&EPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington DC 20460
Office of Solid Waste
and Emergency Response
Washington DC 20460
Technology Transfer
January 1989
EPA/625/6-89/019
Handbook
Guidance on Setting
Permit Conditions and
Reporting Trial Burn
Results
Volume II of the
Hazardous Waste
Incineration Guidance
Series
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EPA/625/6-89/019
January 1989
Handbook
Guidance on Setting
Permit Conditions and Reporting
Trial Burn Results
Volume II of the Hazardous Waste
Incineration Guidance Series
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
Risk Reduction Engineering Laboratory
and
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
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Notice
This document has been reviewed in accordance with the U.S. Environmental Protection
Agency's peer and administrative review policies and approved for publication. Mention of trade
names or commercial products does not constitute endorsement or recommendation for use.
This guidance document is intended to provide information on how regulatory requirements in
40 CFR Subpart O may be satisfied in a wide variety of situations. This guidance document is
not, in and of itself, a regulatory requirement and should not be regarded or used as such.
Therefore, although compliance with regulatory requirements is mandatory, compliance with this
guidance manual (although useful as a means of satisfying regulatory obligations) is not.
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Foreword
Today's rapidly developing and changing technologies and industrial products and practices
frequently carry with them the increased generation of solid and hazardous wastes. These
wastes, if not dealt with properly, can threaten both public health and the environment.
Abandoned waste sites and accidental releases of toxic and hazardous substances to the
environment also have important environmental and public health implications. The Risk
Reduction Engineering Laboratory assists in providing an authoritative and defensible
engineering basis for assessing and solving these problems. Its products support the policies,
programs, and regulations of the Environmental Protection Agency, the permitting and other
responsibilities of State and local governments, and the needs of both large and small
businesses in handling their wastes responsibly and economically.
A recent study has indicated that two areas of guidance are needed to improve the permitting
process for hazardous waste incinerators:
1. Translation of trial burn results into permit conditions by the permit writer
2. Reporting of trial burn data by the permit applicant
The regional and state permit writers are charged with the responsibility to set specific permit
conditions deemed necessary to safeguard public health and protect the environment.
Considering the complexity of incinerator systems and their operation and the variety of wastes
and trial burn cases, this task is clearly difficult. This handbook provides guidance to the permit
writer on setting incinerator permit conditions.
Applicants and their contractors now report trial burn test results in a variety of formats. The
inconsistencies and deficiencies in the information and technical data provided in such reports
result in delays. A consistent format will assist the applicant in drafting a complete and clear trial
burn report and facilitate the permit writer's review of the data. This handbook suggests a
format for trial burn reporting.
This document is Volume II of the Hazardous Waste Incineration Guidance Series. The other
documents in this series are listed in Appendix A, as are sources of further guidance relating to
hazardous waste incinerator permitting.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
in
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Abstract
One of the most difficult and time-demanding tasks for a permit writer is to evaluate and
interpret incinerator trial burn results and to draft facility-specific operating conditions based on
these results. This handbook provides guidance to the permit applicant on reporting trial burn
data and to the permit writer on translating these data into meaningful and enforceable operating
conditions for incinerators.
This report was submitted in partial fulfillment pf EPA contract 68*03-3241 by the
Environmental Systems Division of Acurex Corporation. Midwest Research Institute and the
Energy and Environmental Research Corporation participated as subcontractors. This work was
done under the joint sponsorship of the Office of Solid Waste and the Office of Research and
Development of the U.S. Environmental Protection Agency.
IV
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Executive Summary
Introduction
Subtitle C qf the Resource Conservation and
Recovery Act (RCRA) requires the EPA to develop,
promulgate, and implement regulations which control
the generation, the transportation, and the treatment,
storage, and disposal (TSD) of hazardous waste.
Regulations promulgated under RCRA at 40 CFR Part
264, Subpart O, specify the following performance
standards, which facilities treating hazardous waste
by incineration are required to meet:
1, 99.99 percent destruction and removal efficiency
(ORE) for each principal organic hazardous
constituent (POHC) in its permit for each waste
feed (or 99.9999 percent for dioxin listed wastes),
2. 99 percent removal efficiency of HCI or 1.8 kg (4
lb)/hr of HCI emissions, whichever is greater, and
3. Particulate emissions less than 180 mg/dscm
(0.08 gr/cu ft), corrected to 7 percent oxygen.
The regulations also require that fugitive emissions be
controlled by keeping the combustion zone totally
sealed, maintaining negative draft, or an equivalent
alternative means of control.
Facilities seeking a permit to incinerate hazardous
waste are required to demonstrate the unit's
capability to meet the performance standards during a
trial burn. Since incinerator compliance with these
performance standards cannot be monitored over the
long term, the conditions at which the incinerator
operated during the trial burn (together with any
necessary adjustments to those conditions) are
included in the incinerator permit as conditions for
continuing operation. Compliance with these operating
conditions is then deemed to equal compliance with
the performance standards. An incinerator must be
operated with a system to automatically cut off waste
feed to the incinerator when operating conditions
deviate from limits established in the permit.
Although the regulations specify four operating
parameters that must be set as permit conditions
based on the trial burn (carbon monoxide level, waste
feed rate, combustion temperature, and an indicator
of combustion gas velocity), it is left to the permit
writer to determine how to translate the trial burn data
into permit conditions. Because of the technical
complexity of setting permit conditions for hazardous
waste incinerators and the flexibility the regulations
allow in setting these conditions, there has been a
lack of consistency in the operational portions of
incinerator permits issued across the country. Further,
an excessive number of permit conditions may
severely limit flexibility of operation, while too few
permit conditions may not provide adequate
assurance that the performance standards will
continue to be met.
Approach
The major goals in developing the guidance were to
develop a nationally consistent, technically sound
approach to the setting of operational conditions in
incinerator permits which would maintain proper
performance while allowing a reasonable degree of
operational flexibility. Technical rationales were to be
stated in the document so that it would also serve as
a training tool and to enable the permit writer to
identify and address cases where specific portions of
the guidance may not apply. Various operating
parameters thought to have an effect on achievement
of the incinerator performance standards were
considered for inclusion in the guidance. "Back-up"
parameters which would unnecessarily limit the
permittee's flexibility to operate the incinerator were
avoided. The conditions were evaluated based on
technical knowledge, and, where necessary,
consensus of engineering judgment, to develop a set
of operating parameters to be set in incinerator
permits which would meet with the above goals.
Technical and engineering guidance was provided by
a panel of incineration experts from EPA Regional
Offices, the Office of Solid Waste, and the Office of
Research and Development, and by representatives
of the Research Committee on Industrial and
Municipal Waste of the American Society of
Mechanical Engineers. In addition to providing experts
with whom the authors could discuss ideas, the
groups reviewed two successive drafts of the
document.
Description
The guidance document presents the key control
parameters, shown in Table 1, which should be
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monitored during the trial burn and for which limits
should be set in the incinerator permit. The
parameters are divided into three groups.
Group A parameters are continuously monitored
parameters interlocked to automatic waste feed
cutoff. Most of these parameters are based on trial
burn conditions. A minimal amount of lag time may be
incorporated into the limits for these parameters by
the use of averaging times following the guidelines in
the document. Group B parameters are set to ensure
that the "worst case" conditions demonstrated in the
trial burn are not exceeded during continuing
operation. These parameters are not linked with
automatic waste feed cutoff, and are not continuously
monitored, but, instead, must be recorded in the
facility operating record. Group C parameters, which
are set independently of trial burn results, are based
on equipment manufacturers' design and operating
specifications. These parameters are not continuously
monitored or linked to automatic waste feed cutoff.
Group A Parameters
Temperature is a key parameter of incinerator
performance due to its influence on reaction kinetics
and is a required incinerator permit condition under
RCRA regulations. The minimum temperature limit is
generally set from the lowest temperature trial burn
test at which compliance was demonstrated.
Combustion chamber temperatures are required by
the regulations to be tied to automatic waste feed
cutoff. For a two-chamber incinerator, minimum
temperatures would be set for each chamber. When
minimum temperatures are not maintained in both the
primary and secondary chambers, or in the secondary
chamber only, waste feed must be cutoff to both
chambers. However, if only the primary chamber falls
below its minimum temperature, waste may still be
fed to the secondary chamber.
Carbon monoxide (CO) concentration in the stack gas
is also a parameter which the regulations specifically
require. CO is used as an indicator of the degree of
mixing achieved in the incinerator and is related, by
definition, to combustion efficiency. Separate
guidance on setting permit limits on CO to minimize
emissions of PIC's (products of incomplete
combustion) is being prepared by EPA.
The hazardous waste incinerator regulations require
that the permit specify limits for an indicator of
combustion gas velocity. Combustion gas velocity is
directly related to the gas residence time in the
incinerator, which is known to be one of the key
parameters of combustion. Residence time becomes
more critical at lower combustion temperatures. For
this reason, the limit on maximum combustion gas
velocity should be based on the maximum trial burn
value measured during the lowest temperature test
during which compliance was demonstrated.
A waste feed rate limitation is required by RCRA
regulations primarily to minimize the potential loss of
efficiency from overloading the combustion chambers.
For low heating value wastes, the limits are taken
from the trial burn test with the minimum temperature
during which compliance was achieved, since an
increase in the waste feed rate may cause a
decrease in temperature. Maximum waste feed rate
for high or medium heating value wastes are based
on the highest feed rate of these wastes from any
run.
The requirement in the regulations to control fugitive
emissions is addressed by a permit requirement on
the operating pressure. Incinerator chambers
designed to operate under negative draft (induced
draft) are required by the permit to maintain negative
draft. Forced draft or positive pressure incinerators
must be well sealed, and the maximum operating
pressure is set based on the trial burn.
The guidance recommends that control parameters
for air pollution control equipment (APCE) be set to
maintain the particulate and acid scrubbing capability
demonstrated during the trial burn. For each type of
APCE component, one key parameter was chosen to
be tied to the automatic waste feed cutoff. For
example, since the principal operating parameter
controlling ESP collection efficiency is the power
utilization, or kVA, the minimum kVA demonstrated
during the trial burn at the highest ash feed rate is set
as the permit limit.
Group B Parameters
One of the key principles behind conducting a trial
burn is that the incinerator should operate under the
most severe conditions it is expected to encounter for
the duration of its permitted operation. Group B
parameters are included in the guidance to ensure
that the incinerator will not operate at more taxing
conditions than those at which it demonstrated
compliance during the trial burn.
Parameters affecting APCE performance included in
Group B are total ash and chlorine loading to the
incinerator. These parameters affect the
concentrations of particulate and HCI at the APCE
inlet and the physical and chemical properties of the
gas. The ash and chlorine loadings are limited to the
maximum rate demonstrated in the trial burn. A
minimum scrubber blowdown rate is also set based
on the trial burn, since suspended and dissolved
solids in recycle water, which may be re-entrained
into the flue gas, may contribute to particulate
emissions.
VI
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Table 1.
Group
Control Parameters
Parameter
, Group A
" Continuously monitored parameters are
interlocked with the automatic waste feed
cutoff. Interruption of waste feed is automatic
when specified limits are exceeded. The
.pararrieters.are applicable to all facilities.
Group B
Parameters do not_require continuous
monitoring and are thus not interlocked with the
waste feed cutoff systems. Operating records
are required to ensure that trial burn worst-
case conditions are not exceeded.
Group C
Limits on these parameters are set
independently of trial burn test conditions.
Instead, limits are based on equipment
manufacturers' design and operating
specifications and are thus considered good
operating practices. Selected parameters do
not require continuous monitoring and are not
interlocked with the waste feed cutoff.
l. Minimum temperature measured at each combustion chamber exit
2. Maximum CO emissions measured at the stack or other appropriate location
3. Maximum flue gas flowrate or velocity measured at the stack or other
appropriate location
4. Maximum pressure in PCC and SCC
5. Maximum feed rate of each waste type to each combustion chamber1
6. The following as applicable to the facility:
• Minimum differential pressure across particulate venturi scrubber
• Minimum liquid-to-gas ratio (L/G) and pH to wet scrubber
• Minimum caustic feed to dry scrubber
• Minimum kVA settings to ESP (wet/dry) and kV for ionized wet scrubber
(IWS)
• Minimum pressure differential across baghouse
• Minimum liquid flowrate to IWS
7. POHC incinerability limits
8. Maximum total halides and ash feed rate to the incinerator system
9. Maximum size of batches or containerized waste1
10. Minimum particulate scrubber blowdown or total solids content of the scrubber
liquid
11. Minimum/maximum nozzle pressure to scrubber
12. Maximum total heat input capacity for each chamber
13. Liquid injections chamber burner settings:
• Maximum viscosity of pumped waste
• Maximum burner turndown
• Minimum atomization fluid pressure
• Minimum waste heating value (only applicable when a given waste provides
100% heat input to a given combustion chamber)
14. APCE inlet gas temperature2
11tems 5 and 9 are closely related; therefore, these are discussed under group A parameters.
2ltem 14 can be a group B or C parameter. See text in Section 2.1.6.
The Subpart O regulations require that POHC's
(Principal Organic Hazardous Constituents) be
designated for each waste feed. The required ORE
must then be demonstrated for the POHC's during
the trial burn. Since the POHC's must be
representative of the waste feed, they are chosen on
factors such as difficulty to incinerate and
concentration in the waste feed. The operator is then
limited in the permit to burning only waste containing
hazardous constituents no more difficult to incinerate
than the POHC's for which compliance was
demonstrated during the trial burn. The heat of
combustion of the hazardous constituents has been
used to rank the incinerability of compounds on the
premise that compounds with a lower heat of
combustion are more difficult to burn. Field data
indicate, however, that other ranking systems may
exhibit a better correlation with incinerability. The
guidance presents a draft ranking of the incinerability
of Appendix VIII compounds prepared by the
University of Dayton Research Institute based on
thermal stability at low oxygen (TSLoOa) conditions.
A limit on the maximum size of containerized waste
fed to the incinerator is also recommended to prevent
oxygen depletion from the sudden release of volatiles.
The containerized waste fed during the trial burn
should be representative, with respect to volatile
content, of the waste the facility will be burning under
the permit.
Group C Parameters
Group C parameters were formulated on the need to
ensure that incinerator operation adheres to good
combustion and APCE operating practices. To allow a
reasonable degree of flexibility and to avoid over-
complication of the trial burn, limits for these
parameters are based on manufacturer's design and
operating specifications rather than on the trial burn
settings.
To maintain proper atomization of liquid waste and
promote efficient mixing, burner settings for liquid
injection and afterburner chambers will be limited to
manufacturer's specifications or other acceptable
settings if data show that they are adequate. These
conditions include maximum waste viscosity,
minimum atomization fluid pressure, and maximum
burner turndown. The handbook recommends that a
minimum waste heating value be set in the permit for
liquid injection chambers where 100 percent of the
heat input comes from the waste feed. Total heat
VII
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input to the incinerator is limited to the incinerator
design heat input capacity.
The guidance recommends limiting APCE inlet gas
temperature due to its effect on APCE performance
as well as to prevent equipment deterioration. The
maximum inlet temperature to the APCE would be set
at the trial burn value and a higher temperature would
allow less condensation and thus render less of the
particulate-forming material subject to collection.
These uncollected gases may then condense
downstream of the APCE as temperature decreases
and form additional particulate matter. The maximum
temperature should not be higher than the
manufacturer specification for maximum temperature.
Other Permit Conditions
The guidance also includes additional conditions
related to waste feed cut off. The permit should
require that minimum temperature be maintained in
the secondary combustion chamber after a waste
feed cutoff until wastes remaining in the unit are
burned out. This heating would necessitate use of
auxiliary fuel but must not conflict with the unit's
flame safety management system. The guidance
recommends a condition requiring quarterly reporting
of automatic waste feed cut offs, reasons for the cut
offs, and corrective actions taken.
Translating Trial Burn Results into Permit
Conditions
The guidance presents a strategy for determining the
limits on operating parameters and converting them
into permit conditions. The goal in translating the trial
burn results into permit conditions is to ensure that
the incinerator is operating in a manner sufficiently
similar to the successful trial burn conditions to
maintain compliance but still allow adequate
operational flexibility. The approach commonly
employed is patterned after "mode-based"
operation. The permit contains a different set of
operating conditions for each waste combination the
facility will burn. This approach is best suited for a
facility dedicated to treating a well-defined set of
uniform composition hazardous wastes.
The above approach, however, is not practical for
facilities such as commercial facilities which burn a
wide variety of wastes. The guidance presents an
approach to developing a single set of operating
conditions (termed a "universal set of conditions" or
the "universal permitting strategy") which defines the
allowable range of operation for burning all of the
wastes in the facility permit. Under this approach, the
trial burn must attempt to achieve worst-case
conditions for all permit parameters at a single
operating point by varying factors such as combustion
air flow and steam injection, or to achieve worst-
case conditions in multiple tests with the key
operating parameters kept constant.
In the general approach set forth in the guidance, the
parameters are divided into three groups:
1. Control parameters set from trial burn data that
are related to waste destruction
2. Control parameters set from trial burn data that
are related to APCE performance
3. Control parameters that are independent of trial
burn data
Limits on parameters are set according to the
hierarchy above. The groupings of these parameters
are shown in Tables 2 through 4. Permit limits must
be set only from trial burn tests that show compliance
with the performance standards. Limits should be set
using these basic rules of thumb regarding "worst
case" conditions. The maximum combustion gas
velocity should be set from the trial burn test
conducted at the minimum temperature during which
compliance was achieved. The maximum feed rate of
each low heating value waste stream to each
combustion chamber should be that demonstrated
during the minimum temperature test. The maximum
feed rate of high heating value wastes and the
maximum combined feed rate should be the
maximums demonstrated at any point.
Table 2. Waste-Destruction-Related Control Parameters
Set from Trial Burn Data
Type Parameter
A Minimum temperature at each combustion chamber exit
A Maximum CO emissions
A Maximum flue gas flowrate or velocity
A Maximum pressure in PCC and SCC
A Maximum feed rate of each waste type to each combustion
B
chamber
Maximum size of batches of containerized waste
Permit limits for APCE parameters relating to
particulate collection should be set from the trial burn
test at the maximum inorganic ash feed rate and the
maximum flue gas flow rate, because ash feed rate
determines the load to the APCE and an increase in
the flue gas flow rate may increase entrainment of
particulate matter. Minimum liquor flow rate to the
absorber and minimum pH to the absorber should be
set from the trial burn test at the maximum total
halides feed rate and the maximum flue gas flow rate.
In some instances, it may not be possible to set the
conditions in the manner described due to
interrelationships among parameters which prevent
certain conditions from being achieved at the same
time. The guidance presents an approach to estimate,
through calculations, whether the effect of setting the
VIII
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Table 3. APCE-Performance-Related Control Parameters
Set from Trial Burn Data
Type Parameter
A Minimum differential pressure across paniculate venturi
scrubber1
A Minimum L/G and pH to absorber1
A Minimum caustic feed to dry scrubber
B Minimum scrubber blowdown rates or maximum total solids in
scrubber liquid1
A Minimum kVA settings to ESP (Wet/Dry) and kV for WS's1
A Minimum pressure differential across a FF1
A Scrubber nozzle pressure
B Maximum total halides and inorganic ash feed rate to the
incinerator system
B Minimum particulate scrubber blowdown rate
1 Select as applicable to APCE system.
Table 4. Trial Burn-Independent Control Parameters
Type Parameter
C Maximum total heat input for each chamber
C Liquid injection chamber burner settings
• Maximum viscosity of pumped waste
• Maximum burner turndown
• Minimum atomization fluid pressure
• Minimum waste heating value (if applicable)
C APCE inlet gas temperature
presents a trial burn report format. Example reporting
forms for the design, process, and performance data
required in a trial burn report have been developed
and are presented in the document.
Summary
The Guidance on Setting Permit Conditions and
Reporting Trial Burn Results has been developed to
assist permit writers in translating trial burn results
into site-specific operational conditions in an
incinerator permit. These parameters are presented in
the document along with guidance on how to develop
permit operating conditions using the trial burn data.
The guidance will also assist applicants in planning
trial burns to address the key operating parameters
that must be measured and emphasize the necessity
to test "worst-case" operations to enable applicants
to tailor their proposed operating conditions to the
needs of their facility. One of the key points made by
the guidance is that the permit writer and applicant
should agree, prior to the trial burn, on what permit
conditions will result from the trial burn as planned. In
this way, it can be determined whether it is necessary
to make modifications to the plan to obtain the
desired operating conditions.
conditions based on less than worst-case runs will
be significant. For example, if the permit limit for the
maximum flue gas velocity is to be set from a data
point other than the minimum temperature test, the
permit writer would calculate whether it is likely that
the flue gas flow rate at the minimum temperature
could be increased to the maximum flue gas flow rate
without causing ORE to decrease belpw 99.99
percent. This is done by relating flue gas flow rate to
residence time to ORE assuming a first-order
reaction.
The guidance emphasizes the importance of planning
the trial burn to obtain the desired permit conditions.
The applicant and permit writer should agree, prior to
the trial burn, on the permit conditions that will result
from the trial burn as planned, assuming compliance
is demonstrated. This will allow the applicant to make
modifications to the trial burn plan, if necessary, to
obtain the desired operating conditions.
Trial Burn Reporting
The permit writer is often faced with reviewing a trial
burn report which is incomplete or which is not
structured such that the information necessary to
evaluate compliance and set permit conditions can be
readily located in the report. The permit writer may
need to go back to the applicant to request
clarification or additional data, which slows down the
review process. To assist both applicants and permit
writers, the guidance describes the information which
should be included in the trial burn report and
IX
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Contents
Chapter
Page
Foreword iii
Abstract iv
Executive Summary v
Figures xiv
Tables xv
List of Terms xvii
Conversion Factors xix
Acknowledgments xxi
1 Introduction 1
1.1 RCRA Regulations 1
1.2 Incinerator Permitting Requirements 2
1.2.1 New Facilities 2
1.2.2 Existing Incinerators 4
1.3 Evaluating a Trial Burn and Establishing Permit Conditions 4
2 Control Parameters 9
2.1 Group A Parameters 10
2.1.1 Temperature 11
Mechanics of POHC Destruction 12
Determining Temperature Limit 12
2.1.2 CO Emissions 14
2.1.3 Gas Velocity Indication 14
2.1.4 Combustion Chamber Draft or Pressure 15
2.1.5 Maximum Waste Feed Rate 17
2.1.6 Air Pollution Control Equipment 18
Acid Gas Formation and Control 18
Particulate Formation and Control 20
2.2 Group B Parameters 22
2.2.1 POHC Selection and Incinerability Ranking 22
2.2.2 Maximum Halides and Ash 23
2.2.3 Maximum Batch and Container Size 24
2.2.4 Minimum Particulate Scrubber Slowdown 24
2.3 Group C Parameters 25
2.3.1 Burner Settings 25
2.3.2 Total Heat Input 25
2.3.3 APCE Inlet Gas Temperature 25
2.4 Other Parameters . 26
2.5 References 27
3 Setting Permit Conditions 29
3.1 Permitting Approach 29
3.2 Interrelating Control Parameters 31
3.3 Treatment of Variations in Data 31
XI
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Contents (continued)
3.4 Single Point Approach 32
3.5 Multiple Point Approach . . 32
3.6 Universal Approach 33
3.6.1 Control Parameters Related to Waste Destruction 34
3.6-2 Control Parameters Related to APCE Performance ; 37
3.6.3 Control Parameters Independent of Trial Burn Data 39
3.7 Determining Operating Envelope 39
4 Example Test Case 41
4.1 Site Description 41
4.2 Structuring of the Trial Burn '. 41
4.2.1 Waste Selection and Feed Rates 42
4.2.2 Trial Burn Operating Conditions 45
4.2.3 Operating Conditions: APCE 46
4.3 Trial Burn Test Results 46
4.4 Determining Limits on Control Parameters 46
4.4.1 Control Parameters Related to Waste Destruction 51
4.4.2 APCE-Related Parameters . 54
4.4.3 Parameters Independent of Trial Burn Data . 55
4.4.4 Summary of Operating Limits 55
5 Data Reporting . 59
5.1 Design Data Reporting 59
5.2 Trial Burn Result Reporting . . . 60
5.2.1 Suggested Report Format 64
5.2.2 Guidance for Reporting Process and
Continuous Emissions Monitor (GEM) Data 71
Reporting Continuously Monitored Parameters 72
Special Problems 73
Processing and Reporting CO Data 74
5.3 Operational Recordkeeping and Reporting 74
5.4 Available Computer Program Support 75
Hazardous Waste Control Technology Data Base 75
Energy and Mass Balance Calculation , . 75
5.5 Recommended Forms for Presenting Data Summaries 75
6 Inspection and Maintenance Guidelines 79
6.1 General Facility Equipment 79
6.2 Safety and Waste Cutoff Interlocks ' 81
Appendix A: Sources of Further Information 83
Appendix B: Guidance for Incinerator Design Review 85
B.1 Overall Facility Design 85
B.2 Incineration Equipment 86
B.2.1 Liquid Injection Incinerators 87
B.2.2 Rotary Kiln Incinerators 88
Waste Devolatilization 89
Ash Retention Time 89
Particulate Entrainment 89
B.2.3 Multiple Hearth Incinerators 89
B.2.4 Fluidized Bed Incinerators 90
B,3 Temperature and Gas Residence Time 90
B.3.1 Calculation Technique 90
XII
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Contents (continued)
B.3.2 Example Test Case 92
B.4 Air Pollution Control Equipment 95
B.4.1 Wet Systems 97
Quench Chambers 97
Packed-Bed Scrubbers 98
Venturi Scrubbers 98
B.4.2 Dry Systems 100
Mechanical Collectors 100
Electrostatic Precipitators 100
Fabric Filters > . . 100
Spray Drying Absorbers . . 100
B.5 Measurement Techniques and Safety Interlocks 101
B.6 Special Wastes and Similar Systems 101
B.7 References 101
Appendix C: Time and Temperature Dependency of the Destruction Process 103
Appendix D: Designating Principal Organic Hazardous Constituents . < , 105
D.1 Background 105
D.2 Construction of the Ranking 106
D.3 Using the Ranking 106
D.4 References 107
Appendix E: Energy and Mass Balance Computer Program 125
E.1 Energy and Mass Balance 125
E.1.1 Input 125
E.1.2 Mass Balance 127
E.1.3 Energy Balance . . . 128
E.1.4 Residence Time . 131
E.1.5 Units in Series 132
E.1.6 APCE 132
E.1.7 Limitations of the Current Procedure .., 132
E.2 References 132
Appendix F: Example Reporting Forms 135
Appendix G: Example Reporting Forms: Filled out for Data
from Example Problem 159
XIII
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Figures
Number Page
1-1 Incinerator permitting process - new facilities 3
1-2 Incinerator permitting process - existing facilities (interim status). . . ; 5
1 -3 Steps to evaluating trial burn plan and establish permit conditions 7
2-1 Example of a temperature trace 14
2-2 Effluent flow versus air flow for combustion • • • 16
2-3 Effect of pressure drop on venturi scrubber efficiency . 21
4-1 Incinerator system for example test case. . 42
4-2 Operating envelope for example test case. 57
5-1 Example process diagram showing monitoring points. 66
5-2 Example of process diagram showing sampling locations. 70
5-3 Example of trial burn test timeline. 74
B-1 Incinerator equipment arrangements 86
B-2 Actual-to-ideal residence time ratio
versus moisture-to-air mass flow ratio. 91
B-3 Ideal temperature versus total heat input
to total mass input ratio and fractional heat loss 93
B-4 Correction to ideal temperature versus
ideal temperature and waste/total mass flow ratio 94
B-5 Difference between higher and lower heat value versus
combustion water parameter and moisture in wet fuel/waste. . . . . 94
B-6 Combustion water parameter versus mass fraction
H in dry fuel/waste and mass fraction Cl in dry fuel/waste. . . 94
B-7 Schematic of incinerator for energy and mass balance example 97
B-8 Typical APCE schematic (wet system) 98
G-1 Strip Chart Recording of Combustion Temperatures - Run 1-1 196
G-2 Plot of Corrected CO Readings from Data Logger 1-min Averages - Run 1-1 197
XIV
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Tables
Number Page
1-1 Contents of Trial Burn Plan 2
2-1 Control Parameters 11
2-2 Recommended Waste Feed Cutoffs 12
2-3 Limits on Chamber Draft or Pressure 17
3-1 Permitting Approaches 30
3-2 Waste-Destruction-Related Control Parameters Set From Trial Burn Data 31
3-3 APCE-Performance-Related Control Parameters Set From Trial Burn Data 32
3-4 Trial Burn Independent Control Parameters 32
4-1 Example Incinerator Test Case: Summary Design Information 43
4-2 Example Incinerator Test Case: Major Physical and Chemical
Characteristics of Onsite-Generated Wastes 44
4-3 Example Incinerator Test Case: Trial Burn Test Matrix (Target Settings) 46
4-4 Example Incinerator Test Case: Summary of
Process Operation Results - Test Condition 1 47
4-5 Example Incinerator Test Case: Summary of
.Process Operation Results - Test Condition 2 48
4-6 Example Incinerator Test Case: Summary of
Process Operation Results - Test Condition 3 49
4-7 Example Incinerator Test Case: Summary of
Emission Performance Results - Test Condition 1 50
4-8 Example Incinerator Test Case: Summary of
Emission Performance Results - Test Condition 2 50
4-9 Example Incinerator Test Case: Summary of
Emission Performance Results - Test Condition 3 51
4-10 Average Trial Burn Results at Three Test Conditions 52
4-11 Summary of Permit Limits for Incinerator Example Test Case 53
4-12 Data Used for Setting Temperature Limit 53
5-1 Trial Burn Reporting Format and Requirements - Main Report 61
5-2 Trial Burn Reporting Format and Requirements - Appended Information 64
5-3 Example Summary Table of Process Monitors 67
5-4 Example Summary Table of Sampling and Analysis Methods 68
5-5 Process and GEM Data Requirements 71
5-6 Recommended Usage of Sample Forms in Trial Burn Report 76
6-1 Recommended Inspection and Maintenance Frequency 80
6-2 General Maintenance and Troubleshooting of Incinerator and Auxiliary Equipment 80
6-3 General Maintenance and Troubleshooting of Air Pollution Control Equipment 81
B-1 Incineration Equipment 88
B-2 Input Data for Energy and Mass Balance Example 96
B-3 Comparison of EER Energy and Mass Balance Results with
Permit Application Design Calculations 97
B-4 Typical Values of Kga 99
D-1 Principal Hazardous Organic Constituent Thermal Stability Index 109
D-2 Principal Hazardous Organic Constituent Thermal Stability Index -
Alphabetized Version 116
xv
-------
Tables (continued)
Number Page
D-3 Appendix VIII Thermal Stability Classes 123
E-1 Energy and Mass Balance Input Data 126
E-2 Molecular Weights of Species Considered in Energy and Mass Balance 128
E-3 Molar Equations for Complete Combustion 128
E-4 Weighted Gray Gas Constants 131
F-1 Recommended Usage of Sample Forms in Trial Burn Report 136
G-1 Response to APCE Parameters, Form 6 "Summary of Test Results" 179
G-2 Response to APCE Parameters, Addendum to Form 5 187
G-3 CombustionTemperature Data Taken from Strip Chart - Run 1 . 200
G-4 CEM Data from Data Logger Files - Run 1-1 202
XVI
-------
List of Terms
ACFM Actual cubic feet per minute
APCE Air pollution control equipment
CE Combustion efficiency
C02
* 100 (percent)
co2+co
CEM Continuous emission monitor
CO Carbon monoxide, compound from partial oxidation of hydrocarbons
DE Destruction efficiency of the combustor (only)
POHC. -POHC . , t. , ,
__ in out combustion chamber . „_ ,
DE= - - *100 (percent)
DOE Department of Energy
ORE Destruction and removal efficiency of the incinerator (including APCE)
POHC. -POHC „ ._-_
*100 ("ercent)
.n
EERC Energy and Environmental Research Corporation (Irvine, California, Telephone (714)
859-8851)
EPA United States Environmental Protection Agency
ESD Environmental Systems Division of Acurex Corporation (Mountain View, California,
Telephone (415) 961-5700)
ESP Electrostatic precipitator
FF Fabric Filter
HCI Hydrochloric acid emissions regulated under RCRA to 1 percent of organic chlorine
feed or 1.8 kg (4 lb)/hr maximum emission rate
HHV Higher heating value
HWCTDB Hazardous Waste Control Technology Data Base at ORNL
XVII
-------
List of Terms (continued)
ID Induced draft
I&M Inspection and maintenance
IWS Ionizing wet scrubber
kVA kilovolt-amperes
L/G Liquid-to-gas ratio
LHV Lower heating value
MM5 EPA Modified Method 5 Paniculate Stack Test Procedure
MRI Midwest Research Institute (Kansas City, Missouri, Telephone (816) 753-7600)
NPDES National Pollutant Discharge Elimination System • .. . ,
ORNL Oak Ridge National Laboratory
PCC Primary combustion chamber
PIC Products of incomplete combustions
POHC Principal Organic Hazardous Constituent
QA/QC Quality Assurance/Quality Control
RCRA Resource Conservation and Recovery Act of 1976 and Amendments
RREL Risk Reduction Engineering Laboratory, USEPA, Cincinnati, Ohio
SCC Secondary combustion chamber
SCFM Standard cubic feet per minute
TSD Treatment, Storage, and Disposal
TSLoO2 Thermal stability at low or deficient oxygen level
TSHiO2 Thermal stability at high or oxygen rich level
TUHC Total unburned hydrocarbon
UDRI University of Dayton Research Institute
VOST Volatile organic sampling train
aFor this document, PIC refers to RCRA Appendix VIII organic compounds (100 ppm) not present in the feed
that results from combustion of waste.
bRCRA Appendix VIII organic compounds selected for evaluation of ORE during trial burn.
XVIII
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Conversion Factors
Multiply
atmospheres (pressure)
centigrade (C)
centimeter (cm)
centipoise (cP)
cubic centimeter (cm3)
cubic meter (m3)
cubic meter/second (m3/s)
gram (g)
gram/(centimeter»second) (g/[cm»s])
gram/cubic centimeter (g/cm3)
gram/cubic meter (g/m3)
gram/liter (g/L)
gram/milliliter (g/mL)
inch of water @4°C
(in H2O @ 4°C)
kilogram (kg)
kilogram/minute (kg/min)
kilojoule (kJ)
kilojoule/kilogram (kJ/kg)
kilojoule/second (kJ/s)
liter (L)
liter/cubic meter (L/m3)
meter (m)
pascal (Pa) (kPa = 103Pa)
pascal»seconds (Pa»s)
By
101.3
°F = (1.8 x °C) + 32
°K = °C + 273.17
0.254
0.01
0.061
35.31
1.31
1,000
2119
0.001
0.0022
1
62.427961
0.437
1,000
0.0624
1
0.0025
0.0361
2.205
132.3
0.9478
0.43
3,412
0.035
7.48
3.281
9.869233 X 1Q-6
10
10.00
To Get
kilopascal O(kPa)
Fahrenheit (F)
Kelvin (K)
inch (in)
gram/(centimeter*second) [g/(cm»s)J
cubic inch (in3)
cubic foot (ft3)
cubic yard (yd3)
liter (L)
cubic feet per minute (cfm)
kilogram (kg)
pound (Ib)
poise (P)
pound/cubic foot (Ib/cu ft)
grain/cubic foot (gr/cu ft)
part/million (ppm)
pound/cubic foot (Ib/cu ft)
gram/cubic centimeter (g/cm3)
atmosphere (atm)
pound/square inch (psi)
pound
pound/hour (Ib/hr)
British thermal unit (Btu)
British thermal unit/lb (Btu/lb)
British thermal unit/hour (Btu/hr)
cubic foot (cu ft)
gallon/1000 cubic feet (gal/1,000 cu ft)
foot (ft)
atmosphere (standard) (atm)
dyne/square centimeter (dyne/cm2)
poise
XIX
-------
Multiply
poise (P)
square meter (rr»2)
stoke (St)
ton (metric)
By
100.00
1
1
0.0672
10.76
1x102
1
3.875
0.001076
1,000
1.1023113
To Get
centipoise (cP)
dyne*second/square centimeter
gram/(centimeter»second) (g/[cm«s])
pdund/(second«foot) [lb/s«ft]
square foot (sq ft)
centistoke (cSt)
square centimeter/second (cm2/s)
square foot/hour (ft2/h)
square foot/second (ft2/s)
kilogram (kg)
ton (short 2,000 Ib mass)
xx
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Acknowledgments
This guidance document was prepared for the U.S. Envfrbnmental Protection Agency's (EPA's)
Office of Solid Waste and the Office of Research and Development under the overall direction
of Sonya Stelmack and C. C. Lee. The document was prepared by Acurex Corporation's
Environmental Systems Division with contributions by the Midwest Research Institute (MRI), and
the Energy and Environmental Research Corporation (EERC).
Principal Investigator: Leo Weitzman (Acurex)
Assistant Investigators: Andy Murphy and Carlo Castaldini (Acurex)
Technical contributions were also made by Robin Anderson (EPA), Donald Oberacker (EPA),
Wyman Clark (EERC), Gary Hinshaw (MRI), Scott Klamm (MRI), Randall Seeker (EERC),
Andrew Trenholm (MRI), Barry Dellinger (University of Dayton Research Institute).
Additional technical contributions and review were provided by a panel of incineration experts
from selected EPA Regional Offices. This panel included Gary Gross of Region III, Betty Willis
of Region IV, Y. J. Kim of Region V, and John Hart of Region IX.
Drafts of this document were also reviewed by the Incinerator Permit Writers' Work Group of
the EPA and by the Research Committee on Industrial and Municipal Waste of the American
Society of Mechanical Engineers, as well as Joseph J. Santoleri of Four Nines, Inc.
1
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j
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XXI
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CHAPTER 1
Introduction
When an owner or operator of a hazardous waste
incinerator is issued a permit, conditions are specified
that must be satisfied during operation. These
conditions include limits on operating parameters
such as temperature, gas residence time, and CO
emissions that are chosen to ensure that legal and
safety standards are met. The limits are chosen by
analysis of the results of a "trial burn" that
demonstrates the performance of the incinerator. This
handbook provides guidance on using trial burn data
to set realistic and enforceable permit conditions.
Conversely, the guidance in this handbook can be
used to design a trial burn for an incinerator. The
handbook also provides suggested formats for
presentation of trial burn data.
This chapter describes the impact of the trial burn
and the data it generates on the permitting process.
This is not a comprehensive review of the regulations
and permitting procedures but is a summary to
provide background for the reader.
1.1 RCRA Regulations
The Resource Conservation and Recovery Act
(RCRA) requires the Environmental Protection
Agency (EPA) to establish regulations governing the
handling of hazardous wastes. Regulations governing
incineration of hazardous waste wer'e first
promulgated on January 23, 1981, and have since
been amended numerous times. These regulations,
codified in 40 CFR Part 264, Subpart 0 and Part 265,
Subpart O, are part of EPA's comprehensive set of
regulations that prescribe design and performance
standards for hazardous waste production, storage,
transport, disposal, and treatment. A permit program
that is used to administer the regulations.
The RCRA regulations cover a wide variety of
facilities. They set standards for generators and
transporters of hazardous wastes and for owners and
operators of treatment and disposal facilities. The
general permit requirements for all treatment, storage,
and disposal (TSD) facilities are described in
Standards for Owners of Hazardous Waste
Treatment, Storage, and Disposal Facilities, 40 CFR
264. These regulations require that an owner or
operator satisfy requirements such as to:
• Develop a contingency plan and emergency
procedures
• Maintain extensive records
• Develop a closure and post-closure plan
• Meet financial requirements
• Manage containers, tanks, surface impoundments,
waste piles, and landfills properly
The permit regulations governing hazardous waste
incinerators are covered in 40 CFR 264, Subpart 0,
which requires that the owners or operators also
perform the following:
• Analyze wastes as specified in the permit
• Meet the following performance standards:
- 99.99 percent destruction and removal efficiency
(DRE) of selected principal organic hazardous
constituents (POHCs) and 99.9999 percent DRE
for dioxin listed wastes
- 99 percent removal of hydrochloric acid (HCI) or
1.8 kg (4 lb)/hr HCI emissions, whichever is
greater
- 180 mg/dscm (0.08 gr/cu ft) of particulate
emissions (corrected to 7 percent 62)
• Operate the incinerator according to operating
conditions specified in the permit for the following:
- Carbon monoxide (CO) level in exhaust
- Waste feed rate and composition
- Combustion temperature
- Indicator of combustion gas velocity
- Allowable variations in design
- Other requirements necessary to meet
performance standards
• Control fugitive emissions
• Install automatic waste feed cutoff
• Perform inspections and monitoring (I&M)
• Remove all hazardous waste and hazardous waste
residues upon closure
-------
Although not addressed herein, upcoming
amendments to the incinerator regulations may
include:
• Changes in the requirements for carbon monoxide
(CO) emissions
• Risk-based limits on metals emissions
• Risk-based verification of HCI emissions
• Lower particulate emission limits based on the best
demonstrated available technology
1.2 Incinerator Permitting Requirements
The RCRA regulations require all owners and
operators of TSD facilities to obtain an operating
permit from the appropriate regulatory agency: the
EPA Regional Office or, if authority has been so
transferred, a State agency. To obtain a permit, the
applicant submits the following information:
• Description of the facility
• Security procedures and inspection schedule
• Contingency plan
• Description of preventive maintenance procedures
• Description of the waste
• Personnel training program
• Plan and cost estimates for closure
• Assurance that the operator of the facility is
financially responsible
The permitting process for an incinerator usually
includes a "trial burn," which is a test to determine
whether the unit can meet the performance
requirements specified by the regulations. Although it
is possible to satisfy this requirement by submitting
information showing that a trial burn is not required,
this is a rare occurrence that will not be discussed
here. As part of the permitting process for a new
incinerator, the owner or operator is required to obtain
prior approval of a trial burn plan from the regulatory
authority. Table 1-1 lists the major information that
must be included in a trial burn plan.
Table 1-1. Contents of Trial Burn Plan
Analysis of waste(s)
Quality Assurance/Quality Control (QA/QC) Plan
Engineering description of facility
Sampling and monitoring procedures
Test schedule
Test protocol (operating conditions)
Emissions control operating conditions
Shutdown procedures
Other necessary information
There are different procedures for permitting new and
existing hazardous waste incinerators. Existing
incinerators are those that have been operating under
interim status. These incinerators receive a RCRA
permit after the trial burn. The trial burn plan does not
require prior approval from the permitting agency,
although this is highly recommended.
The other permitting procedure is for new
incinerators. Because these are not allowed to be
constructed or to operate without a permit, they are
permitted prior to construction. Typically, the permit
allows them to operate for a limited period of time
after construction and prior to the test burn to allow
time for startup and shakedown.
1.2.1 New Facilities
Rgure 1-1 outlines the major steps in the permitting
of new facilities. First, the permit application including
the trial burn plan (or in rare cases, data in lieu of the
trial burn) is submitted to the permitting authority.
Then the application goes through an administrative
review to ensure that the application and test plan
include all the major components required by the
regulation. After this review, the application is
evaluated to determine whether all the technical'
information required is provided and if it is internally
consistent. It is important to note that even though
the regulations provide for a two-step administrative
and technical review process, many offices combine
these steps and do not consider the application
complete until it contains all the information
necessary to issue the draft permit.
The permit writer then makes a determination about
the likelihood that the facility will achieve compliance
with the RCRA regulations and that its operation will
not be a hazard to public health or the environment.
This procedure is complex, and the permit writer may
seek assistance from a number of the manuals listed
in Appendix A. At this point, a tentative decision is
made to issue or deny the permit. This decision is
followed by public notice, a public comment period,
and final issuance or denial of the permit.
After the permit is granted, the facility is built and
operated under the startup/shakedown provisions of
the regulations. The permit will include restrictions on
operation during this period. This "pretrial burn"
period may last up to 720 operating hours (defined as
hours of operation while hazardous waste are burned
rather than elapsed time or time when only
nonhazardous fuels are burned) and may be extended
for an additional 720 hours of operation. It is followed
by the trial burn.
Following the trial burn, the facility operates under
conditions set by the Director (the EPA Regional
Administrator or State Director for States with
permitting authority) until the trial burn results are
submitted and evaluated. The evaluation is designed
to answer the following two questions:
-------
Figure 1-1. Incinerator permitting process - new facilities.
CO
Permit application
Technical evaluation
period
• Design
• Operation
• Waste
characterization
Trial burn plan
Deficiencies
• Completeness
• Accuracy
• QA/QC
IsRCR
compliance
probable?
Information
complete?
Public
comment
period
Issue draft permit for
• Pretrial bum
period
Trial burn
Posttrial bum
period
Long-term
operation
Pretrial
bum period
Public
comment
period
Issue/
deny
permit?
Construction
of facility
period (trial burn
data evaluation)
-------
• Under what operating conditions (if any) did the
facility satisfy the RCRA requirements?
• Are the conditions in the permit adequate, or must
they be modified to reflect the results of the trial
burn?
Assuming that the trial burn was successful, the
permit conditions are modified, if necessary, and the
facility proceeds to operate.
1.2.2 Existing Incinerators
The permitting procedure for existing incinerators, i.e.,
those operating under interim status, is shown in
Figure 1-2. As can be seen, the procedure is similar
to that for new incinerators. The principal difference is
that because the facility is already operating prior to
being issued a permit, it does not need one for either
startup and shakedown or for the trial burn] As a
result, the decision to approve or deny the permit is
deferred until after the trial burn results have been
submitted and evaluated. Once again, the simplified
flow diagram (Figure 1-2) should not be interpreted
to mean that the public comments cannot alter this
issue/deny decision for the permit.
" "&— -. " ' • . •
The sections above describe the permitting process
in general terms. Regulations in 40 CFR Part 270 and
in Part 284, Subpart O, should be consulted for full
information.
1.3 Evaluating a Trial Burn Plan and
Establishing Permit Conditions
Sections 1.2.1 and 1.2.2 briefly described the
permitting process for both existing and new
incinerators. They identified the point where the trial
burn fits into the overall permitting procedure and the
points where the permit writer must evaluate the trial
burn information. The remainder of this, handbook
gives guidance on assessing the trial burn plan (if
prior agency approval is sought or required) and the
trial burn results and on establishing the operating
conditions specified in the permit that is issued for the
facility; they are referred to as the "permit
conditions."
Figure 1-3 illustrates steps 1-3 that are followed in
evaluating the trial burn plan and in establishing the
permit conditions relating to the plan. Figure 1-3 also
illustrates steps 4-6 that are followed after the trial
burn to set permit conditions.., After the permit
application is received and found to be complete and
technically acceptable, the trial burn plan is reviewed.
The evaluation process described here is for a new
incinerator; however, because the procedure for new
and existing units is virtually identical except for the
point in the process where the permit is actually
written (before the trial burn for a new incinerator and
after the trial burn for an existing one), the remainder
of this handbook will not differentiate these two
permitting Scenarios further.
< ' ; '. . • ' > :••.
Step 1 in evaluating the trial burn plan involves
selection of the appropriate design and operating
parameters (referred to as control parameters) that
form the basis of the permit. During this evaluation,
the permit writer and the applicant should agree on
the following: .
• Key incinerator operating parametersv
• The parameters for which limits will be specified in
the permit
• The effect of the trial burn on establishing these
limits •
*; ;'
Prior to finalizing the trial burn plan, agreement on
these points between the applicant and permit writer
is very important and highly recommended. In many
cases, operational difficulties can be minimized and
regulatory compliance can be achieved by proper
design of a plan agreed to by the two parties.
Step 2 in' evaluating the trial burri plan involves a
Comparison of the incinerator system design
parameter^ and the control parameters. This review
examines ,the' doijitrdl parameters for both internal
consistency and1 for consistency with the design
parameters. This review also determines whether the
operation of this system is likely to comply with the
pertinent regulations and, more importantly, if the test
is likely to result in an imminent hazard to public
health or the environment.
Jp step 3 of the trial plan evaluation process, limits are
set on the contrbl parameters consistent with the step
2 reyiew. These limits are included.in the permit as
conditions, the', permit conditions, that -define the
range of acceptable operation for: the incineration
;system for the four phases of operation applicable to
a new incinerator: \ ;^ '-
• Startup/shakedown
• Trial burn
• Post-trial burn
» Continuing operation
The permit conditions also include monitoring and
automatic cutoff requirements on some ofkthe control
parameters. The mbnitofirtg conditions are included to
validate compliance and facilitate enforcement
activities.
this handbook does not deal specifically with the trial
burn except for a discussion of the format
recommended for presenting the results. The reader
is referred to the appropriate manuals listed in
Appendix A for further guidance on this subject.
During the trial burn, the control parameters are
measured, and the values are recorded in an
-------
Figure 1-2. Incinerator permitting process - existing facilities (interim status).
Permit application
Technical evaluation
period
• Performance
• Operation
• Waste
characterization
eficiencies
Completeness
Accuracy
QA/QC
Information
complete?
Is trial
burn
required?
en
Yes
Notice of
intent to
deny permit
,
No
; Review j
; trial bum j
>j plan
No
—I /• V
! Modify j / \
' trial burn \A No ./' Is trial \
! plan * «x burn OK? /
Yes
Dashed lines indicate optional steps.
;JHI
-------
"operating log." This log is as important as the
emission and pollutant release data and must be
included in the trial burn report. It is submitted along
with the results of the trial burn to the permitting
agency.
In step 4, the permit writer compares the values of
the control parameters with the measured levels of
emissions, effluents, and wastes produced by the
incinerator during the trial burn. The intent of this
evaluation is to verify that the limits set in step 3 do,
indeed, result in compliance with the regulations and
with safe and environmentally acceptable operation. If
necessary, the limits on the control parameters are
adjusted at this point to reflect the results of the trial
burn.
Step 5 of the permitting process is setting the permit
conditions for the incinerator. The permitting strategy
for the incinerator is designed to organize the limits
on the control parameters into a consistent,
enforceable set of permit conditions. See Sections
3.4, 3.5, and 3.6 for methods that can be used to
develop the strategy.
The final step, step 6, in this process is specification
of the I&M requirements in the permit as required by
40 CFR 264.347. These requirements can include
operational, safety, and other hardware that does not
directly relate to the trial burn and the permit
conditions developed from it. The I&M conditions
discussed here emphasize those requirements that
relate to the control parameters. Other I&M
procedures, i.e., those put on the thermocouples,
pressure sensors, alarms, and circuitry that monitor
the control parameters and trigger actions such as
waste feed cutoffs are outside the scope of this
handbook. .
-------
Figure 1-3. Steps to evaluating trial burn plan and establishing permit conditions.
Trial burn plan
Design
Operating conditions
Estimated emissions
Estimated waste
Other
k
Step 1
Select control parameters
• Design parameters
• Operating parameters
— Temperature
- CO
- Gas flow rate
- Pressure
- Etc.
Step 2
Review of
Design
Operating conditions
Etc.
or consistency with
Design parameters
Operating parameters
and likely compliance with
Regulations
Safety & environmental
factors
— 1
Step 3
Set appropriate permit
conditions
• Operation
• Monitoring
• Performance
• Etc.
Trial bum report
Design
Measured emissions
Measured waste
Other
Step 4
Evaluate values of
• Control parameters
• Emissions
• Effluents
• Wastes
•i» Etc.
k
Steps
Determine permitting
strategy
• Single point
* Multiple point
• Universal
• Set operating envelope
Step 6
Specify inspection and
maintenance requirements
• Equipment 1 & M
• Alarms
• Emergency cutoffs
-------
-------
CHAPTER 2
Control Parameters
Incinerator operating conditions are defined by
"control parameters" such as temperature, pressure,
waste feed rates, and limits on halogens in the
wastes, which can be reliably measured during
incinerator operation. Control parameters are
important because performance parameters such as
ORE and particulate emissions cannot be directly and
continuously measured during actual operation. As a
result, limits are placed on the control parameters,
i.e., ranges are set for measurable parameters, and
these limits are set as conditions in the final operating
permit. The ranges of acceptable conditions are
determined from the trial burn. As long as the
incinerator is operated within these ranges, it is
assumed to be operating under the same conditions
as during the successful trial burn and, hence, to be
in compliance with the regulations. It is necessary,
therefore, to select the control parameters before the
trial burn and to measure their values throughout the
trial burn so that the results may be used to set their
limits.
