994
99.993
99.992
99.992
99.99
99.99
99.99
TEMP.
°F
2070
2120
2030
1810
2050
2230
1952
1952
1952
1198
1198
1240
1650
T701
1729
1620
1830
1735
1830
1780
1830
1780
1780
1630
2400
1650
2000
2400
1650
2000
1810
1810
1650.
2400
2000
2000
2070
2030
2080
2400
1650
1600
1600
1600
1600
1600
1600
1800
1800
1800
1800
1800
1800
2400
1650
2000
1800
1800
1800
1800
2400
2000
1650
1800
2400
2000
1650
HCL.
lb/hb
0.6
h
0.4
0.2
h
h
4.47
0.64
1.83
0.007
0.007
0.004
d
h
h
d
d
h
d
d
d
d
d
d
89.7
3.7
0.8
6.1
1.9
7.8
0.2
0.2
1.9
6.1
7.8
0.8
0.6
0.4
0.3
89.7
3.7
98.2
98.9
98.9
98.5
98.6
98.1
98.2
97.9
98,2 „
98.4
98.3
98.5
60.9
5
16
99.9
99.9
99.9
99.9
" 89.7
0.8
3.7
99.9
6.1
7.8
1.9
TSP.
gr/ds.cf
0.048
h
0.127
0.044
h
h
0.161
1
0.187
0.069
0.175
0.075
0.052
0.017
0.017
0.037
0.041
0.018
0.043
0.04
0.04
0.048
0.04
0.03
f
f
0.123
f
f
0.056
0.044
0.044
f
f
0.056
0.123
0.048
0.127
0.075
f
f
0.094
0.048
0.066
0.057
0.055
0.073
0.075
0.07
0.071
0.064
0.061
0.056
0.444
0.107
0.68
0.21
0.2
0.14
0.19
J
0.123
f
0.14
«
0.056
f
TEST
No.
3
8A
2
4
7
6
3
1
2
3
5
2
3-18
DlES~-4
DIES-3
1-18
1-20
DIES-2
3-20
2-19
2-20
1-19
3-19
2-18
6
4
2
3
1
5
4
4
1
3
5
2
3
2
1
6
4
1
8
7
9
11
2
6
3
4
12
5
10
9
7
8
1
2
3
4
6
2
4
5
3
5
1
SPONSOR
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
"Private '
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
EPA
EPA
Private
Private
Private
Private
EPA
EPA
EF'A
Private
EPA
EPA
EPA
68
-------
Table 1. (continued)
SITE
DUPONT-LA
DUPONT-LA
DUPONT-LA
UPJOHN
UPJOHN
UPJOHN
AMERICAN CYANAMID
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
MITCHELL SYSTEMS
MITCHELL SYSTEMS
MITCHELL SYSTEMS
MITCHELL SYSTEMS
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
AMERICAN CYANAMID
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
TWl
MITCHELL SYSTEMS
MITCHELL SYSTEMS
MITCHELL SYSTEMS
DUPONT-LA
r\i iD^irr i A • > •
DUPONT-LA
DUPONT-LA
GULF OIL
GULF OIL
GULF OIL
ROSS INCINERATION
ROSS INCINERATION
ROSS INCINERATION
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
UPJOHN
UPJOHN
UPJOHN
UPJOHN
UPJOHN
UPJOHN
SCA CHEMICAL SER
SCA CHEMICAL SER
SCA CHEMICAL SER
SCA CHEMICAL SER
CINCINNATI MSD
CINCINNATI MSD
CINCINNATI MSD
MITCHELL SYSTEMS
MITCHELL SYSTEMS
ROSS INCINERATION
MITCHELL SYSTEMS
GULF OIL
ROSS INCINERATION
GULF OIL
ROSS INCINERATION
GULF OIL CORP.
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
UPJOHN
UPJOHN
UPJOHN
AMERICAN CYANAMID
POHC
hexachloroethane8
hexachloroethana
hexachloroethane
m-dichlorobenzene
m-dichlorobenzene
m-dichlorobenzene
m-dinitrobenzene*
MEK
MEK
MEK
MEK
MEK
MEK
MEK
methyl pyridine
methyl pyridine
methyl pyridine
mononitrobenzene*
N.N dimethylacetarnide
N.N dimethylacetarnide
N,N dimethylacetarnide
naphthalene
naphthalene0'9
naphthalene0'8
naphthalene0'8
naphthalene"8
naphthalene0'8
naphthalene0'8
naphthalene
naphthalene
naphthalene
naphthalene0
naphthalene0
naphthalene0
naphthalene0'8
naphthalene0'8
naphthalene0'8
o-dichlorobenzene
o-dichlorobenzene
o-dichlorobenzene
p-dichlorobenzene
p-dichlorobenzene
p-dichlorobenzene
PCB
PCS
PCB
PCB
pentachloroethane
pentachloroethane
pentachloronthane
phenol0
phenol0
phenol0'8
phenol0
phenol
phenol0'8
phenol
phenol0'8
phenol
phenol0
phenol0
phenol0
phenyl isocyanate
phenyl isocyanate
phenyl isocyanate
phenylene diamine
" POHC —
CONC.%'
0.045
0.044
0.0395
2.1
3.1
2.3
0.31
0.86
1.64
0.79
0.273
0.422
0.284
0.042
0.041
0.025
64
1.9
1.82
0.83
0.379
0.0395
0.0148
0.0192
0.009
0.011
0.006
0.036
0.032
0.024
0.0177
0.0174
0.0118
4
6.4
4.6
5.6
8
5.9
27.5
26.7
19
22.1
0.42-0.81
0.42-0.81
0.27-0.83
1.9
2.73
0.012
1.72
0.006
0.005
0.169
0.148
0.249
17
21
16
0.53
DRE,%'
99.99
99.99
99.99
99.922
99.932
99.905
99.99
99.99967
99.99932
99.9993
99.9965
99.9952
99.988
99.987
99.998
99.998
99.998
99.99991
99.9999
99.9999
99.9998
99.996
99.986
99.98
99.96
99.1
98
97.4
99.998
99.998
99.998
99.994
99.994
99.991
99.927
99.85
99.81
99.999
99.999
99.993
99.999
99.999
99.995
99.99994
99.99982
99.9998
99.99949
99.9998
99.9998
99.9994
99.99996
99.9985
99.997
99.996
99.996
99.993
99.993
99.992
99.991
99.989
99.979
99.976
99.99992
99.99992
99.9999
99.9992
— IfcMP.