This chapter recommends the control parameters that
should be used and explains the reasons they were
chosen. Note that it is assumed that the reader is
familiar with the construction and operation of the
common types of incinerator systems and ancillary
equipment. See Appendix B for a discussion of
incinerator designs and guidance on reviewing them
during the permitting process.
Control parameters fall under the following two
classifications:
1. System Parameters, defined as basic design
specifications that typically are fixed for a given
incinerator or incinerator configuration
2. Operating Parameters, defined as easily
changeable parameters that control the day-to-
day performance of the incinerator
The system parameters are functions of the design
and construction of the incineration system and
normally cannot be changed once the incinerator is
built. They include such items as:
• Size and shape of the primary combustion
chamber (PCC) and secondary combustion
chamber (SCC)
• System configuration
• Size of pipes and ducts
• Capacity of the fans and pumps
• Location and type of monitoring equipment
• Type and configuration of the air pollution control
equipment (APCE)
• Dimensions of components such as feed chute,
auger, and screw feeder for solids handling
Generally, system parameters are incorporated into
the permit by reference to design drawings and
specifications and are not directly discussed further
here. Operating parameters are easily changed to
accommodate fluctuations in the demand on the
system and other constantly changing factors. These
parameters include the following:
• Temperatures at various points in the PCC, SCC,
APCE, stack, etc.
• Pressure at various points in the system and
pressure drops across key pieces of equipment
within the system
• Carbon monoxide (CO) and 02 concentrations at a
selected CO monitoring point
• Gas flowrates in the system
• Waste and primary fuel feed rates
• Waste composition such as ash, moisture, volatile
content, and halogen content
• Excess combustion air into PCC and SCC
• Burner atomization setting
• APCE-related parameters, i.e., pressure drop,
scrubbing liquor flowrate, pH, and plate voltage
To establish meaningful and enforceable permit
conditions and to avoid mutually exclusive
requirements, the operating parameters should be
considered in relation to each other and in relation to
the system parameters. A goal of this handbook is to
-------
avoid setting redundant parameters, where consistent
with technical judgement and regulatory requirements;
however, it is important to be aware of the
interactions between the various permit conditions
and ensure that they are internally consistent. For
example, for some facilities, a limit on minimum
temperature and maximum gas throughput would also
define the minimum and maximum thermal duties
(total heat input), waste feed rate, and excess 02-
Since the regulations require that at least some of
these other parameters be regulated, it is important
that they be internally consistent. Wherever
technically possible and consistent with the
regulations, it should be the permit writer's goal to
eliminate redundant restrictions.
The remainder of this chapter discusses the control
parameters and selection of their limits. Table 2-1
lists the control parameters pertinent to most
incinerator facilities. As can be seen, they have been
grouped into three categories identified as groups A
through C. This nomenclature is somewhat arbitrary
and was chosen simply to clarify the ensuing
discussions.
Group A parameters are based strictly on trial burn
results and require continuous monitoring and
automatic waste feed cutoff when permit limits are
exceeded. Because these may fluctuate rapidly
during normal operation, short-term deviations from
the acceptable range may be tolerated. These
variations are discussed further in Section 2.1.
Group B and C parameters are not continuously
monitored and, consequently, are not interlocked with
automatic waste feed cutoff. The primary difference
between groups B and C is that operating limits for
group B parameters also are based strictly on trial
burn results, whereas limits for group C parameters
are based on equipment design specifications and do
not necessarily reflect operational settings recorded
during the trial burn.
The only requirement for group C parameters is that
the operating conditions recommended do not deviate
from those specified by the equipment manufacturer
and are compatible with good operating practices.
This treatment of group C parameters allows greater
flexibility in the permit because worst-case
operational settings for these parameters are not
investigated during the trial burn to demonstrate
compliance with a desired envelope. This procedure
formally and legally requires that the operator use the
equipment in the manner and under the conditions for
which it was designed. For example, nozzles will
typically be designed to properly atomize a liquid or
slurry of specified ranges of viscosity, vapor pressure,
etc. The nozzles will not perform well if these ranges
are exceeded, and incinerator performance may
deteriorate. Permit conditions that require adherence
to manufacturer specifications thus ensure good
operating practices.
The issue has been raised that, in some cases, there
are no manufacturer's specifications because the
equipment may have been made by the applicant or
custom built for this application. Also, in some cases,
the applicant may find that the equipment works well
outside the specified ranges. In that case, the
applicant should provide design specifications and, if
the reviewer requests, backup material on the
adequacy of the specifications and of the equipment.
It may be necessary to incorporate testing of the
proposed ranges for these parameters into the trial
burn. If the trial burn shows the incinerator to perform
properly when the equipment in question operates
well outside the manufacturer's or design speci-
fications, the permit limits may be set at the
demonstrated levels.
Note that a waste feed cutoff is not the same as an
incinerator shutdown. In a cutoff, the incinerator may
keep operating on auxiliary fuel and on nonhazardous
waste until the problem is corrected; and, except in
extreme situations, continued operation is desirable
so that furnace temperature is maintained. A control
parameter such as temperature that exceeds
specification triggers a waste feed cutoff, not a total
shutdown of the system.
A final word of caution regarding the type of systems
used for the waste feed cutoffs. The systems must
be fully automatic to satisfy the requirements of the
regulation. A meter or strip-chart output that is
periodically checked by an operator who shuts off the
waste feed if a problem is noticed is not an adequate
substitute for an automatic system. An automatic
system must monitor the parameter and initiate the
waste feed shutoff when an excursion is detected. It
is highly desirable that the system also trigger an
alarm as the parameter approaches the cutoff limit to
allow for corrective action.
The following sections explain the reasons these
parameters were selected. The discussion provides
insight on the selection and interdependence of the
control parameters. It also suggests alternative
approaches that may be more appropriate in special
cases. The section closes with a discussion of those
parameters which were considered for inclusion but
were not selected along with the rationales for
excluding these parameters and a discussion of
situations when they should be considered.
2.1 Group A Parameters
There are six "group A parameters":
1. Temperature of the gas at each combustion
chamber exit
2. CO emissions
10
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Table 2-1.
Group
Control Parameters
Parameter
Group A
Continuously monitored parameters are interlocked with the
automatic waste feed cutoff. Interruption of waste feed is
automatic when specified limits are exceeded. The
parameters are applicable to all facilities.
Group B
Parameters do ngt/equire continuous monitoring and are thus
not interlocked with the waste feed cutoff systems. Operating
records are nevertheless required to ensure that trial burn
worst-case conditions are not exceeded.
Group C
Limits on these parameters are set independently of trial-
burn test conditions. Instead, limits are based on equipment
manufacturers' design and operating specifications and are
thus considered good operating practices. Selected
parameters do not require continuous monitoring and are not
interlocked with the waste feed cutoff.
1. Minimum temperature measured at each combustion chamber exit
2. Maximum CO emissions measured at the stack or other appropriate
location
3. Maximum flue gas flowrate or velocity measured at the stack or other
appropriate location
4. Maximum pressure in PCC and SCC
5. Maximum feed rate of each waste type to each combustion
chamber1
6. The following as applicable to the facility:
• Minimum differential pressure across paniculate venturi scrubber
• Minimum liquid-to-gas ratio and pH to wet scrubber
• Minimum caustic feed to dry scrubber
• Minimum kVA settings to ESP (wet/dry) and kV for ionized wet
scrubber (IWS)
• Minimum pressure differential across baghouse
• Minimum liquid flowrate to IWS
7. POHC incinerability limits
8. Maximum total halides and ash feed rate to the incinerator system
9. Maximum size of batches or containerized waste1
10. Minimum particulate scrubber blowdown or total solids content of the
scrubber liquid
11. Minimum/maximum nozzle pressure to scrubber
12. Maximum total heat input capacity for each chamber
13. Liquid injections chamber burner settings:
• Maximum viscosity of pumped waste
• Maximum burner turndown
• Minimum atomization fluid pressure
• Minimum waste heating value (only applicable when a given waste
provide 100% heat input to a given combustion chamber)
14. APCE inlet gas temperature2
11tems 5 and 9 are closely related; therefore these are discussed under group A parameters.
2 Item 14 can be a group B or C parameter. See text in Section 2.1.6.
3. Indicator of combustion gas velocity (flue gas
flowrate)
4. Maximum waste feed rate
5. Pressure in the PCC
6. APCE
The regulations (40 CFR 264.345(a)) specifically
require that the levels of the first four parameters be
set in the permit based on the trial burn results. They
also allow additional conditions to be set as deemed
necessary by the permit writer. In addition, 40 CFR
264.347 requires continuous monitoring of the first
four parameters. It is recommended that those
parameters for which the permit sets conditions but
does not require continuous monitoring be logged at
least every 15 min. The following sections discuss
each of the parameters and setting conditions for
them.
2.7.7 Temperature
The regulations require that suitable interlocks be
provided to shut off the hazardous waste feed if the
temperature drops below a value specified in the
permit (see 40 CFR 264.345(f)). This section gives
guidance on establishing the minimum temperature in
each combustion chamber which will trigger the
automatic waste feed cutoff.
A minimum temperature must be specified for each
chamber of an incinerator. It is recommended that the
temperature at which the waste feed is cut off be
specified as not less than the lowest mean
temperature at which a successful test (minimum of
three runs) occurred. If this level is not appropriate for
a facility, a rolling average temperature limit similar to
that which will be used for CO emissions is
acceptable. When these limits are established, it is
important that the minimum temperatures for both the
PCC and SCC be determined from the same test. As
discussed in the example given in Chapter 4, it is
possible for the SCC to achieve its minimum
temperature during one test while the PCC achieves
its minimum during another.
It is not necessary to cut off all waste feeds when the
temperature in only one chamber drops below the
11
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minimum. Table 2-2 summarizes the recommended
guidelines for specifying this.
Table 2-2. Recommended Waste Feed Cutoffs
Waste Feed Is Cut Off To:
Gas Temperature Below
Minimum In:
SCC only
PCC only
SCC and PCC
Both PCC and SCC
PCC only
Both PCC and SCC
PCC = Primary combustion chamber.
SCC = Secondary combustion chamber.
As shown, hazardous waste feed to both chambers
should be stopped if the temperature in the SCC
drops below the trigger value. If only the PCC
temperature drops below the trigger value, the
hazardous waste feed to the SCC may continue, and
only the hazardous waste feed to the PCC needs to
be stopped.
The rationale for waste feed cutoff to both chambers
when the gas temperature in the SCC drops below
the minimum is that the gas leaving the PCC may still
contain undestroyed POHCs and hazardous products
of incomplete combustion (PICs). These compounds
may not be destroyed if the SCC is not maintaining
an adequate temperature. Continued operation of the
SCC if the temperature in the PCC drops below the
minimum is necessary since the waste usually
contributes energy to maintain the SCC temperature.
Sudden changes in the SCC fuel feeds should be
avoided when there are problems with the PCC that
may be releasing POHCs or PICs. As long as the
SCC temperature is being maintained, waste feed to
it may continue.
In performing this evaluation, the permit writer is
cautioned to consider the location and placement of
the temperature sensor. These factors are especially
critical when upset conditions are being monitored;
for example, during the extreme case of "flameout" in
the SCC. The temperature of the bulk gas in the
chamber would quickly drop; however, the walls,
which have a very high thermal mass, would remain
hot for a long time. If improperly installed, the
temperature sensor would absorb heat by radiation
from the walls and indicate a higher temperature than
that to which the residual POHCs are actually being
exposed. See the Engineering Handbook of
Hazardous Waste Incineration, (1) SW-889, and
Hazardous Waste Incineration Measurement
Guidance Manual (2) for more information on this
subject.
The remainder of this section discusses the effects of
temperature, gives additional information to explain
the above recommendations, and shows how the
temperature limits are calculated from test data.
Mechanics of POHC Destruction
Destruction of a POHC is a multistep process. First,
the compound is vaporized either in a solids handling
system such as a rotary kiln, hearth, or fluidized bed
or, if a liquid, by a nozzle. Then, the vaporized
materials are exposed to a flame where the majority
of the POHCs are destroyed. A small fraction of the
POHCs that typically escape the flame zone requires
an extended residence time (~1 sec) at elevated
temperatures [~1,000°C (1,830°F)] to be destroyed.
The time/temperature dependence of the destruction
process is described in Appendix C. Generally, the
longer the residence time and the higher the chamber
gas temperature, the greater the destruction of the
POHC fraction that escapes the flame; the different
segments of the complex flow patterns in the
combustion chamber will have different temperatures.
The area immediately around the flame will be very
hot and poor in oxygen. As the gases move away
from the flame, they mix with additional oxygen
(secondary air), but their temperatures drop. Along
the walls, the refractory will be relatively cool, and it
will keep the adjacent gases cool.
The degree of POHC destruction that will be achieved
in any one slug of material that passes through the
combustion chamber will be a function of the
time/temperature (and oxygen) regime that the
particular slug is exposed to as it follows a somewhat
random path through the chamber. The majority of
the slugs of gas that contain POHCs will pass through
the flame and be destroyed, A small percentage,
however, will bypass the flame and follow a path
which typically results in a lower level of POHC
destruction. This complexity does not lend itself to
detailed analysis without a major investment in time
and testing that is beyond the permitting process in
all but special cases. Fortunately, the trial burn data
preclude the need for a detailed temperature profile of
the incinerator.
Determining Temperature Limit
As discussed above, the temperature at which waste
must be cut off to the incinerator is determined from
the trial burn. This subsection discusses how such a
determination can be made and gives additional
rationale to support the decision.
According to EPA policy for trial burns, three runs
must be conducted at each temperature although a
larger number of replicates may performed to provide
insurance against loss of data from any one run. The
minimum operating temperature for the incinerator is
defined as the lowest temperature at which a set of
runs was performed during the trial burn. If a test is
conducted at only one temperature, that temperature
is defined as the minimum.
12
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During each test, the replicate runs are performed
under as similar conditions as practical; however, a
slight variation in the mean temperature is common.
The mean temperature used to set the minimum is
the average of the mean temperatures of the
replicate runs constituting the test.
The permit condition for the minimum operating
temperature is the lowest mean temperature that
resulted in a successful test. The automatic interlock
should be set so that the waste feed to the
appropriate chamber is cut off when the temperature
drops below this value.
It is recognized that this is a somewhat conservative
automatic waste cutoff level. If the incinerator is
operated at the lowest mean temperature at all times,
frequent cutoffs are likely. The operator can avoid the
cut-off trips by operating the incinerator at a slightly
higher temperature than this minimum. Thus, the trial
burn would be performed at a temperature slightly
lower than that desired for operation.
The second method that can be used is to base the
waste feed cut off on an hourly rolling average of the
temperature during operation. The hourly rolling
average has been defined as the mean of the 60
most recent 1-min values measured by the
continuous monitoring system. For calculation of each
hourly rolling average value, the new data point is
added to those taken over the specified time period
and the least recent data point is excluded from the
average. The permit condition then would specify that
waste feed should be cut off when either (1) the
temperature drops below a minimum (which is the
lowest temperature measured during the trial burn ) or
(2) the rolling 60 minute average temperature falls
below the mean determined from the trial burn. The
absolute minimum temperature for waste cutoff,
condition (1) above, should be the lowest temperature
from the trial burn. Its purpose is to trigger an
immediate waste feed shutoff in case of a sudden,
catastrophic temperature decrease.
T.ne following example illustrates the function and
intent of the lower temperature limit. Consider an
incinerator whose secondary chamber's temperature
is being maintained with a high heating value
hazardous waste. Assume, further, that because of
improper blending, water has accumulated in the
waste storage tank and the feed system begins
sending this water instead of the combustible waste
to the high heating value waste burner. The flame
would become very unstable and the temperature in
the SCC would drop rapidly; however, the
temperature sensor would continue to average the
drop in temperature with the values from the paste
hour of operation and not trigger waste feed cutoffs,
or alarms, for several minutes. A secondary cutoff at
a low temperature would eliminate this problem. It is
recognized that the flame instability described above
would most likely trigger a waste feed cutoff because
of CO limits; however, these are also based on a
rolling average and could, conceivably, also result in a
delay.
In order to assure that normal fluctuations in the
temperature do not trigger waste feed cutoffs, the
lower temperature should be set at the absolute
lowest (not the mean) temperature encountered
during the trial burn. This is essential since the
purpose of requiring the added complexity of a rolling
average temperature would be defeated if normal
variations in the temperature could trigger a waste
feed cutoff.
For example, Table F-15 of Appendix F lists the
SCC and PCC temperatures for each minute during a
trial burn. The "sampling time" for these data is,
therefore, 1 min. The rolling average of the SCC and
PCC temperatures for the first 60 min is the mean of
each set of temperatures recorded between 1,250
and 1,309 min. At 1,251 min, the rolling average
becomes the mean of that calculated between 1,251
and 1,310 min. This pattern is continued for each new
interval.
A rolling average type of permit condition requires
that the temperature monitoring system include, a
computer capable of calculating the rolling average
continuously. Because of the added complexity* the
rolling average conditions should only be used when
requested by the applicant.
The remainder of this section gives background
information to support the two approaches for
establishing the waste feed cutoff level and describes
methods for calculating the mean temperature and
the other values needed to set the permit conditions
on temperature.
The temperature limits recommended can usually pe
readily specified. The trial burn report normally
includes copies of the temperature monitor outputs
and a summary of the mean, maximum, and minimum
values for each run. The temperature of: an
incinerator is always monitored continuously by at
least a strip-chart recorder and usually a data logger
that also records the temperature at 30-sec to 1-
min intervals. The time-weighted average is'the
arithmetic mean of the temperatures recorded at
these intervals. If a mean is not given in the report,- it
can be calculated from the temperature log (if given)
or the strip-chart recorder output by the following
method.
Figure 2-1 is an example of a strip-chart recprder
output. Because fluctuating data usually have a rough
periodicity, a visual examination will identify some
minimum period to the fluctuation. A period smaller
than this minimum is selected as the sampling rate.
For example, if the fluctuations vary at a 1- to 3-
min rate, the 1-min rate is used. Then, the strip-
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Figure 2-1 Example of a temperature trace.
CD
D.
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measure parameters which can be related to the
combustion gas flowrate. Upper limits need to be
placed on combustion gas flow/rates for the following
three reasons. The first is to control the gas
residence time in each chamber. The second is to
control the gas throughput throughout the system to
minimize back pressure at joints and seals; for
example, at the inlet of a rotary kiln to the SCC. The
third is. to control the gas flowrate through the APCE
to ensure that it is not overloaded.
Note that while the measurement of "an indicator of
gas velocity" is required by the RCRA regulations (or
more correctly, they require that limits be placed on
this parameter), it is not an independent variable. The
flue gas flowrate is interrelated with the pressure
measurements described in subsequent sections.
Limits on gas flowrate cannot be set without affecting
the limits on pressure parameters in the incinerator.
This section is not intended to provide detailed
guidance on the type of flue gas measuring device
that should be used. See the Engineering Handbook
for Hazardous Waste Incineration (1), SW-889, and
the Hazardous Waste Incinerator Measurement
Guidance Manual (2) for such guidance. Some
advice is given below on the placement of such
monitors.
The combustion gas flowrate can be monitored in
several different ways. The preferred method is the
use of a direct gas flow monitor at the outlet of the
SCC. In some systems, however, conditions such as
high temperature, high particulate loading, and high
acid gas loading could result in unsatisfactory life and
performance of the monitor.
Another option, and often the more practical one, is to
place the monitor just before the stack. Although this
practice increases the likelihood of introducing errors
due to air infiltration or changes in the water content
of the gas stream, which can be difficult to predict, it
results in an increased life and performance reliability
for the monitor. If this site is chosen for the
combustion gas monitor, the permit writer should add
constraints on the water content and permissible air
infiltration upstream of the monitor to maintain
conditions consistent with those achieved during the
trial burn.
When neither of these alternatives is practical, it may
be possible to measure the combustion air flowrate
instead of the combustion gas. For a given
temperature, the flowrate of the combustion gas (the
products of combustion) can be approximated within
reasonable accuracy by the flowrate of the
combustion air, i.e., the primary and secondary air
being fed to the combustor. In most cases, the
combustion air constitutes 95 percent or more of the
combustion gas, as illustrated by Figure 2-2, which
shows the consistency of this correlation for different
conditions. In many cases, especially for forced-draft
incinerators, the primary and secondary combustion
air can be measured fairly easily. When this is the
case, to monitor combustion air is a good alternative
to monitoring combustion gas.
Another method of measuring the combustion gas
flowrate is to monitor the power usage (voltage and
current are adequate, in most cases) of the induced
draft fans, although sufficient technical justification in
the form of actual power usage versus gas flowrate
should be given to document its accuracy in a given
system.
The limits on the flue gas velocity set by the permit
conditions should be based on the maximum
combustion gas flowrate that was measured during
the trial burn. This flowrate measurement should be
taken at the minimum observed temperatures during
the test to ensure that the condition includes the
lowest temperature and shortest residence time that
achieved acceptable incinerator performance.
2.1.4 Combust/on Chamber Draft or Pressure
The draft or pressure in the chambers of an
incinerator is regulated to minimize the release of
partially burned POHCs and other untreated products
of combustion as fugitive emissions from the PCC.
Fugitive emissions are regulated under 40 CFR
264.345(d). These emissions are of concern in
multichamber and especially in rotary kiln systems
that partially degrade the wastes into gaseous
components in the PCC and feed the off-gases
containing large amounts of POHCs, PICs, acids, and
particulates, first into the SCC where the PICs and
POHCs are destroyed and, then, into the air pollution
control devices where the pollutants are removed to
below the required level. The release of these
intermediate gases is normally prevented by setting
limits on the maximum pressure at which the PCCs
and SCCs can operate.
Normally, the gases from the PCC are forced into the
SCC by the pressure differential between the two. If
there is a sudden increase in the gas production rate
in the PCC or a draft decrease in the SCC that may
be caused by a fan failure or an increase in the
burning rate, partially burned POHCs and PICs as
well as particulate and acid gases from the primary
chamber can be released. Increases in the pressure
in the PCC can be caused by an explosion or when a
drum of exceptionally flammable waste ignites. Any
condition that results in the sudden release of more
gas than the upstream system can accept will result
in an overpressure. Normally, the system between the
PCC and SCC is equipped with seals that can contain
the gas from a specified level of overpressure. When
this level is exceeded, however, untreated gases are
released.
15
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20,000
17,500
I
uJ 10,000
Adiabatic temperature = 2,000°F
Chamber volume = 1,000 ft3
Ideal case: pure air
Combustion with pure monochlorobenzene
Combustion with 10% monochlorobenzene in soil
Combustion with 50% monochlorobenzene in water
Combustion with 25% monochlorobenzene in water
20,000
Figure 2-2. Effluent flow versus air flow for combustion.
40,000
Airflow (Ib/h)
60,000
80,000
The fugitive emissions problem is most common in
rotary kiln incinerators where the kiln must rotate
against a seal between it and the secondary chamber.
Typically, these units are operated at a sufficient draft
to ensure that normal fluctuations in the burning rate
will not result in a pressure above atmospheric. In
addition, the waste and supplemental fuel guns
typically are mounted in openings at the upstream
end of the kiln, and an overpressure would result in
hot gases "backfiring" past the guns. This is a
dangerous situation and indicative of a poorly
designed or operated unit.
A relatively uncommon rotary kiln design is
particularly sensitive to overpressures and the
resulting fugitive emissions. In the typical rotary kiln
design, the kiln enters the SCC without any
constrictions in the gas stream following the rotating
seal. If the kiln, however, is attached to a seal leading
to a hot gas duct that is followed by an elbow,
diameter reduction, or other restriction to the hot gas
flow between the two chambers, the likelihood of
frequent overpressures increases dramatically.
For the majority of the hazardous waste incinerators
that a permit writer is likely to encounter, frequent
fluctuations in pressure at the exit of the PCC usually
indicate highly heterogeneous wastes that burn
unevenly or periodic overfeeding of waste to the
incinerator. If the overpressures are sufficiently high
to result in fugitive emissions from the seals or other
openings between the PCC and SCC, they should be
considered an upset condition that requires the
shutoff of hazardous waste feed to the PCC.
Limits on the PCC draft or pressure should be set in
one of two ways, one for incinerators that are
designed to operate under positive pressure and that
are much more likely to tolerate a short overpressure
without releasing fugitive emissions and the second
for those operating under negative pressure that must
rely on draft to keep the combustion gases in. Table
2-3 summarizes the recommended limits for the
pressure in the PCC.
For forced-draft systems, the automatic waste feed
cutoff for both chambers should be set at the time-
averaged pressure during the trial burn, provided that
there were no fugitive emissions. Brief excursions
above this pressure can be tolerated if they do not
16
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Ff
Table 2-3. Limits on Chamber Draft or Pressure
Forced Draft Induced Draft
(Positive Pressure) (Negative Pressure)
Primary Chamber
Time-averaged Slightly below
pressure determined atmospheric
during trial burn pressure
Secondary Chamber Time-averaged Always below that
pressure determined of the primary
during trial burn chamber
exceed the frequency and maximum excursion
encountered during the trial burn.
For induced draft systems, the PCC pressure level
activating waste feed shutoff can be the lower
pressure of either of the following:
1. Time-averaged pressure measured during the trial
burn, or
2. 2 mm water gauge below atmospheric for the PCC.
The 2-mm water gauge draft is only a guideline, and
a lower pressure should be specified if highly toxic
materials are involved, or if the incinerator appears to
have poorly designed seals.
If pressure variations occurred during the trial burn,
they can be permitted in the permit condition as well;
however, the maximum pressure in the PCC may
never exceed atmospheric pressure under any
circumstances. In fact, if the results of the trial burn
indicate the possibility of surges that result in a PCC
pressure in excess of atmospheric, the operating
conditions of the unit should be evaluated to
determine the cause of these surges, and limits
should be placed on other parameters such as waste
feed and maximum size of container waste to ensure
that this type of surge does not occur.
It is necessary that the maximum pressure in the
SCC must always be below that in the PCC to ensure
that any gases produced in the PCC are drawn
directly into the SCC.
One other point should be mentioned. For those
incinerators incorporating a rotary seal between the
primary and secondary combustion chambers, it is
important that the permit conditions include a rigorous
I&M program for these seals in addition to limitations
on the size and duration of the overpressure. The
seals between the primary and secondary chamber
are exposed to high temperatures, acid gases, and
mechanical wear from the rotation. They must be
properly maintained to prevent a release of unburned
gases during a pressure surge.
2.7.5 Maximum Waste Feed Rate
Regulation 40 CFR 264.345(b) requires that a permit
set limits on the rate at which hazardous waste is fed
to the incinerator. The limits on this parameter serve
several purposes. First, they prevent overload of the
combustion chamber and, thus, reduced incinerator
performance. If low heating value waste is added to
the incinerator at too great a rate, it may cool the
flame and inhibit combustion. Second, waste feed
rate limits keep the residence time above the
minimum level required to destroy the POHCs. The
larger the fuel and waste feed, the greater the flue
gas flowrate and, hence, the lower the residence
time. Also, limiting the waste feed rate also limits (to a
degree) a group C parameter, the heat released per
unit volume (see Section 2.3.2). Finally, limits to the
waste feed rates are often necessary to fix other
parameters such as chlorine or ash feed rates.
Two types of limits should be placed on the total
waste feed. The first is total waste feed per unit time
for each waste stream or waste stream type such as
solid wastes, aqueous wastes, or organic liquids. This
limit is based on the average over time achieved
during the trial burn. The second factor that should be
regulated is the instantaneous waste feed rate. This
parameter is referred to in Table 3-2 as the
"maximum size of batches or containerized waste to
the PCC." This is a group B parameter but is
addressed in this section because of its close relation
to the maximum waste feed rate. The instantaneous
waste feed rate is not important if the waste is fed by
nozzles, a continuous conveyor, or a screw feed. If,
however, the waste is fed in batches as with a ram
feeder or in drums, there is a danger that the batch
that hits the PCC can instantaneously either quench
the flame if, for example, the waste is aqueous or wet
soil, or result in an instantaneous release of heat and
flue gases that exceeds the capacity of the
downstream air handling system. The latter event
would result in puffing at the joint between the PCC
and SCC and in fugitive emissions, as discussed in
Section 2.1.4.
The volatile content of the waste influences the rate
at which such a sudden release would occur. An
excessive amount of volatile material in a waste will
result in a rapid release of hydrocarbons, which, in
turn, will lead to a rapid increase in the PCC pressure
and an increase in the CO level. A shutdown would
be triggered on that basis. This event is discussed
further in Section 2.4.
Drum feeding of waste is particularly susceptible to
this occurrence. To illustrate, consider the case
where an incinerator is fed one 208-L (55-gal)
drum of waste every 15 min in addition to other
wastes on a continuous basis. When that drum hits
the kiln or grate, for example, it will be cold, and it will
first quench the flame and the burning waste in the
PCC. As it heats up, the drum will melt or burn, if it is
a fiber drum, and release the flammable material
within it. A very rapid heat and gas release that may
now overpower the gas handling system will result.
As discussed in Section 2.1.4, this release can result
17
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in puffing and fugitive emissions, or even if they do
not occur, such an event can result in a significant
change in the temperature and the residence time of
the gases in the SCO. This change can affect the
destruction efficiency and, hence, the ORE for the
POHCs.
Such a scenario can be regulated by designing the
trial burn to match both the mean and instantaneous
waste feed rates for the incinerator. For example, the
permit condition could specify that a given waste
stream may not be fed at a rate exceeding 300 kg
(660 lb)/hr with individual batches not exceeding 30
kg (66 Ib) fed at no less than 6-min intervals. Other
ways of specifying this type of limit such as by
maximum drum size can be used depending on the
unique requirements of a given system. Although an
important factor, maximum volatile content of the
containerized waste is not recommended as a permit
condition because it is impractical to measure this
parameter during continued operation. However, it is
recommended that the containerized waste fed during
the trial burn be chosen so as to equal the greatest
amount of volatiles expected during subsequent
operation.
The above approach needs to be modified to
consider different waste streams. An incinerator
which burns all the wastes at a fixed feed ratio will be
the exception rather than the rule. When a variety of
wastes are fed, the trial burn should be designed to
incorporate a combination of waste feeds to ensure
sufficient operating flexibility. The limits on the waste
feeds should be such that the combination of wastes
fed at any one time would result in a total heat
release rate in each chamber that matches the
conditions in the test run. Data from a test burning
one set of wastes should not be used to set limits on
the feedrate for a different category of wastes, but a
certain amount of flexibility in the waste flows based
on the above guidance is acceptable.
In operation, the heating value of the waste does not
have to be known to great accuracy to adhere to the
variations in the waste feeds. Typically, the operator
will feed the waste with the lowest heating value to
the incinerator and then control the temperature at
the exit of the combustion chambers by varying the
feed rate of the wastes with higher heating values. If
the temperature cannot be maintained in this manner,
the operator can either lower the feed rate of the
lower heating value wastes, use supplemental fuel, or
vary the air feed rate.
This procedure will translate into a reasonably
constant heat release rate and, under most
circumstances, a reasonably constant flue gas
flowrate. See the Guidance Manual for Hazardous
Waste Incinerator Permits (3) for further information
on how the heat release rate relates to flue gas
flowrates. Appendix B also briefly describes how the
flue gas flowrate can be calculated.
2.7.6 Air Pollution Control Equipment
The final sets of group A parameters that must be
limited with permit conditions are those relating to the
APCE. Typically, the APCE on a hazardous waste
incinerator removes acid gases (commonly HGI) and
particulate. There are cases where either or both of
these categories of pollutant do not require control.
For example, if the incinerator does not burn
halogenated wastes, no acid scrubber is required and
no limits need to be set on the respective APCE.
Hydrogen chloride emissions will then be regulated by
limiting the chloride content of the wastes so that the
burning of halogenated materials is limited. Monitors
of HCI emissions may prove to be an alternative for
control purposes. Such monitors are now becoming
available, and information on their reliability is being
gathered.
Similarly, if the system does not require particulate
control equipment (because the waste burned during
the compliance test did not contain sufficient
inorganic material to form excessive particulate), the
limits should be placed on the amount of ash and the
cleanliness of the quench water, if appropriate. These
limits are discussed below.
Acid Gas Formation and Control
Incineration of hazardous waste can generate a
variety of acid gases such as SO2, SOa, NOX, HCI,
and HF. The NOx can be formed by oxidation of the
nitrogen in the air and in the wastes. The other gases
are typically formed by the chemical reaction of
sulfur, chlorine, or other elements in the waste. The
most common occurrence is the formation of HCI,
and in most hazardous waste incinerators, acid gas
control is synonymous with HCI removal. As a result,
the remainder of this discussion will deal with HCI
removal. The reader is referred to the Guidance
Manual for Hazardous Waste Incinerator Permits (3)
for information on the mechanisms of formation of
this and the other acid gases.
Briefly, during combustion, the organic chloride in the
waste reacts with hydrogen from the waste, fuel, or
water in the combustion chamber to form HCI. A
small percentage (typically 3 to 5 percent) of the
chlorine will normally be released in the elemental
form as chlorine gas. It is possible for larger
quantities of free chlorine to form when the
combustion chamber contains an insufficient quantity
of hydrogen to convert all the organic chlorine to HCI,
but because this is highly uncommon, it will not be
discussed further here. The permit writer is advised to
seek assistance from the Office of Solid Waste if this
situation is encountered.
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Hydrogen chloride gas is readily soluble in water and
is most commonly removed by a packed-bed
scrubber. It can also be removed by the scrubber
used to control particulate such as the Venturi
scrubber. Recent developments in "dry scrubbing"
technology has resulted in incinerators utilizing some
form of lime-slurry injection to remove the acid
gases. The variety of acid gas removal devices is
large. Fortunately, for the purpose of setting permit
conditions, the performance of these devices can be
determined from the trial bum and, if it is shown to be
adequate, the operation can be monitored with only a
few readily measurable parameters.
The RCRA regulations require that any hazardous
waste incinerator which emits HCI at a rate greater
than 1.8 kg (4 lb)/hr must be equipped with an APCE
whose collection efficiency for HCI exceeds 99
percent. The actual performance of the scrubber is a
complex interaction between the types of packing, the
ability of the system to distribute the flue gases and
scrubbants in the absorber intimately, the alkalinity or
acidity of the absorbant, and the liquid-to-gas (L/G)
flow ratio. Of these, all but the last two are fixed for
the facility and, if the compliance test is satisfactory,
the design is assumed adequate. Any changes in the
design, however, constitute a change in the operating
conditions of the incinerator and should be
considered as a possible deviation from the permit.
Four parameters need to be limited to ensure that the
absorber performs as during the compliance test.
These are (1) the L/G ratio, (2) the pressure of liquid
feed to the nozzles, and the pH of the aqueous
solution (3) entering and (4) leaving the absorber. The
UG ratio and the pH should be specified as no less
than that measured during the successful compliance
test. Because these parameters can be controlled
independently, there is little difficulty in maintaining
them within constant bounds in a property operating
incinerator, and variability does not usually have to be
considered. If variability does occur during the test, a
time-averaged value of these parameters should be
used. The pH of the aqueous solution entering the
scrubber should be limited to assure that the
scrubbing solution has adequate capacity to remove
the acid gases. The pH of the solution exiting the
scrubber should be limited to assure that the
scrubber is not being overloaded with acid.
The pressure of the liquid feed to the air pollution
control device should be a control parameter for the
types of systems discussed below to reduce the risk
of deterioration of APCE performance. For many but
not all types of scrubbers, this parameter, which is an
indicator of how well the scrubbing liquid (water) gets
distributed in the APCE, will have a major influence
on the equipment's performance. Some simple
scrubbers inject the water into the gas stream
through one or more nozzles; others, such as packed
towers, can have complex manifolds to distribute the
scrubbing liquid across the packing. In those cases,
clogging or deterioration of the liquid distribution
system (such as the nozzles) could result in a
decrease in APCE performance. Clogging or
deterioration of these systems would be manifest as a
change in the operating pressure outside the design
range or the range determined during the trial burn.
Clogging increases the pressure drop; erosion or
corrosion decreases the pressure drop. Because
such failure is usually gradual, nozzle pressure does
not have to be interlocked with an automatic waste
cutoff. It should, however, be included in the
operating log, and significant changes in it should
initiate a corrective action.
An important type of control equipment where the
pressure of the water feed will not indicate a change
in scrubbing liquid distribution is an absorber which
uses a distribution plate to spread the water across its
diameter. The water is released onto the plate, and it
then flows by gravity over the top of the packing or
onto the top plate. In this case, there is little
advantage to setting limits on the liquid feed pressure.
The pressure drop across the column along with the
L/G ratio, which is a control parameter, will usually
indicate a deterioration in the liquid distribution and,
hence, scrubber performance. If possible, some form
of regular inspection of the column interior, especially
of the water distribution system, is desirable;
however, a sight glass or inspection port is usually of
limited value for such an inspection. A good
inspection, which usually involves shut down of the
scrubber and careful examination of its innards,
should not be normally required except during
maintenance.
Pressure drop of the gas across the scrubber is of
operational concern in a packed tower, but, except for
a massive failure in the packing, deviation from the
design specification is unlikely to cause an
environmental problem. If liquid flow to the tower and
flue gas flowrates are monitored, pressure does not
need to be in the permit specified for this type of
absorber. It should be noted that pressure drop
across a packed absorption column is frequently
monitored and regulated for operational reasons.
When a Venturi scrubber is used as the acid
absorber, pressure drop across the scrubber will
influence its performance. In that case, the pressure
drop should be maintained at a level at least as high
as that used during the test. Again, because pressure
drop will be a function of L/G ratio and of the throat
area (for a variable throat Venturi), there is little
reason to expect major variability in this control
parameter.
A type of acid absorber which is coming into more
common use is a dry scrubber, which also is called a
spray dryer. In this application, a slurry of caustic or
lime is injected into the flue gas, and the HCI reacts
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with it in suspension. The reaction products are
captured as participate in either a fabric filter or an
ESP.
When the acid absorber is a dry scrubber, neither L/G
ratio nor pH has technical meaning. In that case, the
limits in the permit would have to be based on the
ratio of the flowrate of the absorbent slurry to that of
the acid gas, i.e., "the system should not be operated
at a caustic or lime feed rate of less than X kg lime to
Y kg HCI," where X and Y are determined from the
compliance tests. This type of limit is difficult to
enforce since the personnel evaluating the
performance log would have to correlate the waste
composition and feed rate with the caustic or lime
feed rates to determine the acid production rate.
Continuous HCI monitors are becoming available
which, based on EPA evaluations, appear to be
sufficiently accurate and reliable to use as a stack
sensor. The output of this type of monitor can be
used to control the caustic or lime feed rates to a dry
scrubber. If the applicant chooses to use a dry
scrubber for a given application, the permit writers
should consider requiring a continuous HCI monitor
whose output regulates the scrubbant feed to the dry
scrubber.
An HCI monitor is a highly desirable feature for any
incinerator that burns chlorinated species. Its use can
reduce the scrubber parameters e.g., pH and L/G
ratios, that need to be monitored. For example, an
HCI monitor in place at a facility that uses a packed-
bed absorber for acid gas control could be used to
control the absorber's operating parameters to ensure
the proper HCI release as an alternative to limits on
parameters such as L/G ratio, pH, and pressure of
the nozzles. A continuous HCI monitor simplifies the
permit, operation, and enforcement procedures. Its
use should be encouraged for all but the smallest and
simplest incinerators.
Paniculate Formation and Control
To understand the method of setting limits on the
control parameters for particulate emission control
devices in a hazardous waste incinerator, it is useful
to understand the major mechanisms of particulate
formation. The following are the most common
sources of particulate formation in an incinerator:
1. Ash in the waste and supplemental fuel
2. Volatilization of metals and salts
3. Abrasion and corrosion of the waste particles and
the incinerator hardware, refractory, etc.
4. Suspended and dissolved solids in the quench and
scrubber water
Particulate releases may be caused by other,
transient mechanisms as well. For example, rapping
of an ESP or the cleaning of the bags in a fabric filter
can result in the release of a large amount of
particulate. It is important to ensure that the trial burn
runs include such cycles of potential high particulate
release. The remainder of this discussion will deal
with the mechanisms relating to the four sources of
particulate emissions listed above.
The ash in the waste and in the supplementary fuel of
an incinerator will be released during the combustion
process. This ash will either be entrained by the
solids in the incinerator and leave with the bottom
ash, or it will be carried by the combustion gas into
the APCE. In the case of an incinerator designed to
burn solids, the ash content of the fuel is insignificant
compared to the ash of the solid materials being
burned; and this mechanism can be ignored in favor
of some others discussed below. Liquid injection
incinerators often do not produce a bottom ash. In
that case, the ash in the waste and the fuel will be
released as a particulate and carried through the
incinerator into the APCE.
The composition of the inorganic fractions of the
waste and fuel can be extremely important when the
potential air pollution impacts from it are evaluated.
Many compounds including metals such as tin, zinc,
and lead and salts such as sodium chloride will turn
into vapors at the flame temperatures in an
incinerator. When the gases containing these vapors
cool, as in a quench, these materials form very fine
particulate often in the 1-um-diameter or smaller
range. This fine particulate is difficult for the APCE to
remove. In addition, because of their small diameter,
these particulates present a respiratory hazard. The
potential health risk from many of these particulates is
due to both their very fine size and their toxic metal
content.
Abrasion of the wastes between the waste feed and
the refractory is one mechanism for particulate
formation, especially when waste, such as paper, has
a large amount of friable ash; however, the particulate
formed by this mechanism is usually very large in
diameter and is readily removed by most types of air
pollution control devices. The burning of solid wastes
with these characteristics should trigger an evaluation
of whether an APCE is needed.
The final source of particulate emissions is not
commonly considered when an incinerator is
evaluated. When water is injected into the hot flue
gas to cool it, a significant fraction of the water is
evaporated. Any suspended or dissolved solids in the
water are then released as a fine particulate. Often,
the quench and scrubber water is recirculated or
comes from a source of wastewater. Even if the
water used for this purpose is once-through well
water, it may contain a sufficient level of dissolved
salts (hard water, even when softened, is an example)
to release significant amounts of particulate. Limits on
solids in the ash and water are discussed as
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"minimum scrubber blowdown," under "group C"
parameters.
The particuiate that is produced by these
mechanisms is controlled by the APCE. The most
common type of APCE used on incinerators is an
impaction scrubber, usually of the Venturi design.
Other particuiate control devices used are fabric
filters, ESPs, and ionizing wet scrubbers (IWSs). The
concept for each is discussed briefly in Appendix B
and in greater depth in the references given in
Appendix A.
The most commonly used APCE on an incinerator is
a Venturi scrubber. This device is discussed above
concerning acid gas removal. Figure 2-3 illustrates
the effect of particle diameter and pressure drop
across the scrubber on Venturi scrubber collection
efficiency. As can be seen, very large pressure drops
are required to achieve high collection efficiencies for
submicron particles.
Figure 2-3 Effect of pressure drop on venturi scrubber
efficiency.
1.0 2.0 3.0 4.0 5.0
Aerodynamic particle diameter (microns)
6.0
The important control parameters that must be set to
ensure that Venturi scrubber performance is
maintained are pressure drop across the scrubber
and L/G ratio. Both should be specified as minimums
as determined by the trial burn. Variations in the
values should not be large enough in most cases to
warrant concern with variability of the results. As
discussed earlier, pH of the scrubbant is Only
important if the Venturi is also used for acid gas
removal.
Fabric filters (FFs) are not commonly used for
particuiate control in hazardous waste incinerators.
This situation is changing as FF technology is
modified to fit the new application. Fabric filters are
sometimes used in conjunction with dry acid removal
devices as discussed above. The particuiate
collection efficiency of an FF depends primarily on the
following factors:
• Fabric type and weave
• Face velocity (gas flowrate divided by the surface
area of the filters)
• Cake buildup on the filters
• Frequency and level of cleaning of the bags
It is normally only necessary to specify the minimum
differential pressure across the FF as a permit
condition. This parameter is needed in order to shut
off the waste feed in case of a ruptured bag. This
value should be set as the minimum pressure drop
observed during any successful trial burn. When it
becomes necessary to replace one or more bags in
the fabric filter, the bags can often be pre-coated by
artificial means or by burning auxiliary fuel. If
precoating will not be feasible, a lower minimum
pressure drop can usually be specified for the cutoff
for a relatively short period of time (under an hour)
until the new bags are coated with filter cake. The
particuiate removal efficiency of new bags is
somewhat lower until they have been coated with
filter cake. Thus, it may be desirable to reduce the
ash feed or restrict the amount of metal or fume-
forming wastes during this period in cases where
there is concern about excessive particuiate or metals
emissions.
Limits may be considered on other parameters,
including those listed above, but they normally are
not needed. To illustrate, consider the consequences
of setting limits on the frequency of cleaning and the
upper pressure drop across the bags. The point at
which the bags are cleaned (by shaking, for example)
is typically determined by the pressure drop across
the FF. As the filters accumulate dust, the pressure
drop increases. When it reaches a predetermined
upper value, the cleaning cycle is initiated. A limit on
the maximum pressure drop could identify problems
in the cleaning cycle such as defective equipment or
blinding of the filter media but normally is not
necessary.
An excessive pressure drop will not normally affect
APCE particuiate removal performance adversely.
However, it may result in bag rupturing or "caving in,"
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which would then release excessive participate. When
such failure occurs, the low pressure drop cutoff
would shut down the waste feed and the incinerator in
an orderly manner. In theory, this scenario could be
handled by the low pressure cutoff limit; however, a
waste feed cutoff when the pressure rises above a
maximum specified by the equipment design provides
additional time prior to failure and is highly
recommended when particulate removal efficiency is
a critical parameter.
The ESP is a well-established device for particulate
control. It is usually used only in very large incinerator
installations. For a given installation and fixed
particulate loading, its performance is determined by
the voltage and power consumption in kilovolt-
amperes (KVA) approximately equal to kilowatts (KW).
Alternatively, a minimum value can similarly be
required for the current in mA and the power
consumption in KVA. The permit should specify a
minimum value for the KVA as established in the trial
burn. It should be noted that, at least in theory, the
current can go to zero when the particulate loading
on the input gas stream is very low. This is not
common because an ESP would normally not be
used for installations where it is only required
occasionally because of its high capital cost. If such a
situation is encountered, additional guidance should
be sought. One possible approach in this case is to
maintain the minimum voltage but suspend the
minimum current requirement under selected
operating conditions.
The IWS combines the collection principles of the
ESP with acid gas removal of a conventional
packed-bed scrubber. In the IWS, the incoming
particles are charged in a small ionized section with
high voltage DC power. Charged particles are
scrubbed in the packed-bed section. During the
operation, the KVA usage will vary with gas
composition. The only two factors that need to be
regulated are minimum liquid flowrate (L/G as in an
absorber) and minimum DC voltage. Both of these
should be the minimum measured during the trial
burn.
2.2 Group B Parameters
The group B parameters are those which do not
require continuous monitoring and, thus, are not
interlocked with the waste feed cutoff. They are
typically monitored by sampling and analyzing the
wastes and controlling the quantities of wastes being
fed and other operating parameters for the
incinerator. The results of these monitoring activities
are maintained in an operating log which is used to
ensure that the worst-case conditions established on
the basis of the trial burn are not exceeded.
Three classes of parameters are included in group B.
The first relates to the organic hazardous constituents
that the incinerator is allowed to burn and to the
selection of those (POHCs) that will be measured
during the trial burn to verify incinerator performance.
The second limits the amount of halides and ash that
the waste is permitted to contain so that the APCE is
not overloaded. The third regulates the quality of the
water used for the scrubber and quench.
As can be seen, the group B parameters are very
closely connected to the group A parameters
discussed earlier. They are actually not different when
the impact on incinerator operation is considered.
They are differentiated here largely because the
group B parameters do not require interlocks with
waste feed cutoffs as do the group A parameters.
A category of parameters that are not addressed
under the incinerator regulations but may at times be
important are those which influence the level of solids
burn-down that the incinerator achieves. This is
normally a function of the solids residence time in the
PCC and it will affect the quality of the ash produced.
This can be important in situations such as:
• The applicant requests that it be "delisted"; that is,
tested and shown not to be hazardous.
• The waste is subject to land disposal restrictions
under 40 CFR 268.
• The incinerator is used to destroy toxics
contaminating a material, such as soil, for the
purpose of returning it to a site which is not
necessarily a hazardous waste disposal facility.
In all of these cases, the incinerator is intended to
achieve a specific, maximum level of contaminant in
the residues or ash. This may be achieved during
operation by setting limits on the maximum kiln
rotational speed at a value where the ash was
determined to meet the applicable criteria. As
discussed above, these conditions are not specifically
required under the incinerator regulations, but can be
included in the permit to address other regulations, or
when determined necessary to minimize risk from
contaminants remaining in the residues, under the
authority of the "omnibus" provisions of Section
3005(c)(3) of RCRA, as amended.
2.2.1 POHC Selection and Incinerability Ranking
The type and amount of POHCs in the waste are very
important to the overall performance of the
incinerator. This information is typically specified by
the applicant when the waste streams that are to be
burned are identified. The only permit condition that
needs to be placed on POHCs is one which specifies
that no hazardous organic constituents which were
not represented in the waste burned during the trial
burn may be burned in the incinerator during
subsequent operation. The condition should also
specify that only those waste streams that contained
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the specified type of POHC during the trial burn may
contain it during operation.
For example, if a POHC representing chlorinated
aliphatic compounds only exists in one type of waste
stream during the test, it cannot be introduced in
another one. Types of waste streams refer to
categories of waste such as high BTU, low- BTU,
aqueous, sludge, or solid. A corollary to this limitation
is that no POHC different from that used during the
trial burn can be introduced into a combustion
chamber. The reader is referred to Sections 2.4 and
Chapter 4 for further discussions on how permit
conditions on POHCs are to be treated.
According to 40 CFR 264.342(b)(1), "One or more
POHCs will be specified in the facility's permit from
among those constituents listed in Part 261, Appendix
VIII of this chapter, for each waste to be burned. This
specification will be based on the degree of difficulty
of incineration of the organic constituents in the waste
and on their concentration or mass in the waste feed
. . . ," and "Organic constituents which represent the
greatest degree of difficulty of incineration will be
those most likely to be designated as POHCs
To satisfy this requirement, the permit writer must do
the following:
1. Designate (or approve the applicant's designation)
the POHCs that will be measured during the trial
burn
2. Based on the results of the trial burn, identify those
organic compounds that may be burned in the
system during operation, i.e., those that are "less
difficult" to incinerate
To satisfy this requirement, it is necessary to have a
method of ranking Appendix VIII compounds into an
order of "degree of difficulty of incineration." Such a
ranking is commonly referred to as an "incinerability
ranking" or "incinerability index."
At present, many EPA Regional Offices use a ranking
system based on the heat of combustion of the
Appendix VIII organics as a guide for selecting those
POHCs that are the most difficult to incinerate. This
system is described in the Guidance Manual for
Hazardous Waste Incinerator Permits (3). The higher
the heat of combustion of a compound, the easier it
is assumed to be to incinerate. This procedure is
presently under review, and data now being gathered
by the University of Dayton Research Institute (UDRI)
indicate that more appropriate ranking systems may
exist. A draft of the UDRI Ranking system (called the
TSLoO2 ranking) and the rationale for its use is
presented in Appendix D. This work is still under
review.
Incinerability indices other than heat of combustion
can be used without a regulatory change because the
regulations do not mention a specific incinerability
hierarchy. This was done to allow flexibility in POHC
selection. At the time OSW developed the current
regulations, it was recognized that changes may
occur as new data became available. Thus, thermal
stability at low oxygen may be used as a criterion for
POHC selection. Additional considerations that can be
applied to POHC selection include concentration of
the constituent in the waste stream (the higher the
concentration, the more likely the compound is to be
chosen as a POHC), toxicity (choosing a particularly
toxic compound in the waste to be sure it is
destroyed), and compound structure (choosing a
compound to represent each of the structural
classifications of compounds such as aromatics and
chlorinated compounds in the waste). Finally,
availability of sampling and analysis methods for
potential POHCs and whether it is a common PIC are
other considerations.
When the thermal stability ranking is used, it is
recommended that POHCs be chosen from those
compounds for which actual experimental data exist.
Because the ranking will be changing as additional
laboratory testing is done, compounds fairly close
together in the ranking should not be considered
significantly different with respect to incinerability.
Therefore, when there are testing or availability
problems with the preferred POHC, it would be
reasonable to choose another POHC from the same
class.
Some of the compounds in class I of the TSLo02
ranking present sampling and analysis problems. For
example, reactive compounds such as hydrocyanic
acid and cyanogen and water soluble compounds
such as acetonitrile would require either special
sampling techniques or alternative POHCs. Sampling
and analysis problems should not be encountered
with compounds such as chlorinated benzenes.
Guidance on POHC selection will be issued in the
near future.
2.2.2 Maximum Halides and Ash
As discussed in Section 2.1, the amount of acid-
forming compounds (usually halides) will affect HCI
emissions, and ash in the wastes and the amount of
dissolved and suspended solids in the quench and
scrubber water will affect the particulate emissions.
The permit conditions must include upper limits on
these parameters. The maximum amount of acid-
forming compounds which may be burned in the
incinerator during normal operation should be set at
the maximum that was burned during the trial burn
(assuming the trial burn demonstrated compliance
with performance standards). Care must be-taken to
ensure that when more than one acid-forming
material is burned, the condition reflects the amount
of total alkalinity required to remove them. For
example, in a case where sulfur- and chlorine-
bearing compounds are burned, sulfur will consume
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two equivalents of alkali while chlorine will consume
only one. This situation is uncommon, but the limit
should be written to include these factors.
Limits are set on the maximum amount of ash in the
waste that may be fed to an incinerator to avoid
emissions of excessive particulate and overloading
the APCE. For the purpose of this analysis, ash can
be defined as any constituent of the waste that, when
properly burned, forms a particulate in the stack.
These can include a number of inert materials such
as sand, dissolved compounds such as sodium
chloride or inorganic elements, metals, and metal
salts.
In general, the total amount of ash that may be
burned in an incinerator is limited by specifying the
maximum total ash feed rate that met particulate
emissions limits during the trial burn. There are times,
however, when it is necessary to place restrictions on
specific components of that ash. The following
discussion outlines some of the circumstances when
such restrictions should be considered.
For example, consider the following hypothetical
waste feed:
Waste Stream
A
B
Ash Components, kg/hr
10 - Si02
5 - NaCI
Silicon dioxide (as opposed to silicanes or silicones
which are organosilicon compounds that can form a
fine particulate fume) is not volatile under the
conditions of a typical incinerator; sodium chloride
can volatilize and form a fine particulate. Assume the
trial burn demonstrates acceptable particulate
releases at these maximum feed rates of the two
compounds.
Based on these tests, the total ash feed rate normally
could be limited in the permit to 15 kg (33 lb)/hr. If,
however, the amount of sodium chloride is increased
and silicon dioxide decreased during operation, an
increase in the fine particulate loading to the APCE
and in the total released particulate could occur. If
this release appears to be of concern, the permit
condition might specify a total maximum NaCI feed of
5 kg (11 lb)/hr as well as a limit on the total ash feed
rate. If B is the only waste stream likely to contain
NaCI, that limit could be converted to a maximum
feed rate and NaCI concentration for waste stream B.
While this conversion reduces operator flexibility to
blend wastes, it also reduces the need for waste
analysis during operation and makes the ash limit
easier to enforce.
Typically, fine particulate can form from ash
containing the following categories of materials:
• Sodium salts, especially sodium chloride
• Volatile metals such as mercury, lead, tin,
antimony, arsenic, and chromium
• Inorganics whose oxides are volatile under the
conditions of the combustion chamber
• Silicon-organic compounds such as silanes or
silicones
When these conditions are encountered, the effect of
an increase of the fine particulate loading on the
APCE should be explored, and, if necessary,
restrictions on the amounts of such components of
the ash should be included in the permit conditions.
These restrictions should be considered especially
when the waste includes Appendix VIII metals. Feed
limits for individual metals should be set where metals
emissions are of concern as outlined in Guidance for
Permit Writers for Limiting Metal and HCI Emissions
From Hazardous Waste Incinerators (4).
Another important parameter related to particulate
emissions is the APCE inlet gas temperature. Certain
types of particulate, especially the fine particulate
discussed above, form in the incineration process.
They form as gases in the combustion zone and
condense as the temperature decreases downstream.
The amount of condensed particulate is a function of
the temperature. As the temperature to the inlet of
the APCE increases, less of this "condensible
fraction" enters the APCE as a particulate subject to
collection. It can condense as a particulate
downstream, typically in the stack. Under this
scenario, as the inlet temperature to the APCE
increases, particulate emissions would also increase.
As a result, the maximum APCE inlet temperature
should be the maximum measured during the trial
burn. To protect the APCE from damage due to
excessive temperature, this level should not be higher
than the manufacturer's specification for maximum
temperature.
2.2.3 Maximum Batch and Container Size
The maximum size of batches or waste containers
fed to the PCC is recommended as a group B
parameter because of the effect of the instantaneous
waste feed rate on the ability of the incinerator
system to maintain steady-state operation and
minimize phenomena such as instantaneous oxygen
deficiencies, puffing, and flame quenching. This
parameter is discussed along with maximum waste
feed rate in Section 2.1.5.
2.2.4 Minimum Particulate Scrubber Slowdown
The final group B parameter to be discussed is the
scrubber blowdown. As discussed in Section 2.1, it is
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possible for participate to be produced in the quench
and even in the scrubber. The greater the amount of
solids present in the quench and scrubber water, the
greater the potential for paniculate to be produced.
The operator of an incinerator controls the quality of
the scrubber water by varying the fraction of the
water leaving the scrubber that is recycled back to it
and the fraction being "blown down" or discharged.
The larger the blowdown, the cleaner the scrubber
and quench water tend to be. The permit writer limits
the degree of contamination of the scrubber and
quench water by specifying the minimum amount of
blowdown during operation.
Clearly, blowdown is only an issue when the scrubber
and quench utilize recycled water; for example, when
the (liquid) water leaves the scrubber and quench is
collected in some form of reservoir such as a tank,
sump, or pond where it is partially treated and
neutralized. To control the quality of the water in the
reservoir, a fraction of it is sent to the sewer or other
discharge (the blowdown), and the remainder is
recycled to the incinerator. In some incinerators, the
blowdown can come from a reservoir in the scrubber
or quench equipment. In cases where once-through
water enters the scrubber, "blowdown rate" has no
meaning, and no limit needs to be set for this
parameter.
The minimum blowdown rate for the incinerator
cannot be easily determined directly from the trial
burn. If the operator starts the trial burn with clean
water and then uses the normal blowdown rate, the
scrubber water will start clean and then become
contaminated with dissolved and suspended solids.
The trial burn can, therefore, show a satisfactory level
of particuiate removal, but this could be due to a
transient phenomenon associated with this technique.
One method of reducing the probability of such an
occurrence is to design the trial burn so that the
system is operated for a sufficient time before the
tests to ensure that the quality of the water in the
sump has reached steady state. For example, the
applicant could be required to have not cleaned the
sump or changed the water for a specific pretest
period.
Another approach would be to specify the blowdown
rate such that the combined dissolved and suspended
solids in the scrubber and quench water pond or
sump do not exceed the mean determined during the
successful trial burn with the highest solids in the
quench and scrubber water.
2.3 Group C Parameters
Recommendations for group C parameters are based
on the need to ensure that incinerator operation
adheres to recommended combustion and APCE
operating practices. These practices, which include
waste liquid and slurry burner settings, APCE inlet
gas temperature, and maximum heat input for each
incinerator chamber consistent with design
specification, are based strictly on design limits and
equipment manufacturer specifications. Thus, permit
conditions for these parameters are not based on trial
burn conditions, and compliance verification does not
require continuous monitoring, although maintaining
records in the facility operational logs is necessary.
2.3.7 Burner Settings
The burners in liquid injection and afterburner
chambers should be set to operate according to
manufacturer design and operating specifications.
These settings should also be consistent with the
ability of the burners to atomize the liquid waste
properly and promote efficient mixing. These
specifications vary according to the waste burned,
burner and nozzle type, and method of atomization.
To restrict the operation of these burners to trial burn
settings possibly would constrain the operation of the
facility and limit the types of wastes that can be
incinerated, which is not the intent of the permitting
procedure. The permit should allow sufficient
operational flexibility in waste viscosity, burner
pressures, and turndown limits as long as these
settings are compatible with burner manufacturer
recommendations. Additionally, a minimum waste
heating value should be set in a permit for burners
providing 100 percent of the heat input to a liquid or
afterburner chamber. A liquid waste with a LHV of
11,600 kJ/kg (5,000 Btu/lb) should be sufficient to
maintain a stable flame consistent with good
operating practices.
2.3.2 Total Heat Input
The total heat input requirement states that the
incinerator should not be allowed to operate beyond
its design capacity. Typically, maximum heat input
and maximum temperatures are not important
considerations for the permit writer because facilities
are rarely subjected to operation outside manufacturer
design specifications. Because such operation can
result in refractory damage, it may be self-limiting.
To exceed them will also result in exceedance of
other imposed permit conditions such as the
maximum waste feed rate and combustion gas
velocity. Thus, compliance with the incinerator design
heat input capacity is considered good operating
practice and should be a permit condition for the
facility as long as the limit imposed is consistent with
the other control parameters. The maximum total heat
input would normally be the manufacturer's
specification for the equipment; however, if a greater
heat input is successfully demonstrated during the
trial burn, it may be specified instead.
2.3.3 APCE Inlet Gas Temperature
Typically, some reduction in the temperature of the
incoming gases is required to comply with material
specification of the downstream equipment. For FFs,
the maximum inlet temperature is specified by the
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type of cloth material. This temperature limit can vary
between 120 and 290 °C (250 and 550 °F) for an FF;
for a dry ESP, the inlet gas temperature affects the
particulate resistivity and, thus, the performance of
the ESP. In this context, it is difficult to specify a
maximum inlet temperature because this parameter
depends on the type of control equipment and its
manufacturer. Therefore, it is recommended that the
permit writer obtain the equipment design
specifications from the permit applicant and that the
operating temperature be defined according to those
specifications. It may, however, be necessary to set
the maximum temperature limit at a lower level, as
discussed in Section 2.2.2 (concerning fine
particulate formation) to assure that all particulate
forming fumes condense prior to entering the APCE.
2.4 Other Parameters
Below are listed a number of parameters that were
considered but not selected as control parameters:
• Minimum oxygen concentration
• Maximum gas volumetric flowrate, maximum
velocity, or minimum residence time in each
combustion chamber
• Maximum volatile content of containerized waste
• Minimum total heat input to each combustion
chamber
• Maximum kiln slope
• Maximum kiln rotational speed
• Minimum liquid flow to the Venturi scrubber
The rationale for not selecting these parameters is
discussed below. It is recommended that the permit
writer consider this discussion and note that to
impose more permit conditions may not necessarily
improve compliance since many parameters
interrelate and each condition has an effect on the
operational flexibility of the unit. However, if the unit is
unique in some manner, some restriction on the
above or other parameters may be desirable. This
contingency, while unlikely with fairly standard
incinerator designs, cannot be ruled out in all cases.
The permit writer is urged to seek assistance from
the Office of Solid Waste when an unusual design
appears to require that conditions be set for any
parameters not specifically recommended in the
guidelines.
While the complete combustion of POHCs and PICs
requires the presence of sufficient oxygen, there are
several major arguments against setting minimum
limits on oxygen. The most important reason is that it
is difficult to pick one oxygen level that is satisfactory
for the combustion of a wide variety of wastes. An
oxygen limit based on one type of waste would not
necessarily be adequate for destroying other wastes.
While it may be theoretically possible to determine a
suitable "worst-case" feed to test oxygen demand
during the trial burn, it is extremely difficult to do so
for facilities that burn a range of waste compositions
because of the lack of detailed knowledge on the
mechanisms of waste destruction. Fortunately, it is
unnecessary to set such a limit for the following
reasons:
• Insufficient oxygen results in a rise in CO
concentration. Because CO is already a permit
parameter, to limit oxygen as well would be
redundant.
• It is difficult to continuously and reliably measure
oxygen concentration at combustion chamber exit
conditions; thus, oxygen measurements are
normally made at the stack. Often, air inleakage
occurs between the combustion chamber exit and
the stack. The oxygen in this leakage air can mask
oxygen deficiencies in the combustion chamber,
thus limiting or negating the value of such
measurements.
• Several combustion chambers are designed to
operate under oxygen-starved (pyrolytic)
conditions with additional air supplied in
downstream combustion equipment. Minimum
oxygen requirements for these pyrolytic chambers
would be inappropriate and unenforceable.
To monitor residence time, it is conceptually
preferable to monitor the maximum gas flows or
velocities in each chamber rather than the flue gas
flowrate or velocity at the stack, which is
recommended in Section 2.1.3. For the majority of
incinerators, however, the gas flow in the stack or the
duct leading to the APCE correlates reasonably well
with that in each chamber, especially in the SCC, and
it is far easier to measure. As a result, the gas flows
in each chamber do not need to be measured in most
circumstances.
It should be noted that in cases when there is reason
to believe that a significant amount of air infiltration or
other gas addition occurs between the SCC and the
point at which the stack velocity is being measured, it
may prove necessary to add some form of additional
monitoring of gas velocity. The permit writer is
advised to seek outside guidance in these cases.
The maximum volatile content of containerized waste
was not selected as a control parameter because it is
difficult to measure during operation and because
other control parameters will be impacted should a
highly volatile material be in a container. An excessive
amount of volatile material in a container of waste will
result in a rapid release of hydrocarbons. These
releases will manifest themselves in several ways.
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First, the pressure in the PCC will increase. Second,
the added hydrocarbons will starve the flame and
increase the CO level. If neither of these increases
result in the triggering of the alarms or automatic
shutoffs, the increases can be deemed to be within
the capability of the system. If, however, the limits on
these two parameters is exceeded, an automatic
shutoff of the waste feed will be triggered. In either
case, there is no need to regulate the volatile content
of the containerized waste.
While these guidelines do not recommend that the
maximum volatile content of the waste be set as a
permit condition, it is recognized that to feed
excessive amounts of highly volatile materials in
containers is not desirable. It is suggested, therefore,
that the type of containerized waste chosen for a trial
burn contain the largest amounts of volatiles expected
in continuous operation.
The minimum heat input to each combustion chamber
was not selected as a control parameter as it is very
difficult to measure during normal operation and it is,
in reality, specified by the minimum temperatures of
each combustion chamber. If the heat input to a
combustion chamber is reduced, so, also, is the
temperature. If the heat input is reduced too much, a
temperature cutoff will occur. There is normally little
need to regulate both parameters.
The kiln slope and rotation speed were considered
but not chosen as control parameters. The slope was
not chosen because it is fixed at the time of
construction. It cannot be changed (except,
conceivably, in very unusual designs) without
rebuilding the incinerator, which would require a new
permit or a modification to the existing one. The kiln
rotational speed has a major influence on the quality
of the ash and a minor one on the particulate
emissions. It was not chosen because there are, at
present, no incinerator regulations pertaining to the
quality of the ash and because its impact on the
particulate emissions is small. The ash quality, while
not addressed under the incinerator regulations, can
be important if the applicant requests that it be
"delisted" or subjected to other requirements as
discussed in Section 2.2. Then, limits of the
maximum kiln rotational speed may be necessary.
A kiln's rotation rate also can have an impact on the
particulate released from the waste. An increase in
kiln rotation will result in the "grinding" of the ash and
its increased release into the flue gas. Fortunately,
this type of particulate-forming mechanism results in
large particulate which can easily be removed by a
well-designed APCE. In almost all cases, the kiln
would have to rotate much faster than prudent
operation dictates to generate sufficient particulate to
overload the APCE. Therefore, there is little need to
restrict kiln rotation rate for this purpose unless
incinerator particulate emissions during the trial burn
are close to the maximum allowable.
The final parameter that was considered and not
chosen as a control parameter is the minimum liquid
flow to the Venturi scrubber. Minimum L/G ratio,
which is closely related, was selected instead. Venturi
scrubber efficiency can be related to the L/G ratio
and the velocity through the Venturi. Because the
pressure drop across a Venturi is a function of the
liquid and the gas flow and because the gas flow and
velocity can be related to the flue gas flowrate, permit
limits on the minimum pressure drop across a Venturi
and maximum flue gas flowrate are sufficient. There
is no need to set a limit on the minimum liquid flow to
the Venturi scrubber as well.
2.5 References
1. Engineering Handbook for Hazardous Waste
Incineration. EPA Publication SW-889. September
1981.2.
2. Hazardous Waste Incineration Measurement
Guidance Manual. Midwest Research Institute.
1988. (Draft under EPA review.)
3. Guidance Manual for Hazardous Waste Incinerator
Permits. Mitre Corp. NTIS PB84-100577. July
1983.
4. Guidance for Permit Writers for Limiting Metal and
HCI Emissions From Hazardous Waste
Incinerators. Versar, 1988. (Draft under EPA
review).
[A brief description of each of these documents is
presented in Appendix A.]
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CHAPTER 3
Setting Permit Conditions
Chapter 2 discussed the control parameters for an
incinerator and how they interrelate and affect the
performance of the incinerator system. This chapter
discusses how the limits on the operating parameters
are determined and converted to the conditions in the
permit. The same strategies that are used for setting
permit conditions are also used to determine the
conditions such as temperature and waste feed rate
at which the incinerator should be operated during the
trial burn. In both cases, it is necessary to identify a
range of conditions broad enough to allow the
operator sufficient "elbow room" in which to operate
but still ensure that the incinerator operation complies
with the environmental regulations, i.e., ORE, HCI
emissions.
The conditions in a permit for an incinerator could
encompass many more factors than those discussed
in Chapter 2. These can be related to other features
of the installation; for example, the presence of an
emergency vent stack, or the burning of waste
materials which are unusually toxic or of extreme
concern to the local population. This handbook only
discusses the setting of permit conditions on the
system and operating parameters. It is limited to
those system and operating parameters discussed in
Chapter 2. The reader is referred to the appropriate
manuals listed in Appendix A for guidance on how to
set other permit conditions.
This chapter begins with a discussion of permitting
approaches that may be used by the applicant. It will
then discuss how the control parameters covered in
Chapter 2 interrelate and how variations in their trial-
burn values should be handled. It will end with
specific guidance for setting permit conditions for the
permit approach used. First, however, it is worthwhile
to define several terms relating to the trial burn.
A trial burn is the testing that is done to determine
whether an incinerator can meet the performance
standards and to determine the operating conditions
that should be set in the permit. A "test" must be
done for each set of operating conditions for which
the applicant desires to be permitted. Three replicates
or "runs" must be performed for each test. One set
of conditions constitutes a test; the overall trial burn
consists of one test for each set of operating
conditions. Each run of a test must be passed for the
incinerator to be permitted to operate at that set of
conditions. If the permitting authority determines that
there is good cause, one run may be thrown out
provided that the permit conditions do not include any
operating conditions at which the incinerator was
shown to be out of compliance with the performance
standards.
3.1 Permitting Approach
Three approaches to permitting incinerators are
suggested in this guidance. Table 3-1 summarizes
them and highlights some of the major advantages
and disadvantages of each. The approach that should
be used for a given incinerator is determined almost
completely by the number of different combinations of
wastes and waste types that would be burned at any
one time. The three approaches are called:
1. single waste/single operating condition ~ single
point
2. multiple waste/multiple operating conditions --
multiple point
3. multiple waste/single operating condition --
universal
The third approach is the most commonly used and
can, in reality be used for all incinerators. The single
point approach is a subset of the universal approach.
It is presented as a separate method of setting permit
conditons because it can be used to permit a
relatively common category of simple incinerators,
those that burn only one set of well-defined wastes.
The multiple point approach is a relatively uncommon
method of setting permit conditions; it can be
considered as a variation to the single point approach.
The first approach, the "single point approach," is the
least complex. It applies to incinerators that burn only
a well-defined set of waste streams and operate
under unvarying operating conditions. Hence the
name "single waste/single operating condition."
These dedicated units are typically located at the site
where the waste is generated and operate in an on-
off mode, where "on" is defined by a relatively
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Table 3-1.
Objective
Permitting Approaches
Approach
Advantages
Disadvantages
1. Single waste/single conditon
"single point"
2. Multiple waste/multiple
condition
"multiple point"
Determine one set of operating
parameters based on trial burn
tests on a series of progressively
worse conditions (single point)
Determine multiple sets of
operating conditions, each
applicable to a specific mode of
operation (multiple point)
3. Multiple waste/single condition Determine one set of universal
"universal" operating conditions
(universal conditions)
• Closely related to conditions
tested
• Well-defined operating
conditions
• Closely related to conditions
tested
• Well-defined operating
conditions
• Operational flexibility
• Easily enforced
• Constraining
• Constraining
• Potential redundancy
• Requires detailed support
documentation
• More complicated to enforce
• Complex trial burn
• Requires greater engineering
evaluation of trial burn data
constant composition, waste feed rate and operating
temperature. An example of a facility that could be
permitted with this type of approach is one which
burns a specific high BTU waste, a specific low BTU
waste and a specific sludge. Each of these waste
streams come from one or two well-defined
processes. While the composition and amount of
each waste stream could vary, it only does so within
narrow bounds. No new hazardous constituents
(whether organic or metal) are introduced.
For these facilities, the permit objective may be
satisfied by setting limits on the specific type of waste
to be incinerated and on the operating parameters.
The permit conditions are based on one trial burn
test. The wastes burned during this test are the actual
wastes normally burned possibly fortified with some of
the POHCs for ease of sampling and analysis. During
operation, no changes in the waste composition or
source are allowed.
The second approach, called here the "multiple
point" approach, is to set multiple limits for ech
operating parameter: each limit is based on individual
test conditions or modes of operation investigated in
the trial burn. This approach is typically best suited
for incinerator facilities dedicated to treating a well-
defined set of hazardous wastes of uniform
composition; for example, when drummed waste is
burned with liquid wastes A and B, then one set of
operating conditions apply. When bulk solids are
burned with wastes C and D and waste gas, then a
second set of operating conditions apply. As can be
seen, the multiple point approach is equivalent to
setting a series of single point conditions for the
incinerator when it burns a discrete, consistent mix of
wastes. Each mix of wastes must be defined in the
permit.
The conditions for multiple point permits are readily
defined, but the enforcement agency needs to be
aware of the operating mode to verify compliance
with operational limits. For example, to verify that the
incinerator is operating at the proper conditions for a
given mix of wastes, it is necessary to check the log
of the waste types being fed at the time and compare
it to the logs of the control parameters. Nevertheless,
because the permit conditions are based strictly on
the results of the trial burn, the multiple point strategy
is recommended whenever the incinerator will be
operated at more than one condition. There are,
however, situations when neither approach is
appropriate. Thus, a third approach is suggested
below.
The third approach, referred to here as the "universal
approach," is to develop one set of operating
conditions which allow a given facility to burn a
relatively broad range of wastes. Hence the name,
"multiple waste/single condition." This approach,
while being the most complex, offers the greatest
operating flexibility. It is, hence, the most commonly
used one. The approach requires that the trial burn
be carefully designed to represent the worst case mix
of wastes and operaing conditions that the incinerator
could conceivably encounter during operation. One
set of operating conditions is then set based on that
test. This approach allows the incineration of a
relatively wide variety of wastes but at conditions
which are, generally, more severe than most of these
waste streams require. One, in effect, buys operating
flexibility by requiring that the operating conditions be
sufficiently severe to burn the worst-case
combination of wastes.
The greatest difficulty in using the universal permitting
approach is designing the trial burn. If at all possible,
it should be structured to achieve with one test the
target limits for maximum feed rates for all feeds,
minimum temperature, and maximum combustion gas
velocity. This may require water injection or
exceptionally careful control of the supplemental fuel
compositions and feed rates during the tests. Energy
and mass balance calculations with a computer
program as described in Appendix E may be required
to identify the condition that best satisfies the worst-
case conditions.
If it is impossible to find a worst-case condition for
the mix of wastes the applicant wants to burn, it may
be necessary for him to accept less than optimum
target limits for the control parameters, or some
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restrictions on waste feed rates. The added
complexity is well worth the increased effort in the
design of the test as it results in a single set of permit
conditions that are directly based on the trial burn
without any need to "massage" the data.
It is especially important when the trial burn is this
complex (although this should be done in all cases)
that the permit writer and applicant have a clear
understanding of the permit conditions that will result
from a successful trial burn at the conditions
specified. This gives the operator the option of
changing the test plan to achieve workable
conditions.
In general, the simplest strategy that can be used to
set permit conditions that still allow reasonable
operating flexibility is the most desirable. As such, a
single or multiple point strategy is preferable
whenever the waste types burned justfy it. When the
waste characterization does not allow it, the universal
strategy can be used.
At times, the applicant may want to conduct tests at
more than one operating condition for "insurance."
For example, if he wants to operate the incinerator
near the minimum temperature that will do the job, a
series of tests could be conducted at progressively
lower temperatures. This situation is fundamentally
the same as the case when a test is conducted at
only one condition and is clearly acceptable as long
as, in the judgement of the permit writer, no
dangerous situations occur when the incinerator is
pushed to its design limit. The permitting strategy in
this case is the same as for the single point strategy.
If a facility cannot achieve the critical target limits for
all the contol parameters simultaneously, two or more
tests will be required. At that point, the question
becomes whether a multiple point or universal
permitting strategy is preferable. The discussions
below address the advantages and disadvantages of
each strategy. First, however, it is necessary to
discuss the interrelationship between the control
parameters and how to treat normal data variability.
3.2 Interrelating Control Parameters
In many cases, the guidelines for setting permit
conditions from certain control parameters may be in
conflict. For example, as the temperature is raised,
the gas density decreases, and the gas residence
time falls. Limits cannot, therefore, be set
independently on temperature and gas flowrate since
they interact so closely. Most of the parameters
discussed in Chapter 2 are interrelated to a certain
degree. To address this interrelation in an orderly
fashion so as to avoid detailed system modeling
calculations, it is convenient to order the control
parameters in the following groups:
1. Control parameters set from trial burn data that are
related to waste destruction (Group A)
2. Control parameters set from trial burn data that are
related to APCE performance (Group B)
3. Control parameters that are independent of trial
burn data (Group C)
These parameters are listed in order of importance,
i.e., item 1 is more important than item 2, which is
more important than item 3. Individual control
parameters within each group are listed in Tables 3-
2, 3-3, and 3-4, respectively.
It is recommended that limits be set on the control
parameters according to this hierarchy. That is, the
permit writer should first establish the limit for the first
parameter in group 1, i.e., minimum temperature in
each combustion chamber, then proceed down the
list, making sure that the limit on each parameter is
consistent with the limits on those above it.
Table 3-2. Waste-Destruction-Related Control Parameters
Set From Trial Burn Data
Type
Parameter
A Minimum temperature at each combustion chamber exit
A Maximum CO emissions
A Maximum flue gas flowrate or velocity
A Maximum pressure in PCC and SCC
A Maximum feed rate of each waste type to each
combustion chamber
B Maximum size of batches or containerized waste
3.3 Treatment of Variations in Data
Setting final permit conditions from actual data is
somewhat different from setting tentative limits based
on a trial burn plan because the permit writer must
deal with data variability. Data can vary in three ways:
1. Variations with time within a single run
2. Variations between repeats of the same nominal
operating conditions
3. Variations due to changes in the operating
conditions about the nominal operating point
Incinerators do not operate under totally steady
conditions. Thus, most parameters vary somewhat
with time over the course of a single test run. The
k
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Table 3-3. APCE-Performance-Related Control
Parameters Set From Trial Bum Data
Type Parameter
A Minimum differential pressure across participate venturi
scrubber1
A Minimum L/G and pH to absorber1
A Minimum caustic feed to dry scrubber
B Minimum scrubber Wowdown rates or maximum total
solids in scrubber liquid1
A Minimum kVA settings to ESP (Wet/Dry) and kV for
IWS1
A Minimum pressure differential across a FF1
A Scrubber nozzle pressure
B Maximum total halides and inorganic ash feed rate to the
incinerator system
B Minimum paniculate scrubber blowdown rate
1 Select as applicable to APCE system.
Table 3-4. Trial Burn Independent Control Parameters
Type . Parameter '
C Maximum total heat input for each chamber
C Liquid injection chamber burner settings
• Maximum viscosity of pumped waste
• Maximum burner turndown
• Minimum atomization fluid pressure
• Minimum waste heating value (if applicable)
C APCE inlet gas temperature
effects of this type of variation on the specification of
permit limits are dealt with in Chapter 2.
Random factors make it impossible to repeat exactly
the same nominal operating point. Results from
repeats of the same nominal operating point should
be averaged to yield a single mean value for each
control parameter and other performance. For
example, three repeats of the same nominal operating
point yield SCC temperatures of 1,100, 1,120, and
1,090°C (2,010, 2,040, and 2,000°F) and DREs Of
99.996, 99.998, and 99.990 percent, respectively.
The composite temperature for that nominal operating
point would be [(1,100 + 1,120 + 1,090)*3] 1,103°C
(2,017°F), and the composite ORE would be
[(99.996 + 99.998 + 99.990) * 3] 99.994 percent. It
should be noted that ORE values from individual runs
at a nominal operating point may not be averaged to
demonstrate compliance; for example, 99.99 percent
ORE must be achieved for each run. The calculation
of a composite ORE for a nominal operating point is
shown only for use in the equations presented in
Section 3.6.1 for interpolating between two nominal
operating points.
How closely must the data match to qualify as a
repeat of a nominal data point? No criteria are
recommended. Variations are unacceptable only if
they result in a failure to meet performance
standards. For example, if the last repeat in the
example was performed at 1,000°C (1,830°F) and
resulted in a ORE of 99.94 percent, that data point
would be unacceptable because it resulted in a ORE
lower than the 99.99 percent performance standard.
In such a case, the permit writer must exercise
judgment on the proper course of action. A possible
course is to not use the "failing" condition as a permit
limit. For example, set the minimum temperature
above 1,000°C (1,830°F). An alternative course of
action may be to require that a better repeat be
performed. Note that a "failing test" is defined as one
in which any one of the three runs did not achieve the
specified performance goal. The mean ORE cannot
be used to show compliance if all runs did not show
compliance.
3.4 Single Point Approach
The single point approach is the least complex
permitting strategy suggested here. It is appropriate
for incinerators that burn one type of waste with
relatively constant properties. Typically, this type of
incinerator is integrated into a process and destroys
the one waste stream to which it is dedicated.
Single point permit conditions are defined as the
codification of the minimum demonstrated operating
and system conditions resulting in satisfactory
performance of the incinerator. They are set from one
trial burn test (three runs minimum) with each of the
operating parameters established as described in
Chapter 2. The order of setting the operating
parameters should be that listed Jn Section 3.2,
although the order is not usually, important, since the
trial burn showed the operating conditions to be
consistent with each other and realistic.
3.5 Multiple Point Approach
A straightforward variation on an incinerator which
burns only one waste is one that burns a number of
well-defined sets of Wastes. Typically, these wastes
will be burned in combination; for example, a caloric
(high Btu) waste will be burned along with an
aqueous waste stream. If the types of wastes to be
burned can be clearly identified, i.e., waste 1=30
percent stream A and 70 percent stream B, waste
2 = stream C, etc., it is possible to specify that each
waste combination requires a unique set of permit
conditions.
The conditions for each point are arrived at by testing
the incinerator at each clearly defined condition, and
if the test is successful, these conditions are used for
the permit. This approach is actually equivalent to
setting single point conditions for each unique waste
32
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stream combination and writing several sets of single
point conditions.
Such a strategy is conceptually simple, but unless
care is taken to design the trial burn properly, it can
prove to be difficult to both implement operationally
and to enforce. The conditions must be selected so
that worst-case operating conditions are met during
each test with that set of wastes. The permit
conditions are set for each unique waste combination
in the same way as for a single point approach.
3.6 Universal Approach
For most incinerator applications, it is desirable to
select a single set of permit conditions to apply to all
modes of incinerator operation. This approach gives
the incinerator operator the flexibility to deal with a
variety of wastes and waste combinations while
limiting the number of trial burn data points that have
to be gathered, i.e., every combination need not be
tested. The universal approach allows such a set of
permit conditions to be determined. It must be noted
that this strategy will typically require a much higher
degree of complexity in the trial burn and will result in
operative conditons that in all cases are severe
enough to destroy the worst-case waste. The
interrelationships of the various operating parameters
need to be carefully considered to determine how
worst-case conditions can be achieved for the major
operating parameters simultaneously.
The preferable method for establishing the permit
conditions under a universal approach is to conduct
the test under worst-case conditions. This
procedure will likely involve blending the wastes and
adjusting the feed rates so that the applicant achieves
maximum feed rates for all waste types, maximum
feed rate of the POHCs, minimum temperature, and
maximum combustion gas velocity at the same
nominal operating point.
It is usually possible to set the permit conditions from
one set of trial burn conditons with the proper choice
of the test conditons. For example, worst-case
values for temperature and combustion gas flow rate
can usually be achieved at close to worst-case
values of the firing rates of individual waste streams
by adjusting excess air and auxiliary fuel. If for a
given system normal variation of these parameters
does not allow this to be done, it may be possible to
adjust the temperature and/or the combustion gas
flow rates by injecting water or steam to the
incinerator during the trial burn. In this way, the
applicant demonstrates the system under worst-
case conditions, and the permit writer can base the
permit conditions on hard data.
If, in spite of best efforts to do so, the facility cannot
achieve the critical target limits for all the control
parameters during the trial burn at one combination of
waste feed rates, excess air, etc., and this failure is
confirmed with mass and energy balance calculations,
it will be necessary to conduct the tests at different
conditions. Usually, some form of incompatibility
between the waste streams and the conditions that
are required to destroy them is indicated. Tests then
need to be conducted at two or more conditions.
When two tests are necessary, it is advantageous
that they be conducted at the same thermal duty,
temperature, and combustion gas velocity if at all
possible. While difficult to achieve maximum thermal
duty, combustion gas velocity, and minimum
temperature simultaneously, it is not impossible in
most cases. It is often possible to adjust the excess
air, inject water, and use synthetic or modified
wastes. The condition that facilities may not be able
to achieve under one set of test conditions is the
simultaneous maximum feed rate for all streams
combined. This can be achieved by varying each
individual waste feed rate to maximize its flowrate for
each individual test. The individual feeds can be
varied to maximize different ones in different tests as
long as all feeds are present in each test in a
sufficient quantity to demonstrate 99.99 percent ORE
for the POHCs in that waste stream.
Maximum feed rates for each stream could still be
allowed in the permit. The restrictions on
temperature, combustion gas velocity, and thermal
duty would prevent the operator from maximizing all
of them simultaneously. Another way of looking at this
approach is that the total feed rate (i.e., thermal duty)
does not really change; only the individual component
feeds change.
An important caveat to this approach is illustrated by
the situation when one stream contains a
preponderance of particulate-forming or acid-gas-
forming constituents. In that case, the above
restrictions can be used only to set the conditions on
those parameters that impact the ORE. The test at
which the particulate and HCI parameters, for
example, are worst-case would be used to set the
conditions on these parameters.
As stated earlier, the control parameters are grouped
into the three categories, A, B, and C, listed in Tables
3-2 through 3-4:
• Control parameters set (i.e., converted to permit
conditions) from trial burn data that are related to
waste destruction
• Control parameters set from trial burn data that are
related to APCE performance
• Control parameters that are independent of trial
burn data
33
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The following subsections discuss each of these
three categories and how they should be set as
permit conditions.
3.6.7 Control Parameters Related to Waste
Destruction
Control parameters set from trial burn data that are
related to waste destruction are listed in Table 3-2.
As discussed above, these parameters should be set
directly from tests at a single value for each
whenever possible. In those cases when it proves
impossible to minimize temperature, maximize feed
rate of each stream, maximize flue gas flowrate, and
maximize size of containerized waste at the same
time, these limits can be varied as discussed in
Section 3.6, above. When the permit conditions must
be set on the basis of data from different trial burn
conditions, the following guidelines may prove helpful.
The regulations generally consider temperature the
most important of the control parameters, followed
closely by residence time of the gas in the
combustion chamber. The rationale for this priority is
given in Section 2.1. Briefly, it is assumed that in a
properly operating incinerator, most of the POHCs are
destroyed in the flame. Of the fraction that is not
destroyed in the flame, a portion will be destroyed in
the post-flame zone. Post-flame POHC destruction
occurs slowly and, assuming all other parameters
remain constant, will be a function of temperature and
residence time. It is recognized that other factors
such as turbulence and oxygen, or excess air, as well
as residence time and temperature can affect the
destruction of POHCs in the post-flame zone. Total
POHC destruction is a function of incinerator
operating conditions. Thus, the destruction of the
small fraction of the remaining POHCs can be
correlated with different and successful operating
conditions. It is critical to recognize the basic
assumptions and limitations of this relatively simple
approach. This type of analysis can be used to
interpolate (but not extrapolate) the trial burn results.
Basically, the approach consists of fixing the
incinerator operating temperature and relating the
other parameters to it. Limits on the maximum flue
gas flowrate or maximum velocity measured at the
stack are then set to maintain the residence time in
the SCC, which is inversely proportional to the gas
volumetric flowrate in the SCC, to be greater than
that during the successful trial burn. Whenever
possible, the maximum flue gas flowrate should be
achieved during the test conducted at the minimum
temperature by varying air flow, injecting steam or
water into the system, or by changing the fuel (or
waste) feed rate.
When this is not possible, the minimum temperature
can be achieved by reducing the feed rate of the
waste or auxiliary fuel. In this case, the flue gas
flowrate at the minimum temperature will be less than
the maximum flue gas flowrate unless the excess
oxygen can be increased proportionally. If the permit
limit for the maximum flue gas flowrate (or maximum
velocity) is to be set from a test at a condition other
than the minimum temperature, it must be shown that
the flue gas flowrate at the minimum temperature
could be increased to the maximum flue gas flowrate
without causing ORE to decrease below 99.99
percent. This involves relating flue or stack gas
flowrate to ORE. The following theoretical evaluation,
which is based on the above assumptions regarding
the dependence of ORE on temperature and
residence time, may be useful when it proves
necessary to interpolate data between trial burns at
slightly different conditions.
The first step in the process is to relate the gas
flowrate in the stack to that in the SCC. The gas
flowrate in the stack is simply the flowrate of the gas
leaving the SCC plus air infiltrated and the gas
released by the quenching procedure, all corrected
for temperature change. It can be written as:
Qsec = (Qstack - Qleakage - Qquench) (Tse
-------
associated with a trial bum. Equation 2 can be used
with a reasonable degree of reliability in most cases.
Next, the residence time must be related to waste
destruction. This is a far more difficult and dangerous
step in the derivation. Nevertheless, an approximation
must be made if some means of interpolating the data
is to be used. For this type of analysis, the DE
(destruction efficiency) is approximated by a first-
order reaction according to the formula:
1 —
\
=
100%/
= exp -AT exp I -
F •• *
(3)
where A and E are kinetic rate constants, R is the
universal gas constant, I is temperature, and x is
time. For a particular POHC at a constant
temperature, taking the natural logarithm of both sides
of equation 3 results in:
Infl-
DE \
100%/
(4)
where K is a constant consisting of the terms within
the square brackets in equation 3 except for i.
Equations 3 and 4 assume that the destruction of the
small amount of POHC remaining in an incinerator
which normally destroys more than 99.99 percent of
the POHC will follow first-order reaction kinetics.
This is a reasonable approximation for the very low
concentrations of POHC in the gas phase that occur
under these conditions and for which this
approximation is intended. This assumption is
supported by the results that have been obtained by
the University of Dayton Research Institute in its work
associated with development of the stability rankings
given in Appendix D.
A reasonable way to ensure the ORE remains at
99.99 percent or above is to base the minimum
allowable residence time (tmjn) on the minimum
observed ORE (DREmjn) and the residence time at
the minimum-temperature trial burn point (Tmjn). For
this analysis, it can be assumed that the minimum
ORE corresponds to the minimum temperature. This
assumption js a fallout of the assumption in equation
3, although this will not always be true as the
mechanisms are more complex in actual operation.
In practice, the DE for a POHC is not measured.
Rather, ORE is calculated from measurements of
POHC emissions from the exhaust of the APCE.
Although small, the APCE's contribution toward
POHC removal" will be the same from one test to the
next. The further approximation can be made that the
ORE is proportional to the DE. Without going through
the derivation, equation 4 can be rewritten as:
In 1-
99.99% \
100% /
(5)
TTmin
In 1-
DRE .
nun
100%
In other words, the logarithm of the penetration (1-
DE) for each POHC is proportional to the residence
time and the various gas flows as described in
equation 2. Combining equations 5 and 2 reveals the
following relationships:
Q
ORE
In 1-
rrun
100%
'stack max
-9.21
"stack ^- min
(6)
or
Infl-
DRE
min
100%
stack max
-9.21
stack
min
(7)
where Qstack max is the maximum allowable gas
volumetric flowrate at the stack, and Vstack max is the
maximum allowable gas velocity at the stack.
Thus, if this equation is used to interpolate the results
of trial burns at two slightly different conditions, the
permit limit for maximum flue gas flowrate measured
at the stack (Qstack max) should be either Qstack max
evaluated from equation 6 or the maximum flue gas
flowrate measured in the trial burn, whichever is
lower. Similarly, the permit limit for maximum gas
velocity measured at the stack (Vstack max) should be
either Vstack max evaluated from equation 7 or the
maximum gas velocity measured in the trial burn,
whichever is lower.
This approach should only be used when the permit
writer is faced with results such that one combination
of waste feeds results in one value of the gas
flowrate, the second combination results in a different
value, and the applicant cannot accept the lower
value. Every effort should be made to avoid such a
situation by planning the trial burn to achieve these
conditions simultaneously through use of unregulated
parameters such as excess air, as described earlier in
this chapter. In all cases, this equation should never
be used to extrapolate the data beyond that of a trial
burn. For example, under no circumstances should
this approach be used to allow a higher gas flowrate
(and lower residence time) than measured in the trial
burn. The equations are not sufficiently rigorous for
35
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this purpose. They are given here as an interpolation
tool.
To illustrate the use of this approach, consider a trial
burn on a single chamber, liquid injection incinerator
with two POHCs at two conditions. The first condition
is at a full waste flow to achieve the maximum flue
gas flowrate. The waste flow is reduced for the
second condition to achieve the minimum
temperature at a flue gas flowrate lower than the
maximum. The measurements may be summarized
as follows:
Run
No.
1
2
Combustor
Temperature, °C
1,200
1,000
Flue Gas
Flowrate, m3/s
20
17
ORE, percent
POHC1 POHC2
99.999 99.998
99.997 99.996
The maximum allowable gas volumetric flowrate
based on the ORE observed at the minimum
temperature data point may be calculated from
equation 6:
Q
/ 99.
In 1 - —
\ 1(
996% \
100% /
stack max
-9.21
17 m3/s =19 m3/s
Thus, if 1,000°C (1,830°F) is set as the minimum
temperature limit, the minimum,ORE measured at that
temperature, 99.996 percent, is not enough to justify
setting 20 m3/s (700 cu ft/sec) (maximum measured)
as the maximum flue gas flowrate. The flue gas
flowrate limit should be set at 19 m3/s (670 cfs). Even
if Qstack max calculated by equation 6 were lower, 17
m3/s (600 cfs) would be set as the limit because the
incinerator already demonstrated compliance at the
minimum temperature at that flowrate.
To illustrate how temperature and flue gas flowrates
can be made to correspond so that the actual trial
burn data can be used for setting the limits on these
control parameters, consider the same example with
the change that the tests be conducted to achieve
the minimum temperature by increasing the air flow.
The flue gas flowrate at condition 2 would be higher
than 20 m.3/s (700 cu ft/sec). In this case, the
maximum flue gas flowrate and the minimum
temperature permit limits could be set from the same
trial burn data point.
The maximum feed rate of each low heating value
waste stream to each combustion chamber should be
that demonstrated at the minimum temperature trial
burn point. This is reasonable for a low heating value
waste because an increase in waste feed leads to a
decrease in temperature; thus, it is possible to
minimize temperature and maximize waste feed rate
at the same trial burn point. For a high- or
medium-heating-value waste, the maximum feed
rate should not be tied to the minimum temperature
trial burn because 1) it may not correspond to the
maximize feed rate and minimum temperature and 2)
high heating value wastes are often used in place of
auxiliary fuel. To limit the feed rate to that
demonstrated at the minimum temperature trial burn
point may severely limit the operator's ability to
control temperature.
A low heating value waste is defined as one incapable
of maintaining the incinerator temperature without the
assistance of an auxiliary fuel or a high heating value
waste. The exact value that defines this cutoff
depends on the character of the waste. A waste
whose LHV is less than approximately 11,600 kJ/kg
(5,000 Btu/lb) will generally have difficulty supporting
smooth combustion on its own. This very approximate
cutoff is based on the requirement to maintain a
typical rotary kiln at 871 °C (1,600°F) at 100 percent
excess air.
The limit on the maximum size of containerized waste
to the PCC is designed to prevent depletion of the
chamber oxygen from the sudden release of volatiles.
This limit should not be tied to the minimum
temperature trial burn point because volatile release is
more rapid at higher temperatures. It should also not
be tied to the highest temperature trial burn point
because there is no proposed maximum temperature
permit limit, and overcharging containerized waste to
the PCC should cause CO excursions which are
covered by other permit limits. Therefore, it is
recommended that the limit on the maximum size of
containerized waste to the PCC be set as the
maximum demonstrated for any trial burn point.
In summary, the guidelines for setting permit limits for
parameters related to waste destruction are as
follows:
• Permit limits should only be set from trial burn data
that show compliance with ORE, HCI, particulate,
and CO performance standards.
• When applying the "universal" approach, every
attempt should be made to achieve the worst-
case values of all key parameters during the same
test.
• When the minimum temperature and maximum
combustion gas velocity cannot be achieved during
the same test, the maximum flue gas .flowrate
measured at the stack should be Qstack max
evaluated from equation 7 or the maximum flowrate
measured in the trial burn, whichever is lower.
• The maximum feed rate of each low heating value
waste stream to each combustion chamber should
36
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be the feed rate of that stream at the minimum
temperature trial burn point; the maximum feed rate
of each medium- or high-heating-value waste
stream should be the maximum feed rate of that
stream for any trial burn point.
• The maximum size of containerized waste charged
to the PCC should be the maximum demonstrated
for any trial burn point.
3.6.2 Control Parameters Related to APCE
Performance
Control parameters set from trial burn data that are
related to APCE performance are listed in Table 3-3.
These parameters pertain to specific particulate and
acid gas collection devices. Control parameters that
pertain to particulate control devices include:
• Maximum total ash feed rate to the incinerator
system ,
• Minimum differential pressure across particulate
Venturi scrubber
• Minimum kVA settings to ESP and kV to IWS
• Minimum pressure differential across FF
• Minimum particulate scrubber blowdown rate
The permit limits for APCE parameters relating to
particulate collection devices should be set from the
test performed at the worst-case conditions for the
APCE parameters while the maximum amount of ash
feed is being fed to the incinerator. For an incinerator
burning solids, the maximum flue gas flowrate will
entrain the maximum particulate. In that case, the test
should also be performed at the maximum flue gas
flowrate. The permit limits can then be set on the
basis of this test.
In those cases where it is either impossible or
impractical to achieve the maximum ash feed rate and
flue gas flowrate and maintain the worst-case
conditions for APCE performance. It is possible to
use the results from several tests at similar (but not
the same) values of the control parameters and arrive
at a technically justified limit. It is important to note
that this approach is intended only to verify that
operating limits for different parameters, determined
from two different test conditions, are mutually
consistent. Under no circumstances should this
approach be used to extrapolate values of any
operating parameter beyond a level that has been
tested. Two methods are given, one for a liquid
injections and the second for a rotary kiln incinerator.
For a liquid injection, the particulate loading (at 7
percent 62) can be approximated over a narrow
range of operating conditions as being proportional to
the ash feed rate and inversely proportional to the gas
flowrate. The gas flowrate enters into this since a
higher gas flowrate will tend to dilute the particulate.
Note that the 7 percent oxygen correction does not
influence the correction since the higher gas flowrate
can be caused by a change in fuels or waste
composition rather than by simple dilution. This
generalization can only be made when comparing
results of tests at similar, but not identical, conditions
and it cannot be used to extrapolate the results
beyond the conditions of any test. If extrapolation is
attempted, assumptions on the interaction between
the gas flowrate and oxygen correction, as well as
numerous other factors invalidate the analysis. The
above proportionality can be represented by the
following equation:
PC,
where:
PC = the particulate concentration (mg/dscm) at
each of the two conditions, corrected to 7
percent 02
(mash) = the input rate of the ash to the incinerator
at each of the two conditions
Q = flue gas flowrate at each of the test
conditions
This equation can be reconstructed to compare the
emissions at a given set of hypothetical conditions
which are similar to a trial burn condition with the 180
mg/dscm limit specified by the regulations to yield
equation 8.
PC,. ..
limit
180 mg/dscm
( m ./Q ., . )
\ ash ^stack/n
ash stackymax ash, flue gas flow
(8)
In equation 8, the subscript "limit "denotes the trial
burn at the conditions of the limit of performance of
the APCE (minimum pressure drop, minimum KVA, or
minimum blowdown rate) and the subscript "max ash,
flue gas flow" denotes the trial burn at the conditions
of maximum ash feed rate and maximum flue gas flow
condition.
Equation 8 is presented here mainly for the purpose
of illustration and to show how a similar equation is
determined for a rotary kiln incinerator. Interpolation is
rarely required to set conditions for a liquid injection
incinerator. Because equation 8 is rarely used, no
separate example of its use is given. The following
37
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illustration for a rotary kiln incinerator can, however,
readily be adapted to equation 8.
In summary, the permit limit for the maximum
inorganic ash feed rate to a liquid injection
incineration system should be set from the maximum
flue gas flow rate test conditions whenever possible.
If it is impossible to do so, limits for related control
parameters can be based on the results of more than
one test condition, although the test conditions used
must be as similar as possible. If this is done,
equation 8 should be used to determine if the
"hybrid" conditions are internally consistent and will
still satisfy the regulations.
A similar analysis can be done for rotary kiln
incinerators. In this case, the participate emissions
can (over a narrow operating range) also be assumed
proportional to the ash feed rate. However, for kilns,
the particulate emissions are generally recognized to
be proportional to the cube of the gas flowrate. This
is based on particulate entrainment for kilns. Again,
this is a rough approximation to assist in the
evaluation of similar tests. This fact cannot be used
as a predictive tool. By using these facts in an
analogous way to the derivation of equation 8 one
can generate equation 9 for rotary kiln incinerators.