"F
2640
2640
2640
2040
2040
2040
1254
2110
2040
2090
1930
2000
2050
1975
2090
2040
2110
1254
2040
2090
2110
1810
1975
2000
1930
2640
2640
2640
1310
1320
1320
2090
2110
2040
1952
1952
1952
2040
2040
2040
2040
2040
2040
2212
2231
2225
2247
1650
2400
2000
2000
1930
2110
1975
1320
2090
1320
2040
1310
1952
1952
1952
2040
2040
2040
1198
HCL,
lb/h°
0.6
0.5
0.9
0.9
1.7
1.2
0.007
0.1
0.3
0.3
4.1
4.9
f
3.8
0.3
0.3
0.1
0.007
0.3
0.3
0.1
0.2
3.8
4.9
4.1
0.6
0.5
0.9
0.12
0.12
0.19
0.3
0.1
0.3
4.47
0.64
1.83
0.9
1.7
1.2
0.9
1.7
1.2
2.5
1.4
3.4
2.2
5
60.9
16
4.9
4.1
0.1
3.8
0.12
0.3
0.19
0.3
0.12
1.83
0.64
4.47
0.9
1.7
1.2
0.007
ISP,
gr/dscf
0.004
0.015
0.011
0.094
0.013
0.08
0.007
0.061
0.061
0.077
0.491
0.313
»
0.378
0.077
0.061
0.061
0.007
0.061
0.077
0.061
0.044
0.378
0.313
0.491
0.004
0.015
0.011
0.027
0.053
0.026
0.077
0.061
0.061
0.161
1
0.187
0.094
0.013
0.08
0.094
0.013
0.08
f
0.075
f
f
0.107
0.444
0.68
0.313
0.491
0.061
0.378
0.053
0.077
0.026
0.061
0.027
0.187
f
0.161
0.094
0.013
0.08
0.069
TEST
No.
2
1
3
2
4
3
4
1
3
2
1
2
3
4
2
3
1
4
3
2
1
4
4
2
1
2
1
3
1
2
3
2
1
3
3
1
2
2
4
3
2
4
3
19
17
21
20
7
9
8
2
1
1
4
2
2
3
3
1
2
1
3
2
4
3
3
SPONSOR
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
EPA
Private
EPA
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
69
-------
I
Tnblo 1. (continued)
SITE
AMERICAN CYANAMID
AMERICAN CYANAMID
UPJOHN
UPJOHN
UPJOHN
ROSS INCINERATION
ROSS INCINERATION
CINCINNATI MSD
CINCINNATI MSD
SMITH KLINE CHEM
SMITH KLINE CHEM
SMITH KLINE CHEM
CINCINNATI MSD
CINCINNATI MSD
CIOA-GEIGY
CINCINNATI MSD
CIBA-GEIGY
CIBA-GEIGY
CIBA-GEIGY
CINCINNATI MSD
CIBA-GEIGY
CINCINNATI MSD
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
UNION CARBIDE
DUPONT-LA
UNION CARBIDE
DUPONT-LA
DUPONT-LA
CONFIDENTIAL SITE B
ROSS INCINERATION
ROSS INCINERATION
MCDONNELL DGLS
ROSS INCINERATION
MCDONNELL DGLS
MCDONNELL DGLS
MCDONNELL DGLS
CONFIDENTIAL SITES
CONFIDENTIAL SITES
MITCHELL SYSTEMS
TWI
TWI
TWI
CONFIDENTIAL SITES
CONFIDENTIAL SITES
TWI
TWI
TWI
TWI
DUPONT-LA
TWI
DUPONT-LA
DUPONT-LA
TWI
SMITH KLINE CHEM
TWI
CIBA-GEIGY
CONFIDENTIAL SITES
POHC
phenylene diamine*
phenylene diamine*
phosgene
phosgene
phosgene
phthalic anhydride"
phlhalic anhydride"
tetrachloroethane
tetrachloroethane
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
telrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
telrachloroethylene
telrachloroethylene
letrachloroethylene
tetrachloroethylenac
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene
tetrachloroethylene0
tetrachloroethylene0
tetrachloroethylene8
tetrachloroethylene11
tetrachloroethylene8' k
tetrachloroethylene8
tetrachloroethylene0'1
tetrachloroethylene0'1
tetrachloroethylene0
tetrachloroethylene8'*.
tetrachloroethylene8
tetrachloroethylene0>
toluene
toluene1*
toluene
toluene
toluene1*
toluene
toluene
toluene
toluene0
POHG 1
CONC.%"
0.46 |
0.23 ,
53.4 I
50.8 '
20.2
0.008
0.007 :
0.27
0.128
1.32 ,
0.98
1.36
0.38
0.24
5.03
0.26
5.03
5.03
5.03
0.26
5.03
0.34
1.6
1.7
2.8
1.8
2.1
2.7
1.8
1.6
1.5
2
1.4 ;
0.852
2.7
1.06
0.834
0.398 !