\mash^stack/limit
PC.. ..
limit
180 mg/dscm / 3
ash "stack/maxash, flue gas flow
(9)
y ash "stack/n
If equation 9 is not satisfied, then the permit limit for
maximum inorganic ash feed rate or the permit limit
for maximum flue gas flowrate must be decreased by
decreasing the value of the denominator until the
equation is satisfied. A combination rotary kiln-liquid
injection incinerator should be treated as a rotary kiln
incinerator since most of the particle loading is
expected to come from entrainment in the kiln.
The fpllowing illustrates the use of equation 9.
Suppose a trial burn is conducted on a rotary
kiln/afterburner incinerator at two test conditions. The
first test is run at full waste and air flows to achieve
the maximum flue gas flowrate and the maximum ash
feed rate. The second test is run at reduced waste
and the Venturi's throat is adjusted to achieve the
minimum pressure drop:
Venturi DP,
Test mash,kg/s Qstack-m3/s PC.mg/dscm cm H;O
1
2
1.0
0.5
20
17
150
50
50
40
50 mg/dscm (Q.5kg/s) (17m3/s)3
180 mg/dscm
0 kg/s) (20 m3/s)3
= 0.28:20.31
In this case, equation 9 becomes:
Since equation 9 is satisfied, the maximum inorganic
ash feed rate of 1.0 kg (2.2 lb)/s and the maximum
flue gas flowrate of 20 m3/s (700 cfs) can be taken
from test condition 1 while the minimum pressure
across the Venturi scrubber can be taken from test
condition 2. If equation 9 were not used, then it would
be necessary to pick these conditions at one or .the
other of the test conditions and set all appropriate
parameters on that basis, thereby making the
condition more restrictive.
The use of data from more than one test to set permit
conditions should be avoided if at all possible. The
following are a number of general observations which
may prove useful when designing the trial burn so
that one test condition can be used to set the
conditions.
Whenever possible, the pressure drop across the
Venturi scrubbers should be adjusted for a test by
changing the throat size (if it is a variable throat
Venturi) or, if that is not possible, by adjusting the
liquid flow consistent with adequate performance. It
should not be minimized by lowering the flue gas
flowrate. This is especially important on rotary kiln
incinerators as the flue gas flowrate has a cubed
effect on the particulate emissions.
For systems with Venturi scrubbers, the goal of the
trial burn should be to achieve a minimum pressure
drop at the highest gas flow. For fabric filters,
pressure drop can be decreased by increasing the
cleaning frequency during the tests. In most cases,
the particulate removal efficiency of a fabric filter
increases as the cleaning frequency decreases,
although at a penalty of reduced bag life. A higher
than normal cleaning frequency during the trial burn
will result in a more severe test of the system. To
increase the life of the bags, a longer cleaning cycle
may be desirable during normal operation. Allowing a
longer cleaning cycle (within good operating
practices) will not compromise particulate emission
levels.
Acid gas collection devices must meet a performance
standard of 99 percent HCI removal or a maximum of
1.8 kg (4 lb)/hr emissions. Permit parameters
pertaining to acid gas collection devices include the
following:
• Maximum total halide feed rate to the incinerator
system
• Minimum water/liquor flowrate to the absorber
• Minimum p.H to the absorber
38
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Acid is removed from the gas by diffusing to and
dissolving in a liquid of high surface area. For a given
physical design of the absorber, the critical factors
determining the removal efficiency are the L/G ratio
and the solubility of the acid gas in the solution,
which, except at low pH, is usually high. As acid
gases dissolve and are removed in a scrubber
solution, the pH of that solution decreases and results
ultimately in a decrease in acid solubility and a
decrease in acid removal efficiency.
Typically, this efficiency loss is countered by removal
(blowdown) and replacement of a portion of the
scrubber solution and by addition of caustic to
maintain the pH. The most severe test of the
system's capacity to remove acid from the gas
occurs when the total halide feed rate is at a
maximum, the pH of the scrubbing liquid is at a
minimum, the flow of the scrubbing liquid is at a
minimum, and the gas flow through the APCE is at a
maximum. These conditions^ will result in a minimum
L/G ratio, the highest acid gas loading, and the most
acidic scrubbant. Thus, the permit limits for maximum
total halide feed rate to the incinerator system,
minimum L/G ratio, and minimum pH to the absorber
should all be set from the same trial burn data point.
In summary, the guidelines for setting permit limits for
parameters related to APCE performance are as
follows: .
• Permit limits for minimum differential pressure
across particulate Venturi scrubbers, minimum kVA
settings to ESP kV to IWS, and minimum
blowdown rate for particulate scrubbers should be
set at the trial burn data point with the maximum
total ash feed rate to the incinerator system and
the maximum flue gas flowrate at the stack. If
these limits are set from a data point other than the
maximum ash, maximum flue gas data point, the
maximum ash feed rate and/or the maximum flue
gas feed rate limit should be reduced, if necessary,
to satisfy equation 9 for rotary kiln incinerators.
The permit limit for minimum differential pressure
across a FF is set from manufacturer specifications
for new bags.
• Permit limits for minimum L/G ratio and minimum
pH to the absorber should be set from the trial
burn data point at the maximum total halides feed
rate to the incinerator system.
3.6.3 Control Parameters Independent of Trial
Burn Data
Control parameters which are independent of trial
burn data are listed in Table 3-3. Permit limits for
these parameters should be set independent of trial
burn data and based on manufacturer
recommendations.
3.7 Determining Operating Envelope
Permit limits are set on parameters such as
temperature and flue gas flowrate, which are reliable
indicators of incinerator performance. To meet these
limits, the incinerator operator must maintain the
system within an implied operating envelope of
control variables such as waste, fuel, and air
flowrates. With the exception of waste feed rates, it is
not necessary or desirable to directly limit these
control variables. However, the permit writer, and
especially the permit applicant, should have a clear
understanding of the operating limits imposed by a
proposed set of permit conditions. This is particularly
important in the trial burn planning stage when the
permit applicant has the opportunity to examine the
consequences of the permit conditions resulting from
the trial burn plan and to modify the plan accordingly.
Before the trial burn is approved, the permit writer
and applicant should agree on the set of permit
conditions that will result from the planned trial burn if
it is successful.
Energy and mass balance procedures such as those
described in Appendix E can be used to estimate the
envelope of operating conditions resulting from a set
of permit conditions. An example of use of energy
and mass balance calculations for this purpose is
presented in Chapter 4. It is recommended that, for
flexibility in the permit conditions, these kinds of
calculations be performed by the permit applicant.
39
-------
CHAPTER 4
Example Test Case
The purpose of this chapter is to illustrate the
previous guidelines for setting permit conditions for a
typical incinerator facility. The example test case was
developed using a hypothetical scenario intended to
cover typical permit objectives and trial burn
approach, data reporting requirements, and trial burn
data evaluation. Although the facility design is based
somewhat upon real systems and trial burn results
are intended to represent actual data, any
resemblance to an actual site is unintentional.
4.1 Site Description
The example incinerator is an industrial rotary kiln
system that processes a wide variety of hazardous
waste streams. The incinerator, shown schematically
in Figure 4-1, consists of two combustion chambers
followed by APCE. The PCC is a rotary kiln. The SCC
is an afterburner. The kiln can receive the following
wastes:
• Solids (either bulk or containerized) through a ram
feed system at the front end of the kiln
• Sludge through a lance at the side of the kiln near
the front end
• Liquid organic and aqueous wastes through two
liquid injection units in the front end of the kiln
Kiln ash drops down into a water bath (sump), is
conveyed up an inclined conveyor, and dropped into
an ash hopper. Slowdown from the sump goes to the
wastewater handling system. This wastewater system
should be designed to meet all of the requirements of
the National Pollutant Discharge Elimination System
which was formulated in response to the Clean Water
Act. (Wastewater treatment is not a subject covered
in this handbook or example test case.) The primary
combustion gases exiting the kiln are directed through
the SCC. The SCC contains a waste burner with two
liquid injection nozzles used to fire high heating value
.liquid organic waste. Natural gas is used as an
auxiliary fuel to regulate the desired combustion
temperature in each chamber.
Stack gases leaving the SCC pass through a quench
section and a three-stage IWS before being
exhausted to the atmosphere via the induced draft
(ID) fan and stack. The IWS consists of three stages
in series, with twin parallel chambers in each stage.
The first stage is a prescrubber (nonionizing). The
following two stages are IWSs. The scrubber system
serves for both particulate and acid gas removal.
Scrubber liquor is pumped through separate headers
to each of the three scrubber stages. The caustic
flowrate along with makeup process water is
regulated to maintain a pH of approximately 6.5 to
7.0. Effluents from the quench and all three scrubber
stages are combined and flow to the wastewater
system. Key incinerator design information is
summarized in Table 4-1.
4.2 Structuring of the Trial Burn
In this example case, the facility is dedicated to the
incineration of onsite-generated process wastes.
Individual waste streams to be treated have typically
consistent properties." That is, the physical and
chemical characteristics of each waste stream do not
change appreciably on a daily basis. Under this
scenario, a multiple point permit approach (see
Section 3.5) may be appropriate. The assumption for
this example case, however, is that the applicant
seeks a single set of easily enforceable (universal)
permit conditions that: 1) are consistent with the daily
operating requirements of the facility, 2) incorporate
sufficient flexibility to satisfy anticipated requirements,
and 3) are compatible with the safe and economic
operation of each system component. Specifically,
the applicant desires a permit that will:
• Allow burning of any waste in any combination
consistent with the equipment design and intended
operation
• Allow burning of any waste at feed rates
established by storage and process limitations and
consistent with the design capacity of the
incinerator
• Require the minimum auxiliary heat input, power
consumption, and material (water, caustic) usage
• Require the minimum number of trial burn test
conditions
41
-------
Figure 4-1 Incinerator system for example test case.
Natural Gas
Liquid Waste —,
Waste
Water
Drummed Waste
Bulk Waste
*• NPDES
• Not impose unnecessary operational constraints
and not impose extensive monitoring requirements
To structure a trial burn test matrix that will
accomplish these objectives, four questions need to
be answered:
• What waste streams, feed rates, and POHCs
should be selected for testing?
• What should be the operational settings of thermal
treatment parameters?
• What should be the operational settings of the
APCE?
• How many test conditions will accomplish the
objectives?
The following sections summarize the rationale for
selection of trial burn test conditions, discuss the test
matrix, and define the resulting permit conditions
anticipated from this example test case.
4.2.1 Waste Selection and Feed Rates
The first task in selecting trial burn test conditions is
to examine the individual waste streams and their
disposal requirements to determine the waste types
and quantities that should be burned during the trial
burn. It is necessary to duplicate the most severe
conditions likely to occur during actual operation and
to identify those Appendix VIII (or other) compounds
that will be designated as the POHCs. As illustrated in
Figure 4-1, this facility incinerates three major waste
stream types:
• Solids - containerized and bulk
• Sludge
• Liquid wastes
Table 4-2 lists the eight waste streams that will be
burned at this facility and gives their major physical
characteristics and composition. Note the three waste
stream types listed above as well as their heating
value-high or low. High heating value wastes are
generally those which will support stable combustion
on their own, typically greater than 11,500 kJ/kg
(5,000 Btu/lb)LHV.
The solid wastes that will be burned by this facility
consist of two streams identified as S1 and S2. Of
these two, the "drummed waste," S1, is the larger
stream. This waste makes the most severe demands
on the incinerator's ability to meet ORE, HCI, and
particulate standards because it has high
concentrations of POHCs, it contains difficult-to-
burn Appendix VIII constitutents and has high chlorine
and ash contents. It contains 2.7 percent chlorinated
organics consisting of carbon tetrachloride and
trichlorobenzene, which are potential POHCs, that
have a combined maximum feed rate of 30.6 kg (67.5
lb)/hr. The solids waste stream, S2, is only about half
the size of the drummed waste stream, and the only
potential POHC in it is toluene at 0.5 kg (1.1 lb)/hr.
The applicant is requesting a permit to burn up to 27
-------
Table 4-1. Example Incinerator Test
Parameter
Incinerator type
Inside dimensions (diameter x length)
Cross-sectional area
Volume1
Heat capacity
Refractory thickness1
Refractory conductivity
Refractory surface area1
Cooled surface area
Waste feed system
Case: Summary Design
Units
-
m
(ft)
(sqft)
m3
(cuft)
kJ/hr
(Btu/hr)
cm
(in)
kJ/s-m-°C
(Btu-in/hr-sq ft-°F)
(sqft)
(sqft)
Information
Primary
Combustion
Chamber
Rotary Kiln
3.4 x 6.7
(1 1 x 22)
8.8
(95)
59
(2,090)
72 x 106
(68x106)
15
(6)
0.00144
(10)
88
(950)
0
(0)
Ram feed for drums and
bulk solids; sludge lance;
Secondary
Combustion Combined
Chamber System
Afterburner
3.6 x 7.5
(11.9x24.6)
10.3
(111)
78
(2,750)
36 x 106 108X106
(34x106) (102x106)
15
(6)
0.00144
(10)
106
(1,140)
0
(0)
Liquid injection
for organic
Installation date
ID fan capacity
Maximum quench inlet temperature1
Maximum scrubber inlet temperature1
HCI removal capacity1
Quench water supply capacity1
Quench water temperature1
year
Normal m3/min
(dscf/min)
kg/min
(Ib/hr)
Us
(gpm)
liquid injection for organic
and aqueous
1981
1975
1 Needed for energy and mass balance calculations.
kg/min (3,600 Ib/hr) of solids, which can be met by
burning any combination of S1 and S2. Clearly, the
most severe case would be to burn only S1 for the
test. If this is possible, a successful test will allow the
operator maximum operating flexibility. If the system
cannot burn only drummed solid waste, at least one
test should be performed at a combined feed of S1
and S2 of 27 kg/min (3,600 Ib/hr) with S1 accounting
for as much as possible of this value. The permit
condition would then specify the maximum total
amount of solid waste and maximum drummed waste
to be burned.
As shown in Table 4-2, the largest liquid wastes fed
to the system is L1, the contaminated wastewater
stream. The high concentration of water in this
stream is likely to tax the ability of the kiln to maintain
temperature and prevent quenching of the solid and
liquid wastes. The large quantity of water also results
in the largest gas release per unit of waste and,
570
(20,000)
1,090
(2,000)
96
(205)
3.18
(300)
19
(300)
4-38
(40-100)
hence, the lowest gas residence time for a given
combustion setting. Thus, L1 is a good stream to vary
to establish the liquid waste feed rate limit during the
trial burn.
The third category of waste to be considered is the
sludge waste, SL. This waste will not sustain
combustion on its own. It should be included in the
test program because it represents a separate waste
stream for which a feed rate limit must be determined
and because it will tend to quench the high heating
value solid wastes in the kiln. That this waste
contains a potential POHC, chlorobenzene, adds
weight to including it in at least some of the tests
during the trial burn.
There are four high heating value liquid organic
wastes. These are fed either to the kiln or to the
SCC, and neither of these has a major advantage or
disadvantage as a candidate for the trial burn. Below
43
-------
Table 4-2. Example Incinerator Test Case: Major Physical and Chemical Characteristics of Onsite-Generated Wastes
Waste Type;
Category
Solids
Solids
Low Heating
Value Liquids
High Heating
Value Liquids
High Heating
Value Liquids
High Heating
Value Liquids
High Heating
Value Liquids
Sludge
Site
Waste
10
S1
82
L1
12
L3
L4
L5
SL
EPA
Waste
ID
Code
F005
F005
F002
F005
K016
1
K085
Waste
Description
Drummed
waste
Trash and
bulk solids
Organic
contaminated
wastewater
Liquid organic
waste
Liquid organic
waste
Liquid organic
waste
Liquid organic
waste
Sludge .
Location
Kiln
Kiln
Kiln
Kiln o rSCC
Kiln or SCO
Kiln or SCC
Kiln or SCC
Kiln
High
Heating
Value.
kJ/kg
(Btu/lb)
20.900
(9,000)
20,600
(8,900)
Nil
32,700
(14.100)
35.460
(15,300)
31,500
(13.600)
34.600
(14,900)
6,200
(2.700)
Moisture,
% wt.
4
20
98.67
15
2
2
10
70
Ash,
% wt.
45
39
0.07
1
2
0.8
3
1.4
TOCI,
% wt.
2.2
0
0.2
15
.0
26
5
0.01
Carbon,
% wt.
36
28
0.05
50
78
52.2
48
10
Hydrogen,
% wt.
9
11
0.01
16
10
15
20
3
Oxygen,
% wt.
3.8
2
1
3
8
4
14
2.99
RCRA App. VIII
Compounds
Carbon tetrachloride
Trichlorobenzene
Toluene
Chloroform
Toluene
Carbon tetrachloride
Tetrachloroethylene
Phenol
Toluene
Bis(2-chloro)ethylether
Carbon tetrachloride
Trichloroethylene
Trichlorobenzene
None
Chlorobenzene
Typ.
Cone.,
% wt.
1.1
1.6
0.1
0.14
0.02
6.8
10
26
16
1
18
6
5
NA
0.03
Disposal
Requirements,
kg/s (Ib/hr)
0.31
(2,500)
0.14
(1,100)
0.51
(4,000)
0.032
(250)
0.0063
(50)
0.096
(750)
0.0063
(50)
0.15
(1.200)
1 Not a RCRA waste.
-------
are the requirements for the liquid organic wastes that
must be satisfied during the trial burn:
1. Ensure that the maximum total organic chloride is
fired so that the maximum HCI loading is put on
the scrubber.
2. Ensure that sufficient levels of POHCs are fired so
that 99.99 percent ORE is detected.
It is possible to satisfy these conditions by firing the
amounts of each of the L2 through L5 streams at the
rates specified in Table 4-2. These are the average
firing rates anticipated during normal operation;
however, in this case, the applicant chose to meet
the 8.4 kg/min (1,100 Ib/hr) combined disposal
requirements for these four streams by burning 2.28
kg/min (300 Ib/hr) of the L2 waste in the kiln and 6
kg/min (800 Ib/hr) of the L4 waste in the SCC.
The next step in the process is selection of the
POHCs which will be burned during the trial burn.
Since the guidance for this selection is still (as of this
writing) not finalized, the following three POHCs will
be arbitrarily chosen for the purpose of this example:
1. Trichloroethylene (TCE)
2. Perchloroethylene (PCE)
3. Trichlorobenzene (TCB)
Please see the final guidance on POHC selection or
contact the OSW for further information on the
selection process.
4.2.2 Trial Burn Operating Conditions
When the individual waste streams and feed rates are
selected, the temperatures and excess oxygen levels
are the primary operating conditions that need to be
established for these combustion chambers.
Temperature settings have an impact on the amount
of auxiliary fuels required because the permit imposes
limits on the maximum waste feed rate in each
chamber. However, for this sample case, the
applicant has the option of controlling temperature in
the SCC by waste feed only because the waste (L4)
has a heating value significantly greater than 9,300
kj/kg (4,000 Btu/lb) and can be used as the primary
fuel. Thus, by selecting the appropriate L4 feed rate,
the use of auxiliary fuel can be minimized, and limits
on waste feed rate can be increased. In spite of this
option, the applicant's objective is to obtain a permit
for chamber outlet temperatures sufficiently low to
maximize operational flexibility. These target
temperatures are approximately 800°C (1,470°F) for
the kiln and 950°C (1,750°F) for the SCC exit planes.
The excess oxygen of about 11 percent was
determined to be sufficiently high to permit operation
close to the maximum gas flowrate for the system yet
still within the ability of the ID fan to maintain draft in
the kiln and design pressure drop in the APCE.
Table 4-3 summarizes the three test conditions
selected for the trial burn. All tests will be performed
with the same wastes and feed rates. These feed
rates were selected to reflect maximum anticipated
loading to the incinerator and maximum chloride and
ash handling by the APCE. Waste feed rates are also
within the design waste handling capacity of the
incinerator system. The kiln and SCC temperatures
are reduced progressively from the first test to the
third test. The natural gas fuel to both chambers is
used to control the temperature so that maximum
waste feed can be maintained at relatively constant
rates. Energy and mass balance calculations, as
described in Appendix C, can be used to estimate the
natural gas feed rates necessary to achieve the target
temperatures at 11 percent excess oxygen for the
selected waste feed rates. These calculations also
determine the flue gas flowrate for each operating
condition. The "worst-case" test conditions are
investigated during the third test when temperatures
to both chambers are lowered to target levels
selected by the applicant.
If the incinerator satisfies the RCRA performance
standards for ORE, HGI, particulate emissions, and
CO emissions at these test conditions, it will have
shown compliance under the following permit
conditions for the combustion chambers:
• Minimum Temperatures
- Kiln: 800°C (1(470°F)
- SCC:950°C(1,750°F)
• Maximum Waste Feed Rates
- Solid waste (drummed and/or bulk): 27 kg/min
(3,600 Ib/hr) for 170-L (45-gal) drum size
- Sludge to kiln: 9 kg/min (1,200 Ib/hr)
- Wastewater to kiln: 30.6 kg/min (4,000 Ib/hr)
- Organic liquid waste to kiln: 2.28 kg/min (300
Ib/hr)
- Organic liquid waste to SCC: 6 kg/min (800
Ib/hr)
• Total Ash and Chlorine Feed Rate
- Ash: 1.38 kg/min (1,800 Ib/hr)
- Chlorine (CI'): 2.58 kg/min (340 Ib/hr)
• Maximum Gas Flowrate: 598 actual m3/min (21,000
acfm) at stack conditions (71 °C, 160°F)
• RCRA Listed Compounds: Thermal stability class
equal to or lower than the tested POHC (based on
TSLoO2) in each waste stream
In addition to these limits, the facility would still have
to meet the CO emission limits, maintain negative
pressure in the kiln, and operate the liquid waste
burner in the SCC according to burner design
45
-------
Table 4-3. Example Incinerator Test Case: Trial Burn Test Matrix (Target Settings)
Kiln Waste Feed, kg/min (Ib/hr)
Test
No.
1
2
3
Drummed
Waste1
S1
27
(3,600)
27
(3,600)
27
(3,600)
SiudgB
SL
g
(1 ,200)
g
(1 ,200)
g
(1 ,200)
Wastewater
L1
30.6
(4,000)
30.6
(4,000)
30.6
(4,000)
High Btu
L2
2.28
(300)
2.28
(300)
2.28
(300)
sec
Waste Feed,
kg/min (Ib/hr)
High Btu
L4
6
(800) .
6
(800)
6
(800)
Total
Ash Feed,
kg/min (Ib/hr)
13.8
(1,800)
13.8
(1,800)
13.8
(1,800)
Total
Cl Feed,
kg/min (Ib/hr)
2.58
(340)
2.58
(340)
2.58
(340)
Temperature,
or\ toc\
O
PCC
goo
(1 ,650)
800
(1,470)
800
(1,470)
V ' 1
sec
1,040
(i.goo)
980
(1,800)
950
(1,750)
Average
Excess
02, %
11.0
11.0
11.0
1 Drummed waste feedrate corresponds to 1 drum approximately every 6 minutes.
Table 4-3 (continued). IWS Water Flowrate
Test
No.
1
Estimated uas
Use,
kJ/s (MBtu/hr)
Kiln
1,520
sec
3,780
(5.26) (12.g)
2
3
0
0
3,517
(12.0)
2,740
(9.5)
GasFlowtolWSi,
m3/min (cfm)
@STP2 ©Actual
510 614
(18,000) (21,700)
510 614
(18,000) (21,700)
490 589
(17,000) (20,400)
Quench
Gas
Outlet
Temp
°C (°F)
80
(176)
80
(176)
79
(174)
Water Flow, L/min (gpm)
Quench
910
(240)
887
(234)
gis
(242)
1
320
(85)
320
(85)
320
(85)
IWS Stage
2 3 Total
140 140 600
(38) (38) (161)
140 140 600
(38) (38) (161)
140 140 600
(38) (38) (161)
1 UG.
• Urn3
(gal/fiJ)
1.0
(0.0074)
1.0
(0.0074)
1.0
(0.0074)
IWS
Voltage
Settings
kV
30
30
30
IWS
Inlet
pH
7.0
7.0
7.0
Scrubber
Slowdown
Rate,
L/min
(gpm)
15:
(4.1)
15
(4.1)
15
(4.1)
1 Assumed the same as stack flowrate @ STP.
2STP = 20°C (68°F) and 1 atmosphere.
specifications pertaining to atomization pressures,
viscosity of the waste, and turndown.
4.2.3 Operating Conditions: APCE
The APCE trial burn test conditions are selected by
the applicant, taking into consideration the ability of
the APCE to achieve RCRA compliance with
paniculate and HCI emissions and its feasibility to
maintain these operating conditions during all post-
permit incineration activities.
The operating conditions of the prescrubber and the
two IWSs will be maintained at relatively constant
rates between test conditions. The critical scrubber
operating parameters that will be reflected in the
permit are listed in Table 4-3. The total IWS water
flowrate is targeted for 650 L/min (160 gpm) for an
L/G of 1 L/m3 (0.0074 gal/cu ft) with an inlet pH of
7.0. The kV setting for the two-stage IWS is
targeted for 30 kV, and the total scrubber blowdown
at 15 L/min (4.1 gpm).
4.3 Trial Burn Test Results
The trial burn test consisted of three replicate runs at
the same target test condition but at each of three
(somewhat different, acutal) test conditions.
Performance standards for ORE, HCI, and particulate
emissions were passed at all test conditions. Time-
weighted averages for CO stack gas levels were
below the limit values. The process conditions for
each run are summarized in Tables 4-4 through 4-
6. The performance results are summarized in Tables
4-7 through 4-9. Further supporting data are
included in Appendix G. An example strip-chart
recording for combustion temperatures is also
included in Appendix G along with example logs of
CEM data for CO and oxygen and an example plot of
corrected CO readings.
4.4 Determining Limits on Control
Parameters
The results of the trial burn must now be converted to
a set of limits on all the parameters listed in Table 2-
1. As discussed earlier, the universal permitting
strategy will be followed as described in Section 3.6.
Under this strategy, one value of each parameter
(e.g., temperature, gas flowrate, and pressures),
including allowances for variability, applies to all
modes of incinerator operation. The results are a
readily enforceable set of conditions that have an
adequate level of operating flexibility.
46
-------
Table 4-4. Example Incinerator Test Case: Summary of Process Operation Results1 • Test Condition 1
Run No.
Parameter
Test date
Combustion gas flowrate
PCC temperature
Mean
Maximum
Minimum
SCC temperature
Mean
Maximum
Minimum
PCC pressure
SCC pressure
Quench inlet temperature
Quench outlet temperature2
Heat input rate
Quench water flowrate
IWS inlet pH
IWS outlet pH
1st stage IWS water flowrate
2nd stage IWS3 water flowrate
3rd stage IWS4 water flowrate
IWS Unit 1 A - DC Current
IWS Unit 1A - DC Voltage
IWS Unit 18 - DC Current
IWS Unit 1B- DC Voltage
IWS Unit 2A - DC Current
IWS Unit 2A - DC Voltage
IWS Unit 28 - DC Current
IWS Unit 2B - DC Voltage
Stack height
Stack exit velocity3
Stack temperature3
Stack excess O24
Units
-
Actual m3/min
(acfm)
°C
(°F)
"C
(°F)
°C
(°F)
«c
(°F)
°C
(°F)
°C
(°F)
mm H2O
(in H2O)
mm H2O
(in H2O)
-
°C
<°F)
kJ/hr
(Btu/hr)
L/min
(9pm)
-
-
L/min
(gpm)
L/min
(gpm)
L/min
(gpm)
mA
kV
mA
kV
mA
kV
mA
kV
m
(ft)
m/s
(fps)
"C
(°F)
%
1-1
May 12, 1987
931
(31,800)
910
(1,670)
962
(1,763)
850
(1,562)
1,049
(1.920)
1,118
(2,045)
1,022
(1,872)
-1.6
(-0.10)
-8.6
(-0.34)
NA
79
(174)
74 x 106
(70 x 106)
852
(225)
6.3
2.9
321
(84.9)
142
(37.5)
142
(37.5)
33.8
30.0
21.1
31.1
94.2
28.2
105.4
28.8
18.3
(60)
12.5
(41.0)
71
(159)
10.85
1-2
May 12, 1987
956
(33,300)
916
(1,680)
968
(1,774)
860
(1,580)
1,038
(1,900)
1,115
(2,039)
1,020
(1,868)
-2.6
(-0.10)
-8.4
(-0.33)
NA
79
(172)
72 x 106
(68x106)
912
(241)
6.7
4.7
322
(85.1)
142
(37.5)
142
(37.5)
21.8
30.5
16.5
30.6
126.1
27.8
116.2
29.0
18.3
(60)
12.7
(41.8)
72
(161)
10.58
1-3
May 13, 1987
845
(31 ,300)
916
(1,680)
969
(1,776)
850
(1,562)
1,032
(1,890)
1,113
(2,035)
1,019
(1,866)
-2.5
(-0.10)
-7.6
(-0.30)
NA
77
(171)
69x106
(66x106)
965
(255)
6.8
3.9
322
(85.0)
142
(37.5)
142
(37.5)
14.2
31.0
10.7
31.8
94.4
27.7
81.7
28.5
18.3
(60)
11.8
(38.9)
71
(160)
10.68
1 Average of readings taken during each run.
2 Approximate IWS inlet temperature.
3 Average of readings from two simultaneous MM5 trains.
4 Orsat analysis.
47
-------
Table 4-5. Example Incinerator Test Case: Summary
Parameter
Test date
Combustion gas flowrate
PCC temperature
Mean
Maximum
Minimum
SCC temperature
Mean
Maximum
Minimum
PCC pressure
SCC pressure
Quench inlet temperature
Quench outlet temperature2
Heat input rate
Quench water flowrate
IWS inlet pH
IWS outlet pH
1 st stage IWS water flowrate
2nd stage IWS3 water flowrate
3rd stage IWS4 water flowrate
IWS Unit 1A - DC Current
IWS Unit 1A- DC Voltage
IWS Unit 1B - DC Current
IWS Unit 1B- DC Voltage
IWS Unit 2A - DC Current
IWS Unit 2A - DC Voltage
IWS Unit 2B - DC Current
IWS Unit 2B - DC Voltage
Stack height
Stack exit velocity5
Stack temperature33
Stack excess Og4
Units
-
Actual m3/min
(acfm)
°C
(°F)
°C
(°F)
"C
(°F)
°C
(°F)
°C
(°F)
°C
(°F)
mm H20
(in H2O)
mm H2O
(in H2O)
-
°C
(°F)
kJ/hr
(Btu/hr)
L/min
(gpm)
-
-
L/min
(gpm)
L/min
(gpm)
L/min
(gpm)
mA
kV
mA
kV
mA
kV
mA
kV
m
(ft)
m/s
(fps)
°C
(°F)
%
of Process Operation
2-1
May 13, 1987
915
(33,2800)
816
(1,500)
866
(1,591)
780
(1,436)
1,010
(1,850)
1,060
(1,940)
980
(1,796)
-2.0
(-0.08)
-8.9
(-0.35)
NA
78
(172)
67 x 106
(63 x 106)
927
(245)
6.7
2.9
322
(85.1)
142
(37.5)
142
(37.5)
23.1
29.5
16.4
31.1
63.3
29.0
74.4
29.2
18.3
(60)
12.5
(41.1)
71
(159)
11.59
Results1 • Test Condition 2
Run No.
2-2
May 14, 1987
914
(31,200)
821
(1,510)
872
(1,602)
781
(1,438)
982
(1,800)
1,020
(1,868)
940
(1,724)
-2.0
(-0.08)
-8.9
(-0.35)
NA
80
(176)
68x106
(64 x 106)
893
(236)
7.5
3.1
322
(85.1)
142
(37.5)
142
(37.5)
14.6
30.0
9.7
30.8
106.0
29.3
111.7
29.0
18.3
(60)
12.3
(40.5)
72
(161)
11.72
2-3 -
May 15, 1987
888
(31 ,400)
804
(1,480)
854
(1,569)
779
(1,434)
954
(1.750)
999
(1,830)
915
(1,679)
-2.0
(-0.08)
-8.9,
(-0.35)
NA
82
(180)
70x106
(67x106)
840
(222)
7.1
2.9
321
(84.8)
142
(37.5)
142 :,
(37.5)
31.8
30.4
18.5
30.5
114.1
28.7
96.5
28.9
18.3
(60)
12.0
(39.4)
71
(160)
10.14
1 Average of readings taken during each run.
2 Approximate IWS inlet temperature.
3 Average of readings from two simultaneous MM5 trains.
4 Orsat analysis.
48
-------
Table 4-6. Example Incinerator
Parameter
Test date •
Combustion gas flowrate
PCC temperature
Mean
Maximum
Minimum
SCO temperature
Mean
Maximum
Minimum
PCC pressure
SCC pressure
Quench inlet temperature
Quench outlet temperature2
Heat input rate
Quench water flowrate
IWS pH
IWS pH .
Prescrubber water flowrate
2nd stage IWS3 water flowrate
3rd stage IWS4 water flowrate
IWS Unit 2A - DC Current
IWS Unit 2A - DC Voltage
IWS Unit 28 - DC Current
IWS Unit 2B - DC Voltage
IWS Unit 3A - DC Current
IWS Unit 3A - DC Voltage
IWS Unit 3B - DC Current
IWS Unit 3B - DC Voltage
Stack height
Stack exit velocity3
Stack temperature3
Stack excess Og4
Test Case: Summary of
Units
-
Actual m3/min
(acfm)
°C
(°F)
°C
(°F)
°C
<°F)
"C
(°F)
°C
(°F)
°C
(°F)
mm HoO
(in H2O)
mm HgO
(in H2O)
-
°C
(°F)
kJ/hr
(Btu/hr)
Umin
(gpm)
-
-
L/min
(gpm)
L/min
(gpm)
L/min
(9pm)
mA
kV
mA
kV
mA
kV
mA
kV
m
(ft)
m/s
(fps)
"C
(°F)
%
Process Operation
3-1
May 15, 1987
878
(29,400)
793
(1,460)
840
(1,514)
760
(1,400)
971
(1,780)
1,020
(1,868)
960
(1,760)
-2.0
(-0.08)
-8.1
(-0.32)
NA
81
(177)
62 x 106
(59x106)
871
(230)
6.9
3.3
322
(85.1)
142
(37.5)
142
(37.5)
32.B
29.0
21.3
29.5
129.8
25.0
112.5
24.0
18.3
(60)
11.6
(38.1)
72
(161)
10.68
Results1 - Test Condition 3
Run No.
3-2
May 16, 1987
862
(30.400)
802
(1,475)
860
(1,580)
750
(1,382)
954
(1 ,750)
1,024
(1,875)
954
(1,750)
-2.6
(-0.10)
-8.4
(-0.33)
NA
79
(175)
61 x 10s
(58 x 106)
916
(242)
7.0
4.1
321
(84.9)
142
(37.5)
142
(37.6)
23.2
29.5
17.4
29.5
124.2
27.1
103.6
27.0
18.3
(60)
11.8
(38.9)
72
(161)
11.19
3-3
May 16, 1987
869
(30,700)
804
(1,480)
856
(1,573)
744
(1 ,372)
949
(1,740)
1,018
(1,865)
949
(1,740)
-2.6
(-0.10)
-8.6
(-0.34)
NA
77
(171)
63X106
(60x106)
958
(253)
7.3
3.7
322
(85.1)
142
(37.5)
142
(37.5)
14.5
28.7
8.1
29.3
75.4
26.5
66.5
26.8
18.3
(60)
12.0
(39.2)
71
(160)
10.58
1 Average of readings taken during each run.
2 Approximate IWS inlet temperature.
5 Average of readings from two simultaneous MM5 trains.
6 Orsat analysis.
-------
Table 4-7. Example Incinerator Test Case: Summary of Emission Performance Results • Test Condition 1 ;
Run No.
Parameter
Test date
ORE - Trichloroethylene
ORE - Tetrachloroethylene
ORE - Trichlorobenzene
Paniculate matter1
HCI emissions
Cl removal efficiency
Stack gas flowrate2
Stack gas flowrate2
Oxygen3
Carbon monoxide1 -3
Units
-
%
%
%
mg/Normal m3
(gr/dscf)
kg/hr
(Ib/hr)
%
Actual m3/min
(acfm)
Normal m3/min
(acfm)
%
ppm
1-1
May 12, 1987
99.9960
99.9990
99.9950
80.2
(0.0350)
0.560
(1.24)
99.64
875
30,900
507
17,900
10.55
62.0
1-2
May 12, 1987
99.9980
99.9970
99.9998
65.5
(0.0286)
0.831
(1.83)
99.45
892
31 ,500
515
18,200
10.60
29.9
1-3 ' ;i
May 13, 1987
99.9990
99.9991
•--99.9992 '•'•:-•<
32.8
(0.0143)
1.06
(2.33)
99.31
830
29,300
481
17,000
10.81
52.2
1 Corrected to 7% 02.
2 Average of readings from two simultaneous MM5 trains.
3 Concentrations in stack gas from facility in situ monitor. Oxygen monitor used to correct CO readings.
Table 4-8. Example Incinerator Test Case: Summary of Emission Performance Results - Test Condition 2
Run No.
Parameter
Test date
ORE - Trichloroethylene
ORE • Tetrachloroethylene
ORE - Trichlorobenzene
Paniculate matter1
HCI emissions
Cl removal efficiency
Stack gas flowrate2
Stack gas flowrate2
Oxygen3
Carbon monoxide1.3
Units
-
%
%
%
mg/Normal m3
(gr/dscf)
kg/hr
(Ib/hr)
%
Actual m3/min
(acfm)
Normal m3/min
(acfm)
%
ppm
2-1
May 13, 1987
99.9993
99.9992
99.9930
101.6
(0.0444)
0.217
(0.478)
99.86
878
29,400
518
18,300
11.55
56.3
2-2
May 14, 1987
99.9992
99.9950
99.9960
87.5
(0.0383)
1.39
(3.07)
99.11
864
30,500
510
18,000
11.39
80.1
2-3
May 15, 1987
99.9960
99.9980
99.9991
112.1
(0.0490)
0.319
(0.704)
99.80
841
29,700
496
17,500
10.43
76.5
1 Corrected to 7% O2-
2 Average of readings from two simultaneous MM5 trains.
3 Concentrations in stack gas from facility in situ monitor. Oxygen monitor used to correct CO readings.
50
-------
Table 4-9. Example Incinerator Test Case: Summary of Emission Performance Results - Test Condition 3
Run No.
Parameter
Test date
ORE - Trichloroethylene
ORE - Tetrachloroethylene
ORE - Trichlorobenzene
Particulate matter1
HCI emissions
Cl removal efficiency
Stack gas flowrate2
Stack gas flowrate2
Oxygen3
Carbon monoxide1-3
Units
-
%
%
%
mg/Normal m3
(gr/dscf)
kg/hr
(Ib/hr)
%
Actual m3/min
(acfm)
Normal m3/min
(acfm)
%
ppm
3-1
May 15, 1987
99.9990
99.9994
99.9950
74.4
(0.0325)
1.61
(3.54)
98.93
813
28,700
484
17,100
10.76
63.9
3-2
May 16, 1987
99.9950
99.9980
99.9950
55.3
(0.0242)
0.702
(1.55)
99.53
830
29,300
493
17,400
11.34
66.3
3-3
May 16, 1987
99.9970
99.9980
99.9993
96.4
(0.0421)
1.55
(3.42)
99.02
838
29,600
498
17,600
10.70
90.0
1 Corrected to 7% Oz.
2 Average of readings from two simultaneous MM5 trains.
3 Concentrations in stack gas from facility in situ monitor. Oxygen monitor used to correct CO readings.
The universal strategy sets the values for the control
parameters in the following order:
1. Control parameters from trial burn data that are
related to waste destruction
2. Control parameters from trial burn data that are
related to APCE performance
3. Control parameters that are independent of trial
burn data
The results of the trial burn for the test case have
been summarized in Tables 4-4 through 4-9 and in
Appendix G. The guidelines of Chapter 2 may now be
used to set control parameter limits based on these
data. The trial burn was performed at three test
conditions (or nominal operating points) with three
runs performed at each test condition. Following the
guidelines of Chapter 2, operating conditions of the
three runs were averaged to yield a composite set of
conditions for each test. The composite results, which
are summarized in Table 4-10, show that the
incinerator was in compliance with performance
standards for each run of all three test conditions.
The permit conditions chosen are summarized in
Table 4-11 and are discussed in detail in the
following sections.
4.4.1 Control Parameters Related to Waste
Destruction
The control parameters related to waste destruction
are listed in Table 3-2. The values of the parameters
as they are to be specified in the permit are shown in
Table 4-11. Following the recommended practice,
the group A parameters listed below are the first to be
set.
• Minimum temperature at the kiln and SCC exits
• Maximum CO emissions
• Maximum flue gas flowrate at the stack
• Maximum pressure in the kiln and SCC
• Maximum feed rates:
- of each waste stream to each combustion
chamber
- of combined waste streams to all combustion
chambers
- per container, maximum size of containerized
waste
As shown in Table 4-6, the mean kiln temperature
for each of the three runs under these test conditions
ranged from 793 to 8048C (1,460 to 1,480°F). The
SCC temperature ranged from 949 C to 971 °C (1,740
to 1780°F). The variation of the temperatures for all
the runs is not given here; it is, however, given for
run 1-1 in Appendix G, Table G-4 and Figure G-
1. Table G-4 gives the per minute output from the
k
51
-------
Table 4-10. Average Trial Bum Results At Three Test Conditions
Test Condition
PCC exit temperature, °C
SCC exit temperature, °C
Stack exit velocity, m/s @ 72°C
m/s @ STP
ORE - Trichloroethylene, %
ORE - Tetrachloroethylene, %
ORE - Trichlorobenzene, %
Cl removal efficiency, %
Carbon monoxide1, ppm
Feed rates, kg/min
Drummed waste (Si)
Sludge (SL)
PCC organic waste (L2)
SCC otganic waste (L4)
Wastewater (L1)
Total PCC waste
Total SCC waste
Tolal inorganic ash
Total halides
APCE inlet temperature, °C
Voltage to IWS, kV
Total electrical power to !WSs, kVA
IWS blowdown rate, L/min
Particulate concentration, mg/dscm
IWS water flowrate, L/min
pH to IWS
Permit Target
800
950
12.3
10.4
99.99
99.99
99.99
99
100
27
9
2.3
6.0
31
69
6
13.8
2.3
80
30
7.0
15
180
650
7.0
1
914
1,040
12.3
10.4
99.998
99,998
99.998
99.47
48.0
27
8.4
2.2
5.9
30
73
5.9
13.8
2.5
78
29.6
7.04
17
59.5
606
6.6
Test No.
2
814
932
12.3
10.4
99.998
99.997
99.996
99.59
71.0
29
7.8
2.3
6.0
31
73
6
14.4
2.6
80
29.7
6.63
20
100.4
606
7.1
3
800
958
11.8
.. . .,. 10.Q
99.997
99.998
99.996
99.16
80.1
27
7,8
2.3
.6.0
29
69
6
13.8
2.5
' 79 ' .
27.7
6.44
15
75.4
606
7.1
" Corrected to 7% O2.
temperature data logger; and Figure G-1 is the
graphical representation.
Table 4-10 summarizes the mean operating
conditions during each of the successful tests. Note
that all these values are given in metric units;
however, permit conditions should normally be
reported in the units in which the monitoring
equipment is calibrated. For temperature, the mean is
simply the average of the mean temperatures at
which the kiln and SCC operated during each of the
three runs at each condition, e.g., the mean of the
time-averaged temperatures for each of the three
runs. The lowest kiln temperature was 800°C
(1,470°F) during test 3, while the lowest mean SCC
temperature was 932°C (1,710°F) during test 2. The
minimum temperature permit condition could be
based on either test 2 or test 3. It is recommended
that the SCC and PCC minimum temperatures not be
taken from different tests. While in this case the
differences are inconsequential, they are interrelated,
and a temperature for each based on the results of
different tests could result in incompatible limits.
Table 4-12 summarizes the pertinent results of the
tests for making the decision.
The following calculation can be used to estimate
whether test 2 or 3 have significantly lower SCC gas
residence times. To do this, the gas flowrate (in this
case represented by the gas velocity at the stack at
standard conditions) is converted to the respective
temperatures of the SCC. For example:
10.4 x (932 + 273) / 293 = 42.8
The gas velocities are proportional to the actual gas
volumetric flowrate; hence, they are the inverse of the
residence time in the SCC. Thus, we can say that
test 3 was run at a slightly longer residence time than
test 2. Because in this case test 2 shows the shorter
residence time by a trivial amount and lower SCC
temperature, it should be used to set the limit on
temperature; however, the two conditions are so
slightly different that either could be used with little or
no risk.
The next control parameter that needs to be set is the
CO emissions. As indicated in Section 2.1.2, the EPA
is presently developing guidelines for these
emissions. The CO for the nine runs performed varied
between 29.9 to 90.0 ppm, corrected to 7 percent
oxygen. As a result, under the present guidelines, the
limit should be set at 90 ppm, the highest measured
during test number 3. Under the new guidelines, the
52
-------
Table 4-11. Summary of Permit Limits for Incinerator Example Test Case
Parameter
PCC waste cutoff temperature, °C
SCO waste cutoff temperature, °C
Maximum stack velocity, m/s
Maximum feed rates, kg/min
PCC solid waste (S1 & S2)
PCC sludge (SL)
PCC organic liquid (L2-L5)
SCC organic liquid (L2-L5)
PCC wastewater (L1 )
Total PCC waste
Total SCC waste
Total inorganic ash
Total halides
Maximum size waste drum, m3
Minimum IWS voltage, kV
Minimum scrubber blowdown, L/min
Minimum scrubber water flow, L/min
Minimum pH to scrubber
Maximum CO, ppm {1 -hr average)
Maximum kiln cutoff pressure
Maximum heat input rate, kJ/hr
Maximum SCC waste viscosity, cp
Maximum SCC waste turndown ratio
Minimum SCC waste burner pressure, N/m2
Minimum SCC waste HHV, kJ/kg
Maximum APCE inlet temperature, °C
Target
800
950
12.3
27
9
2.28
6
30
69
6
22.8
2.28
0.17
30
15
650
7.0
-
_
-
-
-
-
80
Limit
800
960
12.3
288
7.8
2.34
6
28.8
73.2
6
14.4
2.64
. 0.17
29.7
15
606
7.1
100
Atmospheric
63 x 106
100
8:1
310,000
11,600
80
Test
Condition
3
3
1,2
2
2
2,3
3
2
2,3
2
2
1,2,3
2
3
2
2
-
m
-
-
-
-
2
Justification
Minimum measured
Minimum measured
Equation 7
Maximum measured
Minimum temperature condition
Maximum measured
Maximum measured
Minimum temperature condition
Maximum measured
Maximum measured
Maximum stack velocity condition
Maximum stack velocity condition
Only trial burn setting
Maximum stack velocity condition
Equation 9
Maximum stack velocity condition
Maximum stack velocity condition
Per CO guidelines
Manufacturer specification
Maximum measured
Manufacturer specification
Manufacturer specification
Manufacturer specification
Manufacturer specification
Maximum measured
Table 4-12 Data Used for Setting Temperature Limit
- • . . Test 2 Test3
PCC temperature, °C 814 800
SCC temperature, °C 932 958
Combustion gas velocity, m/s
At stack conditions . 12.3 11.8
AtSTP : "... 10.4 10.0
At SCC temperature 42.8 42.0
limit should be set at 100 ppm, because 100 ppm CO
is generally considered to be the range for proper
operation of the incinerator which would minimize the
risk of excessive PIC formation and POHC emissions.
The next operating parameter that needs to be set is
the maximum flue gas velocity or flowrate. As
discussed in Section 2.1.3, flowrate should be
measured as close to the exit of the SCC as possible;
however, in most cases, the gas velocity at the inlet
to the stack is an adequate indicator of combustion
gas velocity. It was used in this case and found to be
adequate., By the careful selection of the test
conditions, the maximum combustion gas flowrate (by
whatever measurement method decided on) should
be specified from the same test as was the
temperature, whenever possible. In this case, the
maximum gas flowrate when corrected to SCC
conditions was very slightly lower in test 3 than in test
1 or 2. It was the same during test 1 and 2. If the
results of test 2 are used to specify the maximum
combustion gas flowrate, all the criteria are satisfied,
i.e., maximum measured during a test and chosen
from the same test as the minimum SCC
temperature.
For illustration, however, assume that the results
require interpolation of data and that equation 7 of
Section 3.6.1 will be used to implement the universal
strategy. If the temperature and combustion gas
flowrate limit were set on the basis of test 3 instead
of test 2, the maximum gas velocity that would be
allowed is 11.8 m/s (38.7 fps). This limit could be
unduly restrictive; for example, when a high heat
value waste is burned, the temperature will increase
above the minimum, (which by itself is acceptable),
but the gas velocity would also increase above the
11.8-m/s (38.7-fps) maximum and trigger a waste
cutoff. Under these very narrow circumstances, it is
possible to use equation 7 of Section 3.6.1 to
determine whether the higher gas velocity of tests 1
and 2 can still achieve the ORE under the lower
53
-------
temperature of test 3. It is worth repeating that in the
example case, the exercise is trivial since the
difference between the two sets of conditions is
negligible. It is presented here for illustration.
The residence time (or gas flowrate) that is required
to achieve 99.99 percent ORE at the lower
temperature conditions can be estimated from
equation 7 of Section 3.6.1. As the trichlorobenzene
had the lowest average ORE of 99.996 percent at this
minimum temperature test condition, its results can
be used for the purpose. By equation 7, for this
compound, then,
99.996% \
stack max
-9.21
11.8m/s=13.0m/s
The value of 13.0 m/s (42.6 fps) is greater than the
12.3 m/s (40.3 fps) that was measured at the higher
temperatures; hence, the maximum gas velocity in
the stack can safely be set at 12.3 m/s (40.3 fps).
Had the value calculated by equation 7 been less
than 12.3 m/s (40.3 fps) (the highest velocity
measured), the lower, calculated velocity would have
been used. However, the applicant can design the
test in most cases to achieve minimum temperature
and maximum gas flowrates by the addition of water
to the PCC or by the use of waste blending. Although
this example was used to demonstrate the universal
approach, the permit conditions could be set using a
multiple point permitting strategy, i.e., different
temperatures and velocities for different combinations
of waste feeds.
The next parameter to be set is the maximum
pressure in the kiln and SCC. During the tests, both
the kiln and SCC pressures were constant during
each run. As Tables 4-4 through 4-6 show, the
pressure differences among runs were modest as
well. Although not shown in the results, no indications
of puffing were observed during the trial burns. As a
result, following the guidelines in Section 2.1.4, the
minimum operating pressure set-point for both the
kiln and the SCC is atmospheric pressure, with the
caveat that the SCC pressure must be lower than that
in the PCC at all times.
According to the guidelines of Chapters 2 and 3, the
maximum feed rates of low heating value wastes
should be taken from the minimum temperature test
condition. The wastewater (with no heating value) and
the high-moisture sludge (with a heating value of
6,200 kJ/kg [2,700 Btu/lb]) may be classified as low
heating value wastes. The permit limits for the
maximum feed rates for these waste streams could
be taken from either test 2 or 3. In this case, it was
taken from test condition 2 for consistency with the
temperature selection. From Table 4-10, the permit
limit for maximum sludge feed rate should be set at
7.8 kg/min (1,030 Ib/hr), and the permit limit for
maximum wastewater feed rate should be set at 28.8
kg/min (3,800 Ib/hr).
The maximum feed rates of medium- and high-
heating value waste streams should be taken from
the test condition at which each individual feed rate is
maximized. Thus, from Table 4-10, the permit limits
for maximum feed rates should be 28.8 kg/min (3,800
Ib/hr) for the solid waste, 2.3 kg/min (300 Ib/hr) for the
12 liquid waste, and 6 kg/min (790 Ib/hr) for the L4
liquid waste. All these feed rates meet or exceed the
permit limit targets.
The permit limit for the combined feed rates of all
wastes to each combustion chamber should be taken
from the test condition at which that value is
maximized for each chamber. In this case, the
combined feed rate of all wastes to the kiln was
maximized at 73.2 kg/min (9,660 Ib/hr) in test
condition 2, and the combined feed rate of all wastes
to the SCC was maximized at 6 kg/min (790 Ib/hr) in
test condition 2. Those values should be taken as the
permit limits.
Only one size of containerized waste was fired in the
trial burn: 208-L (55-gal) drums. Thus, the permit
limit for the maximum size of containerized waste
fired to the kiln should be set at 208 L. This waste
was fired at a rate of one drum every 6 minutes. This
value should also be incorporated into the permit
condition.
4.4.2 APCE-Related Parameters
Permit limits for parameters set from trial burn data
that are related to APCE performance should be set
according to the guidelines of Section 3.6.2. For this
example test case, these parameters include:
• Maximum ash feed rate to the incinerator system
• Minimum kV settings to IWS
• Minimum paniculate scrubber blowdown rate
• Maximum total chloride feed rate to the incinerator
system
• Minimum L/G ratio to the absorber
• Minimum pH to the absorber
• Maximum APCE inlet gas temperature
The maximum ash feed rate should be taken from the
maximum stack gas velocity data point that occurred
at test conditions 1 and 2. The ash feed rate was
highest at test condition 2 at 14.4 kg/min (1,890
Ib/hr), which exceeds the permit limit target. This
value should be set as the limit.
The minimum kV setting to the IWSs (taken as the
sum of the electrical power to all scrubbers) was 27.7
54
-------
kV, taken at test condition 3. However, because the
ash feed rate at condition 2 is actually higher than the
ash feed rate at test condition 3 and the stack
velocity at that condition is also higher than that of
test condition 3, the maximum setting of 29.7 KV
measured at condition 2 should be set as the permit
limit for minimum KV to the IWSs.
The minimum particulate scrubber blowdown rate of
15 L/min (4 gpm) was achieved at test condition 3.
Because the maximum ash feed rate and maximum
stack velocity were recorded at test condition 2,
equation 9 must be satisfied to justify setting
minimum blowdown from a nominal operating point
other than test condition 2. From Table 4-10, the
ash feed rate and stack velocity at test condition 2
were 14.4 kg/min (1,900 Ib/hr) and 12.3 m/s (40.3
fps), respectively. At test condition 3, the ash feed
rate was 13.8 kg/min (1,820 Ib/hr), the stack velocity
was 11.8 m/s (38.7 fps), and the particle
concentration was 75.4 mg/dscm. Because velocity is
equal to gas flowrate divided by cross-sectional
area, equation 9 can be solved:
13.8 kg/min
75.4 mg/dscm
180 mg/dscm
stack
14.4 kg/min
12.3
stack
0.42 <, 0.88
where the cross-sectional area of the stack (Astack)
cancels out. The equation is satisfied; so the
minimum scrubber blowdown rate permit limit can be
taken from test condition 3 at 15 L/min (4 gpm).
According to the guidelines of Section 3.6.2, the
permit limits for maximum total halide feed rate,
minimum water flowrate, and minimum pH to the
absorber (in this case, the scrubber system) should
all be set from the maximum flue gas flowrate, or
stack velocity, operating condition. Extreme values of
these parameters were not all achieved at the same
test condition. However, in test condition 1 where the
stack velocity was at a maximum, all values satisfied
the permit limit targets. Thus, the permit limits should
be taken from test condition 1 at 2.52 kg/min (332
Ib/hr) maximum total halide feed rate, 606 L/min (160
gpm) minimum scrubber water flowrate, and 6.6
minimum pH to the scrubbers.
The maximum APCE inlet temperature (same as
quench outlet temperature) was 80 °C (176°F) during
test 2. Therefore, the maximum APCE temperature
will be set at 80°C (176°F) which is less than the
manufacturers specification of 100°C (212°F).
4.4.3 Parameters Independent of Trial Burn Data
Permit parameters for the example test case that are
independent of the trial burn include:
• Maximum total heat input capacity for each
chamber
• Maximum viscosity of liquid waste to the SCC
• Maximum SCC liquid waste turndown
• Minimum SCC atomization fluid pressure
• Minimum SCC waste heating value (when no
auxiliary fuel is fired)
The permit parameters listed above should be set
according to the recommendations of the
manufacturer. For this system, the kiln should be
maintained at negative pressure; the maximum total
heat input to the kiln is 20,000 kJ (19,000 Btu)/s; the
maximum total heat input to the SCC is 11,700 kJ
(11,000 Btu)/s; the maximum viscosity of liquid waste
to the SCC is 100 cp; the maximum turndown for the
liquid waste to the SCC is 8:1, which results in a
liquid waste flowrate range of 0.06 to 0.45 kg/min (8
to 60 Ib/hr) to each of the two waste burners; the
minimum atomization fluid pressure for the liquid
waste SCC is 310,000 N/m2 (45 psig); and the
minimum SCC waste heating value in the absence of
auxiliary fuel is 11,600 kJ/kg (5,000 Btu/lb).
4.4.4 Summary of Operating Limits
The permit writer and especially the permit applicant
should have a clear understanding of the interrelated
effects of the operating limits imposed by a proposed
set of permit conditions. This is particularly important
during the trial burn planning stage when the permit
applicant has the opportunity to examine the
consequences of the permit conditions that would
result from the trial burn and to modify the plan
accordingly. Before agreeing to a set of limits, the
operator is encouraged to perform energy and mass
balance calculations such as those described in
Appendix E to verify that the permit conditions are
internally consistent. As an example, energy and
mass balance calculations have been used to
establish the operating envelope for the rotary
kiln/SCC incinerator of the example test case to meet
the following set of permit conditions as established
by the trial burn:
• Minimum kiln temperature: 800°C (1,470°F)
• Minimum SCC temperature: 950 °C (1,750°F)
• Maximum stack velocity: 12.3 m/s (40 fps)
• Maximum waste feed rates
- Kiln solid waste: 27 kg/min (3,600 Ib/hr)
- Kiln sludge: 9 kg/min (1,200 Ib/hr)
- Kiln wastewater: 30 kg/min (4,000 Ib/hr)
- Kiln liquid organic waste: 2.28 kg/min (300 Ib/hr)
- SCC liquid organic waste: 6 kg/min (800 Ib/hr)
55
-------
• Maximum total halides feed rate: 2.28 kg/min (300
Ib/hr)
• Maximum total ash feed rate: 13.8 kg/min (1,800
Ib/hr)
• Minimum water flowrate to absorber: 650 L/min
(170 gpm)
• Minimum pH to absorber: 7.0
• Minimum KV settings to IWSs: 30 KV
• Maximum size of containerized waste to PCC: 208
L (55 gal)
A complete operating envelope for this system would
involve calculation of the interrelated effects of
variations in those parameters that the operator can
control, i.e., waste, fuel and air feed rates and
variations in those parameters that the operator
cannot control such as waste composition. While an
energy and mass balance could be used to develop a
complete operating envelope, a large number of
calculations would be involved, and the resulting n-
dimensional (where n is the number of variables)
operating envelope would be difficult to present and
interpret. For most systems, it is not necessary or
desirable to investigate the effects of variations in all
parameters simultaneously.
An energy and mass balance can be useful to the
operator to achieve the following:
1. Predict operating conditions for new incinerators
2. Verify trial burn temperature and combustion gas
velocity targets for existing facilities and specific
trial burn feed compositions
3. Check that all feeds can be maximized in one test,
and verify that temperatures and combustion gas
velocity will be the same for any two tests to be
used in obtaining one set of conditions.
To illustrate the value of energy and mass balance
calculations, the operating envelope for the test
example was developed for the following constraints:
• The feed rate of only one waste stream at a time
was allowed to vary. All other waste feed rates
were assumed to be constant at their permit limits.
• Waste compositions were assumed to be constant.
• The primary air flow was assumed to be constant
at 480 kg/min (63,400 Ib/hr).
• The SCC was assumed to operate at 20 percent
local excess air.
Under these constraints, the controlling permit limits
were the combustion chamber exit temperatures, the
waste feed rates, and the flue gas flowrate. Figure
4-2 shows the effect of varying the feed rate of each
waste stream about the baseline on the total auxiliary
fuel (combined natural gas flow to the kiln and the
SCC) required to maintain operation within the permit
limits. The splid lines in the figure' represent the
operating limit imposed by maintaining the kiln or the
SCC at the minimum temperature, the dotted lines
represent the maximum waste feed rate limit, the
dashed lines represent the maximum flue gas flowrate
limit, and the dash-dotted lines represent the
physical limit of zero waste flow. ...-•,;
Allowing for fluctuations, it is most economical (i.e., it
requires the least auxiliary fuel) to run as close to the
minimum temperature line as possible. The liquid
wastes and the drummed waste have sufficient
heating values so that a reduction in waste flow rnust
be offset by an increase in auxiliary fuel flow to
maintain minimum temperature. Because the sludge
heating value is barely sufficient to maintain the
minimum kiln temperature, a reduction in sludge flow
has little effect on the fuel flow required to maintain
temperature. The wastewater has no heating value,
so a reduction in wastewater flow reduces the
auxiliary fuel requirement.
In all cases, as the auxiliary fuel flowrate is increased
above the minimum temperature operating line,
temperatures rise and the flue gas flowrate increases.
The upper limit on auxiliary fuel flow is imposed by
the maximum permitted flue gas flowrate. In many
cases, this limit is academic because economics and
equipment temperature limitations will prevent the
operator from reaching these limits.
These conclusions are valid only under the
constraints for which the operating envelope was
developed. For instance, if primary air flow were
allowed to vary, the maximum flue gas flowrate limit
may become more important. If the waste
compositions varied, the maximum halide and ash
feed rates may become more restrictive than the
maximum feed rate of each waste stream. Therefore,
in developing an operating envelope, it is important to
consider the system involved and set the constraints
accordingly. Because the permit applicant best
understands the system and how it is to be operated,
it is recommended that calculations of this nature be
performed by the permit applicant during the trial burn
planning stage and prior to accepting permit
conditions to ensure that all parameters required can,
in fact, be achieved.
56
-------
Figure 4-2. Operating envelope for example test case.
30001- r
2000
o
1000
i r
Baseline Flows (Ib/h*
Drummed Waste
Sludge
Waste Water
Kiln Liquid
Afterburner Liquid
Primary Air
3,600
1,200
4,000
300
800
63,700
0 1000 2000 3000 0 500 1000 0 2000 4000 0 100 200 300 0
Drummed Waste Sludge Waste Water Kiln Liquid
Variations of Individual Waste Flows About Baseline (Ib/h)*
400
SCC
800
Liquid
57
-------
-------
CHAPTERS
Data Reporting
The review of relevant permit information is often
complicated by the lack of uniformity in content and
format of the data submitted. Required information
may be either missing or buried in a trial burn report
in an inappropriate location. Furthermore, redundant
or irrelevant information in the report may also delay
the review and permit writing process.
The following are typical problems that the permit
reviewer/writer may encounter:
• It is not always clear which data are used to
calculate the results.
• Treatment of analytical, sampling, and field blank
corrections is not uniform.
• Not all relevant operating conditions are reported.
• Departures from standard sampling and analysis
methods are not well documented.
• Some analytical results do not appear in the report.
• Quality assurance data are inadequate.
• Significant departures have been taken from the
trial burn plan, which may have been written
several months before the trial burn.
Clearly, there is a need for uniformity in kind, extent,
and organization of the trial burn information so that
the permit writer's task is facilitated. The entire
permitting process would be speeded up, and soundly
demonstrated technology to treat hazardous waste
would be made available to serve the needs of the
regulatory agency, the facility, and the public.
Reports of certain performance results and other
information resulting from trial burns are mandated by
the regulations. Other information is needed to
support the performance results and indicate facility
operations, while additional information is needed to
ensure the integrity of the results and confirm that the
protocol agreed upon was adhered to. In the past,
because this assortment of test results and
supporting data has been presented in a wide variety
of formats and units, it has been difficult for the
permit writer to rapidly assess or compare trial burn
results.
There are several types of reporting needs. First, the
permit writer needs the results of performance and
operation tests during the trial burn itself. Second,
design data are also required for engineering analysis
in support of permit conditions. Finally, both design
data and performance results are needed as input
into the national data base for hazardous waste
treatment, the HWCTDB, under development by the
EPA and the Department of Energy (DOE), Trial burn
data presented in a consistent format will facilitate
entry of the results into the HWCTDB.
It is difficult and unnecessary to develop a single,
uniform reporting format that will apply to all
situations. However, the format given below should
be applicable to most trial burns, and the applicant is
urged to follow it as closely as is practical.
Example reporting forms to be followed as closely as
is feasible are included in Appendix F. An example
trial burn report format is provided in Section 5.2. To
follow the example format and use the appended
forms should alleviate many of the problems cited. In
addition, an example trial burn report of a test case
has been provided in Chapter 4 as a guide to using
the format and forms.
5.1 Design Data Reporting
Basic design information is required in the permit
application according to regulations in 40 CFR
270.62. To produce a complete, stand-alone
document, the permit applicant should insert in the
trial burn report a summary of the major design
criteria of the incineration facility including basic
design information and key operating parameters.
Reviewers can then compare the test conditions with
the original design criteria without reference to the
original permit application. Furthermore, as discussed
in Chapter 2, group D permit parameters reflect limits
on operation based on equipment design information
and manufacturer specifications. These design data
should be made available to the permit writer for rapid
evaluation of necessary permit limits. In some cases,
additional design information can be requested for
59
-------
computer modeling of the test results using the
energy and mass balance model mentioned above.
Following is an example of the design information that
should be listed in a trial burn report:
• Type of incinerator (i.e., liquid injection, kiln)
• Linear dimensions of the incineration unit including
the cross-sectional area of each combustion
chamber
• Heat capacity of each combustion chamber
• Type(s) of waste feed systems
Additional design information should be provided for
the following equipment:
• Liquid waste burner type(s) and capacity and
design specifications for viscosity of feed,
suspended solids, atomization requirements,
turndown, and waste heating value
• Forced and induced draft fan capacities
• Auxiliary fuel type and capacity for each
combustion chamber
• Design pressures and pressure drops for the
combustion chambers and other gas handling
equipment
• APCE
- Maximum design and inlet temperature
- Gas handling capacity
- Pressure drop
- Liquor (water) feed rate capacities
- ESP or IWS electrical requirements
- Other parameters which affect performance
A sample reporting format is shown in Appendix F. As
noted, most of the summary design information is
needed to support the energy and mass balance
model and set permit limits for group C parameters.
Calculations of the design range of gaseous retention
time in each combustion chamber may also be
requested by the permit writer.
5.2 Trial Burn Result Reporting
The requirements for reporting various types of trial
burn data are indicated in Tables 5-1 and 5-2.
Several levels of requirements are shown:
a. Required by regulation
b. Recommended by this guidance handbook or by
EPA policy
c. Needed for energy and mass balance model
d. Standard practice/highly recommended
e. Recommended
f. Optional
Data that are required by regulation certainly must be
reported. Other information may be called for by EPA
policy statements, and this, too, may be required by
the permit writer on a case-by-case basis through
use of 270.62(b)(3) or (b)(6)(x). Other information
may not have been required in the past but is
necessary for developing permit conditions or
performing an energy and mass balance as discussed
in this guidance handbook. In addition, a large volume
of the trial burn report consists of information reported
by standard practice or convention and should be
reported. Some information designated as
"recommended" may not have been typically
reported in the past, but this type information is highly
recommended to facilitate the review. Results that
may have some value to the permit writer also are
designated as "recommended." Finally, other results
are optional in most situations and may be included
for good documentation or in anticipation of future
regulations.
In any event, "highly recommended,"
"recommended," and optional data to be reported
must be agreed upon prior to the trial burn and
included in the trial burn plan so that provisions can
be made to acquire and report the data.
Reporting requirements and informational needs
discussed in this handbook are based on EPA
regulations, policy or practice. However, State or
other regulatory agencies may have additional
reporting requirements that are more stringent than
the Federal requirements.
Regulations for hazardous waste incinerator permits
are found in 40 CFR 270.62. Specific information
currently required in the trial burn report is covered in
270.62(b)(6) to 270.62(b)(9) and is 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, O2, and HCI
• A quantitative analysis of the scrubber water (if
any), ash residues, and other residues for
estimating the fate of the trial POHCs
• A computation of ORE
• If the HCI emission rate exceeds 1.8 kg (4 lb)/hr of
HCI, a computation of HCI removal efficiency
• A computation of particulate emissions
• An identification of sources of fugitive emissions
and means of their control
60
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Table 5-1. Trial-Burn Reporting Format and Requirements - Main Report
Reporting Requirements1
Incinerator Type
Air Pollution Control Equipment
Recommended Report Organization
Specific Information
LFI
RKI
Q
V PT IWS ME CY DS BH ESP
en
Preliminary
Preface
Table of contents/tables and figures
1.0 Summary of Test Results
1.1 Process operation
1.2 Emissions performance
1.3 Metals
2.0 Introduction
2.1 Background
2.2 Non-standsard
practices/events
3.0 Performance Results
3.1 POHCs
3.2 Chlorine
3.3 Paniculate
4.0 Process Operating Conditions
4.1 Process Overview
R,P
P
R,P
+v
R
• +.F2
R.P
R.P
R.P
R.P
R.P
R
R.P
P
R.P
-t-
R
+ +.F2
R.P
R.P
R,P
R.P
R,P
R
Certification letter
Facility name/location ,
Name of company performing testing
Test dates t -t- ,F2 + + ,p2
Residence times * • +
Combustion temperatures
High input (firing) rate
Summary of APCE parameters
Stack height
Stack exit velocity
Stack temperature
Stack excess 02
Test dates
DREs
Particulate emissions
HCI emissions
Cl REs
Stack gas flowrates
02
CO2 + +
CO R,P R,P
Brief discussion of incinerator type + + -
Design data summary M,F M,F M,F
Objective for trial burn + + + +
Planned test matrix and deviations + + + •*•
Description of wastes/fuels + + + +
Description of any unusual test methodologoies + + + +
Discussion of any special problems encountered + + + +
Input rates R,P,F R,P,F
Emission rates R,P,F R,P,F
DREs R.P.F R.P.F
Input rates R.P.F R,P,F
Emission rates R,P,F R,P,F
REs R.P.F R,P,F
Concentrations R,P,F R,P,F
Brief description + + + +
Process diagram + + + +
Summary of process monitors + + + +
M,F
-------
Table 5-1. Trial-Burn Reporting Format and Requirements - Main Report (continued)
Reporting Requirements1
Incinerator Type
Recommended Report Organization
4.2 Incinerator Operating Conditions
• Combustion temperature
• Waste feed/auxiliary fuel data
• Waste burner data
• Airflow data
• Residue generation rates
• Other operating
Specific Information
PCC Temperature
SCC Temperature
Brief description/firing locations
Feedrates
Firing rates (heat release)
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
LFI
R.P.F .
R.P.F
+ +.P
R.P.M
P
P.F
=
P.F
+
R.P.F
+ ,M
R.P.F
-
-
-
-
O
RKI Q
R.P.F
R.P.F
+ +,P
R.P.M
P
P.F
=
P.F
+
R.P.F
+ ,M
R.P.F
M
-
-
+ +
O
Air Pollution Control Equipment
V PT IWS ME CY DS BH ESP
.
.
.
.
.
.......
.
......
.
.
.
.
.
+ -00
o - - - + - -
-
-
4.3 APCE Operating Conditions
• Wet process
O)
ro
- Quench
- Venturi scrubber
- Packed tower scrubber
(adsorber)
- Ionized wet scrubber/wet
ESP
- Mist eliminator
• Dry processes
- Cyclone
- Dry scrubber
- Baghouse
:..:•. .J::. - ESP; .-•'. : '
Inlet temperature
Exit temperature
Water flowrate
Inlet temperature
Pressure drop
Water/liquor flowrate
Inlet temperature
Pressure drop
Liquor flowrate
Influent pH
Inlet temperature
Voltage (AC, DC)
Current (AC, DC)
Sparking rate
Water flowrate
Pressure drop
-
Pressure drop
Reagent flowrate
Atomizer rotational speed or nozzle pressure
InleVexit temperatures
Inlet temperature
Pressure drop
Inlet temperature
Voltage -
Current -
Sparking rate
. P.F --------
+ +.
+ +.
P.F .....
P.F -------
+ + -
P.F
+ + . . .
P,F
P,F - - - -
p.F .....
P.F
P.F
. . . + +
•V -----
+ +
.
+ +
+ •!•-
+ +
+ +
P,F
P,F
.- . ' - ...... - - - ... - - . P,F
. . .: - . .. • . . p.F
- ; .. - • -••- - •..-.-.": ;; , . . pf
, - - .... - - - - .. •+.+
-------
Table 5-1. Trial-Burn Reporting Format and Requirements - Main Report (continued)
Reporting Requirements1
en
CO
Incinerator Type
Recommended Report Organization
5.0 Sampling and Analysis Results
5.1 Methods Description
5.2 Waste Feed/Fuel Characteristics
• Physical characteristics
• Chemical characteristics
5.3 Stack Gas Concentration Data
• Gases
- CEMs
- Orsat
•POHCs
• Other
5.4 APCE Aqueous Streams
5.5 Ash and APCE Residues
1 Legend for reporting requirements:
Specific Information
Summary table
Diagram indicating sampling locations
Moisture
Ash
Volatile matter
HHV
Specific gravity
Viscosity
Chlorine
POHCs
Other Appendix VIII compounds
Metals
Fixed carbon
Elemental analysis
Heat capacity
Heat of Vaporization
CO
CO2
02
S02
NOX
TUHC
C02
02
Volatiles, semivolatiles, other analytes
Moisture
Chloride
Participate
Metals
PICs/other Appendix VII compounds
POHCs
ft hlnrirlo
IslllUriUD
TDS
pH
Metals
EP toxicity test results
POHCs
Metals
LFI
+ +
+ +
+ +.M
R.P.M
M
R,P,M
R
R",p4
R.P
R,P
0
0
M
M
M
M
R,P
R
P
0
O
+
+ +
R
R.P
R
R.P
R,P
O
O
-
.
-
.
-
-
•
RKI Q
+ +
+ +
+ +,M
R.P.M
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R.P.M
R
R4.P4
R.P
R,P
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M
M
M
M
R.P
R
P
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O
+
+• +
R
R.P
R
R.P
R,P
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R
+ •
+
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+ +5
R
05
Air Pollution Control Equipment
V PT IWS ME CY DS BH ESP
.
.......
-
.
.
.
.
.
.
.
.
.
.
.
.
.
..
.
.
.
.
-
.
.
-
.
.
.
.
-
.
.
R R R - - - - -
+ + '+ + +
+ +++ +
O O O
+ + O O
R R O O
0000
R = required by current regulation or EPA policy O = optional
P = required by this permitting guidan
ce F = standard form available
in Appendix B
M = needed for energy and mass balance model
+ + = standard practice/highly recommended
not applicable
recommended
2 Standard forms available for all information in Process Operations Summary and Emissions Performance Summary
3 Recommended for containerized solid waste
4 Recommended for liquid waste fired in SCC
5 Recommended for bottom ash
-------
Table 5-2. Trial Burn Reporting
Typical Appendix Format
Format and Requirements - Appended Information
Contents
Reporting Requirements1
Detailed S&A Results
• POHCs
• Chloride
• Paniculate
• All analytical test results
Raw Data Logs
• Process data
• CEM data
• Stack sampling data
Sample Traceability Records
QA Results
S&A Methods
Chromatograms2
Concentration in each sample
Sampling durations
Trip and field blank values
Averages
Concentration
Impinger volumes
Blank values
Filter weights
Laboratory reports/data
Log sheets, strip charts
Strip charts, printouts
Field data forms
Sample collection, treatment, and analysis log
Surrogate recoveries
Blind audit samples
Summary of standard method
Description of any deviations
"Nonstandard" methods
Waste analysis
Emissions analysis
R
R
R
R
R
R
R
R
R
R
R
R
R
R
O
R
R
R
R
1 Legend for reporting requirements:
R = required by regulations or can be required due to EPA policy
O = optional
2 In some cases, one set of chromatograms may be requested by the permit writer. This may be a complete set of all chromatography-
based analyses or only chromatograms from selected samples. Routine submission of chromatograms is not recommended due to their
bulk.
• A measurement of average, maximum, and
minimum temperatures and combustion gas
velocity
• A continuous measurement of CO in the exhaust
gas
• Such other information as necessary to ensure that
the trial burn determines compliance with the
performance standards and to establish the
operating conditions required to meet that
performance standard
• A certification that the trial burn has been carried
out in accordance with the approved trial burn plan
and 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 permitting authority
• All data collected during any trial burn, to be
submitted 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/quality control (QA/QC) results may also
be required according to EPA policy. See reference 2
in Appendix A for specific guidance materials on
QA/QC requirements.
Some information items listed in Table 5-1 may not
be essential for developing incinerator permit
conditions or conducting an energy and mass balance
but, instead, may be required under other RCRA
regulations or regulations in support of the NPDES or
air quality permits. These items are included for
completeness and to indicate the logical location in a
trial burn report where the information may be
presented. Some examples include chloride; total
dissolved solids and metals in APCE aqueous
streams; leachate extraction test results and metals in
solid residues; and gases such as SO2, NOX, and
TUHCs in the stack gas. The applicant may desire or
be requested to include these items in the trial burn
report to present a more complete picture of the total
discharges of the facility in all media.
5.2.7 Suggested Report Format
The trial burn report should be structured in a format
parallel to that for the trial burn plan to facilitate the
review of the report and simplify the final report
preparation. A useful technique is to use the same
section numbers and identifiers in both documents.
Assuming this parallelism, the remainder of this
section will discuss the report format only.
64
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The trial burn report provides several distinct types of
information for which a recommended general outline
is provided below; a detailed outline of specific
information and requirements is provided in Tables
5-1 and 5-2 as an example format. The tables
provide an overview of all information that might be
required or otherwise included in trial burn reports,
although no one incinerator would have all of the
components covered in this matrix. This ordering of
information represents a logical sequence of results
that can easily be followed by the permit reviewer. It
is for illustrative purposes; other organizational
techniques could also be acceptable. However, it is
important that all results needed for permitting be
presented clearly, and unnecessary information
should not be interspersed among them.
The preliminary information in the trial burn report
must include certification required under 40 CFR
270.62(b)(7),(9) signed by a corporate officer or other
authorized agent of the facility that the trial burn has
been conducted according to the approved trial burn
plan. It must also include a preface identifying the
facility, location, and the name of the company(ies)
that performed the trial burn testing and sample
analysis.
Chapter 1 of the report gives a summary of the test
results as well as of the facility information. It should
include copies of Forms 1-4 of Appendix F for each
test: The summary data for each run can be given in
the appendix. The purpose of this section is to
summarize all pertinent information required for
establishing permit conditions. This should be a
"stand-alone" section that provides the key
performance results, operating conditions, design,
and facility information needed for permitting. The
section consists of several summary tables sufficient
to explain the results. Appendix F gives examples of
the summary forms needed.
The Introduction (Chapter 2) should primarily be text
material "summarizing the background of the facility
and the:type of waste(s) for which it was designed
and should include a summary of trial burn objectives
and the planned test matrix. Any deviations from the
planned test matrix should be noted and explained.
Also to be included here are brief descriptions of the
types and sources of wastes and fuels to be normally
burned at this facility as compared to the wastes
burned during the test as well as any special wastes
or spiking procedures used for the trial. burn. The
Introduction is also an appropriate location to describe
any unusual (nonstandard) test methods used and
any special problems encountered in testing including
sampling and analysis problems such as
breakthrough or loss of samples.
The remaining three sections should primarily contain
detailed tables of results. Chapter 3, Performance
Results, summarizes data involving the performance
standards for POHCs, chlorine, particulate material,
and any applicable metal limitations. This section,
which is a more detailed version of material supplied
in Chapter 2, provides the values used in calculating
the results.
Chapter 4, Process Operating Conditions,
summarizes all equipment operating conditions for the
combustion chambers, APCE, and air/combustion gas
moving equipment. A process diagram showing all the
main components of equipment and process
monitoring locations should be included under Section
4.1 of the trial burn report, Process Overview. An
example of a process diagram is provided in Figure
5-1. Note that Figure 5-1 is given here for
simplicity; however, a permit application should
include a full piping and instrumentation diagram
(P&ID). The process monitors may be summarized in
a table referencing the locations indicated on the
diagram. An example is provided in Table 5-3.
Section 5 in the outline, Sampling and Analysis
Results, is the final section of the main report body. It
should begin with a subsection on the sampling
method used including a summary table of sample
types, sampling points, sampling methods, frequency
of sampling, sample preparation steps, and analytical
methods. A diagram of sampling locations should also
be included. Examples of the methods summary table
and sampling point diagram are given in Table 5-4
and Figure 5-2, respectively. The analytical results
may logically be organized into four areas: waste feed
and fuel, stack gas, APCE aqueous streams, and ash
and other solid residues.
General reporting requirements for trial burn data that
are typically appended to the main report are
indicated in Table 5-2. The appropriate regulatory
agency will refine this list.
The appendices to the trial burn report are used
primarily for reporting raw data and supporting logs.
"Detailed S&A Results" can include data such as
sample volumes, measured concentrations and
weights, calibration curves, and response factors.
"Raw Data Logs" may include sampling data forms
and logs, logs of process data, strip-charts, and
printouts from data loggers. "Example Calculations"
should show precisely the processes by which final
values were obtained for the performance results.
"QA Results" is an important section showing
surrogate recoveries, blind audit samples, and
calibration data. "Sample Traceability Records" (or
chain-of-custody logs) show the movement of each
sample from collection to final analysis and any
intermediate sample, splitting, compositing, or
treatment. "S&A Methods" may include complete
method write-ups, or it may describe any deviations
from referenced standard methods or any
"nonstandard" methods used. Some permitting
agencies request that "Chromatograms" be included
k
65
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Figure 5-1. Example process diagram showing monitoring points.
en
O)
! 25 I
v A Recirculated Scrubber Water
Secondary
Combustion
Chamber
I QDQQQO!
'—' DDQOQQ J
l_BQBQBBj
Drummed Solids
Staging Area
To NPDES
System
Ash Dumpster
-------
Table 5-3. Example Summary Table of Process Monitors
Parameter
High-Btu liquid waste feed rate
Low-Btu liquid waste feed rate
Auxiliary fuel flow
Sludge waste feed rate
Drummed solid waste
charge weight
Atomization steam pressure
Rotary kiln temperature
SCC temperature
Quench inlet temperature
Quench discharge temperature
Adsorber temperature
IWS inlet temperature
Rotary kiln pressure (draft)
SCC pressure (draft)
Rotary kiln speed
Quench water flowrate
Caustic water flowrate
IWS water flowrate
Oxygen
Carbon Monoxide
Combustion gas flowrate
Combustion air flowrate
IWS electrical readings
Adsorber differential pressure
Scrubber water blowdown rate
Location of Monitor1
10A - Feed line to nozzle on SCC
10B - Feed line to nozzle on PCC
1 1 - Feed line to injector on SCC
1 2A - Fuel oil line to SCC
12B - Fuel oil line to kiln
1 3 - Feed line to injector on kiln
14 - Automatic weigh scale
at feed conveyor
15A - Waste burner in SCC
1 5B - Waste burner in kiln
16 - Kiln outlet
17 - Secondary chamber outlet
18 - Quench inlet
19 - Quench outlet duct
20 - Adsorber inlet
21A- Inlet duct to IWS No. 1
21 B - Inlet duct to IWS No. 2
22 - Rotary kiln chamber
23 - Secondary combustion chamber
24 - Kiln rollers
25 - Quench water line
26 - Caustic water line to adsorber
27A - IWS water line to unit No. 1
27B - IWS water line to unit No. 2
28 - IWS outlet duct
28 - IWS outlet duct
29 - Stack
30A - Air inlet duct to SCC
30B - Air inlet duct to kiln
31 A - Power lines to IWS electrodes for unit
No. 1
31 B - Power lines to IWS electrodes for unit
No. 2
32 - Adsorber inlet and outlet ducts
33 - Sewer line to NPDES system
Type of Monitor
Mass flowmeter
Mass flowmeter
Mass flowmeter
Mass flowmeter
Weigh scale
Pressure transducer
Type R thermocouple
Type R thermocouple
Type J thermocouple
Type J thermocouple
Type J thermocouple
Type J thermocouple
Pressure transducer
Pressure transducer
Tachometer
Orifice meter
Rotameter
Orifice meter
Zirconium oxide fuel cell
In situ NDIR
Resistance temperature
flow detector
Venturi meter
Voltmeter,
Mill-ammeter
Pressure transducer
Triangular weir
Operating
Range
0-100
0-100
0-100
0-100
0-2,000
0-100
2,650
2,650
150-600
150-600
150-600
150-600
-5 to 5
-5 to 5
0-1.0
0-200
0-50
0-50
0-25
0-500
0-100,000
0-60,000
0-20
0-200
0-20
0-12
Units
Recorded
in Process
Log
Ib/min
Ib/min
Ib/min
Ib/min
Ib
psig
°F
°F
°F
°F
°F
°F
in H2O
in H2O
rpm
gpm
gpm
gpm
percent
ppm
ACFM
ACFM
kV
mA
in H2O
in H2O
1 Refer to Figure 4-1.
67
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Table 5-4. Example Summary Table of Sampling and Analysis Methods
Sample
Sample Frequency For Sampling Sample Analytical
Sample Location1 Each Run Method Size Parameters
High-Bill liquid
(organic waste)
Low-Btu liquid
(aqueous waste)
Auxiliary fuel
(fuel oil)
Sludge
Drummed solid
waste
Ininerator ash
Caustic solution
1 One grab
sample every
15 min
omposited into
one sample
for each run
1 One VOA vial
every 1 5
minutes5
2 One grab
sample every
15 min
composited
into one
sample for
each run
2 One VOA vial
every 15 min5
3 One per run
4 One grab
sample every
30 min
composited
into one
sample for
each run
4 One VOA vial5
every 30 min
5 One grab
sample every
other solid
charge,
composited at
end of test
Each sample
clearly
identified.
6 One grab
sample per run
7 One grab
sample per run
Tap
(S004)
Tap
(S004)
Tap
(S004)
Tap
(S004)
Tap
(S004)
Tap
(S004)
Tap
(S004)
Scoop
(S007)
Scoop
(S007)
Tap
(S004)
~100mL
per grab
40 ml
per vial
-100 mL
perg
40 mL
per vial
250 mL
-100 mL
per grab
40 mL
per vial
~250 g
per grab
500 g
500 g
SV POHC3
Heating value
Ash
Viscosity
Chlorine
Elemental
analysis
V POHC6
SV POHC
Heating value
Ash
Viscosity
Chlorine
Elemental
analysis
VPOHC
Heating value
Ash
Density
SV POHC
Heating value
Ash
Viscosity
Chlorine
Elemental
analysis
VPOHC
VPOHC
SV POHC
Chlorine
Elemental
analysis
Heating value
Ash
SV POHC
Archive
Preparation
Method2
Solvent dilution
NA
NA
NA
NA
Dispersion/purge
and trap
Solvent extraction
NA
NA
NA
NA
Dispersion/
purge and trap
NA
NA
NA
Solvent extraction
NA
NA
NA
NA
Dispersion/
purge and trap
Dispersion/
purge and trap
Soxhlet extraction
NA
NA
NA
Solvent extraction
NA
Analytical Method2
HRGC/MS4
Calorimeter (D240-73)
Ignition (D482-80)
Viscometer (D-88-81)
Organic halide
(D808-81 and
D4327-84) or
(E442-81)
HRGC/MS
HRGC/MS4
Calorimeter (D240-73)
Ignition (D482-80)
Viscometer (D-88-81)
Organic halide
(D808-81 and
D4327-84) or
(E442-81)7
HRGC/MS
Calorimeter
Ignition (D482-80)
Gravimetric
HRGC/MS
Calorimeter (D240-73)
Ignition (D482-80)
Viscometer (D-88-81)
Organic halide
(D808-81 and
D4327-84) or
(E442-81)7
',.
HRGC/MS
HRGC/MS
HRGC/MS
Organic halide
(D808-81 and
D4327-84) or
(E442-81)7
Calorimeter (D201 5-77)
Ignition (D482-80)
HRGC/MS
NA
68
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Table 5-4. Example Summary Table of Sampling and Analysis Methods (continued)
Sample
Scrubber water
blow/down
Stack gas
•...". -
Sample
Sample Frequency For
Location1 Each Run
8 One grab
sample every
30 min
composited ..
into one
sample for
each run
8 One VOA vial
every 30 min5
9 2-hr
composite per
run
Sampling
Method
Dipper (S002)
VOA vial filled
from grab
sample
MM59
Sample
Size
4L
40 mL
per
VOA
60-100
cuft10
Analytical
Parameters
SV POHC
Specific
conductivity
VPOHC
Particulate
HCI
Moisture
Temperature
Velocity
Preparation
Method2
Solvent extraction
NA
Purge and trap
Desiccation
NA
NA
NA
NA
Analytical Method2
GC/MS8
Conductivity meter
GC/MS
Gravimetric (EPA RMS)
IC12 (D4327-84)
Gravimetric
Thermocouple
Pitot tube
2-hr MM5 60-100 SV POHC
composite per cu ft10 Moisture
run Temperature
Velocity
3-4 trap pairs VOST 20 L VPOHC
per run (S012)12 max. per
trap pair
Solvent extraction HRGC/MS
NA Gravimetric
NA Thermocouple
NA Pitot tube
Purge and trap GC/MS
City water
9 One composite EPA Ref.
sample per run Method 3
-20 L Oxygen, CO NA
Continuous
10 Once pretest
NA
Tap
(S004)
NA CO
NA
NA Ash, chloride NA
Orsar
NDIR continuous monitor,
specific extracting or in
situ
Gravimetric, 1C
NOTE: Sampling method numbers (e.g., S004) refer to methods published in Sampling and Analysis Methods for Hazardous Waste
Combustion, December, 1983; analytical methods beginning with prefixes D and E refer to ASTM methods.
NA = not applicable.
1 Refers to Figure 4-2; give P&ID reference number.
2 Sample preparation and analytical methods reference the A. D. Little, EPA 600 and SW-846 methods.
3 Semivolatile principal organic hazardous constituent.
4 HRGC/MS = high resolution gas chromatography/mass spectroscopy. .
5 VOA = volatile organic analysis. All VOA vials from each run are composited just prior to analysis,
6 Volatile principle organip hazardous constituent.
7E442-81 is used for samples with high (> 0.1%) concentrations, and D808-81 and D4327-84 are used for samples with low
concentrations, .-••-••v
8 GC/MS = gas chromatography/mass spectroscopy.
9 MM5 = Modified Method 5 (EPA Reference Method 5, Modified), SW 846, Method 0010.
10 Exact volume of gas sampled is dependent on isokinetic sampling rate.
11 Ion chromatography.
12 VOST = volatile organic sampling train.
69
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Figure 5-2. Example of process diagram showing sampling locations.
-si
o
Recirculated Scrubber Water
»
Secondary
Combustion
Chamber
,' DQOQOQ !
' QBQQQB ;
Drummed Solids
Staging Area
ToNPDES
System
Ash Dumpster
( j Sampling Point
-------
for organic analysis of both the waste feed and stack
emissions; however, this information can be
voluminous and should not be included with every
copy of the report.
5.2.2 Guidance for Reporting Process and
Continuous Emissions Monitor (CEM) Data
Ideally, measurement of incinerator performance
would be done on a real-time basis; however, a
certain amount of time averaging must be used to
evaluate and report trial burn data. Most of the trial
burn data fall into two categories: data that must
represent an average over the test period or portion
of the test period and data that is recorded
continuously or semicontinuously. Data that by
necessity are an average include most of the
analytical results, e.g., waste characterization results
for a composited sample of waste feed as well as
Modified Method 5 (MM5) or Volatile Organic
Sampling Train (VOST) results for a sampling period
of minutes to hours. Data taken continuously (or as
continuously as practical) include both process and
CEM data. This section discusses primarily the
method by which continuously monitored data are
processed and reported.
Process and CEM data needed for the trial burn are
shown in Table 5-5. Sixteen parameters of this type
are required for establishing permit conditions that fall
into groups A, B, and C. Additional parameters
needed to support the permitting process are also
shown although others, not specified here, may be
required at the discretion of the permit writer.
Parameters that are related primarily to waste
analysis (e.g., ash and halides input) are not included
here. As discussed in Chapter 2, group A and B
parameters are those which require continuous
monitoring of process instrumentation and are tied to
automatic waste feed cutoff. In addition, their status
must be continuously monitored as described below.
Specific RCRA requirements apply only to the group
A parameters. Permitted operation requires
continuous monitoring of combustion temperature,
CO, waste feed rate, and a combustion gas velocity
indicator (40 CFR 264.347(a)(1,2)) with automatic
waste feed cutoff tied in if permit limits are exceeded
(40 CFR 264.345(b,e)). The level of .CO in the stack
gas is the only parameter which by RCRA regulations
specifically state must be continuously monitored
during the trial burn (40 CFR 270.62(b)(6)(ix)).
However, the incinerator should already have had
continuous monitors installed for temperature, feed
rate, and gas velocity to obtain approval for the trial
burn because measurements of continuous
operations should be taken with the same instruments
used during the trial burn. Draft or pressure
measurement, presumably on a continuous basis, is
also required by RCRA to ensure that fugitive
emissions are not released (40 CFR 264.345(d)). The
RCRA regulations require reporting of the trial burn
average, minimum, and maximum only for combustion
temperature and gas velocity (40 CFR
270.62(b)(6)(viii)). A measurement of QZ level in the
stack gas is also required by RCRA (40 CFR
270.62(b)(6)(ii)). Continuous measurement is required
per this guidance and other guidance material
primarily to correct CO levels to a standard value of
02- Based on this guidance, continuous monitoring
and waste feed cutoff interlocks for important APCE
parameters should also be required.
Table 5-5. Process and CEM Data Requirements
Permitting
Level Parameters
A Combustion temperature for each chamber
A CO level in stack gas
A Indicator of combustion gas velocity
A Pressure in PCC
A Waste feed rate of each stream to each combustion
chamber
A Differential pressure across venturi scrubber
A Differential pressure across FF
A Absorber water flowrate and pH
B Voltages and amperages for ESP or IWS
B POHC and halides in waste
B Size of containerized waste to PCC
B Particle scrubber blowdown rate
C Heat input rate for each combustion chamber
C Burner turndown for LI chamber
C Atomization pressure for LI chamber
C APCE inlet gas temperature
Oxygen level in stack gas
Quench water flowrate
Quench water temperature
Auxiliary fuel feed rate
PCC/SCC air flowrate
Group B and C parameters require maintenance of
operating records. Parameters in group B require the
use of trial burn data to establish permit conditions.
Group C parameters, on the other hand, are set
independently of trial burn conditions according to
manufacturer specifications. Nevertheless, group C
parameters must still be measured during the trial
burn to demonstrate compliance with the permit limits
that are based upon those specifications.
Some of the process and CEM data shown are
needed for the energy and mass balance model, if it
is to be used. Waste and auxiliary fuel feed rates are
required for the model. Combustion gas velocity may
be used as an alternative to design ID fan capacity;
and measured APCE inlet temperature, quench water
flowrate, and quench water temperature may be used
instead of the design maximums. Finally, primary and
secondary combustion air flow rates and ash
generation rates, if available, need to be measured
71
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during the trial burn and reported for use in the
energy and mass balance.
Operating records must be used to report trial burn
values for group C parameters and any other
parameters needed for the energy and mass balance.
The size of containerized waste to the PCC may be
described in the text in Section 4.2 of the trial burn
report. The maximum volume and mass used for
each containerized waste must be reported along with
the interval between Charges. The paniculate
scrubber blowdown rate for each test run is based
upon readings taken at regular intervals (1 hr or less).
The heat input rate for each chamber is reported for
each test run. It is based on the heating value and
average feed rate of each composited waste and fuel
stream. Burner turndown should be reported for each
burner using design maxima and the average feed
rate of the waste. Atomization fluid pressure for each
burner on the liquid injection chamber should also be
reported. An average of readings taken at regular
intervals (1 hr or less) is usually sufficient.
The APCE inlet gas temperatures do not normally
vary significantly. To report an average of readings
taken at regular intervals (minimum of 15 min) is
sufficient. Averages of readings for the trial burn
period need to be reported for quench water flowrate,
pH, and temperature. Again, readings taken at regular
intervals of at least 15 min are recommended.
Primary and secondary combustion air flow rates, if
available, should 'be reported with at least 15-min
readings used for the average.
Power readings on the blowers along with calibration
curves for conversion to flowrates should be reported
if air flowrates are not available. The ash generation
rate for each run involving solid waste should be
reported. This rate is normally based upon the weight
of all the ash collected during the test period. As an
internal consistency check, it may be worthwhile to
compare this value to the amount of ash fed to the
incinerator as determined by the waste analysis and
flowrate.
Example reporting forms for process and CEM data
are located in Appendix F. The forms are divided into
categories of combustion equipment, stack gas data,
and APCE data.
Reporting Continuously Monitored Parameters
All the group A parameters (as defined in Chapter 2)
must be monitored continuously during the trial burn
as well as during subsequent operations. Using the
recorded data for the trial burn test period, an
average, maximum, and minimum must be reported
for 'each parameter. For each run, reporting
approaches will vary according to the instrumentation
utilized. Some facilities may use strip-chart
recorders for recording the data, and some will use
computerized data. loggers., Because data loggers
often use strip-chart recorders as a backup, both
types of information may be available. Continuous
recording, which is available only through strip-chart
recorders, is not necessarily required, although it is
recommended that data be read in some manner at
least every 15 ,sec and that a value be recorded at
least every minute. Either strip-charts or data logger
printouts for the trial1 burn period are normally
included in an appendix to the trial burn report.
Averages, minimums, and maximums for each of the
A and B parameters:,may be calculated using either
strip-charts or data logger printouts. In some cases,
both types of hard data .may be used for a single
parameter (e.g., maximum and minimum from strip-
chart recording and time-weighted; average from
data logger printout). Each basic approach is
described rbelow. ,. . .... .: . -:
Use of data loggers: Data Joggers are normally
equipped to provide, a time-weighted average of
readings taken within the interval between printing or
recording. In general, during hazardous waste
incineration, readings should be taken every minute.
These frequent readings are needed,as part of the
continuous record unless strip-charts are also
available. In addition, for the trial burn, it is useful to
program the data logger to print out time-weighted
averages for a longer period, typically 15 min.
Following the trial burn, the 15-min averages
corresponding to the sampling period may then be
used to determine the average, for each run; this is
done by simply determining the arithmetic mean of all
of the appropriate readings. ,
Some data loggers can be programmed to print out
the minimum and maximum readings taken within the
period between printing. If this approach is used to
determine the minimum and maximum for each trial
burn run, the printouts must be examined for all the
sampling period. The lowest interval minimum and the
highest interval maximum must then be reported. If
the data logger does .not record interval minimums
and maximums, these must be read off the strip-
chart, as explained below. . .
Use of Strip-charts: The use of strip-charts for
determining minimums and maximums is relatively
straightforward. . The main problem is .one of
calibration. The strip-chart must be legible, and units
of instrument readings and time must. be clearly
visible. The recording should be checked against the
instrument gauge or read out at several values just
before or during the trial burn. These instrument
readings should be marked on the strip-chart paper.
At the start and end of the trial burn run, the time
should be marked on the x-axis of the. paper as a
cross-check. The date,' operator .initials,., notes about
run numbers, and other .comments should also be
recorded. Interruptions in sampling should be marked
72
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on the strip-charts so that the nonsampling interval
will not be included in determinations of the minimum,
maximum, and average.
Special data-handling problems exist if the range of
the strip-chart is exceeded for the maximum or
minimum. Each exceeded time off scale and minimum
or maximum value should be recorded. For example,
if the kiln temperature spiked downward offscale
every time a drum of chlorinated still bottoms was
fired, the reported minimum temperature might be
"<700°C for 16 min (24 exceeded ranges)." Of
course, it is best to ensure that the strip-chart has a
range wide enough to avoid such offscale readings
for determining averages. While they may be used in
some cases, offscale readings may limit the flexibility
in permit limits for the facility. For example, in the
case above, to report 700 °C temperature for 16 min
when the actual temperature was lower will result in a
higher permit limit for temperature than if all values
were recorded. Upward temperature spikes that go
offscale, on the other hand, would not be allowed for
establishing a permit limit.
Other approaches to using strip-chart data are
available. Devices such as a planimeter can integrate
under the trace. Computerized methods in which the
recorder trace is optically or mechanically entered
into a data base may also be applicable. The data
base can then be used to calculate the time-
weighted average, minimum, and maximum. The
major concern with all these approaches is that the
strip-chart must be appropriately calibrated and the
device must account for instrument calibration factors
and nonlinear responses. The approach to be used
by the applicant should be specified in the trial burn
plan and approved by the permit reviewer prior to the
trial burn.
Special Problems
Most process instruments produce nearly
instantaneous electrical signals that may be read off a
gauge or processed in a data logging system. The
CEMs, however, are generally not as responsive to
changing conditions. Delays are caused by the gas
stream physically moving through a sampling line, and
instrumental delays are caused by a sensor that must
adapt to changing gas composition. For a given gas,
one type of instrument may be more responsive than
another. For example, paramagnetic oxygen monitors
respond more rapidly than do 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 a large, sudden peak or dip.
Delays such as these are important to consider for
permit conditions involving time-delayed waste feed
cutoff. This type of problem should be worked out as
early as possible in the trial burn planning stage.
Another general data quality problem common to
most trial burn tests involves the correlation of the
performance results with the operating conditions.
Different measurements span different time periods.
The trial burn run can easily span 6 to 8 hr or longer
as analytical detection limits often dictate actual
sampling times. An additional problem may occur
during the test when unavoidable variations in waste
properties and other factors cause the unit to deviate
from the planned conditions. Variations in process
conditions outside the planned ranges can make
correlating sampling results difficult. An example trial
burn run timeline is shown in Figure 5-3 to illustrate
these correlational problems.
Figure 5-3 shows how the various sampling and
monitoring activities are coordinated during a typical
trial burn run. Six 40-min VOST samples were taken
during the run ("Slow VOST" at 0.5 L/min) for a total
of 4 hours of volatile sampling. Two MM5 trains were
used: one for particulate sampling and the other for
semivolatile POHCs. Each train sampled for CI". One
train was started several minutes before the other.
The total sampling time for MM5 was 6 hr with a port
change midway to traverse the stack again at a 90°
angle to the first traverse for isokinetic sampling.
Grab sampling was used for waste feed and scrubber
liquids with compositing during or following the test.
The waste feed was sampled at 12-min intervals
and the scrubber liquid and bottom ash at 1-hr
intervals. Grab sampling of liquids was briefly
discontinued during the MM5 port changes for the
best achievable correlation of POHC inlet and outlet
measurement, but sampling of waste continued as.
solids retention time is normally greater than 30 min.
The fourth VOST sample was also delayed until MM5
sampling continued. Logging of process and CEM
data was continued during this interval.
Logging of process and CEM data must occur over
the entire period of any sampling activity. This period
of any concurrent sampling activity and logging
becomes the formal trial burn period for that run. In
the case illustrated in Figure 5-1, the trial burn run
period is from 10:00 to 15:36 and from 17:06 to 18:12
for a total test time of 6.7 hr. The actual time required
was 8.2 hr due to a 1.5-hr process upset when
sampling and logging were discontinued because a
process parameter deviated outside the planned trial
burn range. It should be noted that sampling and
logging of data may be discontinued only when a
major process upset occurs that prevents proper
waste incineration. In such a case, the run can only
be considered a successful run if permit conditions
can be written such that the conditions triggering the
upset will not occur in subsequent operation.