1.67
0.78
0.6 '
0.69 '
0.57
0.64
0.64 ,
0.582
0.347 i
0.00861
0.0183
0.0044
0.00567
0.235
0.29
0.0124
0.00377
0.00636
0.0041
20.2
9.87
21.9
21.54
11.03
3.86
7.92
60.58 ;
2.47
DRE.%"
99.999
99.997
99.9985
99.993
99.981
99.99
99.99
99.9998
99.9997
99.99999
99.99999
99.99997
99.999
99.999
99.997
99.997
99.995
99.995
99.991
99.99
99.982
99.97
99.99986
99.99985
99.99984
99.99984
99.99983
99.99979
99.99977
99.99977
99.99977
99.99975
99.99972
99.99972
99.99966
99.99948
99.99926
99.99918
99.99912
99.9986
99.99779
99.9977
99.9977
99.99763
99.9971
99.9968
99.9966
99.9929
99.982
99.966
99.965
99.948
99.937
99.88
99.81
99.78
99.64
99.99993
99.99988
99.99986
99.99986
99.99959
99.99953
99.99946
99.9994
99.99923
TEMP.
°F
119fl
1240
2040
2040
2040
2090
2040
2400
1650
1620
1710
1640
2400
1650
1800
1650
1800
1800
1800
2000
1800
2400
1800
1800
1600
1800
1600
1600
1800
1800
1800
1600
1600
2640
1600
2640
2640
1952
2040
2110
1800
2090
1800
1800
1800
1952
1952
2050
1810
2140
2080
1776
2070
2050
2030
2230
2640
2140
2640
2640
2120
1620
2080
1800
1952
HCL,
lb/hb
0.007
0.004
0.9
1.2
1.7
0.3
0.3
60.9
5
0.2
0.6
0.6
6.1
1.9
99.9
3.7
99.9
99.9
99.9
7.8
99.9
89.7
98.2
98.4
98.9
97.9
98.6
98.5
98.2
98.3
98.5
98.1
98.2
0.6
9B.9
0.5
0.9
4.47
0.3
0.1
1.67
0.3
0.8
1.64
0.74
0.64
1.83
f
0.2
h
0.3
h
h
0.6
h
0.4
h
0.6
h
0.9
0.5
h
0.2
0.3
99.9
0.64
TSP,
gr/dscf
0.175
0.075
0.094
0.08
0.013
0.077
0.061
0.444
0.107
0.027
0.03
0.057
f
f
0.21
•
0.2
0.14
0.19
0.056
0.14
f
0.075
0.064
0.048
0.07
0.055
0.057
0.071
0.061
0.056
0.073
0.094
0.004
0.066
0.015
0.011
0.161
0.061
0.061
0.047
0.077
0.032
0.044
0.032
1
0.187
f
0.044
h
0.075
h
h
0.048
h
0.127
h
0.004
h
0.011
0.015
h
0.027
0.075
0.21
1
Itbl
No.
5
2
2
3
4
2
3
9
7
7
8
6
3
1
1
4
2
3
4
5
5
6
6
12
8
3
11
9
4
5
10
2
1
2
7
1
3
3
3
1
1
2
2
3
4
1
2
3
4
8B
1
4
5
3
7
2
6
2
88
3
1
8A
7
1
1
1
SPONSOR
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
EPA
EPA
Private
EPA
Private
Private
Private
EPA
Private
EPA
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
Private
EPA
Private
EPA
EPA
EPA
EPA
EPA
Private'
EPA
Private
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
EPA
Private
EPA
70
-------
Table 1. (continued)
SITE
CIBA-GEK3Y
CIBA-GEK3Y
ROSS INCINERATION
ROSS INCINERATION
SMITH KLINE CHEM
CIBA-GEK3Y
TWl
ROSS INCINERATION
TWl
CIBA-GEKSY
SMITH KLINE CHEM
TWl
ZAP ATA INDUSTRIES
CONFIDENTIAL SITE B
ZAPATA INDUSTRIES
CONFIDENTIAL SITE B
TWl
ZAPATA INDUSTRIES
TWl
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
MITCHELL SYSTEMS
MITCHELL SYSTEMS
MITCHELL SYSTEMS
ZAPATA INDUSTRIES
MITCHELL SYSTEMS
DUPONT-LA
DUPONT-LA'
DUPONT-LA
OLIN
OLIN
DOW CHEMICAL
DOW CHEMICAL
CINCINNATI MSD
CINCINNATI MSD
MCDONNELL DGLS
MCDONNELL DGLS
MCDONNELL DGLS
DUPONT-LA
ROSS INCINERATION
UPJOHN
MCDONNELL DGLS
TWl
TWl
DUPONT-LA
UPJOHN
TWl
ZAPATA INDUSTRIES
UPJOHN
ZAPATA INDUSTRIES
ROSS INCINERATION
ROSS INCINERATION
TWl i
MITCHELL SYSTEMS
DUPONTLA
ZAPATA INDUSTRIES
TWl
TWl
TWl
MITCHELL SYSTEMS
TWl
MITCHELL SYSTEMS
MITCHELL SYSTEMS
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
ZAPATA INDUSTRIES
POHC
toluene
toluene
toluene
toluene
toluene
toluene
toluene11
toluene
toluene11
toluene
toluene
toluene
toluene
toluene0'1
toluene
toluene0
toluene
toluene
toluene
toluene"
toluene0'1
toluene0
toluene0
toluene0
toluene
toluene0
trans-dichlorobutene
trans-dichlorobutene
trans-dichlorobutene
Irichtorlluormethano
trJchlorfluormethano
trichlorobenzenes
trichlorobenzenes
trichloroethane
trichloroethane
trichloroethylene
trichloroelhylena
Irichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene1'
trichloroethylene"
trichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene
Irichloroethylene
Irichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene0
Irichloroethylene
trichloroethylene
trichloroethylene
trichloroethylene''
trichloroethylene
trichloroethylene0
trichloroethylene
trichloroethylene0
trichloroethylene0
trichloroethylene0
trichloroethylene0
trichloroethylene
• POHC
CONC.%'
60.58
60.58
4.04
2.87
3.2
60.58
8.52
2.74
8.55
60.58
4.53
9.56
0.42
0.748
0.073
1.62
6.01
0.33
4.08
1.317
1.3
0.0618
0.0738
0.0957
0.11
0.105
5.27
4.48
4.4
14.85
10.97
3.1
0.96
18
21
9.5
0.277
1.04
4
0.5
0.555
0.67
0.309
4
0.353
0.52
3.3
0.71
0.83
0.47
0.178
0.202
0.198
0.29
0.212
0.29
0.277
0.232
0.956
0.222
0.223
0.136
0.166
1.1
DRE.%a
99.9992
99.9992
99.99904
99.9987
99.9982
99.998
99.9979
99.9978
99.9976
99.997
99.997
99.9963
99.9956
99.994
99.9932
99.9923
99.9922
99.9914
99.9908
99.989
99.982
99.979
99.966
99.957
99.952
99.941
99.99992
99.9999
99.9999
99.9999
99.9998
99.995
99.992
99.999
99.985
99.99999
99.99998
99.99995
99.99984
99.99963
99.99956
99.9995
99.99924
99.99921
99.999
99.9989
99.9989
99.9985
99.9983
99.9979
99.9969
99.9965
99.9962
99.9959
99.9951
99.9946
99.9945
99.9926
99.9917
99.991
99.989
99.985
99.984
99.983
99.981
99.979
— TOFT"
°F
1800
1800
2110
2090
1710
1800
2230
2040
2050
1800
1640
2070
1660
1776
1550
1952
1810
1600
2030
1952
1975
1930
2050
1570
2000
2640
2640
2640
2095
2088
1800
1820
2400
1650
1800
1800
1800
2640
2110
2040
1800
2140
2120
2640
2040
1810
1550
2040
1600
2040
2090
2080
2050
2640" '
1660
2030
2050
2070
2000
2230
1930
1975
1952
1952
1570
HCL.
Ib/h"
99.9
99.9
0.1
0.3
0.6
99.9
h
0.3
h
99.9
0.6
0.6
3.3
h
2.8
4.47
0.2
1.4
0.4
1.83
h
3.8
4.1
1
2.2
4.9
0.9
0.6
0.5
1.2
0.7
99.7
99.8
60.9
5
1.64
1.67
0.8
0.5
0.1
1.7
0.74
h
h
0.6
1.2
0.2
2.8
0.9
1.4
0.3
0.3
0.3
1
o.g—
3.3
0.4
h
0.6
4.9
h
4.t
3.8
1.83
0.64
2.2
ISP.
gr/dscf
0.2
0.14
0.061
0.077
0.03
0.19
h
0.061
h
0.14
0.057
0.048
0.017
h
0.036
0.161
0.044
0.022
0.127
0.187
h
0.378
0.491
1
0.03
0.313
0.011
0.004
0.015
0.031
0.052
0.444
0.107
0.044
0.047
0.032
0.015
0.061
0.013
0.032
h
h
0.004
0.08
0.044
0.036
0.094
0.022
0.061
0.077
0.075
f
— 0.01 r~
0.017
0.127
h
0.048
0.313
h
0.491
0.378
0.187
f
0.03
TEST
No.
2
3
1
2
8
4
6
3
7
5
6
3
4
4
3
3
4
2
2
2
5
4
1
3
1
2
3
2
1
3a,b,c
2a.b,c
10272-1
10272-2
9
7
3
1
2
1
1
4
4
88
8A
2
3
4
3
2
2
3
2
1
3
3
4
2
7
3
2
6
1
4
2
1
1
SPONSOR
Private
Private
EPA
EPA
Private
Private
EPA
EPA
EPA
Private
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Private
Private
Private
Private
EPA
EPA
Private
Private
Private
EPA
EPA
EPA
Private
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA: —
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
-------
Table 1. (continued)
SITE
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
CONFIDENTIAL SITE B
POHC
trichloroothyiene1-'
lrichloroethytenec
trichtofoethy!aneCl1
POHC
CONC.y.,'
0.124 !
0.147
0.123
DRE.%'
99.949
99.8
99.8
TEMP.
°F
1776
1952
HCL,
Ib/h"
h
4.47
h
laP,
gr/dsd
h
0.161
h
TEST
No.
4
3
5
SPONSOR
EPA
EPA
EPA
for tho*o runt In which a range of POHC waste food concentrations wore tested, only the lowest reported ORE is listed.
*HCI valuM for Dow. Siauffer Chemical, and Upjohn are listed as % removal, not Ib/h.
'Sampling and/or analytical problems; data suspect.
iNono delected; limit ol detection unknown.
•Temperature reading suspect—may be low by 300°F.
"No! reported.
•Low POHC concentration (200 ppm or less) in waste feed.
Ttoi measured.
'Abnormal operating conditions—low temperature.
'Abnormal operating conditions—unspecified.
''Abnormal operating conditions—waste feed rate increased and combustion air distribution changed in attempt to increase CO and THC emissions.