Otherwise, sampling must be continued during
"upset" conditions, and the results of that run must
73
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Figure 5-3. Example of trial bum test timeline.
Sample 1 Sample 2 Sample 3
(Volatile POHCs)
MM5 Tfain No. 1
(Cl, Paniculate)
MM5 Train No. 2
(Cl, SV POHCs)
Grab Sampling:
Waste (
APCE Liquids •
-Bottom Ash *
Logging of Process
and CEM Data
Process Parameter
(e.g., Temperature)
Sample 4 Sample 5
Sample 6
_, Port j_
'Change
-»Port K-
Change
*\l/V*ry*WS/<\*^/^^^ I . jAA^^/^^^^AAVt^v/vv
i Proccess Upset
I
I
I
1000 1100
1200
1300
1400 1500
Military Time
1600
1700
1800
1900,
be reported. The CEMs and logging of data must
continue whenever hazardous waste is being fed to
the incinerator.
It is necessary to report all minimum and maximum
parameter values measured during a test to provide
the data heeded to set these limits. For example, if
the temperature drops to a minimum during the trial
burn and remains constant for a period, that period
should be reported along with the minimum
temperature. If there is more than one period of the
same minimum temperature, the total time at this
minimum value would be reported.
Processing and Reporting CO Data
The stack gas CO concentration is considered to be
a real-time indicator of incinerator performance.
Although CO levels cannot be directly related to ORE
at high levels of ORE, on a site-specific basis, CO is
a useful indicator of overall performance. Because of
the interdependency of CO levels and incinerator
monitoring, specific guidelines for CO are necessary.
Separate guidance manuals on CO monitoring and on
CO limits for hazardous waste incinerators are
currently under development by EPA.
5.3 Operational Recordkeeping and
Reporting
Recordkeeping requirements for permitted operation,
although not part of trial burn reporting, are briefly
mentioned here because of the close association
between reporting trial burn data and establishing
permit limits.
Operational logs constitute the major source of
records for the facility. The exact format of the log is
left to the facility because it includes important
information for the operator (e.g., damper settings
and tank level readings) that is not necessary for
establishing permit conditions. .The logs must,
however, include all appropriate information needed to
demonstrate compliance with permit limits. Units of
measurement may be the same as the instruments
record as long as they may be readily converted to
units appropriate to the permit limits. Each,instrument
should be identified with a code number,
manufacturer's name and model number, or other
unique identifier. Detailed information, the", operating
principle, and calibration method for each instrument
type are normally required in the permit application,
and the log should reflect these information
requirements.
74
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In addition to operating logs for process data, logs
that relate to waste characteristics are also essential
for compliance with permit limits. Reporting forms for
demonstrating compliance with the maximum permit
limits on halides and inorganic ash are provided in
Appendix F. It is also recommended that the
permitting authority require that the facility record in
the operating log the dates, times, and reasons for
any permit violations or any automatic waste feed
shutoff along with corrective actions taken, as well as
any instances where the automatic waste shutoff
system was not activated when parameters reached
shutoff levels, the reasons, and corrective actions
taken. The proposed amendments to the incinerator
regulations include a requirement that such
information be compiled into a report to be submitted
to the permitting authority on a quarterly basis. The
permit writer may wish to include this type of
reporting requirement in the permit.
5.4 Available Computer Program Support
Two computer data bases are available that can be
used by permit applicants to increase knowledge of
incineration systems: 1) Hazardous Waste Control
Technology Data Base and 2) Energy and Mass
Balance Model Requirements.
Hazardous Waste Control Technology Data Base
The HWCTDB, which is jointly funded by the EPA's
HWERL and the DOE through the Oak Ridge National
Laboratory (ORNL), is a source of detailed
information on thermal treatment technologies that
may be useful in the permitting process. The
HWCTDB is a compilation of data from regulations,
guidance manuals, permit applications, and trial burn
reports submitted to the EPA. The information is
retrievable thrpugh a menu-driven system, and
customized reports of summary information and
itemized data listings can be obtained online.
Parameters in the data base have been grouped into
five areas for ease of retrieval and selection:
1. General facility information
2. Design information
3. Waste characteristics
4. Operating conditions
5. Trial burn results
." '; ~-i ':? -'•;.; :" ,
Within these parameters, HWCTDB provides
information on the following:
• Existing thermal treatment facilities and their
capabilities
• Trial burn and design data
• Heating valiies
• Waste components and concentrations
• ORE
• Permit status for existing, new, and research,
development, and demonstration facilities
The data base is currently operated by ORNL, which
has produced search forms that permit writers may
use to access data on waste feed characteristics,
capacity, incinerator design, and performance. A
sample form for collecting trial burn data is included
in Appendix F.
Energy and Mass Balance Calculation
To facilitate performance of energy and mass balance
calculations for hazardous waste incinerators, a
computer model has been developed under an EPA
contract by EERC. The model is currently in draft
form and is being reviewed by EPA. The model can
assist the permit writer in evaluating incinerator trial
burn and design data to develop consistent operating
conditions. The use of this model is discussed in
Appendices B and E of this handbook. A sample form
for the engineering analysis data is also provided in
Appendix E.
5.5 Recommended Forms for Presenting
Data Summaries
Appendix F contains 12 forms which can be useful in
presenting the information needed to evaluate a trial
burn. While it is recognized that no one set of forms
can include all variations of incinerator system
designs, these should, if possible, be used as a
guide. Use of the forms will help the permit writer
identify key pieces of information quickly and facilitate
the evaluation process. The forms in Appendix F fit
into three categories:
1. Summary of the facility and target operating ranges
2. Summary of average operating conditions during
each test condition of the trial burn. Note that a
minimum of three runs at the same operating
conditions constitute a test
3. Summary of the key parameters monitored and
measured during each run
Table 5-6 lists the 12 forms in Appendix F and
summarizes how they are used. The first two tables
simply summarize the general facility information and
the general design and operating information. Some
operating information in Form 2 can be given as a
range. The purpose of Form 2 is to summarize the
facility's major attributes and to serve as a guide to
the permit writer.
L
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Table 5-6. Recommended Usage of Sample Forms in Trial Burn Report
Form No. of
No. Title Copies
Purpose
1 Summary of Facility Information 1
2 Summary of Design Information 1
3 Description of Waste Streams 1
4 Summary of Test Conditions (Waste Feed) 1 per test
5 Summary of Operating Parameter Values 1 per test
1 per run
6 Summary of System Performance 1 per test
1 per run
7 Method 5 and Participate Results 1 per run
8a Input Rates 1 per run
8b Chloride Emissions 1 per run
9a POHC Emissions (may be used for volatiles and 1 per run
semfvolatiles or use Form 9c for semivolatiles
separately)
9b POHC Input Rates 1 per run
9c Semivolatile POHC Emissions (may be used in lieu of 1 per run
Form 9a for semivolatile emission results)
10 Monitoring Data for Halides and Inorganic Ash and 1 per run
Operations
11 List of Samples 1 per test
12 Emergency Shutdown and Permit Compliance Record 1
To indicate the range of values that would be encountered
during operation or to describe the facility
To indicate the range of values that would be encountered
during operation or to describe the facility
To indicate the range of values that would be encountered
during operation or to describe the facility
To summarize the results of each test, i.e., average of the
runs for that test condition1
To summarize the results of each test, i.e., average of the
runs for that test condition
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test.
To summarize the results of each test, i.e., average of the
runs for that test condition
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test.
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test.
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test.
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test.
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test.
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test
To summarize the results of each run. The average of these
data for each test constitute input to summary of the results
of each test
As a QA/QC check on the samples taken during the test
Operation only
Note: Submit pages that have been copied on one side only to facilitate evaluation and review.
11f waste composition changes for each run, then Form 3 should be included to identify the actual composition of the wastes burned during
each run.
Form 3 describes the waste streams that the facility
will burn both during normal operation and during the
trial burn. Different wastes may be burned during
these two operations, for example, to fortify one or
more waste streams with a specific POHC or to push
the system to an extreme for the trial burn. Form 3 is
used, therefore, to summarize the data for three
different purposes. First, they can be used to
summarize the ranges of waste types and
•composition that the facility will burn during normal
operation. This summary, along with Forms 1 and 2,
constitutes the overall facility summary. Second,
Form 3 can be used to summarize the waste burned
at each test condition. For this purpose, the forms
present the summary of the runs constituting each
complete test. Finally, Form 3 can be used to present
the information on the wastes burned during each
run. As can be seen, the averages of the information
entered at this point form the input for the second
purpose. This approach presents the information in a
concise format which the permit writer can use to
determine quickly how summary results were
obtained.
Forms 4, 5, and 6 are used in a similar manner as
Form 3. They can be used to present the operating
76
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conditions of the incinerator during each run. It can They would normally be presented in the appendix to
also be used to summarize the mean operating introduce the raw data log for each run. Form 10 is
conditions during each test. Once again, the same only used if an emergency shutdown occurred during
form is used to present data at two summary levels. the trial burn. It is intended to document the
occurrence and the conditions which caused it.
Forms 5 through 9 are intended to summarize some
of the raw data on the performance of the incinerator.
77
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CHAPTER 6
Inspection and Maintenance Guidelines
A regular I&M program is critical to the successful
operation of the incinerator facility. The primary
objective of the I&M program is to ensure that major
equipment is operated safely, reliably, and according
to manufacturer operating specifications. Additionally,
the I&M program addresses the calibration and
maintenance of monitoring equipment used to
establish the accuracy and reliability of process data
that must demonstrate compliance with regulatory
limits imposed in the operating permit.
Any hazardous waste incineration facility is required
to adhere to an I&M program (40 CFR 264.347). The
permit applicant must detail this program in the
application. The information should address the
specific I&M activities for major system components
and monitoring instrumentation including the proposed
I&M frequency. The permit writer relies on this
information because I&M requirements are specific to
the type of equipment, its intended operation, and the
manufacturer. On the basis of this information and
other recommended guidelines discussed below, the
permit writer specifies the type of I&M program
applicable to the facility under review.
Table 6-1 summarizes a recommended permit
approach to the I&M program. Details of the I&M
program and general guidelines are discussed in the
following sections.
6.1 General Facility Equipment
Incineration equipment and APCE should be
inspected daily or weekly to verify the operational
status. This frequency implies an outside visual
inspection of the equipment rather than a systematic
component inspection. A detailed inspection of
incinerator refractory, scrubber nozzles, or fabric
collector bags, which would require a system
shutdown, is recommended on a much less frequent
schedule, as specified by the particular equipment
manufacturer. Occasionally, a piece of equipment
may indicate a potential problem. In this event, a
detailed inspection of those equipment components is
necessary to ward off potential noncompliance with
RCRA performance specifications. Such problems are
generally manifest through a variety of performance
indicators.
Tables 6-2 and 6-3 list indicators of poor
performance, the equipment problems generally
associated with these indicators, and recommended
maintenance and troubleshooting" programs. If the
facility cannot correct the problems by operational
adjustment (within the limits of the operating permit),
the equipment generally requires detailed inspection
and possible repair. Appropriate troubleshooting and
repairs should then be implemented to prevent
possible safety risks or noncompliance with permit
requirements. The inspection, maintenance, and
troubleshooting practices recommended in Tables 6-
2 and 6-3 require, in most cases, that the incinerator
facility be shut down.
Operational and performance monitoring
instrumentation such as liquid (pumpable) waste
flowmeters, water flowmeters, pH meters, and CO,
temperature and 02 continuous recorders should also
be subjected to a routine inspection and maintenance
program. A visual inspection of this equipment should
be carried out on a daily basis if possible. In the
longer time frame, thermocouples should be
inspected to determine whether the ceramic shields
show signs of cracking or deterioration. Monitors for
O2 and CO should be inspected at clearly specified
intervals for proper gas flowrate, vacuum pressures,
and potentiometer settings. The gas conditioning
systems that support this instrumentation should also
be inspected to determine possible air inleakage and
moisture dropout efficiency. Any supporting
electronics hardware should also be inspected. The
continuous monitoring response of this equipment
also provides a continuous readout of instrument
functionality.
The maintenance program for this equipment includes
routine service and calibration activities. Service
requirements are normally specified by the
manufacturer, as they are specific to the type of
instrumentation used. Response and calibration
checks should be performed regularly. For gaseous
analyzers for 02 and CO (and others if required by
regulations other than RCRA), calibration and
response checks should be performed daily because
these instruments are subject to drift and reduced
sensitivity.
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Table 6-1. Recommended Inspection and Maintenance Frequency
Inspection and Maintenance Frequency
Equipment/Parameter
Incinerator equipment
Waste feed/fuel systems
PCC and SCC outlet gas
temperature
Oz and CO monitors
Gas flow monitors
• Direct gas velocity
• Indirect fan amps
Other incinerator monitoring
equipment (flame scanners, air
blowers, etc.)
APCE
APCE support systems
APCE performance instrumentation
Inspection and Maintenenace
Criteria
Proper Operation
Proper Operation and Accuracy
Proper Operation and Accuracy
Proper Operation and Accuracy
Proper Operation and Accuracy
Accuracy
Proper Operation
Proper Operation
Proper Operation
Proper Operation and Accuracy
Operation and
Calibration
-
2
Monthly
Daily
Monthly
6 Months
'"
Weekly
Monitoring
Inspection
Daily
Daily
Daily3
DailyS
Daily3
Daily
Daily
Weekly
Daily
Daily
Equipment
Service
1
1
1
1
1
1
1
1
1
Emergency
Systems
Alarms Waste Cutoff
-
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
' " - • .
Weekly
Weekly
-
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
•••-•'
Weekly
Weekly
1 Equipment manufacturer's recommendation.
2 Equipment manufacturer's recommendation or no less than monthly.
2 Operators are also alerted immediately as to the functionality of the instruments because of the continuous monitoring response of this
equipment
Table 6-2. General Maintenance and Troubleshooting of Incinerator and Auxiliary Equipment
Equipment
Indicators
Problems
Recommended Maintenance
and Troubleshooting
Incinerator refractory Excessive temperature
Chamber pressure
Chamber excess Og
Liquid/slurry/sludge
waste feed system
Solid feed mechanism
Excessive pressure
(high Or low)
Excessive Oa; unresponsive
to firing rate
Excessive variations in Q%
and CO
Excessive variations in waste
feed pressure at the burner
Excessive variation in 02,
temperature, CO, and/or
pressure
• Loss of refractory, corrosion
• Flame impingement
• Ash deposit, plugging
• Excessive flowrate
• Excessive air leakage
• Obstructed fan dampers
• Variable waste concentration and
heating value
• Excessive feed rate
• Feed line plugging
• Feed line plugging
• Excessive solids in the waste
• Improper preheating of waste
Pump problems
Loss of atomization fluid
(air-steam)
• Feed conveyor problems
• Feed ram cycle timer
• Hydraulic feed system
• Blockage of screw feeder
Inspect and replace. Review refractory
specifications. ..-..,
Nozzle erosion. Inspect and replace.
Inspect chamber, transition ducts,
APCE indicators
Inspect combustion air control System,
fan and dampers .
Inspect seals and air fan dampers and
control mechanism .
• Inspect mixing tank and recirculation
• Adjust feedrate
• Inspect feed line screens, filter for
deposits, plugs
• Adjust temperature control for waste
viscosity
• Inspect waste pump operation
• Inspect atomization air blower, steam
supply
• Inspect solid feed system for timing,
blockage and proper operation of
components •
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Table 6-3. General Maintenance and Troubleshooting of Air Pollution Control Equipment
Equipment Indicators Problems
Recommended Maintenance
and Troubleshooting
Quencher
Erratic outlet temperature
Venturi scrubber
(conventional and
IWS)
Consistently high outlet
temperature
Erratic pressure differential
Absorption scrubber Surging pressure differential
Fabric filter
Excessive pressure differential
Electrostatic
precipitator
Excessive sparking rate
Intermittent smoke "puff"
• Partially plugged nozzles
• High variation in Incinerator
moisture feed
• Low gas flowrate (< 30 fps)
• Water droplet impinging on
thermocouple
• Plugged nozzles
• Low water flowrate and high
temperature ' •
• Excessive gas speed (> 50 fps)
• Plugged nozzles
• Adjustable throat diameter is too
wide
Face velocity in excess of 12 fps
Plugged tray sections
Nonuniform scrubber liquor
distribution
Leaking seals
Localized plugging of packing
Hole in the packing
Excessive gas flowrate
Bag blinding (high dust loadings)
Leaking air lock or dampers
Faulty cleaning mechanism
Excessive dust accumulation in
clean side of bags
• High moisture in gas
• Excessive voltage and current
settings
• Improper sampling or cleaning
frequency
• Poor incinerator operation
• Overload of ash hoppers
• Inspect and replace plugged nozzles
• Control moisture feed to incinerator
« Increase gas flowrate to design range
• Relocate "thermocouple, replace
defective nozzles
• Inspect and replace plugged nozzles
• Calibrate water flowmeter; adjust to
'50-80 percent of evaporation loss
• Reduce pas flowrate
• Inspect headers, flanges and nozzles
• Reduce throat diameter and adjust liquid
flowrate
• Inspect throat regularly for deposits and
wear
• Inspect spray nozzles, water flowrate,
weir bozes, seals, and downcomers for
proper operation.
• Inspect packing, adjust caustic.
conecntration to 15-20 percent.
* Reduce gas flowrate; check bleed air
• Inspect cleaning mechanism; replace
bags
• Check proper temperature of gas to
prevent condensation
• Inspect proper removal of collected ash
from hoppers
• Reduce moisture feedrate
• Adjust setting assembly
• Adjust rapping cycle
• Inspect waste feed to incinerator
• Inspect hopper for excessive deposits
6.2 Safety and Waste Cutoff Interlocks
The operating permit should also specify that all
alarms, automatic waste cutoff systems, and
emergency shutdown interlock systems be routinely
checked to verify operational status. This I&M activity
is particularly critical to the operation of the facility
because the failure to interrupt waste feed during an
operational upset could result in a dangerous
situation. Therefore, and as required under 40 CFR
264.347(c), all automatic waste feed systems and
associated alarms should be tested on at least a
weekly basis. Checking at a lesser frequency, up to a
monthly basis can be allowed if adequate and if more
frequent testing can be shown to unduly upset
operation.
m
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APPEND1XA
Sources of Further Information
This document is part of the Hazardous Waste
Incineration Guidance Series prepared by the EPA to
assist both the applicant and the permit writer in the
RCRA process leading to a final operating permit for
hazardous waste incinerators.
Hazardous Waste Incineration Guidance
Series
Volume I
Guidance Manual for Hazardous Waste
Incinerator Permits. Mitre Corp. NTIS PB84-
100577. July 1983. (Document is scheduled for
revision.) Describes the overall incinerator
permitting process, highlights the specific
guidance provided by other manuals, and
addresses permitting issues not covered in the
other manuals such as treatment of data in lieu of
trial burn. Thus, it can be viewed as a road map
and a good summary of all permitting issues.
Volume II
Guidance on Setting Permit Conditions and
Reporting Trial Burn Results. Provides guidance
to the permit applicant on reporting trial burn data
and to the permit writer on translating these data
into meaningful and enforceable operating
conditions for incinerators. Acurex Corp. 1989.
Volume III
Hazardous Waste 'Incineration Measurement
Guidance Manual. Midwest Research Institute.
1988. (Draft under EPA review.) Addresses
monitoring, sampling, and analytical
instrumentation and the test methods required for
trial burn testing and enforcement activities.
Sampling and analysis methods for multimedia
emission evaluations including quality
assurance/quality control are also discussed.
Volume IV
Guidance on Metals and Hydrogen Chloride for
Hazardous Waste Incinerators. Versar, 1989.
(Draft under EPA review.) Specific guidance on
limiting metals emissions from incinerators is
provided. In particular, a risk assessment
approach to setting limits on metal components
inthe waste is employed. Guidance is also
provided on doing risk-based checks on HCI
emissions. (NOTE: Earlier title was: Guidance for
Permit Writers for Limiting Metal and HCI
Emissions from Hazardous Waste Incinerators.)
Volume V
Guidance on PIC Controls for Hazardous Waste
Incineration. Midwest Research Institute. 1989.
(Draft under EPA review). Details the specific
permit requirements for CO and total hydrocarbon
(THC) emissions from hazardous waste
incinerators in the RCRA system. Emission limits
for CO and THC and the rationale for their
selection are discussed. (NOTE: Earlier title was:
Guidance on Carbon Monoxide Controls for
Hazardous Waste Incineration.)
Volume VI
Proposed Methods for Measurement of CO, Oz,
THC, HCI and Metals at Hazardous Waste
Incinerators. 1989. Presents a draft measurement
method for the above parameters including
performance specifications for continuous CO
monitors.
Other Reference Documents
1. Engineering Handbook for Hazardous Waste
Incineration. EPA Publication SW-889.
September 1981.
2. Practical Guide - Trial Burns for Hazardous
Waste Incinerators. Midwest Research Institute.
EPA Publication No. 600/2-86-050. 1986
3. Trial Burn Observation Guide. Midwest Research
Institute. 1988. (Draft under EPA review). Includes
general guidance on preparation, on-site
activities, and reporting aspects of observing a
trial burn test.
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4. Background Information on Sampling and
Analysis Methods Related to the Amendments to
the Incinerator Regulations and to the Regulations
on Bo'lers and Industrial Furnaces. Midwest
Research Institute. 1988. (Document under
preparation.) Includes descriptions of
recommended sampling and analysis methods.
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APPENDIX B
Guidance For Incinerator Design Review
During the process of permitting a hazardous waste
incinerator, the permit writer must make a number of
engineering assessments. Before approving the trial
burn, the permit writer must be assured that the
design is adequate to protect human health and the
environment. After the trial burn, the permit writer
must be assured that the trial burn data are
consistent and believable and that the data can be
properly interpreted to establish a flexible set of
permit conditions which are in compliance with
performance standards. This appendix gives the
permit writer background on incinerator design so that
an application is reviewed to:
1. Ensure that there are no major design flaws of
sufficient magnitude to render a trial burn unsafe"
2. Ensure that the trial burn will generate sufficient
verification information so that trial burn data may
be propeny interpreted and evaluated
In pursuit of the first objective, the permit writer
should remember that the key phrase is "major
design flaws." Incinerator design information available
to the permit writer is not so universally applicable
that a prior prediction of incinerator performance
could be made with confidence; otherwise, there
would be no need for trial burns. An example of a
major design flaw would be an incinerator that is
predicted to operate 200°C (390°F) lower than its
design temperature but has inadequate auxiliary fuel
provisions to make up the difference. An example of a
minor design flaw is an incinerator that is predicted to
operate 200°C (390 °F) hotter than its design
temperature.
The design review is most applicable to new
incinerators which must be permitted before they can
be built. For existing facilities, one can generally
determine from observation of the unit or from
operating data that it can attain specifications such as
trial burn temperature and sufficient quench water
flow to achieve the desired APCE temperatures.
The permit writer should perform the following steps
for a design review:
1. Review the overall facility design and system
schematics
2. Review thermal treatment equipment design
3. Estimate temperature and gas residence time and
verify other control parameters for internal
consistency
4. Review APCE design and estimate efficiency
5. Review measurement techniques and safety
interlocks
6. Consider special wastes and similar systems
B.1 Overall Facility Design
A schematic diagram of the incineration system
should always be reviewed by the permit writer. All
waste, fuel, air, water, and other input streams as well
as the locations of all required measurement, should
be labeled on the diagram. The permit writer should
determine if all components of the system are being
taken into account and that the permit parameters are
being set and monitored with the proper
measurements.
Figure B-1 provides layouts for typical incinerator
facilities. For the most part, these facilities can be
viewed as straight-through systems in which wastes
are incinerated in single or multiple chambers with
further thermal and flue gas treatment occurring
downstream. The layout at the top of the figure shows
a typical facility where the combustion gases leaving
a PCC such as a rotary kiln or liquid injection
chamber are further treated with a SCC, which is
sometimes called an afterburner. Frequently, the SCC
is fired with a liquid organic waste instead of fossil
fuel. This practice is quite common as it results in
significant cost reductions.
In most cases, flue gas scrubbing for particulate and
acid control is required to meet current emission
standards. It is important to point out that some
facilities do not use afterburners nor APCE. For these
units, operation is considerably simplified, but they
are restricted to burn essentially ash-and halogen-
free wastes to comply with RCRA standards for
particulate and acid emissions.
Some commercial facilities use two PCC units, each
designed to incinerate a category of wastes; for
85
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r
Figure B-1 Incinerator equipment arrangements.
'1
L ^
r*
Primary
Chamber
(PCC)
A
— I/
r*
Secondary
Chamber
(SCC)
APCE
Stack
Pumpable
Pumpable
Ash
V
Residue
Primary
Liquid
Chamber
(PCC)
Residue
Stack
Solids
Sludge
Slurries
Ash
A-Combustion air
F-Primary fuel
APCA - Air pollution control
equipment
example, liquids in a liquid injection chamber and
solids/sludges in a rotary kiln. These facilities are
designed for maximum waste flexibility and operation.
The combustion gases from both chambers are
ducted to a common SCC unit for complete
incineration of remaining combustible byproducts
before scrubbing for paniculate and acids takes
place.
One other design variation, especially for large
commercial incinerators, is heat recovery using waste
heat steam generators or boilers. This equipment,
which is always found upstream of APCE, is typically
a "passive" device where no supplemental firing
occurs. Therefore, it requires little or no consideration
on the part of the permit writer in setting operating
permit conditions. However, in the case where the
boiler is supplementary fired, the permit writer should
consider its operation as a tertiary combustion
chamber where further waste destruction occurs.
B.2 Incineration Equipment
There are a number of different types of incinerators
and many design variations for each type. The permit
writer should realize, therefore, that no single design
review tool is universally applicable. Thus, it is
important for the permit writer to know the basic
principles of incineration to perform a "best-
engineering" analysis of the design. Towards this
aim, this section reviews the principal design features
of thermal treatment equipment and specifically
provides review guidance for design factors deemed
most important to incinerator performance.
As mentioned, incineration of hazardous waste can
be accomplished by several types of high-
temperature combustion devices. Some of these have
a rather long operating experience, other more
recently developed types are not yet in widespread
use, while still others are currently under research
and development. By far the most common
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incineration devices or PCC units are the liquid
injection chamber, rotary kiln, and fixed hearth. The
discussions below focus on these three principal
designs that comprise well over 80 percent of the
estimated 221 incinerator facilities already permitted
or operating under interim status (1). The total
thermal capacity of these units is projected at about
650 MW (2,200 x 1Q6 Btu/hr) or 93 percent of total
incinerator capacity. Table B-1 summarizes major
design features, typical operating characteristics,
suitable wastes, and other general information
pertinent to these incinerator types. For the reader
interested in obtaining additional information, Kiang
and Metry (2) and Bonner, et al, (3) are
recommended as guides. Other information can be
obtained directly from incinerator manufacturers.
A section on fluidized bed combustor (FBC)
incinerators is also presented below. These units,
which represent less than 3 percent of the existing
population, are not specifically treated in this permit
guidance because of specific design and operating
considerations and the inadequate data base on
performance characteristics.
B.2.1 Liquid Injection Incinerators
As the name implies, a liquid injection incinerator is
designed to burn liquid or pumpable hazardous
wastes. The refractory chamber is typically cylindrical
and is oriented for either down-firing or horizontal
firing. The primary consideration in the selection of
the firing orientation is the amount of inorganic ash in
the waste and its chemical composition. Waste with a
significant quantity of inorganic salts is typically
treated in a down-fired system. At the high
temperatures required for waste destruction, these
salts are liquified; they may adhere to the refractory
and form a slag. Removal of the molten slag in the
down-fired liquid injection chamber is aided by
gravity. However, in a horizontally-fired chamber,
this gravity-assisted slag removal is not possible,
and deposits of successive layers of ash often
accumulate on the lower part of the chamber.
Because these increased ash deposits can effectively
reduce the available chamber volume, lower gas
residence times and reduced gas mixing, increased
maintenance, and reduced firing capacity can result.
For example, for a 260-KW/m3 (25,000-Btu/hr-cu
ft) liquid injection chamber fired with liquid waste
containing 5 percent alkaline salts and low-melting-
point metal oxide ash, the accumulation of slag in the
chamber could be as much as 15 percent of its
volume for 100 hr of operation. For these cases,
routine visual inspection combined with practical limits
on ash content for horizontally-fired liquid
incinerators should be considered by either the facility
operator or the permit writer.
Liquid injection incinerators can be fired under
positive (forced draft) or negative pressures (induced
or balanced draft systems). Typically, positive-
pressure chambers are used unless the facility is
equipped with APCE. Because high-efficiency APCE
often results in high pressure drops, a balanced draft
(forced draft-plus-induced draft (FD plus ID))
system is often used. This configuration prevents the
PCC unit from operating under excessive positive
pressure to overcome flow restrictions in the APCE.
To maintain the proper pressure in the chamber is
important for equipment safety as well as for fugitive
emission control considerations.
Pumpable liquid waste is injected into the chamber
through atomizing burner nozzles. The liquid feed
system should be properly designed to avoid feed line
plugging, excessively variable feed composition,
nozzle erosion, and poor atomization. A good,
commonly used method of minimizing these problems
is the use of waste recirculation at the tank and at the
burner.
Other desirable designs include multiple burner
arrangements which allow better waste distribution in
the chamber, more efficient atomization, and
improved turndown firing capability. Preferably,
primary combustion air should be injected at each
waste burner location to provide stable combustion
with rapid droplet vaporization and burnout. Waste
heating value is not critical when supplementary fuel
(waste or fossil fuel) is available to maintain chamber
temperature. For high-water-content waste, the
feed rate should not be too high to prevent primary
flame quenching, which can be manifest in increased
CO and hydrocarbon emissions. The design and
operating practices are also important for SCC units
or afterburners because liquid wastes are also
incinerated in these devices.
A key factor in the performance of liquid injection
incinerators is atomization quality, which is defined by
the droplet size distribution of the spray. The
presence of large drops cannot be tolerated because
if the residence time in the combustion zone is
insufficient to ensure complete combustion, unburned
material may exit the combustion chamber.
Nozzles are typically either internal or external
atomizing and mechanical or twin fluid. The difference
between an internal and external atomizing nozzle
relates to the point in the nozzle where the fluid
(waste or fuel) is atomized. While this difference is
important in the design and selection of the nozzle, it
is not important in the evaluation of a permit
application. Mechanical or twin fluid atomizing nozzles
are generally employed in liquid injection incinerators.
One common type of mechanical atomizer is a simple
pressure jet in which the liquid is forced through a
constriction; atomization occurs because of the
instability of the liquid film formed downstream of the
constriction. Droplet size increases with increasing
liquid flow and decreasing hole size. Another type of
mechanical atomizer is the rotary cup in which a
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Table B-1. Incineration Equipment
Equipment Type Typical Design Features
Suitable Wastes
Other Considerations•
Liquid Injection • Refractory-lined furnace down- or
horizontally-fired
• Positive pressure or balance draft design
• Heat input capacity of 0.37-38 MW(0.125-
130 x 10s Btu/hr)
• Typical L/D = 2 to 3:1
• Heat release rates of 100-370 KW/m3
(10,000-35,000 Btu/hr-cu ft)
• Operating temperatures of 980-1,650°C
(1,800-3,000°F)
• Gas residence times of 0.3-2 sec
Rotary Kiln • Refractory-lined cylindrical rotating furnace
mounted horizontally with a slight incline for
passage of ash
• Negative pressure in the kiln
• Heat release rates of 160-470 KW/m3
(15,000-45,000 Btu/hr-cu ft)
• Operating temperatures of 650-1,260°C
(1,200-2,300°F) for PCC; 800-1,600°C
(1,470-2,800 °F) for SCC
• Gas residence times of 1-3 sec (in SCC)
• L/D of 1:5 for kiln
• Variable rotational speed typically in the
range of 0.01-1 rpm
• Solids retention time of 1 -2 hr
• Solids waste feed capacity 0.17-0.56 kg/s
(1,300-4,000 Ib/hr)
Fixed Hearth • Single or multiple refractory chambers
• Typical waste loading capacity 0.05-0.3
kg/s (400-2,400 Ib/hr)
• Heat capacity 0.9-5.3 MW (3-18 x 106
Btu/hr)
• Underfire and overfire air injection designs
available
Primarily pumpable
and atomizable liquid
wastes
Low- and high-
heating value wastes
Halogenated wastes
Organic vapor-laden
waste gases
Solid, liquid, and slurry
wastes
Contaminated, bulk
low- or high-heating
value wastes
Suitable for gaseous
wastes . .
Primarily solids and
sludges
Low- and high-
heating value wastes
Halogenated wastes
Supplemental fuels are required for the
initial refractory heat-up period and for '
incineration of LHV wastes •
Typically operating with excess air from
combustiori blower
SCC not always necessary
Supplemental fuel is required for the
initial heat-up period and for. .,
incineration of low heating value wastes
Considerable retention time of solids is
required •
SCC is required with pyrolytic or excess
air combustion .
Supplemental fuel is required for the
initial heat-up period and for
incineration of LHV wastes
Typically used for treatment of small
quantity of wastes
PCC can be operated with both excess
or starved air
liquid jet is impinged on a spinning cup or disk.
Centrifugal forces cause the resulting droplets to
move radially outward, and the combustion air flow
must be used to direct the droplets into a favorable
path for combustion within the incinerator chamber.
Rotary cup atomizers are used for sludges and
slurries because they do not have narrow passages
that can be plugged. In the twin fluid atomizer, a
second fluid, either high-pressure steam or air, is
forced at high pressure and velocity into a slower
moving liquid jet, and atomization occurs because of
the high shear between the two streams. These
nozzles can produce extremely fine drops if sufficient
atomization fluid is employed (4).
The permit writer should compare the liquid waste
burner specifications with the quantity and properties
of the waste to be burned to ensure the following:
• The burner is the appropriate size to handle the
range of waste flows expected.
• The viscosity of the waste as fired is not too high.
• The particle size and quantity of solids in the waste
are not too high.
B.2.2 Rotary Kiln Incinerators
Rotary kilns are refractory-lined cylindrical chambers
positioned with a slight incline from the horizontal
plane. The rotation of the kiln promotes the mixing of
the solid waste and hot combustion gases and
transports the ash down the length of the chamber to
the ash hopper. Incinerator facilities utilizing rotary
kilns provide the greatest flexibility for hazardous
waste disposal. The kiln can accommodate a variety
of solids, slurries, and sludge waste streams in
containerized form such as fiber packs and drums or
as bulk or shredded solids. In addition, the rotary kiln
operates as a liquid injection unit because liquid
wastes are also injected through atomized waste feed
burners. Existing rotary kiln capacities range as high
as 44 MW (150 x 1Q.6 Btu/hr), and larger .commercial
facilities are under construction. Chamber operating
temperatures are typically below 1,090°C {2,000°F),
with many units operating with exit gas temperatures
aslowas650°C(1,200°F).
Several factors should be scrutinized when rotary kiln
designs and trial burn data are reviewed. Waste
devolatilization, ash retention time, and .paniculate
entrainment have a strong influence on the
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performance of rotary kilns and snould be considered,
or computed, as follows.
Waste Devoiatilization
Wastes are generally fed to kilns in batches, often in
disposable drums that cause cyclical transient
behavior. When a batch first enters the kiln, it heats
up, dries, and devolatilizes, consuming heat and
cooling the kiln. Then the volatiles burn very quickly;
the rate is limited only by turbulent mixing and the
availability of oxygen. The rapid burning can cause a
rapid increase in gas temperature and decrease in the
excess air level. These transient effects of batch
feeding become more pronounced with increasing
charge size, volatile content, and kiln temperature.
Kilns are generally run at high excess air levels (often
100 percent or more) to allow for these transients.
After the volatiles are released and burned, the
remainder of the heat content of the waste burns
relatively slowly.
Ash Retention Time
Kiln ash retention time is inversely proportional to kiln
slope and rotational speed and is directly proportional
to the length-to-diameier ratio. It may be estimated
according to the U.S. Bureau of Mines (1927) formula
(5):
6^0.19L -8- NSD
where:
8 = Ash retention time, min
L = Kiln length, m
D = Kiln diameter, m
N = Kiln rotational speed, rpm
S = Kiln slope, m/m
Participate Entrainment
Particulate entrapment in a rotary kiln depends
primarily on the size and density of the solids, the
velocity and properties of the gas, and kiln design and
operating conditions. The subject has been treated by
Khodorov (1961) and by Li (1974) (6):
w =
,J/2
where:
W = Entrapment rate, kg/s
K£ = Proportionality constant which varies with
the roughness between the cylinder wall
and feed solid
D = Inside diameter of the cylinder, m
F = Solid feed rate, kg/s
N = Cylinder rotation speed, radians/s
S = Cylinder slope, m/m
6 = Dynamic angle of repose of the solid,
radians
U = Gas velocity, m/s
p = Gas viscosity, N s/m2
p = Gas density, kg/m3
d = Solid density, kg/m3
Ds = Diameter of the feed particles, m
n = Solid particle size distribution parameter .
f(Cf) = Modification parameter, which is a function
of the concentration of entrainable fines in
the solid
Incineration of bulk solids and containerized
hazardous wastes requires special considerations.
The complete burning of solid combustible material
requires longer residence times than liquid and gas
waste fuels. The length of time, which can be as long
as 2 hr, depends on the rate of the mass transfer of
the organic component in the solid waste to the gas
stream. The rate of mass transfer, in turn, depends
on temperature, the size of the solids, the volatile
content of the waste, and the degree of mixing
achieved. The rate of solid feed, the size of
containerized solid waste, the solids loading in the
kiln, and the retention time of ash in the kiln are all
important considerations for achieving complete
combustion of combustible material while retaining
sufficient efficiency to destroy volatilized POHCs.
Although current RCRA regulations do not address
incinerator residue quality (i.e., the degree of
complete combustion of the ash leaving the kiln),
many States and local regulatory agencies require
that the incinerator operate in a manner that avoids
creating an ash disposal problem. This requirement
imposes routine analyses of the residual ash, with
further treatment if necessary, before landfill disposal.
Rotary kilns can operate with excess combustion air
or under pyrolytic or oxygen-starved conditions.
Typically, excess air is used, thus providing an
oxidizing environment which is generally more
protective of refractory material. Irrespective of
excess air levels, the combustion gases generally
pass through a SCC or afterburner to ensure
complete combustion of measured organics leaving
the kiln unit. For a rotary kiln burning a variety of bulk
solids, secondary incineration of combustion
byproducts is more critical to efficient destruction
than a liquid injection incinerator. Typically, SCC
chambers for rotary kiln systems are conservatively
designed to provide high temperature and longer
residence times. Also, most rotary kilns operate under
negative pressure for control of fugitive emissions
from waste feed areas and kiln end seals during ash
removal. Air pollution control is inevitably required
with this incineration system due to the nature of
hazardous waste treated.
8.2.3 Multiple Hearth Incinerators
A multiple hearth incinerator typically consists of a
series of flat hearths within a refractory shell. Sludge
or solid waste is continuously fed through the roof
onto the top hearth. Rotating arms cause the waste to
drop from hearth to hearth until the remaining ash is
discharged at the bottom of the furnace. Air is
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preheated as it is used to cool the rotating arms.
Additional heat is provided through auxiliary burners.
Gas flows countercurrent to the waste and exits at
the top of the furnace.
Existing multiple hearth incinerator designs have a
heat input capacity of 0.9 to 5.3 MW (3 to 18 x 1Q6
Btu/hr). Each chamber is typically equipped with oil or
gas burners for startup and supplemental heat
requirements. For larger incinerators with capacities
greater than 93 kg (200 lb)/hr, solid waste feed and
ash removal are automated with hydraulic-
ram/hopper or cart-dumping systems.
As with rotary kiln incinerators, the factors of waste
devolatilization, ash retention, and entrainment should
be considered. Waste bed combustion on the primary
chamber grate is typically accomplished at low
temperature and with a minimum of underfire air to
prevent formation of metallic salts and minimize
particulate emissions. Solid waste-charging systems
are designed so that volatiles from "fresh" waste
pass through the flames in the flame port before
entering the mixing chamber. The rate of ignition of
unburned solid waste containing high concentrations
of volatiles (including moisture) is maximized using
small waste feed batches. This operation prevents
flash volatilization, which carries the potential for
flame quenching and smoke generation. Controlled
waste charging also reduces the need for bed stoking
required at times to enhance solid waste burnout.
Solids transport is determined by the rotational rate of
the rabble arms and the location of the drop holes.
Entrainment can occur as the waste drops from
hearth to hearth if the opposing gas velocity is greater
than the terminal velocity of the waste particles.
Entrainment increases with increasing gas flow and
with decreasing particle size and density:
B.2.4 Fluidized Bed Incinerators
Although fluidized bed incinerators or combustors
(FBCs) represent a minor fraction of the existing
waste incinerator population, several design and
operating advantages of these units are likely to result
in increased use of these equipment types in the
thermal destruction of hazardous waste. The FBCs
are typically simple, compact combustors that provide
efficient destruction of a wide variety of wastes (i.e.,
solid, liquid, and gaseous) at low temperature. The
main chamber consists of a bed of hot inert material
which is fluidized with 0.76 to 2.4 m/s (2.5 to 8.0 fps)
combustion air. Bed temperature is typically
maintained in the range of 450 to 850°C (840 to
1,650°F). Waste incineration occurs in and above the
bed (freeboard area) where temperatures can reach
980°C (1,800°F). The bed material can be selected
to maximize retention of halogenated acids and
metallic oxides, thus reducing the emission burden to
the APCE. For several FBC designs, a high residence
time of liquid and solid waste in the hot bed is
achieved. Circulating bed combustors (CBCs) are
designed for increased reentrainment of solids in the
gas stream leaving the chamber. The solids are then
captured in a downstream cyclonic hopper and
reinjected into the PCC. This CBC design essentially
extends the bed volume to the entire primary
chamber in comparison with conventional FBC
design. - ._.., .
Aside from temperature, the primary design factor to
be considered is the gas velocity, which must be high
enough to maintain bed fluidization but low enough to
prevent bed attrition. It is constrained by the terminal
velocity of the bed particles and is, therefore, a
function of the particle size. Superficial velocities in
the range of 1.5 to 3 m/s (5 to 10 fps) are common.
Entrainment from a fluidized bed occurs when the
terminal velocity of the waste (or bed) particles is less
than the velocity of the gas in the freeboard space
above the bed. Entrainment increases with increasing
gas flow and with decreasing particle size and
density.
B.3 Temperature and Gas Residence
Time
Incinerators allow for the destruction of hazardous
wastes by providing high temperature and sufficient
time in an oxidizing environment for the waste to burn
such that harmless or easily removed products such
as 02, H2O, HCI, and ash remain. The permit writer
should perform specific calculations to determine if
the temperatures and gas residence times reported in
the trial burn plan are reasonable and can be
expected to be demonstrated in the trial burn.
B.3.1 Calculation Technique
This section presents a technique by which the
permit writer can calculate the temperature and gas
residence time in the combustion chamber of an
incinerator using the waste feed and design data as
presented in a permit application. It should be kept in
mind that every incinerator is unique and that
application of this generalized technique to a
particular incinerator may be inaccurate. When
possible, a detailed energy and mass balance
(E&MB), as described in Appendix E, should be
performed. An E&MB is capable of computing not
only both temperature and residence time but also
many operational parameters. It can, therefore, be
used as a tool to verify information developed from
the trial burn itself. Nevertheless, generalized
correlations such as those presented in this section
are useful to illustrate trends and to extrapolate data
over a limited range.
Residence time and effluent flow in an incinerator
largely depend on total air flow to the incinerator. A
fair approximation of residence time can be made
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using the ideal assumption that only air flows through
the incinerator, resulting in equation 1:
Figure B-2. Actual-to-ideal residence time ratio vs.
moisture-to-air mass flow ratio.
where:
^ideal
V
P
mair
(1)
= Ideal incinerator residence time, s
= Volume of the combustion chamber, m3
= Pressure of the combustion chamber, atm
= Total flow of all air including leaks into the
combustion chamber, kg/s
= Combustion chamber temperature, °K
This approximation can be made because most of the
volumetric throughput in an incinerator is due to air
and because combustion of most fuels and wastes
produces about the same number of moles as it
consumes.
When the waste has a high aqueous or moisture
content or when a significant water stream is fed into
the incinerator, equation 1 tends to overpredict
residence time, and a correction factor must be
applied. Figure B-2 shows the value of this
correction factor as a function of the mass ratio of
water to air flows to the incinerator, where the water
flow includes the sum of all moisture content,
aqueous content, or water in all streams input to the
incinerator, and the air flow includes the sum of all air
flows including leaks. For incinerators in series,
residence time of the first unit would be calculated
from all air and water flows into that unit alone, but
residence time of each succeeding unit would be
calculated from all air and water flows into that unit
and all units upstream. Residence time can be
converted into actual volumetric flow in actual cubic
meters per second by equation 2:
Volumetric flow = V •*•
(2)
or to velocity (U) in m/s by equation 3:
U = Volumetric flow -s- Cross-sectional area (3)
where cross-sectional area is in m2
Temperature in an incinerator can be roughly
correlated with the fractional heat loss and the ratio of
total heat input to total mass input, as shown in
Figure B-3. This correlation assumes that the heat
capacity of a combustion mixture is independent of
composition, which is a reasonably accurate
assumption unless the mixture has a high water
content. Figure B-4 shows the correction to the ideal
temperature that must be applied to account for water
content.
Fractional heat loss is the ratio of heat loss through
the walls to total heat input to the incinerator. It is a
function of temperature, size, shape, insulation, and
0)
ir
<»
-Q
1.0
0.8
0.6
0.4
0.2
l
0.2 0.4 0.6 0.8
Moisture Mass Flow/Air Mass Flow
1.0
heat input. Most hazardous waste incinerators are
fairly well-insulated and have a fractional heat loss
of less than 10 percent.
The total heat input to the system includes the sum of
all chemical and sensible heat inputs as shown in
equation 4:
Total Heat Input
= 2 Chemical Heat Input
+ S Sensible Heat Input
(4)
The chemical heat input from a fuel/waste stream is
the product of its mass flow and lower heating value
(LHV) as calculated in equation 5:
Chemical Heat Input =
x LHV (5)
Because only the higher heating value (HHV) of a
fuel/waste is typically measured, the LHV may be
approximated from equation 6:
LHV = HHV - [(1-MOISTURE)HFAC + MOISTURE] 2,440
- Cl (1 - MOISTURE) 1,160
(6)
where both LHV and HHV are in units of kJ/kg and
where MOISTURE is the mass fraction of liquid water
in the fuel/waste, Cl is the mass fraction of chlorine in
the dry fuel/waste, the combustion water parameter
(HFAC) is the ratio of the mass of water generated
from the combustion of hydrogen in the fuel/waste to
the mass of the dry fuel/waste and 2,440 kJ/kg (1,060
Btu/lb) is the heat of vaporization of water. The final
term in equation 6 is not normally seen in the
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classical definition of lower heating value, but is used
to account for the fact that in most heating value
measurements, the ^chlorine comes out in solution;
1,160 kJ/kg (500 Btu/lb) is the heat of solution of HCI.
Figure B-5 shows the difference between higher and
lower heating value as a function of MOISTURE and
HFAC. For these calculations, all input streams
containing liquid water . should b'e. considered
fuel/waste streams; thus, a pure water stream from
equation 6 would have a LHV of -2,440 kJ/kg (-
1,060 Btu/lb). The value of the combustion water
parameter is calculated from equation 7: ..
35.5 / 2
where H and Cl are the mass fractions of H and Cl in
the dry fuel/waste. Figure B-6 shows that HFAC
increases sharply with H and decreases slightly with
Cl. The sensible heat input of a stream is the product
of the mass flow of the stream (m), the mean heat
capacity of the stream, and the difference between
the preheat temperature (Tpreheat) and the reference
temperature. Under most conditions, sensible heat
may be approximated with reasonable accuracy from
equation 8:
Sensible Heat Input = 1.01 m(Tpreheat- 298)
(8)
where sensible heat is in units of kJ/kg and Tpreheat
is in °K, and 1.01 kJ/kg is the heat capacity of air.
B.3.2 Example Test Case
This section describes an example application of the
calculation technique discussed above. The example
test case is for a rotary kiln/SCC incineration system
that is shown schematically in Figure B-7. Control
parameter inputs, which are summarized in Table B-
2, were taken from design data supplied by the
applicant for a representative operating point.
- ' ' . «' ' ' "
The rotary kiln has a volume of 160 m3 (5,650 cu ft),
an inside surface area of 320 m2 (3,440 sq ft), and a
0.21-m (8.2-in) thick refractory covering with a
conductivity of 8.2 x 1CH kJ/s-m-°C (5.7 Btu
in/hr-sq.ft-°F). For the operating point of interest,
the rotary kiln has three input streams: waste, steam
used to atomize liquid waste, and air. The feed rates
for the three streams are 1.05 kg/s (8,330 Ib/hr)
waste, 0.096 kg/s (760 Ib/hr), steam, and 5.39 kg/s
(42,800 Ib/hr) air, including 0.067 kg/s (530 Ib/hr)
water vapor in the ajr. The preheat temperature is
450°K (350°F) for the steam, and 289°K (60°F) for
both the waste and the air. The waste stream has an
HHV of 7,690 kJ (3,310 Btu/lb), with 1,24 dry weight
percent hydrogen, 5.83 dry weight percent chlorine,
and 18.47 weight percent water.
Using the above data, the necessary normalized
parameters for the rotary kiln may be calculated. To
calculate the total heat input, chemical heat from the
waste stream must be considered along with the
sensible heats of all input streams. For this waste
composition, the combustion water parameter HFAC
is calculated from equation 7:
HFAC =
0.0124
0.0583
35.5
18
— = 0.0968
2
This value of HFAC, combined with a MOISTURE
value of 0.1847 and a Cl value of 0.0583, can be
used to obtain the LHV of the waste from equation 6:
LHV = 7,690 - [(1 - 0.1847) 0.0968 + 0.1847] 2,440
- 0.0583 (1 - 0.1847) 1,160
= ,6,990 kJ/kg (3,006 Btu/lb)
Because the water stream is input in the vaporized
form of steam, its LHV is 0. The chemical heat from
the waste stream (and the total chemical heat in this
case) is calculated from equation 5:
Chemical Heat Input =1,05x6,990
= 7,340 kJ/s (25 x 106 Btu/hr)
The mass flows and preheat temperatures of each
stream may be substituted in equation 8:
Sensible Heat Input = 5.39 x 1.01 (289 - 298)
= -49 kJ/s (-167,000 Btu/hr)
for air,
= -9.5 kJ/s (-31,000 Btu/hr)
for the waste, and
= +14.7 kJ/s (50,000 Btu/lb)
for the steam,
amounting to a total sensible heat input of -43.8 kJ/s
(-150,000 Btu/hr). The total heat input to the kiln
may be calculated from equation 4:
Total heat input = 7,340 - 43.8
= 7,300 kJ/s (24.9 x 106 Btu/hr)
Because the sum of all feed rates to the kiln is 6.54
kg/s (51,900 Ib/hr),.
Total heat input/total mass input
= 7,300 * 6.54
= 1.120kJ/kg (480 Btu/lb)
Assuming 10 percent heat loss from the kiln, e.g., the
example test kiln is very long and, thus," is expected
to have a high heat loss, the ideal kiln temperature
may be estimated to be 1,200°K (1,70Q°F) from
Figure B-3. This ideal temperature must be
corrected to take into account the high heat capacity
92
-------
Figure B-3. Ideal temperature vs. total heat input to total mass input ratio and fractional heat loss.