Particulate and Hydrogen Chloride
Emissions
Emissions of paniculate matter and HCI are limited by 40
CFR 264.343 as follows:
Particulate matter
HCI
0.08 gr/dscf corrected to 7 percent
02
4 Ib/h, or an HCI removal efficiency
of at least 99 percent ;
Although these emissions are generally a function of the
ash and chloride contents of the waste burned, the outlet
concentration also depends on the exhaust gas control
system. Because control systems varied from site to site,
correlating the paniculate and HCI emissions with input
concentrations is impossible. Although the available data
do not permit the development of such a relationship,
they do indicate that, in general, the HCI and paniculate
emission limits are achievable. Data from the E PA tests
suggest that any facility firing wastes with ash cqntent ;
greater than 0.5 percent will need a paniculate control <
device to meet the standard.
Other Results
i
Other important findings from the incineration tests
conducted by EPA relative to (1) heat of combustion, (2)
carbon monoxide (CO), total hydrocarbons (THC), and
dioxin emissions, and (3) the sampling and analysis of :
waste feed and stack gases are presented below:2 ;
Heat of Combustion— f
i
• Analysis of the data collected in the EPA program
showed no clear correlation between ORE and heat of
combustion for the POHCs tested.
CO, THC, and Dioxin Emissions—
• CO and THC were monitored on a continuous basis to
assess their utility as indicators of incinerator
performance. The analysis indicates that CO and THC
may provide some indication of changes in incinerator
performance and gross malfunctions in the
combustion process. However, under the conditions of
these tests CO and THC levels did not appear to be
good predictors of POHC emissions or ORE, either
across the plants tested or at a specific site, for DREs
in the vicinity of 99.99 percent. It should also be
pointed out that these tests were not conducted in a
parametric fashion specifically designed to determine
if such a correlation could be found.
• Of six sites that were tested by EPA for tetra- and penta-
chlorinated dioxins and furans, dioxins were found at
one site and furans were found at three sites. No
2,3,7,8-TCDD was detected. The maximum
concentrations detected were 0.06 rig/liter of
chlorinated furans and 0.02 ng/liter of chlorinated
dioxins.
Sampling and Analysis—
• The VOST method used in the EPA tests provided a
consistent and reliable data base when operated by
personnel familiar with the apparatus and procedures.
Proper use of these procedures was critical to
obtaining reliable data.
• Of the two methods used in the EPA program for
sampling volatile organics in the stack—VOST and gas
bags—the VOST method provided lower blank values
than gas bags, resulting in a higher percentage of
quantifiable data points. Also the VOST method was
less cumbersome and less prone to contamination
than gas bags.
• Hazardous waste samples contain a complex matrix of
compounds which present a variety of analytical
difficulties. Analysis by a gas chromatograph/mass
spectrometer (GC/MS) was highly successful for
identifying Appendix VIII compounds in the waste
streams and effluents. Prescreening by a gas
chromatograph/flame ionization detector (GC/FID)
was useful when analyzing waste streams.
• Because small concentrations of organics must be
72
-------
measured in stack gases, sample contamination can 7.
present significant problems. Careful control blanks
and well defined blank correction procedures are
required.
The results of the external and internal quality
assurance program used in the EPA study indicate
that established quality assurance procedures were 8.
followed and the overall quality of laboratory and field
work was adequate to meet the objectives of the
study.
Evaluation of the QA/QC data for the eight incinerator
tests indicated low or erratic recoveries in the
analyses of phenol, cis- and trans-1,2,-dichlorobutene, 9.
naphthalene, aniline, and bis(2-ethylhexyl)phthalate
for the complex waste feed matrices encountered
during this program. Caution should be used when
evaluating these compounds as POHCs during actual
triaJ burns. , 10.
The results from waste sampling and analysis at plants
where Appendix VIII compounds were spiked into the
liquid waste feed line indicate that inadequate mixing
and, as a result, nonrepresentative waste feed
samples may be a problem at some facilities. One 11.
approach used to alleviate the problem was the use of
in-line mixers. This approach was successful at the
one facility where it was used during the program.
Day, D. R., and L. A. Cox. 1984b. Evaluation of
Hazardous Waste Incineration in a Lime Kiln:
Rockwell Lime Company. Prepared for U.S.
Environmental Protection Agency by Monsanto
Research Corporation under Contract No. 68-03-
3025, June 1984.
Higgins, G. M., and A. J. Helmstetter. 1983.
Evaluation of Hazardous Waste Incineration in a
Dry Process Cement Kiln. In: Incineration and
Treatment of Hazardous Waste: Proceedings of the
Eighth Annual Research Symposium, March 1982.
E PA/600/9-83/003.
Jenkins A. C., et. al. 1982. Supplemental Fuels
Project, General Portland, Inc., Los Robles Cement
Plant. Report C-82-080. State of California Air
Resources Board.
MacDonald, L. P., et al. 1977. Burning Waste
Chlorinated Hydrocarbons in a Cement Kiln. Water
Pollution Control Directorate, Environmental
Protection Service, Fisheries and Environment
Canada, Report No. E PS 4-W P-77-2.
PEI Associates, Inc. 1985. Guidance Manual for Co-
Firing Hazardous Wastes in Cement and Lime Kilns
(Draft). Prepared for U.S. Environmental Protection
Agency under Contract No. 68-02-3995.
References
1. Part B Trial Burn Reports submitted to E PA Regions
II, III, IV, V, VI, and VII, 1 983-85.
2. Trenholm, A., et. al. Performance Evaluation of Full-
Scale Hazardous Waste Incinerators, Volumes I
through V. Midwest Research Institute. E PA
Contract No. 68-02-3177. 1985.
3. Gorman, P. G., and K. P. Ananth. Trial Burn Protocol
Verification at a Hazardous Waste Incinerator.
Midwest Research Institute. E PA/600/2-84/048.
February 1984.
4. Branscome, M., et al. 1984. Evaluation of Waste
Combustion in Dry-Process Cement Kiln at Lone
Star Industries, Oglesby, Illinois. Prepared for U.S.
Environmental Protection Agency by Research
Triangle Institute and Engineering Science Under
Contract No. 68-02-3149.
5. Branscome, M. 1985. Summary Report on
Hazardous Waste Combustion in Calcining Kilns.
Prepared for U.S. Environmental Protection
Agency, Cincinnati, OH, by Research Triangle
Institute.
6. Day, D. R., and L. A. Cox. 1 984a. Evaluation of
Hazardous Waste Incineration in an Aggregate Kiln:
Florida Solite Corporation. Prepared for U.S.
Environmental Protection Agency by Monsanto
Research Corporation Under Contract No. 68-03-
3025.
12. Peters, J. A., et al. 1983. Evaluation of Hazardous
Waste Incineration in Cement Kilns at San Juan
Cement Company. Prepared for U.S. Environmental
Protection Agency by Monsanto Research
Corporation under Contract No. 68-03-3025,
August 1983.
13. Research Triangle Institute and Engineering Science
(RTI and ES). 1984. Evaluation of Waste
Combustion in Cement Kilns at General Portland,
Inc., Paulding, Ohio. Prepared for U.S.
Environmental Protection Agency under Contract
No. 68-02-3149, March 1984.
14. Weitzman, L. 1983. Cement Kilns as Hazardous
Waste Incinerators. Environmental Progress,
2{1):10-14, February 1983.
15. Wyss, A. W., C. Castaldini, and M. M. Murray. 1984.
Field Evaluation of Resource Recovery of Hazardous
Wastes. Prepared for U.S. Environmental
Protection Agency by Acurex Corporation under
Contract No. 68-02-3176.
1 6. Castaldini C., H. B. Mason, and R. J. DeRosier. 1 984.
Field Tests of Industrial Boilers Cofiring Hazardous
Wastes. In: Proceedings from the Tenth Annual
Research Symposium. EPA/600/9-84/022. U.S.
Environmental Protection Agency, Industrial
Environmental Research Laboratory, Cincinnati,
Ohio.
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17. Castaldini C., S. Unnash, and H. B. Mason. 1984.
Engineering Assessment Report—Hazardous Waste
Cofiring in Industrial Boilers. Prepared by Acurex
Corporation for U.S. Environmental Protection !
Agency under Contract No. 68-02-3188. Cincinnati,
Ohio.
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RCRA Exemptions, Waivers, and Petitions for
Hazardous Waste Incinerators
By ,
Gary Gross
U.S. Environmental Protection Agency
Region III
Philadelphia, PA
Introduction
Several specialized exemptions and waivers are available
to permit applicants based primarily on incinerator design
and/or waste feed characteristics. The descriptions
which follow are based on the Federal RCRA regulations,
40 C.F.R. Parts 260-264 and 270. In States that have
been authorized by E PA to implement the RCRA
program. State regulations have superseded the federal
requirements, except as noted. In most instances there is ,
little practical difference between the two regulations.
However, some States may have more limited
exemptions or have eliminated some exemptions entirely.
It is important to remember that while State
requirements may be more restrictive than those
described here, they cannot be any broader in scope.
Even when identical regulations apply, there is sufficient
discretionary authority to allow varying interpretations
from State to State and even among E PA Regions. The
permit applicant should always review prospective
exemptions and variances with the responsible
permitting authority before submitting a Part B permit
application.'.
General Petitions
This provision is applicable to all hazardous waste
treatment, storage and disposal facilities. 40 C.F.R.
§260.20 provides that any affected person may petition
the E PA Administrator to modify or revoke any regulatory
provision of RCRA. Each petition must be submitted to
the Administrator by certified mail and must include:
1. The petitioner's name and address;
2. A statement of the petitioner's interest in the
proposed action;
3. A description of the proposed action, including
(where applicable) suggested regulatory language;
and
4. A statement of need and justification for the
proposed action, including supporting tests,
studies, or other information.
E PA's approval or denial of these petitions follows formal
rulemaking procedures including proposal of a tentative
determination in the Federal Register, consideration of
public comments, and final rulemaking notice in the
Federal Register. This authority is not delegated to
authorized State RCRA programs.
Delisting
This provision is also applicable to all hazardous waste
treatment, storage and disposal facilities. It is essentially
a subcategory of general petitions as described above.
In order to understand the meaning of waste delisting, it
is necessary to understand the distinction between
"listed" and "characteristic" wastes. Listed wastes are
those designated in 40 C.F.R. Part 261, Subpart D and
identified by E PA Waste Codes F, K, U or P. "F" wastes
are particular waste types, largely spent solvents,
generated by non-specific sources. "K" wastes are
various waste streams generated by specific
manufacturing processes. "U" and " P" wastes both
describe discarded or off-specification commercial
chemical products including container and spill residues
thereof. {" P" wastes are acutely hazardous, "U" wastes
are hazardous.) Listed wastes, including all mixtures and
treatment residues of listed wastes, are classified as
hazardous wastes regardless of their actual chemical
characteristics.
Characteristic wastes are those designated in 40 C.F.R.
Part 261, Subpart C with an E PA Waste Code beginning
with D. They are divided into four categories:
Characteristic
E PA Waste Code
Ignitable
Corrosive
Reactive
E P Toxic
P001
D002
D003
D004,thru D017
These classifications are based entirely on the waste's
chemical properties. The generating process is generally
not relevant. Unlike listed wastes, mixtures and residues
of characteristic wastes are not hazardous wastes unless
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the mixture or residue also exhibits one of the
characteristics.