2,500
2,000
CD
' 3
ra
cu
a
E
CD
1,500
1,000
- 1,600
- 1,400
a>
o.
0)
t-
1,200 •§
- 1,000
300
400 500 600
Total Heat Input/Total Mass Input (Btu/lb)
700
800
of the water in the combustion gas. All three input
streams contain water: 0.19 kg/s (1540 Ib/hr) in the
waste, 0.067 kg/s (530 Ib/hr) in the air, and 0.096
kg/s (760 Ib/hr) of steam. Thus, there is a total of
0.35 kg/s (2,800 Ib/hr) water input to the kiln, which is
5.4 percent of the total input mass flow. From Figure
B-4, at an ideal temperature of 1200°K (1700°F)
and 5.4 percent water, the actual temperature is
predicted to be 34° K (61 °F) lower than the ideal
temperature, or 1,170°K (1,640°F).
The ideal residence time may be estimated from
equation 1:
^ideal = (353 x 160 x 1)^(5.39 x 1,170) = 9.0 s
This may be corrected for water using Figure B-2.
For mmoisture/mair of 0.35/5.39 = 0.065. The ratio of
the actual to the ideal residence time is 0.88; thus the
estimated actual residence time is 7.9 s. The
volumetric flbwrate may be calculated from equation
2:
Volumetric Flow = 160 T 7.9
= 20.3 m3/s (43,000 acfm)
To carry but this analysis on the SCC, the procedure
is the sajme except that the mass and energy carried
over from the kiln must be considered. The total heat
leaving the kiln is the heat entering the kiln minus the
10 percent heat loss which is 7,300 - 0.1 x 7,300 =
6,570 kJ/s (23.2 x 1fj6 Btu/hr). However, 0.42 kg/s
(3,370 Btu/hr) of ash is removed from this stream
before it enters the SCC. From equation 8, the
sensible heat of the ash being removed at 1,170 K is
370 kJ/s (1.26 x 106 Btu/hr), so that the net heat
going from the kiln into the SCC is 6,200 kJ/s (21.2 x
106 Btu/hr).
The SCC has a volume of 113 m3 (4,000 cu ft), and
an inside surface area of 147 m2 (1,580 sq ft). It has
a refractory covering 0.21 m (8.2 in) thick with a
conductivity of 5.05 x 10"* kJ/s-m-°C (3.5 Btu
in/hr-sq ft-°F). In addition to the carryover from the
kiln, for the operating point of interest, the SCC has
four other input streams: waste, auxiliary fuel,
atomizing steam, and air. The feed rates for these
streams are 0.26 kg/s (2,060 Ib/hr) waste, 0.062 kg/s
(490 Ib/hr) fuel, 0.093 kg/s (738 Ib/hr) steam, and
3.16 kg/s (25,100 Ib/hr) air (including 0.04 kg/s [334
Ib/hr] water vapor in the air). The preheat
temperatures for all fresh streams are 289 °K (60 °F),
except for the steam, which is preheated to 450 °K
(350°F). The waste stream has a HHV of 23,300
93
-------
Figure B-4. Correction to Ideal temperature vs. Ideal temperature and water/total mass flow ratio.
Ideal Temperature (°K)
1000 1200 1400 1600
1800
500
400
0>
3 300
Q.
(D
B 200
i
£
(0
Q.
ID
100
-100
I
I
0%
200
0)
3
100
0)
a
-------
kJ/kg (10,000 Btu/lb), with 5.86 dry weight percent
hydrogen, 25.70 dry weight percent Cl, and no
moisture. The fuel stream has a HHV of 44,000 kJ/kg
(19,000 Btu/lb) with 12.65 dry weight percent
hydrogen, and no moisture.
Following the same method as for the kiln input
streams, HFAC is calculated as 0.4625 for the waste
and 1.1388 for the fuel from equation 7. From
equation 6, the LHVs are 21,900 kJ/kg (9,420 Btu/lb)
for the waste and 41,200 kJ/kg (17,700 Btu/lb) for the
fuel. From equation 5, the chemical heat inputs are
5,700 kJ/s (19.5 x 106 Btu/hr) for waste and 2,550
kJ/s (8.7 x 106 Btu/hr) for fuel for a total chemical
heat input of 8,250 kJ/s (28.2 x 106 Btu/hr). From
equation 8, the sensible heat of the fresh input
streams is -2.36 kJ/s (-8,100 Btu/hr) for waste,
-0.56 kJ/s (-1,910 Btu/lb) for fuel, +14.28 kJ/s
(48,800 Btu/lb) for steam, and -28.72 kJ/s (-98,200
Btu/lb) for air. Thus, the total sensible heat input,
including the carryover from the kiln, is 6,180 kJ/s
(21.1 x 106 Btu/hr). From equation 4, the total heat
input to the SCC is 14,400 kJ/s (49.2 x 1Q6 Btu/hr).
The total mass flow is 9.7 kg/s (77,000 Ib/hr), so the
total heat/total mass input is 1,480 kJ/kg (640 Btu/lb).
Because the SCC is much shorter than the kiln, a
smaller fractional heat loss is expected. Thus,
assuming 5 percent heat loss, the ideal afterburner
temperature is estimated to be 1,520°K (2,280°F).
The air, the steam, and the kiln effluent have a
combined 0.48 kg/s (3,800 Ib/hr) water, which is 4.9
percent of the total input mass flow. From Figure B-
4, the temperature correction is 50 8K (90 °F), and the
estimated actual temperature is 1,470°K (2,190°F).
The ideal residence time from equation 1 is 3.2 s
(using the combined air flows to the kiln and the
SCC), and the ratio of actual-to-ideal residence
time is 0.89. Thus, the estimated actual residence
time in the SCC is 2.8 s. The volumetric flow from
equation 2 is 40.4 m3/s (86,000 acfm).
Detailed energy and mass balance calculations were
performed for this example using the computer
program described in Appendix E. Results of the
calculations and correlations were compared with the
design calculations of the permit applicant in Table
B-3. The program, the correlations, and the design
calculations all showed excellent agreement in
calculating temperatures and flows. Thus, it can be
concluded that these correlations agree quite well
with the energy and mass balance program on which
they are based. It can also be concluded that this
construction permit application is based on
reasonable design calculations and that the
manufacturer's claims concerning temperatures and
flows are achievable.
The energy and mass balance program is the
preferred method for performing these calculations.
Although the correlations have been shown to be
viable, to use them can be tedious. Errors can result
from calculational mistakes, inaccurate graph
readings, or poor assumptions (such as the assumed
heat loss from each combustion chamber).
B.4 Air Pollution Control Equipment
Th3 two kinds of pollutants that emerge from
hazardous waste incinerators are gaseous pollutants
and particulate pollutants. Because hazardous wastes
are often highly chlorinated, the gaseous pollutant of
greatest concern is HCI. Flyash comprises most of
the particulate pollutants. Flyash particles emerging
from incinerators typically have mass mean diameters
of >10 urn. However, they have broad distributions;
thus, there may be a significant fraction of particles in
the submicron range. In addition, high concentrations
of toxic heavy metals tend to "be found in submicron
particles. Therefore, APCE for incinerators burning
metal-containing wastes should effectively remove
small particles.
Hazardous waste incineration systems generally
employ more than one type of pollution control device
to remove both particles and gases effectively. The
APCE must be properly designed, operated, and
maintained to achieve design performance
continuously under a variety of incinerator operating
conditions. The permit writer must, therefore, review
the proposed APCE design as presented in the permit
application. It should be assessed for engineering
soundness, and an estimate should be made whether
the APCE can achieve the performance expected in
the trial burn. Calculations should be made to verify
many of the system and operating parameters to
ensure their consistency and soundness.
Specifically, the APCE specifications should be
reviewed to ensure the following:
• Sufficient quench water is available to cool the flue
gas to the recommended APCE operating
temperature.
• Sufficient fan capacity is available to handle the
maximum expected gas flowrate.
• The system can meet the 180 mg/dscm particulate
performance standard for the expected particle
loading and size distribution.
• The system can meet the 99 percent Cl removal
performance standard for the expected total Cl
feed rate.
This section will present a brief description of most
types of APCE and provide the permit writer with
several tools to help verify expected system and
operating parameters and performance.
95
-------
co
05
Table B-2. Input Data for Energy and Mass Balance Example
Primary waste
Primary fuel
Secondary waste
Secondary fuel
Primary air
Secondary air
Secondary water
Primary water
Ash dropout
Proximate analysis
(as received) (percent) Heating Elemental analysis (dry percent)
Feed (higher)
rate Preheat Fixed asrecvd)
(Ib/h) (°F) carbon Volatiles Ash Moisture (Btu/lb) C H N S Ash O
8,330 60 4.42 23.12 53.99 18.47 3310 22.85 1.24 0.0 3.86 66.23 0.0
Q .
2,060 60 0.0 100.0 0.0 0.0 10,000 55.18 5.87 0.0 1.86 0.0 11.39
490 60 0.0 100.0 0.0 0.0 19,000 87.35 12.65 0.0 0.0 0.0 0.0
42,800 60
25,100 60
738 350
760 350
3,370
Design Specifications Primary Secondary
Refractory thickness (in) 8.2 8.2
Refractory conductivity [(Btu)(in)/(h)(ft2)(°F)] 5.7 3.5
Unit volume (ft3) 5,650 4,000
Refractory surface area (ft2) 3,440 1,580
Cooled surface area (fi2) 0 0
Cl
5.83
—
25.71
0.0
-------
B.4.1 Wet Systems
Wet APCE is predominant among existing
incinerators. Typical equipment that is used includes
quench chambers, scrubbers, and wet ESPs. Most
systems are designed for particulate control. The
capture of HCI also occurs because of the solubility
of the acid in water. The control efficiency for HCI
can be enhanced by adding a caustic solution to the
scrubbing water. Caustics such as NaOH or NaCOs
are also used to control the pH of water recirculated
to the wet scrubber. Control of pH requires 1.10 kg of
NaOH or 1.46 kg of CaCOa per kg HCI. Figure B-8
presents a layout of a typical wet control system.
Quench Chambers
The quencher often precedes the scrubber
equipment. Its function is to reduce the temperature
of the hot gases leaving the thermal equipment units
and to increase the humidity of the gases to the
saturation point. This action reduces water
evaporation in the downstream scrubbing equipment
and alleviates the potential problems associated with
particle generation in caustic scrubbers. Also, the
quencher facilitates particulate scrubbing by initiating
particulate agglomeration as well as protecting the
downstream equipment from high-temperature
damage. Because particulate scrubbing occurs in the
quencher, these units are also called spray
scrubbers. Designed as integral parts of a venturi
scrubber, some quenchers are located at the inlet of
the scrubber converging section.
A constant gas temperature at the quencher outlet
often signifies proper operation of the unit. This
temperature is typically maintained close to the
saturation temperature of the gas, 82 to 93°C (180 to
200°F). Often, the quench water is recirculated from
the sump back to the inlet to minimize water use.
However, even in closed loop systems, some amount
of water makeup is required to replace the amount
lost through evaporation. Optimum operation would
use only makeup water (about 50 to 80 percent of
evaporative loss) to minimize reentrainment of
particulate back into the gas stream. Quench water
requirements to achieve saturation temperature can
Table 8-3. Comparison of EER Energy and Mass Balance
Results with Permit Application Design
Calculations
Rotary kiln temp. (°F)
Flow (acfm)
SCO temp. (°F)
Flow (acfm)
EER Energy and
Mass Balance
Program Correlations
1,623. 1,640
41,821 43,000
2,218 2,190
85,742 86,000
Permit
Application
Design
Calculations
1,600
41,922
2,200
84,668
be calculated as follows:
18
MW.
DG
(p-Vo)
KG)
(9)
where:
MW = Quench water feed rate which yields
saturation (Ib/hr).
PH2O = Vapor pressure of moisture (psia)
(function of inlet gas temperature).
= DrV 9as molecular weight.
= Absolute pressure (psia).
MQ = Dry gas mass flowrate (Ib/hr).
Up to this quench feed water rate, both sensible and
evaporate cooling occur. Any additional quench feed
water cools through sensible heat transfer. Generally,
for quench/venturi scrubber applications, only 80
percent of the evaporate water less (FW) is
recommended for the quench chamber with a gas
temperature slightly above saturation (e.g., 93°C
[200° F]). The total water vapor mass flowrate leaving
the quench is:
Figure B-7. Schematic of incinerator for energy and mass balance example.
Waste Fuel Steam Air
11 11
Waste
Steam
Air
1
k
k
f
Kiln
^
r
Afterburner
L
f
Ash
k
97
-------
Figure B-8. Typical APCE schematic (wet system).
Process water
Hot
untreated
gas
TIC -Temperature indicator controller
LIC - Level indicator controller
FIC - Flow indicator controller
PI - Pressure indicator
Fl - Flow Indicator
AIC - Analysis (pH) indicator controller
Al - Analysis (Oz, FO, COz) indicator
To permitted landfill
or waste pond
FH.O(out) = MW + FH Q(in)
(10)
where:
= Mass flowrate of water vapor in
entering gas, (Ib/hr).
A regimented maintenance program for the quencher
should be followed to ensure that effective water
spray (unobstructed nozzles) is retained.
Several types of wet scrubbers are used in industry.
Despite their low mechanical efficiency, the adjustable
and fixed throat venturi scrubbers are most commonly
used for incinerator applications because of their high
particulate collection efficiency. Other scrubber
devices include packed bed (vertical and horizontal),
tray or plate, impingement, entrainment, mechanically
aided, and ionized scrubbers. They remove gaseous
pollutants through the mechanism of absorption.
Alkaline scrubbing solutions are often used to
increase the rate of mass transfer and to neutralize
acids.
Packed-Bed Scrubbers
Absorption removal efficiency for packed-bed
scrubbers can be described by the number of transfer
units attained by a device. Efficiency increases with
increasing number of transfer units. The number of
transfer units can be found from:
NTU = Z^-HTU (11)
where:
= Number of transfer units
= Scrubber length (m)
= Height of a transfer unit (m)
The number of transfer units increases, and, thus,
efficiency increases with increasing scrubber length.
The height of a transfer unit is generally determined
empirically for different packed-tower configurations.
The height of a transfer unit generally decreases,
and, thus, efficiency increases with increasing L/G
ratio, packing interfacial area, and gas diffusivity.
Venturi Scrubbers
Venturi scrubbers atomize water into small droplets
and then use the droplets to collect particles.
Efficiency generally increases with increasing L/G
ratio, throat velocity, and particle size. Particle
98
-------
collection efficiency in a venturi scrubber can be
estimated using the equation of Calvert (1972) (7):
Efficiency = 1 - exp[(QL/QG) x UG x F(Kp)]
where:
CL-
OG
UG
Kp
(12)
= Liquid flowrate (m3/s)
= Gas flow velocity (m3/s)
= Gas throat velocity (m/s)
= Inertial impaction parameter (a function of
particle size)
This equation and Figure 2-3 show that scrubber
efficiency is a function of the pressure drop across
the venturi, which can be estimated using the
following empirical equation (8):
.0.133.0.78
L
AP=-
1,270
where:
AP
VT
PG
AT
L
(13)
= Pressure drop in
= Throat velocity (fps)
= Gas density (Ib/cu ft)
= Area of throat (sq ft)
= L/G ratio (gal/1,000 cfm)
For a fixed gas flowrate and throat area, control of AP
inherently controls the amount of liquid or L/G ratio
required. Typically, the higher the AP, the greater the
efficiency. Some scrubbers at existing incinerators
operate with AP as high as 2.0 m H^O (80 in W.C.)
or higher. Venturi scrubber operation is optimum
when the AP is maintained relatively constant (<5
percent variation in AP), which can be achieved by
proper setting of the liquid flow and adjustment of the
throat when allowable.. Routine maintenance of the
nozzles and visual inspection of the critical parts of a
scrubber (e.g., throat) are important for the equipment
to maintain design performance.
Scrubbers in general can also be used for acid
emission control by adding caustic solution to the
spray water. Although venturi scrubbers can be used
to absorb HCI, the most commonly used absorbers
are the packed, tray, or spray towers. Good
absorption efficiency is primarily a function of L/G
distribution, alkaline concentration of scrubbing
solution, gas, water temperature, and gas residence
time (face velocity). For packed-bed scrubbers, the
packing depth (Z) is defined as follows (3):
where the constant 4.6 is determined by the natural
logarithm of the scrubbing efficiency (e.g., In 100/1
for 99 percent efficiency), ACFS is the actual cu ft/s
of the flue gas, P is the total pressure, and Kga is the
absorbing capacity of the scrubbing solution as
shown in Table B-4. From these data, it is evident
that when excessive C\2 is anticipated, a caustic
solution is necessary to absorb the free chlorine,
whereas HCI can effectively be scrubbed with water
because of its high solubility.
Table B-4. Typical Values of Kga (B-3)
Gas
CI2
HCI
SO2
SO2
CI2
Scrubbing Kga,
Solution (lb/mole)/(in-H2O-cu ft-sec)
NaOH
H2O
NaOH
H20
H2O
1.4 x 10-5
1.1 X TO'5
4.8 x 10-6
2.2 x 10'7
9.5 x 10-8
The packing material and tray and plate arrangement
also provide the mechanism for particulate collection
utilizing the hydraulic energy of the liquid and mass
transfer of the solids from the gas into the scrubbing
liquid. As in the quencher and venturi, the scrubbing
water or liquor is recirculated. This process requires
careful monitoring of the solids and pH level of the
scrubbing solution to maintain equipment design
performance. Relatively constant pressure drop
across these units is also indicative of good
operation. Because localized plugging may occur in
these units, routine maintenance and inspection are
necessary.
All scrubbers are equipped with separators or
demisters. These are passive units which are
designed to trap water droplets entrained with the flue
gas prior to the stack. Although important for system
design evaluation, this equipment requires little or,no
consideration in the operating permit once its design
has demonstrated compliance with the particulate
emission standard.
Additional wet particulate control devices are
electrically-induced systems such as the IWSs and
wet ESPs. These units compensate for the lower
kinetic energy of high-pressure-drop systems by
ionizing the gas stream. Performance of these units is
strictly a function of secondary voltage and electrical
current, gas flowrate, and scrubber water flowrate.
Ionized wet scrubbers combine the principle of
electrostatic particle charging with packed-bed
scrubbing technology. A constant DC voltage is
applied in the ionizing section. Because wetted
positively charged plates are continuously flushed, the
buildup of a resistive layer is prevented. The flue gas
leaving the ionizing section is further scrubbed in a
packed-bed. The efficiency of IWSs is relatively
insensitive to particulate resistivity, but control of
constant voltage and packed-bed scrubbing water
flowrate is required.
99
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B.4.2 Dry Systems
The most commonly used dry participate collection
systems are mechanical collectors, ESPs, and FFs.
Although these alternative control devices are
currently less popular than their counterpart wet
systems for complete emission control, these
alternative control devices may be the systems of
choice for future incinerator facilities because they
require reduced residue handling and disposal
requirements. Several of these technologies are
currently used in combination with wet technologies.
Mechanical Collectors
Mechanical collectors remove particles through the
forces of inertia and gravity. Cyclones are the most
common type of mechanical collectors. In a cyclone,
the air flow impinges tangentially onto the inner wall
of a cylinder. Particles strike the cylinder wall and
then slide down into a hopper, where they are
removed. The most important operating parameters
are particle size, gas flowrate, and cyclone design
geometry. Cyclone efficiency can be estimated using
the equation of Lapple (1951) (9):
Efficiency .=
(14)
where:
K
V
V
p
dp
1+ K /V AT
^ P/ P
= Cyclone geometry factor (m)
= Gas viscosity (kg/m-s)
= Inlet gas velocity (m/s)
= Particle density (kg/m3)
= Particle diameter (m)
Cyclones are not highly efficient (e.g., <90 percent
control), but they are inexpensive, and, thus, are
often used as methods of pretreatment before other
APCE.
Electrostatic Precipltators
Electrostatic precipitators remove particles by
charging them and then collecting them on oppositely
charged plates. Plates are periodically rapped to
remove the collected particles. The ESPs are highly
efficient, even for submicron particles. For example,
typical ESP efficiency might exceed 99 percent for 5
mm particles, dip to 95 percent for 1 mm particles,
and again increase to above 99 percent for 0.1 mm
particles. Submicron particle collection efficiency is
high because the mechanism of Brownian diffusion
increases the ability of submicron particles to migrate
to collection plates. Collection efficiency increases
with increasing plate area and applied voltage and
decreases with increasing gas flowrate. ESP
efficiency can be predicted using the Deutsch
equation:
Efficiency
where:)
= 1 — exp(
-AW\
~Q~J
(15)
A = Plate area (m2)
W = Particle drift velocity (m/s) (a Junction of
applied voltage and particle size)
Q = Gas flowrate (m3/s)
Dry ESPs are much more efficient in capturing small
size particles (<10 pm) than cyclones. Contrary to
wet ESPs, however, the collection efficiency is also a
function of particle resistivity, which, in turn, will vary
with waste type burned as well as gas temperature
and acid concentration in the flue gas.
Fabric Filters
Filters remove particles by collecting them on filter
fibers or on previously collected particles. The most
commonly used types are fabric filters (FFs), in which
gas flows through parallel arrangements of filter bags.
Bags are periodically cleaned by shaking or reversing
the air flow. Well-maintained baghbuses are highly
efficient, but problems may arise if the gas stream
has high moisture or acid content or if holes or cracks
develop in the bags from manufacturing flaws or
aging.
Efficiency increases with increasing pressure drop
and decreases with increasing air-to-cloth ratio.
Fabric filters often have collection efficiencies in
excess of 99 percent, exclusive of water vapor and
condensibles. The type of material used for the bags
varies with such factors as temperature, humidity, and
chemical characteristics of the dust and gases.
Maximum gas temperature inlet is typically 260 °C
(500 °F), although it varies according to the type of
material. Steady pressure drop across the FF is
indicative of good operation with the minimum AP
defined by the manufacturer for operation with clean
bags. Careful temperature .control is necessary to
minimize water vapor condensation, blinding, and
corrosion.
Spray Drying Absorbers
Acid absorption can also be achieved in the gas
phase using spray drying absorbers (SDAs). In this
process, a solution, slurry, or paste containing an
absorbent is atomized and injected into the flue gas.
The amount of water injected is not sufficient to lower
the temperature to the dew point, and the atomized
material is transformed into a dry, free-flowing
product. The chemical reaction between HCI and the
caustic absorbent occurs in the gas phasa-in contrast
to wet scrubbing devices. Thus, particulate control is
necessary downstream of the dry scrubber to prevent
the escape of the caustic and salts to the stack.
100
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B.5 Measurement Techniques and Safety
Interlocks
The measurement techniques should be reviewed to
verify that appropriate QA/QC requirements are met
as described in Reference 10. Special attention
should be paid to critical measurements such as
temperature and gas concentrations.
Thermocouple placements should be so marked that
the temperatures that are being measured and
reported are clearly indicated. Each thermocouple
should be described in the application as to type,
sheath or shielding material, sheath or shielding
diameter, the proximity and visibility of any flames or
cooled surfaces, and. the typical condition of the
thermocouple during operation, e.g., clean,
blackened, or slagged. This information is important
because the temperature a thermocouple measures is
not truly the gas, temperature but is an equilibrium
temperature based on radiative and convective heat
transfer between the thermocouple and its
surroundings. When radiative heat transfer is
significant, the thermocouple reading may be too high
because radiative heat,is transferred from the flame,
or it may be too low because the radiative heat is
transferred to cooled surfaces or incinerator walls.
Radiation becomes more significant for high
temperatures, large thermocouple sheaths, blackened
thermocouple sheaths, and increased visibility of the
flame or cooled surfaces. If these conditions change
drastically from those of the trial burn because of
change in operation, thermocouple deterioration, or
thermocouple, replacement, the permit limit
temperature as measured by the thermocouple during
the trial burn may no longer be the conservative level.
Thermocouple placement is discussed in the
Engineering Handbook for Hazardous Waste
Incineration (SW-889), Briefly, the thermocouple
must be placed in the center of a turbulent zone of
the gas stream exiting the combustion chamber. It is
typically placed as close to the center of the gas flow
as possible. Shielding must be provided to prevent
direct impingement of radiation from the flame and
from glowing portions of the wall onto the
thermocouple housing.
Gas concentration measurements can be made on a
wet or on a dry basis. Concentrations measured on a
wet basis can be substantially lower than those
measured on a dry basis, especially if the
measurements are taken from the stack gas, which is
typically saturated with water. The permit writer
should be aware of the basis on which gas
concentrations are reported and should take this into
account in any calculations such as the energy and
mass balance calculations described elsewhere in
these appendices.
Automatic waste feed cutoff is required when permit
limits for group A and group B parameters are
exceeded. The permit writer should examine the
schematic diagrams for the instrumentation and
control systems to verify that the safety interlocks for
waste feed cutoff are tied to the appropriate
monitoring devices.
B.6 Special Wastes and Similar Systems
The guidelines for evaluating incinerator design and
setting permit limits outlined in this handbook are not
universally applicable. For example, a waste with a
high content of toxic metals may warrant special
consideration. Some toxic metals may vaporize in
high-temperature incinerators and condense on the
surface of fine particles. If the waste has a high
concentration of toxic metals, the permit writer may
want to set a maximum and a minimum combustion
chamber temperature limit and may want the trial
burn to meet fine particulate as well as total
particulate emissions standards. Specific guidance on
toxic metals from incinerators will be developed by
the EPA (see Appendix A).
In evaluating incinerator designs, the permit writer
should take into account the design and performance
of similar incinerator systems. Such design >and
performance data may be accessed through the
HWCTDB that is maintained at the ORNL.
B.7 References
1. Vogel, G.A., et al. Incinerator and Cement Kiln
Capacity for Hazardous Waste Treatment. EPA-
600/2-86/093 (NTIS PB87-11089C/AS). 1987.
2. Kiang, Y.H. and A.A. Metry. Hazardous Waste
Processing Technology. .Ann Arbor, Michigan:
Ann Arbor Science Publishers. 1982.
3. Bonner, T.A. Engineering Handbook for
Hazardous Waste Incineration. EPA-SW-889
(NTIS PB81-248163). 1981.
4. Seeker, W.R., W.D. Clark, and G.S. Samuelsen.
The Influence of Scale and Fuel Properties on
Fuel Oil Atomizer Properties. Presented at: The
Joint EPA/EPRI Symposium on Stationary
Combustion NOX Control, Dallas, Texas. 1982.
5. U.S. Bureau of Mines. Technical Paper 384.
1927.
6. Li, K.W. Applications of Khodorov's and Li's
Entrapment Equations to Rotary Coke Calciners.
AlChEJ. 20:1017. 1974.
101
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7. Calvert, S., D. Goldschmid, and D. Mehta. 10. Midwest Research Institute. Hazardous Waste
Scrubber Handbook. U.S. Department of Incineration Measurement Guidance Manual.
Commerce. NTIS PB-213016. 1972. Prepared for U.S. Environmental Protection
3-
9. Lapple, C.E. Processes Use Many Collector
Types. Chemical Engineering. 58:144. 1951.
102
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APPENDIX C
Time and Temperature Dependency of the Destruction Process
Incineration is a high-temperature oxidation reaction
process governed by chemical reaction equilibrium
and kinetics. The basic reaction equilibrium parameter
is the equilibrium constant at constant pressure
expressed mathematically as follows:
(1)
where,
Kp(T) = exp(-AE/RT)
Where Ppj and Prj are the partial pressures of
products and reactants, respectively, and ai and pi
are the chemical reaction constants. The equilibrium
constant Kp is an exponential function of temperature
(T) and free energy (E) of each reaction component.
In all practical combustion systems, the chemical
reaction involves several intermediate reaction
products that exist for a limited amount of time. This
time dependency is taken into consideration by
chemical reaction kinetics and is expressed as
follows:
(2)
where A and E are the organic compound Arrhenius
rate constants (determined empirically using
laboratory thermal decomposition devices), R is the
universal gas constant, T and Ax are temperature and
time available at that temperature, CA and CQ are the
concentrations of the compound at time T, and t = 0,
respectively.
These expressions indicate that temperature is the
primary parameter in driving reactions to equilibrium
and the predominant force of the reaction rate for all
chemical compounds. High temperature is also
necessary to provide the thermal energy to heat,
vaporize, and devolatize organic compounds trapped
in the waste feed. Heating, vaporization, and
devolatilization are necessary first steps for
combustion of fuels and destruction and oxidation of
all toxic organic compounds. Thus, temperature in
each thermal chamber is the primary control
parameter needed to ensure high destruction
efficiency (DE) of organics in hazardous waste
incinerators. The temperature in each chamber
should be controlled to the demonstrated minimum.
The kinetic rate expression suggests that for organics
fed in the PCC, the DE (1 - CA/CQ) is the result of a
series of decomposition reactions in the PCC and
downstream combustion chambers as illustrated by
the following expression:
C.
c~
i-i
1=1
(3)
where Cn is the concentration of the compound at the
exit of the n
-------
This equation can be used to make approximate estimate of 2.6 x 10'6 s~1 can be used for this
estimates of gas phase decomposition of the purpose if a better value is not available.
compound under well-mixed conditions. An empirical
104
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APPENDIX D
Designating Principal Organic Hazardous Constituents
Barry Dellinger and Phillip H. Taylor
University of Dayton Research Institute
Dayton, Ohio
(Duplicated in this document without change)
D.1 Background
The destruction efficiency (DE) of POHCs is
dominated by the temperature, time, and fuel/air
stoichiometry (excess air) experienced by the POHCs
in the high temperature zones of incinerators.
Calculations and experimental observations have
shown that the emissions of undestroyed, residual
POHCs are kinetically (reaction rate), not
thermodynamically controlled [Tsang and Shaub
(1982), Trenholm, et al (1984)]. Thus, determination
of the exact time, temperature, and stoichiometry
history of all the molecules in an incinerator is
necessary to determine the absolute DE of a POHC.
This type of information is, of course, not currently
available. However, sufficient information is available
to estimate the relative DE of potential POHCs.
Simple conceptual and more complex models suggest
that the gas-phase residence time and temperature
in the post-flame or thermal zones of incinerators
control the relative emissions of most POHCs
[Dellinger, et al (1986), Clark, et al (1984)]. The basic
reason behind this is that all molecules entering the
flame zone of an incinerator are essentially destroyed
and only the small fraction escaping the flame zone
may be emitted from the facility. Various flame zone
"failure modes" exist which may cause residual
POHCs to be emitted. Once in the post-flame zone,
gas-phase thermal decomposition kinetics control
the rate of POHC destruction and PIC formation and
destruction.
If all POHCs in a given waste stream in a given
incinerator are volatilized at nearly the same rate,
they will experience the same post-flame gas-
phase residence time, temperature, and stoichiometry
history. This means that the gas-phase thermal
stability of the POHCs (as determined under a
standardized set of conditions) may be used to
predict their relative incinerability. The temperature for
99% destruction at 2.0 seconds gas-phase
residence time, [T9g(2)(°C)], is one method of
ranking the thermal stability of POHCs. Other
residence times or temperatures may be used to
develop this ranking. However, laboratory data
indicate that although absolute POHC DEs are
dependent upon time and temperature, the relative
DEs, i.e., incinerability ranking, are relatively
insensitive to these parameters [Dellinger, et ..al
(1984), Graham, et al (1986), Taylor and Dellinger
(1988)]. On the other hand, stoichiometry has been
shown to be a major variable in determining relative
stability [Graham, et al (1986) Taylor and Dellinger
(1988)].
Theoretical considerations suggest that oxygen-
starved pathways through the incinerator are
responsible for most POHC and PIC emissions. Even
though the facility may be operating under nominally
excess air conditions, poor mixing will result in
oxygen-deficient pockets where the rate of POHC
destruction is low and PIC formation is favored.
Consequently, it is believed that gas-phase thermal
stability under sub-stoichiometric oxygen conditions
is an effective predictor of POHC relative
incinerability.
A recent study compared the incinerability predictions
of several proposed POHC ranking methods with
results of 10 pilot- or full-scale test burns
[Dellinger, et al (1986)]. The ranking methods
included heat of combustion, autoignition
temperature, ignition delay time, flame failure modes,
theoretical flame mode kinetics, thermal stability of
pure compounds under excess air conditions, thermal
stability of mixtures under oxidative conditions, and
the thermal stability of mixtures under oxygen-
starved conditions. Correlations of the prediction of
the rankings with field results were poor except for
thermal stability of mixtures under oxygen-starved
conditions. Although the laboratory data base used to
predict full-scale POHC DREs was very limited,
statistically significant correlations in 7 of 10 cases
105
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were observed using this ranking approach. The
results of this comparison along with theoretical
considerations suggest that this type of thermal
stability ranking should be used to replace the
previously recommended heat of combustion index.
D.2 Construction of the Ranking
Tables
-------
the least stable POHC for which 99.99% ORE can be
demonstrated.
Another alternative approach involves the use of the
incinerability class divisions. In this approach, one can
demonstrate 99.99% ORE of a group of
experimentally evaluated POHCs within an
incinerability class and receive approval to burn all
other POHCs within and below that class. For
example, if 99.99% ORE can be demonstrated for
chloromethane, acetonitrile, and chlorobenzene, the
facility would be allowed to burn any Appendix VIII
compound. As a second example, if 99.99% ORE is
demonstrated for hexachlorobutadiene, methyl ethyl
ketone, and cresol, the facility would only be allowed
to burn compounds ranked in class 3 or lower. Since
the ranking is subject to semi-annual revision, it is
suggested that the ranking which is current when the
trial burn is approved be used throughout the permit
process unless a change in POHC selection is
mutually agreed upon by all interested parties. A
summary of the ranking by classes is given in Table
D-3.
It should be noted that reformation of a POHC from
its own decomposition products or formation of the
POHC as a PIC from another waste feed component
is generally not included as a factor in this ranking.
Significantly, laboratory studies have shown that both
POHC reformation and PIC formation can affect
observed DEs [Taylor and Dellinger (1988), Dellinger,
et al (1988)]. In some instances, it is felt that the
laboratory determination of Tgg(2)(°C) were
unavoidably affected by POHC reformation, (e.g.,
formation of chloromethane from chlorine atom attack
on methane). When it was judged that POHC
reformation was inevitable from almost any waste,
reformation was included in the thermal stability
ranking. However, some deviation from the predicted
ranking may be expected due to PIC formation. As
additional studies concerning PICs are completed,
guidelines for evaluating the role of PIC formation will
be furnished.
The extensive testing conducted by UDRI has shown
that the ranking of most of the compounds is
relatively insensitive to composition of the waste
mixture. However, a few notable exceptions have
been observed in initial tests. This includes aniline
derivatives and PNAs in general. Somewhat lesser
variability has been observed for benzene, toluene,
and pyridine, which were judged to be sufficiently
constant to be included as experimentally evaluated
compounds. Consequently, it is suggested that the
waste composition be carefully considered before
these compounds are selected as POHCs. Benzene,
toluene, and PNAs are expected to be particularly
prone to formation as PICs in full-scale incinerations
and observed DREs may be significantly affected.
Effects of PIC formation may be minimized by feeding
the POHC at a sufficiently high concentration.
Finally, it should be noted that no rankings are given
for PCBs which are listed as N.O.S. in Appendix VIII.
An estimate of the stability of individual PCB
congeners may be made by assuming that the
congener is slightly less stable than the chlorinated
benzene corresponding to the least chlorinated ring in
the PCB congener of interest. This means, for
example, that dichlorobenzene would be a suitable
incineration surrogate for 2,2',3,3',4-
pentachlorobiphenyl, monochlorobenzene would be a
suitable incineration surrogate for 3,3',4,5-
tetrachlorobiphenyl and pentachlorobenzene would be
a surrogate for decachlorobiphenyl. As suitable
experimental data is generated, thermal stability data
on PCBs will be furnished in the updated ranking.
Although not currently listed specifically on the
Appendix VIII list, the incinerability of chlorinated
dibenzo-p-dioxin and dibenzofuran isomers are of
intense interest. As further testing proceeds, we plan
to furnish stability data on these important
compounds.
D.4 References
1. W. Tsang and W. Shaub. Chemical Process in
the Incineration of Hazardous Materials,
Detoxification of Hazardous Waste. J. Exner, Ed.
Ann Arbor. 1982, pp. 41-59.
2. A. Trenholm, P. Gorman, and G. Jungelaus.
Performance Evaluation of Full-Scale
Incineration. MRI Report Under EPA Contract
68-02-3177. 1984.
3. B. Dellinger, W. Rubey, D. Hall, and J. Graham.
Hazardous Waste and Hazardous Materials, 3,
No. 2, 1986, pp. 139-150.
4. W. Clark, M. Heap, W. Richter, and W. Seeker,
The Prediction of Liquid Injection Hazardous
Waste Incinerator Performance. ASME AlChE
22nd National Heat Transfer Conference. 1984.
5. B. Dellinger, J. Torres, W. Rubey, D. Hall, J.
Graham, and R. Carnes. Hazardous Waste and
Hazardous Materials, 1, No. 2. 1984. pp. 137-
157.
6. J. Graham, D. Hall, and B. Dellinger. Environ. Sci.
Technol. 20, No. 7. 1986, pp. 703-710.
7. B. Dellinger, M. Graham, and D. Tirey.
Hazardous Waste and Hazardous Materials, 3,
No. 3, 1986. pp. 293-307.
8. P.H. Taylor and B. Dellinger. Thermal
Degradation Characteristics of Chloromethane
Mixtures. Environ. Sci. Technol., Vol. 22,. No. 4,
p. 438. 1988.
k
107
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9. P.M. Taylor and J.F. Chadbourne. Sulfur
Hexafluoride as a Surrogate for Monitoring
Hazardous Waste Incinerator Performance.
Journal of the Air Pollution Control Association,
Vol. 37, No. 6. p. 729. 1987.
10. B. Dellinger, D.A. Tirey, P.M. Taylor, J. Pan, and
C.C. Lee. Products of Incomplete Combustion
from the High Temperature Pyrolysis of
Chlorinated Methanes. 3rd Chemical Congress of
North America and the 195th National Meeting of
the American Chemical Society, Division of
Environmental Chemistry Preprints, Vol. 28, No.
1. p. 81. Toronto, Ontario, Canada. 1988.
108
I
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index
Principal Hazardous Organic Constituent Rank
CLASS 1
CYANOGEN (ETHANEDINITRILE) 1
HYDROGEN CYANIDE {HYDROCYANIC ACID} [2] 2
BENZENE [2] 3
SULFUR HEXAFLUORIDE [3] 4
NAPHTHALENE [2] 5
FLUORANTHENE{BENZO[j,k]FLUORENE} 6
BENZO[j]FLUORANTHENE {7,8-BENZOFLUORANTHENE} 7
BENZO[b]FLUORANTHENE {2,3-BENZOFLUORANTHENE} 8
BENZANTHRACENE (1,2-) (BENZ[a]ANTHRACENE} 9
CHRYSENE {1,2-BENZPHENANTHRENE} 10
BENZO[a]PYRENE {1,2-BENZOPYRENE} 11
DIBENZ[a,h]ANTHRACENE {1,2,5,6-DIBENZANTHRACENE} 12
INDENO(1,2,3-cd)PYRENE {1,10-(1,2-PHENYLENE)PYRENE} 13
DIBENZO[a,hJPYRENE {1,2,5,6-DIBENZOPYRENE} 14
DIBENZO[a,i]PYRENE{1,2,7,8-DIBENZOPYRENE} 15
DIBENZO[a,e]PYRENE {1,2,4,5-DIBENZOPYRENE} 16
CYANOGEN CHLORIDE {CHLORINE CYANIDE} 17-18
ACETONITRILE {ETHANENITRILE} [2] 17-18
CHLOROBENZENE [2] 19
ACRYLONITRILE {2-PROPENENITRILE} [2] 20
DICHLOROBENZENE {1,4-DICHLOROBENZENE} 21-22
CHLORONAPHTHALENE (1-) [2] 21-22
CYANOGEN BROMIDE {BROMINE CYANIDE} 23-24
DICHLOROBENZENE {1,2-DICHLOROBENZENE} [2] 23-24
DICHLOROBENZENE {1,3-DlCHLOROBENZENE} [2] 25
TRICHLOROBENZENE (1,3,5-TRICHLOROBENZENE) [2] [4] 26-27
TRICHLOROBENZENE (1,2,4-TRICHLOROBENZENE) [2] 26-27
TETRACHLOROBENZENE (1,2,3,5-TETRACHLOROBENZENE) [2] [4] 20
CHLOROMETHANE {METHYL CHLORIDE} [2] 29-30
TETRACHLOROBENZENE (1,2,4,5-TETRACHLOROBENZENE) 29-30
PENTACHLOROBENZENE [2] 31-33
HEXACHLOROBENZENE [2] 31-33
BROMOMETHANE {METHYL BROMIDE} [2] 31-33
TETRACHLORODIBENZO-p-DIOXIN (2,3,7,8-) {TCDD} 34
CLASS 2
TOLUENE {METHYLBENZENE} [2] 35
TETRACHLOROETHENE [2] 36
CHLOROANILINE {CHLOROBENZENAMINE} 37
DDE{1,1-DICHLORO-2,2-BIS(4-CHLOROPHENYLETHYLENE} 38
FORMIC ACID {METHANOIC ACID} 39-40
PHOSGENE {CARBONYL CHLORIDE} 39-40
TRICHLOROETHENE [2] 41
DIPHENYLAMINE {N-PHENYLBENZENAMINE} 42-44
DICHLOROETHENE (1,1-) [2] 42-44
FLUOROACETIC ACID 42-44
DIMETHYLBENZ[aJANTHRACENE (7,12-) 45
ANILINE {BENZENAMINE} 46-50
FORMALDEHYDE {METHYLENE OXIDE} 46-50
MALONONITRILE {PROPANEDINITRILE} 46-50
METHYL CHLOROCARBONATE {CARBONOCHLORIDIC ACID, METHYL ESTER} 46-50
109
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
METHYL ISOCYANATE (METHYLCARBYLAMINE) 46-50
AMINOBIPHENYL (4-) {[1,1'-BIPHENYL]-4-AMINE} 51
NAPHTHYLAMINE (1 -) 52-53
NAPHTHYLAMINE (2-) 52-53
D1CHLOROETHENE (trans-1,2-) [2] 54
FLUOROACETAMIDE (2-) 55-56
PROPYN-1 -OL (2-) (PROPARGYL ALCOHOL} 55-56
PHENYLENEDIAMINE (1,4) {BENZENEDIAMINE} 57-59
PHENYLENEDIAMINE (1,2-) {BENZENEDIAMINE} 57-59
PHENYLENEDIAMINE (1,3-) {BENZENEDIAMINE} 57-59
BENZIDINE{[1,1'-BIPHENYL]-4,4'DIAMINE} 60-64
ACRYLAMIDE {2-PROPENAMIDE} 60-64
DIMETHYLPHENETHYLAMINE (alpha, alpha-) 60-64
METHYL METHACRYLATE (2-PROPENOIC ACID, 2-METHYL-, METHYL ESTER} 60-64
VINYL CHLORIDE (CHLOROETHENE) 60-64
DICHLOROMETHANE {METHYLENE CHLORIDE} [2] 65-66
METHACRYLONITRILE {2-METHYL-2-PROPENENITRILE} [2] 65-6 6
DICHLOROBENZIDINE (3,3'-) 67
METHYLCHOLANTHRENE (3-) 68
TOLUENEDIAMINE (2,6-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (1,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (2,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (1,3-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3,5-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3,4-) {DIAMINOTOLUENE} 69-77
CHLORO-1,3-BUTADIENE (2-) {CHLOROPRENE} 69-77
PRONAMIDE {3,5-DICHLORO-N-[1,1-DIMETHYL-2-PROPYNYL] BENZAMIDE} 69-77
ACETYLAMINOFLUORENE (2-) {ACETAMIDE,N-[9H-FLUOREN-2-YL]-} 69-77
CLASS 3
DIMETHYLBENZIDINE (3,3'-) 78
n-PROPYLAMINE{1-PROPANAMINE} 79
PYRIDINE [2] 80
PICOLINE (2-) {PYRIDINE, 2-METHYL-} 81-84
DICHLOROPROPENE (1,1-) [2] 81-84
THIOACETAMIDE {ETHANETHIOAMIDE} 81-84
I^-TRICHLORO-I.I^-TRIFLUOROETHANE [2] [3] 81-84
BENZ[c]ACRIDINE {3,4-BENZACRIDINE} 85-88
DICHLORODIFLUOROMETHANE [2] 85-88
ACETOPHENONE {ETHANONE, 1-PHENYL-} [2] 85-88
TRICHLOROFLUOROMETHANE [2] 85-88
DICHLOROPROPENE (trans-1,2-) 89-91
ETHYL CYANIDE {PROPIONITRILE} [2] 89-91
BENZOQUINONE {1,4-CYCLOHEXADIENEDIONE} 89-91
DIBENZ[a,h]ACRIDINE {1,2,5,6-DIBENZACRIDINE} 92-97
DIBENZ[a,j]ACRIDINE {1,2,7,8-DIBENZACRIDINE} 92-97
HEXACHLOROBUTADIENE (trans-1,3) [2] 92-97
NAPHTHOQUINONE (1,4-) {1,4-NAPHTHALENEDIONE} 92-97
DIMETHYL PHTHALATE [2] 92-97
ACETYL CHLORIDE {ETHANOYL CHLORIDE} [2] 92-97
ACETONYLBENZYL-4-HYDROXYCOUMARIN (3-alpha-) {WARFARIN} 98-99
MALEIC ANHYDRIDE {2,5-FURANDIONE} 98-99
110
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
PHENOL (HYDROXYBENZENE) 100-101
DIBENZO[c,g]CARBAZOLE (7H-) {3,4,5,6-DIBENZCARBAZOLE} 100-101
CHLOROPHENOL (2-) 102
CRESOL (1,3-) {METHYLPHENOL} 103
CRESOL (1,4-) {METHYLPHENOL} [2] 104-105
CRESOL (1,2-) {METHYLPHENOL} 1 04-1 05
ACROLEIN {2-PROPENAL} 106-107
DIHYDROXY-ALPHA-[METHYLAMINO]METHYL BENZYL ALCOHOL (3,4-) 106-107
METHYL ETHYL KETONE {2-BUTANONE} [2] 108-109
DIETHYLSTILBESTEROL 108-109
BENZENETHIOL {THIOPHENOL} [2] 110
RESORCINOL {1,3-BENZENEDIOL} 111
ISOBUTYL ALCOHOL {2-METHYL-1-PROPANOL} [2] 112
CROTONALDEHYDE {2-BUTENAL} [2] 113-115
DICHLOROPHENOL (2,4-) 113-115
DICHLOROPHENOL (2,6-) 113-115
METHYLACTONITRILE (2-) {PROPANENITRILE.2-HYDROXY-2-METHYL} 116-118
ALLYL ALCOHOL {2-PROPEN-1 -OL} 116-118
CHLOROCRESOL {4-CHLORO-3-METHYLPHENOL} 116-118
DIMETHYLPHENOL (2,4-) 119
CLASS 4
CHLOROPROPENE 3-{ALLYL CHLORIDE} [2] 120
DICHLOROPROPENE (cis-1,3-) 121-125
DICHLOROPROPENE (trans-1,3-) 121-125
TETRACHLOROETHANE (1,1,2,2-) [2] 1 21-1 25
TRICHLOROPHENOL (2,4,5-) 121-125
TRICHLOROPHENOL (2,4,6-) 121-125
CHLOROETHANE (ETHYL CHLORIDE) [4] [5] 126
DICHLOROPROPENE (2,3-) 127-130
HYDRAZINE (DIAMINE) [5] 127-130
BENZYL CHLORIDE {CHLOROMETHYLBENZENE} [2] 127-130
DIBROMOMETHANE {METHYLENE BROMIDE} [2] 127-1 30
DICHLOROETHANE (1,2-) [2] 131
MUSTARD GAS {bis[2-CHLOROETHYL]-SULFIDE} 132-1 34
NITROGEN MUSTARD 132-134
N,N-BIS(2-CHLOROETHYL)2-NAPHTHYLAMINE {CHLORNAPHAZINE} 1 32-1 34
DICHLOROPROPENE (3,3-) 135
DICHLORO-2-BUTENE (1,4-) 1 36-1 40
TETRACHLOROPHENOL (2,3,4,6-) 136-140
TETRACHLOROMETHANE {CARBONTETRACHLORIDE} [2] 136-140
BROMOACETONE {1-BROMO-2-PROPANONE} 136-1 40
HEXACHLOROPHENE {2,2'-METHYLENEbis[3,4,6-TRICHLOROPHENOL]} 136-1 40
DIOXANE (1,4-) {1,4-DIETHYLENE OXIDE} [2] 141
CHLORAMBUCIL 142
NITROBENZENE [2] 143
CHLOROPROPIONITRILE (3-) {3-CHLOROPROPANENITRILE} [2] 1 43-1 44
DICHLORO-2-PROPANOL(1,1-) 145-146
ODD {DICHLORODIPHENYLDICHLOROETHANE} 1 45-1 46
DICHLORO-2-PROPANOL (1,3-) 147
PHTHALIC ANHYDRIDE {1,2-BENZENEDICARBOXYLIC ACID ANHYDRIDE} 148-1 50
METHYL PARATHION 1 48-1 50
111
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued) ' •
Principal Hazardous Organic Constituent • :- Rank •'•-'•
NITROPHENOL (4-) . , , 148-150
CHLORODIFLUOROMETHANE [2] [4] 151-153
PENTACHLOROPHENOL , ! 15lr153
HEXACHLOROCYCLOHEXANE {LINDANE} [2] 151-153
DICHLOROFLUOROMETHANE [2] [4] 154-157
DINITROBENZENE (1,3-) . 154-157
NITROANILINE{4-NITROBENZENAMINE} 154-157
PENTACHLOROETHANE [2] 154-157
DINITROBENZENE (1,4-) . 158-161
DINITROBENZENE (1,2-) 158-161
TRICHLOROETHANE (1,1,2-) [2] 158-161
TRICHLOROMETHANE {CHLOROFORM} [2] 158-161
DIELDRIN .•.•••••-••••••• 162-164.