Any person may petition the E PA Administrator to
exclude a waste at a particular generating facility from
classification as a listed waste. To be successful, the
petitioner must demonstrate that the waste does not
meat any of the criteria for which it was listed as a
hazardous waste, nor does it contain any other
hazardous constituents which warrant retaining the1
hazardous waste classification.
A dolisted waste is excluded from all RCRA permitting
requirements unless it exhibits one or more of the
hazardous waste characteristics (i.e., ignitability,
corrosJvity, or reactivity). [Note: A waste exhibiting the
fourth hazardous waste characteristic, EP toxicity, would
not qualify for delisting.] If it does exhibit one or more of
the characteristics, a permit is required, but most of the
incinerator requirements, including performance !
standards for ORE, HCI and paniculate emissions, do not
apply (see I-C-R Exemption).
Although delisting can be applicable to wastes as
generated, in the realm of incineration it is more likely to
be applied to ash and/or air pollution control residues
generated during incineration. Since any residue
resulting from the treatment of a listed hazardous waste
retains the same listing as the original waste [see 40
C.F.R. §261.3(c)(2)(i)], it is subject to the same treatment,
storage and disposal requirements as the original waste.
Some incinerators generate very large quantities of ash
and air pollution control device residues. If it can be
shown that those wastes qualify for delisting, there can
be significant reductions in the overall cost of
incineration.
Delisting petitions may only be approved by the EPA
Administrator or his designee. State authorizations do
not include this authority at the present time. Petition
procedures are detailed in 40 C.F.R. §260.22. They
require that the applicant supply analyses of a .sufficient
number of waste samples (at least four) taken over a
period of time so as to characterize both the composition
and variability of the waste. Consult the Code of Federal
Regulations and the appropriate regulatory agency for
more detailed application requirements.
Like general rulemaking petitions, delisting decisions
follow formal rulemaking procedures including proposal
in the Federal Register, consideration of public
comments, and final rulemaking notice in the Federal
Register.
Variances for Classification as a Boiler
Under the definitions in §260.10, all enclosed devices
using controlled flame combustion for treatment of
hazardous wastes fall into one of three categories. To be
a "boiler", a unit must:
1. Have provisions for recovering and exporting energy
in the form of steam or other heated fluids;
2. Have a combustion chamber and primary energy
recovery section that are of "integral design"
(incinerators with waste heat boilers do not meet
this criterion);
3. Maintain a thermal efficiency of at least 60 percent;
and
4. Utilize at least 75 percent of the recovered energy on
an annual basis.
The integral design requirement notwithstanding,
process heaters and fluid bed combustion units are not
precluded from classification as boilers.
To be an "industrial furnace", the unit must be one of the
specific process operations listed in §260.10 (e.g. cement
kiln, lime kiln, blast furnace, etc.). All units which are not
boilers or industrial furnaces are classified as
"incinerators."
Boilers and industrial furnaces which burn wastes for
purposes of heat recovery are not presently subject to
any RCRA performance standards or permitting
requirements. Those units which burn low-Btu (i.e. less
than 8000 Btu per pound) wastes for purposes of
disposal are subject to the incinerator permit
requirements of Part 264, Subpart 0. Blending of low-Btu
wastes with high heating value materials for the purpose
of avoiding regulation under Subpart 0 is prohibited.
Section 260.32 of the RCRA regulations provides that the
EPA Regional Administrator may determine on a case-by-
case basis that certain units are boilers, even though
they do not otherwise meet the definition of "boiler",
after considering the following:
1. The extent to which the unit racovers and exports
useful energy; and
2. The extent to which the combustion chamber and
energy recovery units are of integral design; and
3. The energy recovery efficiency of the entire system;
and
4. The extent to which the exported energy is utilized;
and
5. The extent to which the unit is in common use as a
boiler; and
6. Other factors, as appropriate.
When evaluating an application for a variance from
classification as a boiler, the Regional Administrator is
required to follow the same administrative procedures as
are required for processing a RCRA permit. That is, he
must issue a tentative decision accompanied by
newspaper and radio advertisement in the affected area.
After a 30-day public comment period and a public
hearing, if appropriate, he must issue a final decision.
This is a final action and may not be appealed within the
Agency.
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This variance provision was made to allow development
of unique or innovative boiler designs. It is probably not
applicable to any existing units.
It should be noted that performance standards for all
boilers are currently under development by EPA. When in
place, those standards will remove much of the
advantage that a boiler classification has over that for an
incinerator. However, some procedural advantages may
remain. It is likely that the boiler standards will provide
two different permitting tracks. Boilers burning "clean"
wastes (i.e. low metals and halogen contents, high heat
content) may qualify for a permit-by-rule that will not
require a trial burn. All other wastes would be subject to
trial burn requirements much like those currently in
effect for incinerators.
Promulgation of final boiler standards is being projected
for mid- to late-1987. This discussion is, of course,
speculative at this time. It is provided only so that
potential variance applicants may more fully evaluate
each option and its resultant benefit.
I-C-R Exemption
This is the most widely applicable incinerator exemption.
In- order to qualify, an incinerator must burn only
ignitable, corrosive or certain reactive wastes. A
qualifying incinerator must obtain a RCRA incinerator
permit, but the permit is limited to a waste analysis plan
and a closure plan. No operating or emission standards
are imposed and no trial burn is required [see 40 C.F.R.
264.340(b) and (c)].
The following wastes qualify for this exemption provided
that they do not contain any of the hazardous
constituents listed in Part 261, Appendix VIII:
1. Those that are listed in Part 261, Subpart D solely
because they are ignitable (Hazard Code I) and/or
corrosive (Hazard Code C);
2. Those that are listed in Part 261, Subpart D solely
because they are reactive (Hazard Code R), and they
do not generate toxic gases when reacted, and they
are not burned simultaneously with any other
hazardous wastes;
3. Those that are hazardous solely because they exhibit
the characteristic of ignitability (Waste Code D001)
and/or corrosivity (Waste Code D002) as specified
in Part 261, Subpart C; and
4. Those that are hazardous solely because they exhibit
the characteristic of reactivity (Waste Code D003)
as specified in Part 261, Subpart C and they do not
generate toxic gases when reacted, and they are
not burned simultaneously with any other
hazardous wastes.
The permitting authority may also grant the exemption to
any incinerator which meets the above criteria except
that "insignificant" concentrations of Appendix VIM
constituents are present. This determination of
"insignificance" is entirely at the discretion of the
permitting authority. No firm criteria exist. It has been
suggested that anything below 100 ppm be considered
insignificant for most organics. For some constituents
(e.g. polychlorinated dioxins and dibenzofurans) much
lower levels may be considered significant. For some less
toxic constituents (e.g. toluene), concentrations in the
1000 ppm range may be insignificant.
In addition to toxicity of the waste constituent, the permit
writer may consider other factors such as dispersion
characteristics of the exhaust plume, size of the exposed
population, incremental human health risk associated
with the emission, and other environmental impacts.
It should be noted that any waste which is listed in Part
261, Subpart D due to the presumed presence of-toxic
constituents cannot be granted an I-C-R exemption
regardless of the actual concentration of those
constituents in the waste. If the applicant can
demonstrate a sufficiently low concentration ,of toxic
constituents, these wastes may be "delisted" as
previously described.
Data in Lieu of a Trial Burn
For similar incinerators burning similar wastes,
§270.19(d) requires the permit writer to use trial burn
results from one incinerator to develop permit conditions
for.the other incinerator, if requested to do so by the
applicant and if he finds that the previous trial burn data
is sufficient. It is the determination as to what constitutes
"similar" wastes and incinerator designs that leads to
perhaps the greatest divergence of opinion among
incinerator permit writers. Some permit writers contend
that the provision is only applicable to identical units at
the same facility burning identical wastes under identical
conditions. Others take a much more liberal approach.
EPA's Office of Solid Waste is currently reviewing the
issue with the intent of developing a more consistent
national approach.
The Guidance Manual for Hazardous Waste Incinerator
Permits ("Permit Writer's Manual"), U.S. EPA, March
1983, provides some guidance as to the criteria which
may be useful in evaluating similarity. It suggests the
following for evaluating wastes:
1. Heating Value —It must be equal to or higher than
that used in the trial burn.
2. Hazardous Constituents—The proposed waste must
not contain significant quantities of any hazardous
constituents considered more difficult to incinerate
than those used as principal organic hazardous
constituents (POHCs) during the trial burn.
3. Organic Chlorine Content—It must be less than or
equal to the trial burn waste.
4. Ash Content—It must be less than or equal to the trial
burn waste.
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Some additional criteria which may be applicable are:
1. Viscosity—For atomized liquid injection incinerators,
it should be less than or equal to the trial burn
waste.
2. Solids Content—Particularly for injected liquid;
wastes, it should be less than or equal to the trial
burn waste.
If it is determined that the wastes are similar, it is then
necessary to evaluate whether the incinerators are
similar in design, construction, and maintenance. The
Permit Writer's Manual suggests that all of the following
criteria must be met for units to be considered similar:
1. Type—For obvious reasons, both incinerators must
be of the same type (e.g. liquid injection, rotary kiln,
etc.).
2. Components and Dimensions—Combustion zo'ne
volume and cross sectional area should be ±20% of
the other incinerator. Linear dimensions of major
components should conform within ±10%.
3. Combustion Zone Temperature—Should be no more
than 20°C (36°F) less than, nor 200°C (360°F)
more than, that of the trial burn incinerator.
4. Excess Air and Air/Waste Feed Ratio—Excess air
rate should be no less than, nor more than 50%
higher than, that of the trial burn incinerator. Air/
waste feed ratio should differ by no more than 10%.
5. Residence Time—Should be no more than 5% less
nor 100% more than that of the trial burn
incinerator.
6. Air Pollution Control Devices (APCDs)—These shoulc
be of the same type for both incinerators. Liquid to
gas ratios should be within ±20%.
7. Auxiliary Fuel Use—Both incinerators should use the
same fuel type with waste/fuel ratios within ±5%.
3. Carbon Monoxide Level—This should be less than or
equal to that of the trial burn incinerator for both
long-term average and short-term peaks.
4. Other APCD Operating Parameters—Each type of
APCD operation should be fully characterized. Such
parameters as pressure drop, pH, and power use
may affect performance in addition to the liquid/
gas ratio. Critical operating parameters for each
equipment type are well documented in the air
pollution control literature.
5. Controls—All monitoring and control systems should
be similar. This is particularly important for any
automated control logic. ••
Due to the wide variability in possible interpretations of
similarity, it is highly recommended that any applicant
wishing to pursue this course meet with the responsible
permit writer prior to preparing the RCRA application. At
that time, both parties should establish the specific
criteria to be used for evaluating similarity.
ftU.S. GOVERNMENT PRINTING OFFICE: 1987 748-121/67041
When evaluating these factors it is important that
decisions be based on updated, "as built" drawings and
actual operating conditions as opposed to design
drawings and design operating conditions. Even :
Identically designed incinerators are frequently modified
in the field resulting in varying performance. Some other
factors which may be useful when assessing similarity
include: '
1. Maintenance—Have refractory surfaces, kiln seals,
nozzles and other components been similarly
maintained at both incinerators? The use of "as
built" drawings will aid in this evaluation.
2. Burners—All burners should be similar in design and
operation (e.g. size, atomizing fluid, atomizing fluid
pressure).
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