ISODRIN 163-1,6.4
ALDRIN : . 162-164
DICHLOROPROPANE (1,3-) (5] i65
NITROTOLUIDINE (5-) {BENZENAMINE.2-METHYL-5-NITRO-} , 1,66-167
CHLOROACETALDEHYDE 166-167
TRICHLOROPROPANE (1,2,3-) [2] 168-173
DINITROTOLUENE (2,4-) 168-173,
DINITROTOLUENE (2,6-) .168-173
HEXACHLOROCYCLOPENTADIENE . 168-173
BENZAL CHLORIDE {ALPHA, ALPHA-DICHLOROTOLUENE} (2] 168-173
DICHLORO-1-PROPANOL(2,3-) 168-1.73
ETHYLENE OXIDE {OX1RANE} f5] 174,
DICHLOROETHANE(1,1-) (ETHYLIDENE DICHLORIDE} [5] 175-178
DIMETHYLCARBAMOYLCHLORIDE , 175-178,
GLYCIDYALDEHYDE{1-PROPANOL-2,3-EPOXY} 175-178
DDT{DICHLORODIPHENYLTRICHLOROETHANE) . . . . 175-1,78
DICHLOROPROPANE (1,2-) (PROPYLENE DICHLORIDE} (5} ...,.'.' 179
AURAMINE 180-181
HEPTACHLOR '.,. . 180-181
DICHLOROPROPANE (1,1-) [5] 182
CHLORO-2,3-EPOXYPROPANE(1-) {OXIRANE.2-CHLOROMETHYL-} 183-186
DINITROPHENOL (2,4-) 183.-186
bis(2-CHLOROETHYL)ETHER [2] 183-186
TRINITROBENZENE{1,3,5-TRINITROBENZENE} 183-186
BUTYL-4,6-DINITROPHENOL (2-sec-) {DNBP} 187-,188
CYCLOHEXYL-4.6-DINITROPHENOL (2-) 187-188
bis(2-CHLOROETHOXY)METHANE 189-192
CHLORAL {TRICHLOROACETALDEHYDE} 189-192
TRICHLOROMETHANETHIOL ,189-192
DINITROCRESOL (4,6-) {PHENOL,2,4-DINITRO-6-METHYL-} .'-..' 189-192
HEPTACHLOR EPOXIDE . 193
DIEPOXYBUTANE (1,2,3,4-) {2,2'-BIOXIRANE} 194
CLASS 5
BENZOTRICHLORIDE{TRICHLOROMETHYLBENZENE} 195-196
METHAPYRILENE . ..195-196
PHENACETIN{N-[4-ETHOXYPHENYL]ACETAMIDE> t9.7r19'8
METHYL HYDRAZINE [5] 197-198
DIBROMOETHANE (1,2-) {ETHYLENE DIBROMIDE) ', 199
112
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
AFLATOXINS 200
TRICHLOROETHANE (1,1,1-) {METHYL CHLOROFORM} [2] 201
HEXACHLOROETHANE [2] 202-203
BROMOFORM {TRIBROMOMETHANE} [2] 202-203
CHLOROBENZILATE 204-207
ETHYL CARBAMATE (URETHAN) (CARBAMIC ACID, ETHYL ESTER) 204-207
ETHYL METHACRYLATE (2-PROPENOIC ACID, 2-METHYL-.ETHYL ESTER) , 204-207
LASIOCARPINE 204-207
AMITROLE{lH-1,2,4-TRIAZOL-3-AMINE} 208-209
MUSCIMOL {5-AMINOMETHYL-3-ISOAZOTOL} 208-209
IODOMETHANE (METHYL IODIDE} 210
DICHLOROPHENOXYACETIC ACID (2,4-) {2,4-D} . 211-213
CHLORQETHYLVINYLETHER (2-) {ETHENE,[2-CHLOROETHOXYJ-} [2] 211-213
METHYLENE BIS(2-CHLOROANILINE) (4,4-) 211-21-3
DIBROMO-3-CHLOROPROPANE (1,2-) 214
TETRACHLOROETHANE(1,1,1,2-)[2] 215
DIMETHYLHYDRAZINE (1,1-) [5] . 216-217
N,N-DIETHYLHYDRAZINE{1,2-DIETHYLHYDRAZINE) 216-217
CHLOROMETHYLMETHYL ETHER {CHLOROMETHOXYMETHANE} 21 8-220
DIMETHYL-1-METHYLTHIO-2-BUTANONE,O-[(METHYLAMINO)-CARBONYL] 218-220
OXIME (3,3-) {THIOFANOX}
DIMETHYLHYDRAZINE (1,2-) 218-220
CHLORDANE (ALPHA AND GAMMA ISOMERS) 221
bis(CHLOROMETHYL)ETHER {METHANE-OXYbis[2-CHLbRO-]} "" ' ' 222-223
PARATHION [5] 222-223
DtCHLOROPROPANE (2,2-) [5] 224
MALEIC HYDRAZIDE{1,2-DIHYDRO-3,6-PYRIDAZINEDIONE) 225
BROMOPHENYL PHENYL ETHER (4-) {BENZENE, 1-BROMO-4-PHENOXY-} 226
bis(2-CHLOROISOPROPYL)ETHER 227-228
DIHYDROSAFROLE{1,2-METHYLENEDIOXY-4-PROPYLBENZENE} 227-228
METHYL METHANESULFONATE {METHANESUFONIC ACID, METHYL ESTER) 229
PROPANE SULFONE (1,3-) {1,2-OXATHIOLANE,2,2-DIOXIDE} 230
SACCHARIN {1.2-BENZOISOTHIAZOLIN-3-ONE, 1,1-DIOXIDE) 231
METHYL-2-METHYLTHIO-PROPIONALDEHYDE-0-(METHYLCARBONYL)OXIME(2-) 232-233
METHYOMYL 232-233
HEXACHLOROPROPENE [2] 234
PENTACHLORONITROBENZENE {PCNB} 235-239
DIALLATE {S-(2,3-DICHLOROALLYL)DIISOPROPYL THIOCARBAMATE) 235-239
ETHYLENEIMINE {AZIRIDINE} 235-239
ARAMITE 235-239
DIMETHOATE 235-239
TRICHLOROPHENOXYACETIC ACID (2,4,5-) {2,4,5-T} 240-241
TRICHLOROPHENOXYPROPIONIC ACID (2,4,5-) {2,4,5-TP} {SILVEX} 240-241
tris(2,3-DIBROMOPROPYL)PHOSPHATE 242
METHYLAZIRIDINE (2-) {1,2-PROPYLENIMINE} 243-244
METHOXYCHLOR 243-244
BRUCINE {STRYCHNIDIN-10-ONE,2,3-DIMETHOXY-} 245-246
KEPONE 245-246
ISOSAFROLE {1.2-METHYLENEDIOXY-4-ALLYLBENZENE} ' 247-249
SAFROLE{1,2-METHYLENE-4-ALLYLBENZENE) , . 247-249
tris(l-AZRlDINYL) PHOSPHINE SULFIDE ' 247-249
DIMETHOXYBENZIDINE (3,3'-) 250
DIPHENYLHYDRAZINE (1,2-) 251
O,O-DIETHYLPHOSPHORIC AClD,0-p-NITROPHENYL ESTER 252
113
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent • Rank
CLASS 6
n-BUTYLBENZYL PHTHALATE [2J 253
O,O-DIETHYL-O-2-PYRAZINYLPHOSPHOROTHIOATE 254
DIMETHYLAMINOAZOBENZENE 255
DIETHYL PHTHALATE 256-257
O.O-DIETHYL-S-METHYL ESTER OF PHOSPHORIC ACID 256-257
O.O-DIETHYL S-[(ETHYLTHIO)METHYL]ESTER OF PHOSPHORODITHIOIC ACID 258-259
CITRUS RED No. 2 {2-NAPHTHOL,1-[(2,5-DIMETHOXYPHENYL)AZO]} 258-259
TRYPAN BLUE 260
ETHYL METHANESULFONATE (METHANESULFONIC ACID, ETHYL ESTER} 261-265
DISULFOTON 261-265
DIISOPROPYLFLUOROPHOSPHATE {DFP} 261-265
OAO-TRIETHYL PHOSPHOROTHIOATE 261-255
Di-n-BUTYL PHTHALATE 261-265
PARALDEHYDE {2,4,6-TRIMETHYL-1,3,5-TRIOXANE} [5] 266
Di-n-OCTYL PHTHALATE [2] 267
OCTAMETHYLPYROPHOSPHORAMIDE {OCTAMETHYLDIPHOSPHORAMIDE} 268
bis(2-ETHYLHEXYL)PHTHALATE 269-270
METHYLTHIOURACIL 269-270
PROPYLTHIOURACIL 271
CLASS 7
STRYCHNINE {STRYCHNIDIN-10-ONE} 272
CYCLOPHOSPHAMIDE 273-276
NICOTINE {{S)-3-[1-METHYL-2-PYRROLIDINYL]PYRIDINE} 273-276
RESERPINE 273-276
TOLUIDINE HYDROCHLORIDE {2-METHYL-BENZENAMINE HYDROCHLORIDE} 273-276
TOLYLENE DIISOCYANATE {1,3-DIISOCYANATOMETHYLBENZENE} 277
ENDRIN 278
BUTANONE PEROXIDE (2-) (METHYL ETHYL KETONE. PEROXIDE} 279
TETRAETHYLPYROPHOSPHATE 280
NITROGLYCERINE {JRINITRATE-1,2,3-PROPANETRIOL} [5] 281
TETRAETHYLDITHIOPYROPHOSPHATE 282
ETHYLENEbisDITHIOCARBAMIC ACID 283
TETRANITROMETHANE [5J 284
URACIL MUSTARD {5-[bis(2-CHLOROETHYL)AMINO]URACIL} 285
ACETYL-2-THIOUREA(1-) (ACETAMIDE,N-[AM)NOTHIOXOMETHYL]-} 286-290
CHLOROPHENYL THIOUREA (1-) {THIOUREA, [2-CHLOROPHENYL]-} 286-290
N-PHENYLTHIOUREA 286-290
NAPHTHYL-2-THIOUREA (1-) {THIOUREA, 1-NAPHTHALENYL-} 286-290
THIOUREA {THIOCARBAMIDE} 286-290
DAUNOMYCIN 291-292
ETHYLENE THIOUREA {2-IMIDAZOLIDINETHIONE} 291-292
THIOSEMICARBAZIDE{HYDRAZINECARBOTHIOAMIDE} 293-294
MELPHALAN {ALANINE,3-[p-bis(2-CHLOROETHYL)AMINO]PHENYL-,L-} 293-294
DITHIOBIURET (2,4-) (THIOIMIDODICARBONIC DIAMIDE} 295-296
THIURAM {bis[DIMETHYLTHIOCARBAMOYL]DISULFIDE} 295-296
AZASERINE {L-SERINE,DIAZOACETATE[ESTER]> 297
HEXAETHYL TETRAPHOSPHATE 298
NITROGEN MUSTARD N-OXIDE 299-300
NITROQUINOLINE-1-OXIDE (4-) 299-300
CYCASIN {beta-D-GLUCOPYRANOSIDE,[METHYL-ONN-AZOXY]METHYL-} 301
114
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Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
STREPTOZOTOCIN 302
N-METHYL-N'-NITRO-N-NITROSOGUANIDINE 303-318
N-NITROSO-DI-ETHANOLAMINE{[2,2'-N!TROSOIMINO]bisETHANOL} 303-318
N-NITROSQ-DI-N-BUTYLAMINE {N-BUTYL-N-NITROSO-1-BUTANAMINE} 303-31 8
N-NITROSO-N-ETHYLUREA (N-ETHYL-N-NITROSOCARBAMIDE) 303-31 8
N-NITROSO-N-METHYLUREA{N-METHYL-N-NITROSOCARBAMIDE> 303-318
N-NITROSO-N-METHYLURETHANE 303-318
N-NITROSODIETHYLAMINE{N-ETHYL-N-NITROSOETHANAMINE} 303-318
N-NITROSODIMETHYLAMINE{DIMETHYLNITROSAMINE} 303-318
N-NITROSOMETHYLETHYLAMINE (N-METHYL-N-NITROSOETHANAMINE) 303-31 8
N-NITROSOMETHYLVINYLAMINE {N-METHYL-N-NITROSOETHENAMINE} 303-318
N-NITROSOMORPHOLINE 303-318
N-NITRQSONORNICOTINE 303-318
N-NITROSOPIPERIDINE{HEXAHYDRO-N-NITROSOPYRIDINE} 303-318
N-NITROSOSARCOSINE 303-318
NITROSOPYRROLIDINE (N-NITROSOTETRAHYDROPYRROLE) 303-31 8
DI-n-PROPYLNITROSAMINE {N-NITROSO-DI-n-PROPYLAMINE} 303-318
OXABICYCLO[2.2.1]HEPTANE-2,3-DICARBOXYLIC ACID (7-) {ENDOTHAL} 319
ENDOSULFAN 320
FOOTNOTES:
1. UNITS OF TEMPERATURE ARE DEGREES CELSIUS.
2. BOLDFACE INDICATES COMPOUND THERMAL STABILITY IS "EXPERIMENTALLY EVALUATED"
(RANKING BASED ON UDRI EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY).
3. NON-APPENDIX VIII COMPOUND.
4. N.O.S. LISTING; RANKING IS PRESENTED BASED ON EITHER UDRI OR LITERATURE EXPERIMENTAL
DATA COUPLED WITH REACTION KINETIC THEORY.
5. ITALICS INDICATE COMPOUND THERMAL STABILITY IS RANKED BASED ON LITERATURE
EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY.
115
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Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized
Principal Hazardous Organic Constituent Rank
ACETONITRILE {ETHANENITRILE} [2] 17-18
ACETONYLBENZYL-4-HYDROXYCOUMARIN (3-alpha-) {WARFARIN} 98-99
ACETOPHENONE {ETHANONE, 1-PHENYL-} [2] 85-88
ACETYL CHLORIDE {ETHANOYL CHLORIDE} [2] 92-97
ACETYL-2-THIOUREA(1-) {ACETAMIDE,N-[AMINOTHIOXOMETHYL]-} 286-290
ACETYLAMINOFLUORENE (2-) (ACETAMIDE,N-[9H-FLUOREN-2-YL]-} 69-77
ACROLEIN {2-PROPENAL} 106-107
ACRYLAMIDE {2-PROPENAMIDE} 60-64
ACRYLONITRILE {2-PROPENENITRILE} [2] 20
AFLATOXINS 200
ALDRIN 162-164
ALLYL ALCOHOL {2-PROPEN-1-OL} 116-118
AMINOBIPHENYL(4-){[1,1' BIPHENYLJ-4-AMINE} 51
AMITROLE {1H-1,2,4-TRIAZOL-3-AMINE} 208-209
ANILINE {BENZENAMINE} 46-50
ARAMITE 235-239
AURAMINE 180-181
AZASERINE (L-SERINE,DIAZOACETATE[ESTER]} 297
BENZAL CHLORIDE {ALPHA, ALPHA-DICHLOROTOLUENE} [2] 168-1 73
BENZANTHRACENE(1,2-) {BENZ[a]ANTHRACENE} 9
BENZENE [2] 3
BENZENETHIOL {THIOPHENOL} [2] 110
BENZIDINE {[1,1 '-BIPHENYL]-4,4' DIAMINE} 60-64
BENZOQUINONE{1,4-CYCLOHEXADIENEDIONE} 89-91
BENZOTRICHLORIDE {TRICHLOROMETHYLBENZENE} 195-196
BENZO[a]PYRENE{1,2-BENZOPYRENE} 11
BENZO[b]FLUORANTHENE {2,3-BENZOFLUORANTHENE} 8
BENZO[j]FLUORANTHENE {7,8-BENZOFLUORANTHENE} 7.
BENZYL CHLORIDE {CHLOROMETHYLBENZENE} [2] 127-130
BENZ[c]ACRIDINE{3,4-BENZACRIDINE} 85-88
bis(2-CHLOROETHOXY)METHANE 1 89-1 92
bis(2-CHLOROETHYL)ETHER [2] 183-186
bis(2-CHLOROISOPROPYL)ETHER 227-228
bis(2-ETHYLHEXYL)PHTHALATE 269-270
bis(CHLOROMETHYL)ETHER {METHANE-OXYbis[2-CHLORO-]} 222-223
BROMOACETONE{1-BROMO-2-PROPANONE} 136-140
BROMOFORM {TRIBROMOMETHANE} [2] 202-203
BROMOMETHANE {METHYL BROMIDE} [2] 31-33
BROMOPHENYL PHENYL ETHER (4-) {BENZENE.1-BROMO-4-PHENOXY-} 226
BRUCINE {STRYCHNIDIN-10-ONE,2,3-DIMETHOXY-} 245-246
BUTANONE PEROXIDE (2-) {METHYL ETHYL KETONE, PEROXIDE} 279
I BUTYL-4,6-DINITROPHENOL (2-sec-) {DNBP} 187-188
CHLORAL {TRICHLOROACETALDEHYDE} 189-192
CHLORAMBUCIL 142
CHLORDANE (ALPHA AND GAMMA ISOMERS) 221
CHLORO-1.3-BUTADIENE (2-) {CHLOROPRENE} 69-77
CHLORO-2,3-EPOXYPROPANE (1-) {OXIRANE.2-CHLOROMETHYL-} 183-186
CHLOROACETALDEHYDE 166-167
CHLOROANILINE{CHLOROBENZENAMINE} 37
CHLOROBENZENE [2] 19
CHLOROBENZILATE 204-207
CHLOROCRESOL {4-CHLORO-3-METHYLPHENOL} 116-118
116
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Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index'- Alphabetized (continued)
Principal Hazardous Organic Constituent " Rank
CHLORODIFLUOROMETHANE [2] [4] 151-153
CHLOROETHANE (ETHYL CHLORIDE) (4] (5) 126
CHLOROETHYLVINYLETHER (2-) {ETHENE,[2-CHLOROETHOXYJ-} [2] 211-213
CHLOROMETHANE {METHYL CHLORIDE} [2] 29-30
CHLOROMETHYLMETHYL ETHER {CHLOROMETHOXYMETHANE} 218-220
CHLORONAPHTHALENE (1-) [2] 21-22
CHLOROPHENOL (2-) 102
CHLOROPHENYLTHIOUREA(I-) {THIOUREA,[2-CHLOROPHENYL]-} 286-290
CHLOROPROPENE (3-) (ALLYL CHLORIDE} [2] , 120
CHLOROPROPIONITRILE (3-) {3-CHLOROPROPANENITRILE} [2] 143-1 44
CHRYSENE {1,2-BENZPHENANTHRENE} 10
CITRUS RED No. 2 {2-NAPHTHOL,1-[(2,5-DIMETHOXYPHENYL)AZOl} 258-259
CRESOL(1,2-){METHYLPHENOL} 104-105
CRESOL(1,3-){METHYLPHENOL} 103
CRESOL (1,4-) {METHYLPHENOL} [2] 104-105
CROTONALDEHYDE {2-BUTENAL} [2] 113-115
CYANOGEN BROMIDE (BROMINE CYANIDE} 23-24
CYANOGEN CHLORIDE {CHLORINE CYANIDE} • 17-18
CYANOGEN {ETHANEDINITRILE} ' ... 1
CYCASIN{beta-D-GLUCOPYRANOSIDE,[METHYL-ONN-AZOXY] METHYL-} 301
CYCLOHEXYL-4.6-DINITROPHENOL (2-) 1 87-1 88
CYCLOPHOSPHAMIDE ' - 273-276
DAUNOMYCIN 291-292
DDD{DICHLORODIPHENYLDICHLOROETHANE} 145-146
DDE{1,1-DICHLORO-2,2-BIS(4-CHLOROPHENYLETHYLENE} 38
DDT{DICHLORODIPHENYLTRICHLOROETHANE} 175-178
Di-n-BUTYL PHTHALATE 261-265
Di-n-OCTYL PHTHALATE [2] 267
DI-n-PROPYLNITROSAMINE{N-N1TROSO-DI-n-PROPYLAMINE} 303-318
DIALLATE {S-(2,3-DICHLOROALLYL)DIISOPROPYL THIOCARBAMATE) 235-239
DIBENZO[a,e]PYRENE{1,2,4,5-DIBENZOPYRENE} 16
DIBENZO[a,hlPYRENE{1,2,5,6-DIBENZOPYRENE} ,,..""• 14
DIBENZO[a,i]PYRENE {1,2,7,8-DIBENZOPYRENE} 15
DIBENZO[c,g]CARBAZOLE (7H-) {3,4,5,6-DIBENZCARBAZOLE} 100-101
DIBENZ[a,h]ACRIDINE{1,2,5,6-DIBENZACRIDINE} 92-97
DIBENZ[a,h]ANTHRACENE{1,2,5,6-DIBENZANTHRACENE} s 12
DIBENZ[a,j]ACRIDINE{1,2,7,8-DIBENZACRIDINE} . . : 92-97
DIBROMO-3-CHLOROPROPANE (1,2-) •• 214
DIBROMOETHANE(1,2-) {ETHYLENE DIBROMIDE} 199
DIBROMOMETHANE {METHYLENE BROMIDE} [2] 127-130
DICHLORO-1-PROPANOL (2,3-) 168-173
DICHLORO-2-BUTENE(1,4-) 136-140
DICHLORO-2-PROPANOL(1,1-) 145-146
DICHLORO-2-PROPANOL(1,3-) 147
DICHLOROBENZENE {1,2-DICHLOROBENZENE} [2] 23-24
DICHLOROBENZENE {1,3-DICHLOROBENZENE} [2] 25
DICHLOROBENZENE {1,4-DICHLOROBENZENE} 21-22
DICHLOROBENZIDINE (3,3'-) 67
DICHLORODIFLUOROMETHANE [2] 85-88
DICHLOROETHANE (1,1-) {ETHYL/DENE DICHLORIDE} [5] 175.-1 78
DICHLOROETHANE (1,2-) [2] 131
DICHLOROETHENE (1,1-) [2] 42-44
117
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Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
DICHLOROETHENE (trans-1,2-) [2] 54
DICHLOROFLUOROMETHANE [2] [4] 154-157
DICHLOROMETHANE {METHYLENE CHLORIDE} [2] 65-66
DICHLOROPHENOL (2,4-) 113-115
DICHLOROPHENOL (2,6-) 113-115
DICHLOROPHENOXYACETIC ACID (2,4-) {2,4-D} 211-213
DICHLOROPROPANE(1,1-)[5] 182
DICHLOROPROPANE (1,2-) {PROPYLENE DICHLORIDE} [5] 179
DICHLOROPROPANE(1,3-)[5] 165
DICHLOROPROPANE (2,2-) [51 224
DICHLOROPROPENE (1,1-) [2] 81-84
DICHLOROPROPENE (2,3-) 127-130
DICHLOROPROPENE (3,3-) 135
DICHLOROPROPENE (cis-1,3-) 121-125
DICHLOROPROPENE (trans-1,2-) 89-91
DICHLOROPROPENE (trans-1,3-) 121-125
DIELDRIN 161-163
DIEPOXYBUTANE (1,2,3,4-) {2,2'-BIOXlRANE} 194
DIETHYL PHTHALATE 256-257
DIETHYLSTILBESTEROL 108-109
DIHYDROSAFROLE {1.2-METHYLENEDIOXY-4-PROPYLBENZENE} 227-228
DIHYDROXY-ALPHA-[METHYLAMINO]METHYL BENZYL ALCOHOL (3,4-) 106-107
DIISOPROPYLFLUOROPHOSPHATE {DFP} 261-265
DIMETHOATE 235-239
DIMETHOXYBENZIDINE (3,3'-) 250
DIMETHYL PHTHALATE [2] 92-97
DIMETHYL-1-METHYLTHIO-2-BUTANONE,0-[(METHYLAMINO)-CARBONYL] 218-220
OXIME (3,3-) {THIOFANOX}
DIMETHYLAMINOAZOBENZENE 255
DIMETHYLBENZIDINE (3,3'-) 78
DIMETHYLBENZ[a]ANTHRACENE (7,12-) 45
DIMETHYLCARBAMOYLCHLORIDE 175-178
DIMETHYLHYDRAZINE (1,1-) [5] 216-217
DIMETHYLHYDRAZINE (1,2-) 218-220
DIMETHYLPHENETHYLAMINE (alpha, alpha-) 60-64
DIMETHYLPHENOL (2,4-) 119
DINITROBENZENE(1,2-) 158-161
DINITROBENZENE(1,3-) 154-157
DINITROBENZENE(1,4-) 158-161
DINITROCRESOL (4,6-) {PHENOL,2,4-D!NITRO-6-METHYL-} 1 89-192
DINITROPHENOL (2,4-) 183-186
DINITROTOLUENE (2,4-) 168-173
DINITROTOLUENE (2,6-) 168-173
DIOXANE (1,4-) {1,4-DIETHYLENE OXIDE} [2] 141
DIPHENYLAMINE {N-PHENYLBENZENAMINE} 42-44
DIPHENYLHYDRAZINE (1,2-) 251
DISULFOTON 261-265
DITHIOBIURET (2,4-) (THIOIMIDODICARBONIC DIAMIDE} 295-296
ENDOSULFAN 320
ENDRIN 278
ETHYL CARBAMATE {URETHAN} {CARBAMIC ACID, ETHYL ESTER} 204-207
ETHYL CYANIDE {PROPIONITRILE} [2] 89-91
ETHYL METHACRYLATE {2-PROPENOIC ACID, 2-METHYL-.ETHYL ESTER} 204-207
118
-------
Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
ETHYL METHANESULFONATE {METHANESULFONIC ACID, ETHYL ESTER} 261-265
ETHYLENE OXIDE {OXIRANE} [5] 174
ETHYLENE THIOUREA {2-IMIDAZOLIDINETHIONE} 291-292
ETHYLENEbisDITHIOCARBAMIC ACID 283
ETHYLENEIMINE {AZIRIDINE} 235-239
FLUORANTHENE {BENZO[j,k]FLUORENE} 6
FLUOROACETAMIDE (2-) 55-56
FLUOROACETIC ACID 42-44
FORMALDEHYDE (METHYLENE OXIDE} 46-50
FORMIC ACID {METHANOIC ACID} 39-40
GLYCIDYALDEHYDE {1-PROPANOL-2.3-EPOXY} 1 75-1 78
HEPTACHLOR 180-181
HEPTACHLOR EPOXIDE 193
HEXACHLOROBENZENE [2] 31-33
HEXACHLOROBUTADIENE (trans-1,3) [2] 92-97
HEXACHLOROCYCLOHEXANE {LINDANE} [2] 151-153
HEXACHLOROCYCLOPENTADIENE 168-173
HEXACHLOROETHANE [2] 202-203
HEXACHLOROPHENE{2,2'-METHYLENEbis[3,4,6-TRICHLOROPHENOL]} 136-140
HEXACHLOROPROPENE [2] 234
HEXAETHYL TETRAPHOSPHATE 298
HYDRAZINE (DIAMINE) 127-130
HYDROGEN CYANIDE {HYDROCYANIC ACID} [2] 2
INDENO(1,2,3-cd)PYRENE{1,10-(1,2-PHENYLENE)PYRENE} 13
IODOMETHANE {METHYL IODIDE} 210
ISOBUTYL ALCOHOL {2-METHYL-1-PROPANOL} [2] 112
ISODRIN 162-164
ISOSAFROLE {1.2-METHYLENEDIOXY-4-ALLYLBENZENE} 247-249
KEPONE 245-246
LASIOCARPINE 204-207
MALEIC ANHYDRIDE {2,5-FURANDIONE} 98-99
MALEIC HYDRAZIDE {1,2-DIHYDRO-3,6-PYRIDAZINEDIONE} 225
MALONONITRILE {PROPANEDINITRILE} 46-50
MELPHALAN {ALANINE,3-[p-bis(2-CHLOROETHYL)AMINO]PHENYL-,L-} 293-294
METHACRYLONITRILE {2-METHYL-2-PROPENENITRILE} [2] 65-66
METHAPYRILENE 195-196
METHOXYCHLOR 243-244
METHYL CHLOROCARBONATE {CARBONOCHLORIDIC ACID, METHYL ESTER} 46-50
METHYL ETHYL KETONE {2-BUTANONE} [2] 108-109
METHYL HYDRAZINE [5] 197-198
METHYL ISOCYANATE {METHYLCARBYLAMINE} 46-50
METHYL METHACRYLATE {2-PROPENOIC ACID, 2-METHYL-, METHYL ESTER} 60-64
METHYL METHANESULFONATE {METHANESULFONIC ACID, METHYL ESTER} 229
METHYL PARATHION 148-150
METHYL-2-METHYLTHIO-PROPIONALDEHYDE-0-(METHYLCARBONYL)OXIME(2-) 232-233
METHYLACTONITRILE (2-) {PROPANENITRILE.2-HYDROXY-2-METHYL} 116-118
METHYLAZIRIDINE (2-) {1,2-PROPYLENIMINE} 243-244
METHYLCHOLANTHRENE (3-) 68
METHYLENE BIS(2-CHLOROANILINE) (4,4-) 211-213
METHYLTHIOURACIL 269-270
METHYOMYL 232-233
MUSCIMOL{5-AMINOMETHYL-3-ISOAZOTOL} 208-209
119
-------
Table D-2. Principal,Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Principal Hazardous Organic Constituent Rank ,.
MUSTARD GAS (bis[2-CHLOROETHYL]-SULFIDE) :
N,N-BIS(2-CHLOROETHYL)2-NAPHTHYLAMINE (CHLORNAPHAZINE)
N.N-DIETHYLHYDRAZINE (1,2-DIETHYLHYDRAZINE)
n-BUTYLBENZYL PHTHALATE [2]
N-METHYL-N'-NITRO-N-NITROSOGUANIDINE
N-NITROSO-DI-ETHANOLAMINE{[2,2'-NITROSOIMINQ]bisETHANOL)
N-NITROSO-DI-N-BUTYLAMINE (N-BUTYL-N-NITROSO-1 -BUTANAMINE)
N-NITROSO-N-ETHYLUREA {N-ETHYL-N-NITROSOCARBAMIDE} • , • •
N-NITROSO-N-METHYLUREA(N-METHYL-N-NITROSOCARBAMIDE)
N-NITROSO-N-METHYLURETHANE
N-NITROSODIETHYLAMINE (N-ETHYL-N-NITROSOETHANAMINE)
N-NITROSODIMETHYLAMINE {DIMETHYLNITROSAMINE}. . •
N-NITROSOMETHYLETHYLAMINE {N-METHYL-N-NITROSOETHANAMINE}
N-NITROSOMETHYLVINYLAMINE{N-METHYL-N-NITROSOETHENAMINE>
N-NITROSOMORPHOLINE
N-NITROSONORNICOTINE
N-NITROSOPIPERIDINE {HEXAHYDRO-N-NITROSOPYRIDINE}. •
N-NITROSOSARCOSINE
N-PHENYLTHIOUREA
n-PROPYLAMINE {1-PROPANAMINE}
NAPHTHALENE [2]
NAPHTHOQUINONE (1,4-) {1,4-NAPHTHALENEDIONE}
NAPHTHYL-2-THIOUREA(1-){THIOUREA,1-NAPHTHALENYL-} .
NAPHTHYLAMINE (1-)
NAPHTHYLAMINE (2-)
NICOTINE {(S)-3-[1-METHYL-2-PYRROLIDINYL]PYRIDlNE)
NITROANILINE{4-NITROBENZENAMINE)
NITROBENZENE [2]
NITROGEN MUSTARD ;
NITROGEN MUSTARD N-OXIDE
NITROGLYCERINE {JRINITRATE-1,2,3-PROPANETRIOL} [5]
NITROPHENOL (4-)
NITROQUINOLINE-1-OXIDE (4-)
NITROSOPYRROLIDINE (N-NITROSOTETRAHYDROPYRROLE)
NITROTOLUIDINE (5-) {BENZENAMINE.2-METHYL-5-NITRO-}
O,O,O-TRIETHYL PHOSPHOROTHIOATE
O.O-DIETHYL S-[(ETHYLTHIO)METHYL]ESTER OF PHOSPHORODITHIOIC ACID
O.O-DIETHYL-O-2-PYRAZINYL PHOSPHOROTHIOATE
O.O-DIETHYL-S-METHYL ESTER OF PHOSPHORIC ACID
O.O-DIETHYLPHOSPHORIC ACID.O-p-NITROPHENYL ESTER
OCTAMETHYLPYROPHOSPHORAMIDE {OCTAMETHYLDIPHOSPHORAMIDE}
OXABICYCLO[2.2.1]HEPTANE-2,3-DICARBOXYLIC ACID (7-) {ENDOTHAL}
PARALDEHYDE {2,4,6-TRIMETHYL-1,3,5-TRIOXANE} [5] <
PARATHION [5]
PENTACHLOROBENZENE [2J
PENTACHLOROETHANE [2]
PENTACHLORONITROBENZENE {PCNB}
PENTACHLOROPHENOL
PHENACETIN {N-[4-ETHOXYPHENYL]ACETAMIDE>
PHENOL {HYDROXYBENZENE}
PHENYLENEDIAMINE(1,2-) (BENZENEDIAMINE) , . ,
PHENYLENEDIAMINE (1,3-) {BENZENEDIAMINE}
132-134
132-134
216-217
253
303-318
303-318
303-318
303-318
303-318
303-318
303-318
303-318
303-318
303-318
303-318
303-3 l^
303-31,8;
303-318
286-290^
92-97
286-290
52-53
52-53,
273-276
154-157
143
132^134
299-300
.. 281
148-150
299-300
303-318
166-167.
261-26.5
258-259
254 s -
256-257
252
268 ,
7 319 ••:.>:•.
266
222-223
31-33,
154-157
235-239
151-153
197-198
100-101
57-59
57-59
120
-------
Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
PHENYLENEDIAMINE (1,4) {BENZENEDIAMINE} 57-59
PHOSGENE (CARBONYL CHLORIDE} 39-40
PHTHALIC ANHYDRIDE {1,2-BENZENEDICARBOXYLIC ACID ANHYDRIDE) 1 48-1 50
PICOLINE (2-) (PYRIDINE, 2-METHYL-} 81-84
PRONAMIDE{3,5-DICHLORO-N-[1,1-DIMETHYL-2-PROPYNYL] BENZAMIDE) 69-77
PROPANE SULFONE (1,3-) (1,2-OXATHIOLANE,2,2-DIOXIDE} 230
PROPYLTHIOURACIL 271
PROPYN-1 -OL (2-) {PROPARGYL ALCOHOL} 55-56
PYRIDINE [2] 80
RESERPINE 273-276
RESORCINOL{1,3-BENZENEDIOL> 111
SACCHARIN {1.2-BENZOISOTHIAZOLIN-3-ONE, 1,1-DIOXIDE} 231
SAFROLE{1,2-METHYLENE-4-ALLYLBENZENE} 247-249
STREPTOZOTOCIN 302
STRYCHNINE {STRYCHNIDIN-10-ONE} 272
SULFUR HEXAFLUORIDE [31 4
TETRACHLOROBENZENE (1,2,3,5-TETRACHLOROBENZENE) [2] [4] 20
TETRACHLOROBENZENE (1,2,4,5-TETRACHLOROBENZENE) 29-30
TETRACHLORODIBENZO-p-DIOXIN (2,3,7,8-) {TCDD} 34
TETRACHLOROETHANE (1,1,1,2-) [2] 215
TETRACHLOROETHANE (1,1,2,2-) [2] 121-125
TETRACHLOROETHENE [2] 36
TETRACHLOROMETHANE {CARBONTETRACHLORIDE} [2] 136-140
TETRACHLOROPHENOL (2,3,4,6-) 136-140
TETRAETHYLDITHIOPYROPHOSPHATE 282
TETRAETHYLPYROPHOSPHATE 280
TETRANITROMETHANE [5] 284
THIOACETAMIDE {ETHANETHIOAMIDE} 81-84
THIOSEMICARBAZIDE{HYDRAZINECARBOTHIOAMIDE} 293-294
THIOUREA {THIOCARBAMIDE} 286-290
THIURAM {bis[DIMETHYLTHIOCARBAMOYL]DISULFIDE} 295-296
TOLUENE {METHYLBENZENE} [2] 35
TOLUENEDIAMINE (1,3-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (1,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (2,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (2,6-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3,5-) {DIAMINOTOLUENE} 69-77
TOLUIDINE HYDROCHLORIDE {2-METHYL-BENZENAMINE HYDROCHLORIDE} 273-276
TOLYLENE DIISOCYANATE {1,3-DIISOCYANATOMETHYLBENZENE} 277
TRICHLOROBENZENE (1,2,4-TRICHLOROBENZENE) [2] 26-27
TRICHLOROBENZENE (1,3,5-TRICHLOROBENZENE) [2] [4] 26-27
TRICHLOROETHANE (1,1,1-) {METHYL CHLOROFORM} [2] 201
TRICHLOROETHANE (1,1,2-) [2] 158-161
TRICHLOROETHENE [2] 41
TRICHLOROFLUOROMETHANE [2] 85-88
TRICHLOROMETHANE {CHLOROFORM} [2] 195-196
TRICHLOROMETHANETHIOL 189-192
TRICHLOROPHENOL (2,4,5-) 121-125
TRICHLOROPHENOL (2,4,6-) 121-125
TRICHLOROPHENOXYACETIC ACID (2,4,5-) {2,4,5-T} ' 240-241
TRICHLOROPHENOXYPROPIONIC ACID (2,4,5-) {2,4,5-TP} {SILVEX} 240-241
121
-------
Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued) ^
Principal Hazardous Organic Constituent Rank
TRICHLOROPROPANE (1,2,3-) [2] 168-1 73
TRICHLORO-(1,2,2)-TRIFLUOROETHANE (1,1,2) [2] [3] 81-84
TRINITROBENZENE{1,3,5-TRINITROBENZENE} 183-186
tris(l-AZRIDINYL) PHOSPHINE SULFIDE - 247-249
tris(2,3-DIBROMOPROPYL)PHOSPHATE 242
TRYPANBLUE 260
URACIL MUSTARD {5-[bis(2-CHLOROETHYL)AMINO]URACIL} 285
VINYL CHLORIDE (CHLOROETHENE) 60-64
FOOTNOTES:
1. UNITS OF TEMPERATURE ARE DEGREES CELSIUS.
2. BOLDFACE INDICATES COMPOUND THERMAL STABILITY IS "EXPERIMENTALLY EVALUATED"
(RANKING BASED ON UDRI EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY).
3. NON-APPENDIX VIII COMPOUND.
4. N.O.S. LISTING; RANKING IS PRESENTED BASED ON EITHER UDRI OR LITERATURE EXPERIMENTAL
DATA COUPLED WITH REACTION KINETIC THEORY.
5. ITALICS INDICATE COMPOUND THERMAL STABILITY IS RANKED BASED ON LITERATURE
EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY.
122
-------
Table D-3. Appendix Vlll Thermal Stability Classes
Class Compound Ranking
T9g(2) Range
1
2
3
4
5
6
7
1-34
35-77
78-119
120-193
194-252
253-271
272-320
1,590-900
895-800
790-705
695-604
600-425
415-360
320-100
123
-------
APPENDIX £
Energy and Mass Balance Computer Program
E.1 Energy and Mass Balance
A computer program has been developed by Energy
and Environmental Research Corporation (EER)
under contract to the EPA to perform energy and
mass balance calculations on hazardous waste
incinerators.
The calculations are performed for a single zone
incinerator or for an incinerator system composed of
single zones in series. The composition of gases and
solids in a zone is assumed to be the same as the
exit composition--that of complete reaction; the
temperature in a zone is assumed to be the same as
the exit temperature; and the residence time within a
zone is assumed to be the mean residence time.
Products of one zone enter the next zone at the exit
temperature of the first zone. In cases where there is
a significant heat loss between the incinerator units, a
transition zone is included between the units to allow
the products to enter the second unit at a lower
temperature than they exit the first.
This section discusses the components of the June
1987 version of the EER program and the principles,
assumptions, and limitations involved. Because the
inputs and outputs of the model are in English units,
this section is written in English units.
E.1.1 Input
Inputs to the energy and mass balance include feed
rate, temperature, heating value, heat capacity, heat
of vaporization, and composition of all input streams
to each unit including wastes, fuels, water, air, and
oxygen; incinerator design specifications including the
thickness and conductivity of the refractory, the
volume of the unit, the area of the refractory and any
cooled surfaces, and the outer shell temperature; and
the air pollution control equipment (APCE) design
specifications including gas volumetric capacity, acid
capacity, quench water capacity and temperature,
and the temperature to which the gas must be
quenched. Table E-1 shows a typical blank input
form.
Feed rates are in the form of mass flows. Preheat
denotes the temperature at which a stream enters the
incinerator. Proximate analysis is a standard analytical
procedure used to characterize fuels consisting of
mass percentages of fixed carbon, volatiles, ash, and
moisture. Elemental analysis consists of the dry mass
percentages of carbon, hydrogen, nitrogen, sulfur,
ash, oxygen and chlorine. Halogens other than
chlorine are treated as chlorine by multiplying their
mass percentage by the ratio of atomic weight of
chlorine to the atomic weight of the halogen and
renormalizing so that the total mass percentage is
100.
Heating value is input as the higher or gross heating
value, the way it is typically measured and reported.
The higher heating value (HHV) is defined as the heat
of complete combustion of the fuel/waste at 77° F
(298°K) with all product water in liquid form and all
product chlorine in the form of HO. If the heating
value is unknown, it can be estimated from the
fuel/waste composition by equation 1:
HHV = 1.8 [(100 - ASH - MOISTURE)/!00]
X {83.2C + 275.15H + 25.0S
+ 15.0N - 25.8(0)
- 568.4 [1 - exp(-0.582 Cl/C)]} Btu/lb
(1)
where ASH and MOISTURE are mass percentages
on a wet as-fired basis and C, H, S, N, Cl, and O
are mass percentages on a dry ash-free basis. To
convert from a dry basis to a dry ash-free basis,
divide each mass fraction by [100 - ASHwet/(100 •
MOISTURE)]. Note that equation 1 includes the heat
of solution of HCI in the value for the high heating
value; this is not a common usage. Normal
nomenclature defines high heating value as the sum
of the waste's (or fuel's) lower heating value (LHV)
and the latent heat of vaporization of the water
formed in the combustion process. For highly
chlorinated material, however, the heat of solution of
the HCI also becomes significant and is, therefore,
included here.
Heat capacity is only important if the preheat
temperature is significantly different from the
reference temperature of 77°F (298°K). The heat
capacity depends on the composition: aqueous
wastes generally have a heat capacity around 1.0,
125
-------
Table E-1. Energy and Mass Balance Input Data.
ro
en
LIQUID WASTE
SOLID WASTE
PRIMARY FUEL
SECONDARY FUEL
PRIMARY AIR
SECONDARY AIR
WATER
OXYGEN
ASH DROPOUT
HAZARDOUS
COMPOUNDS
FEED RATE
(LB/H)
PREHEAT
(°R
PROXIMATE ANALYSIS (PERCENT)
(AS RECEIVED)
FIXED
CARBON
VOLAT1LES
ASH
MOISTURE
HEATNG
VALUE
(HIGHER
ASRECVD)
(BTU/LB)
HEAT
CAPACrTY
(AS
RECEIVED)
(BTU/LB)
HEAT OF
VAPORI-
ZATION
(DRY)
(BTU/LB)
ELEMENTAL ANALYSIS
(DRY PERCENT)
C
H
N
S
ASH O Cl
DESIGN SPECIFICATIONS
REFRACTORY THICKNESS (IN)
REFRACTORY CONOUCTIVrTY (BTU INM FT2 °F)
UNIT VOLUME (FT3)
REFRACTORY SURFACE AREA (FT 2)
COOLED SURFACE AREA (FT2)
OUTER SHELL TEMPERATURE ( ° F)
PCC
sec
APCD
GASCAPAOTY(SCFM)
STACK GAS TEMPERATURE ( ° F)
HCI CAPACITY (LB/H)
QUENCH WATER CAPACITY (GPM)
QUENCH WATER TEMPERATURE (
OF)
-------
organic wastes around 0.4, and inert solids around
0.2 Btu/lb-°F.
Heat of vaporization is generally incorporated into the
heating value. If the heating value is given for the
fuel/waste in liquid form, the heat of vaporization
should be entered as zero. Heat of vaporization is
only for the dry fuel/waste. Moisture vaporization is
automatically taken into account in the program.
The refractory thickness is the distance between the
inside and the. outside wall of the refractory. The
refractory conductivity is the effective conductivity of
the refractory as if it were a flat slab of uniform
composition. For a cylindrical incinerator, the effective
thermal conductivity can be calculated from equation
2:
K'X t
ff
eff
r.ln -
(2)
where Keff and K are the effective and actual thermal
conductivities, t0 is the overall thickness, and r0 and
rj are the outer and inner refractory radii. For a
cylindrical incinerator with layers of refractory, the
composite thermal conductivity can be calculated
from equation 3:
t
. ,
eff
In -
(3)
' +
K2
+ ...
K
For a flat wall with layers of refractory, the composite
thermal conductivity can be calculated from equation
4:
t
Keff =
(4)
— H
Kl K2
K
For an incinerator with sections or walls with different
refractories such as an incinerator with different
insulation on its end walls, the effective thermal
conductivity is the area-weighted average of the
individual conductivities as calculated in equation 5:
K1A1
V0+ ...K A
2 n n
(5)
The volume of the unit is the inside volume, and the
refractory surface area is the inside refractory surface
area. In cases where two units connect with an open
surface in between rather than a wall, the area of the
interface is added to the refractory surface area. The
cooled surface area is the optical area of any cooled
surfaces; thus, for a cooled plate, it is the area of one
side of the plate; for a cooled tube against the wall, it
is the length of the tube times the diameter; and for a
cooled tube within the flow, it is the length of the tube
times twice its diameter. The outer shell temperature
is only important if the heat balance on the outer shell
has been disabled. Otherwise, the program calculates
outer shell temperature.
The APCD gas capacity is the specified maximum
capacity of the APCD, which is usually dictated by the
capacity of the ID fan. The HCI capacity is the
capacity of the system to remove HCI. The available
quench water is usually dictated by pump size. The
quench water temperature serves as a limit
temperature below which the gas cannot be
quenched. The stack gas temperature is the
temperature of effluent in the stack.
£.7.2 Mass Balance
The mass balance calculates the products of
complete combustion of the mixture of all the inputs
to each unit of the incinerator. Species considered
include C, H, N, 0, S, Cl, Ash, H2O, C>2, C02, N2,
SC-2, and HCI.
Each input stream is broken down into the mass
flows of its individual components by equation 6:
m. = m . x mass fraction.
i stream i
(6)
where m is mass flow. Air is considered to be 23.31
percent C>2 and 76.69 percent N2 by mass. All the
mass flows of each species input into the unit are
summed and divided by the molecule weight (MW) of
that species to calculate molar flows (M) by equation
7:
m.
Molar Flow. =
(7)
Table E-2 lists the molecular weights of each
species.
Complete combustion is calculated according to the
molar equations listed in Table E-3. A warning is
issued if insufficient oxygen is present for complete
combustion or if insufficient hydrogen is present for
complete conversion of Cl to HCI.
where Aj is the area of each section and Aj is the
total refractory area.
The volumetric flow is calculated from the total flow
by the ideal gas law in the form of equation 8:
127
-------
Volumetric Flow (@ 70°F)
^— sft (K)
= Y Molar Flow, x 386.7 W
*-~ i HJ mole i
/H2°f
-UcJ „
Dry oxygen volume percentage fs~ calculated from the x CAp 1.92 jj
molar flows by equation 9:
Dry 69 Volume Percentage Table E-2- Molecular Weights of Species Considered In
, Energy and Mass Balance
M : ..•••".•
0,, Species , Molecular Weight
xlOO% (9)
MC02 + MN2+VMS02
Finally, molar flows are converted back into mass
flows by equation 10:
m. = M.xMW. (10)
i ii
£.7.3 Energy Balance
The energy balance solves three equations: .
Heat of Combustion + Sensible Heat
- Heat of Vaporization - Total Radiation
- Total Convection = 0 (11)
Radiation to Refractory
+ Convection to Refractory Table E-3
- Conduction Through Refractory = 0 (12)
Conduction Through Refractory
- Radiation from Outer Shell
- Convection from Outer Shell = 0 (13)
for gas temperature, wall temperature, and outer shell
temperature.
The heat of combustion is the heat released in the
reaction of reactants to products at the reference
state of 77° F with H20 in liquid form. The heat of
combustion is calculated by equation 14:
Heat of Combustion = S [(HHVixmi)
-(Heat of Solution xClixm;)] (14)
where (H^C
where HHV is higher heating value and Heat of produced i
Solution is the energy released when gaseous HCI calculated b
dissolves in water. The heat of solution of HCI is
subtracted out because HHV is typically measured
with HCI in aqueous form, but the reference state of „
HCI used in the program is gaseous. The heat of ' ( '
C 12
H 1
N 14
O 16
S 32
Cl 35.5
Ash
H2O 18
Oz 32
N2 . ... 28
C02 44
HCI 36.5
S02 64
Molar Equations for Complete Combustion
C + O2 = CO2
H + i02 = }H26
N = JN2
O = }O2
S + 02 = SO2
Cl + H = HCI
H2O = H2O
Excess 02 = C>2
. N2 = N2
CO2 = CO2
HCI = HCI
)/HCI) is the molar ratio of H20 to HCI
n the oxidation of the fuel/waste as
y:
(*\ ( C1 V
j°\ Vl / V 35.57 (i6)
solution of HCI is based on a curve fit to data \HCl7 / Cl \
presented in Daniels and Alberty (1967) (1): 2x( I
\ 35.5 /
Heat of Solution! Higher heating value is used because of the choice of
= m.X Cl. (1 - Moisture.)887.36
liquid water as the reference state. The heat of
vaporization is the energy required to convert reactant
and product water to liquid H2O at the reference
temperature of 77° F according to equation 17;
128
-------
vap \ reactant steam product steam
Btu
X 1,050.54
ID
(17)
where all product water is assumed to be in the form
of steam. The change in sensible heat is the sensible
heat of the products minus the sensible heat of the
inputs. Sensible heats are calculated according to
equation 18:
Sensible Heat. = m. C . (T - 77°F) (18)
i i pi
For input streams, T is the preheat temperature and
Cp is the heat capacity which is given for fuel/waste
streams and is assumed to be 1.00, 0.44, 0.24, and
0.22 Btu/lb°F for liquid water, steam, air, and oxygen,
respectively. For products, T is the gas temperature,
and Cp is the mean heat capacity of each species
between the reference temperature and the gas
temperature. For gas species, Cp is calculated
according to equation 19:
),(T2-T2ef
pi
i.(T-T ,)+•
i ref 2
- (T-Tref)
+
l.(T4-T4
ref
(19)
with constants a, b, c, and d for species COa, H20,
N2, SC-2, HCI, and C>2 taken from Hougen, Watson
and Ragatz (1967) (2). For ash, heat capacity is
calculated from an integration of a formula from Perry
and Chilton (1973) according to equation 20(3):
0.18( T-T f j + 0.00003(T2-T2ef
^p ash
T-T
ref
(20)
Heat loss through the wall is calculated from the area
(A), the conductivity and thickness of the refractory,
and from the difference between the inside refractory
wall temperature and the outer shell temperature as
shown in equation 21:
Heat Loss Through Wall
I
T —T
J. -, —"• J. . .,
wall shell
v
(21)
according to equation 22:
Convection = hA T -T
wall
(22)
where h is the corrective heat transfer coefficient
and TCOO| can be substituted for Twa|| for heat
transfer to cooled surfaces. The heat transfer
coefficient is defined by equation 23:
K
= Nu
D
(23)
where Kgas is the thermal conductivity of the gas, Nu
is the Nusselt number, and D is the effective diameter
of the incinerator. For noncylindrical incinerators, the
effective diameter and length (L) are calculated from
the area and volume (V) by the simultaneous solution
of equations 24 and 25:
A =
2D2n
+ DnL
V =
LD2n
(24)
(25)
Gas thermal conductivity is approximated by a
method taken from Perry and Ghilton (1973) and
tailored to combustion gases according to equation
26 (3):
K =
0.3703u(c +0.0855
C . + 0.0855
pref
(26)
where Cp ref is the heat capacity of the gas at a
reference temperature of 1,500°F and p, is the
viscosity of the gas which is approximated by a
method taken from Perry and Chilton (1973) and
tailored to combustion gases according to equation
27(3):
>-5
l,960°fl
1.5
2,180.5°R
(T + 220.5°R)
(27)
The Nusselt number is estimated from Kroll's
correlation for tubular combustors as referenced by
Field, et al (1967) according to equation 28 (4):
Nu = 0.023 Re°'8 Pr0'4
,0.7
(28)
Heat loss through cooled surfaces is the sum of the
convective and radiative heat transfer to those
surfaces. Convective heat transfer is calculated
where Re is the Reynolds number and Pr is the
Prandtl number. The Prandtl number is defined by
equation 29:
I
129
-------
temperature:
Pr=
(29)
K
gas
and the Reynolds number is defined by equation 30:
Re =
PU°
(30)
where p is the gas density which is calculated by
equation 31:
p = MW
mole 530°R sft
mean 386,7 sft3
sn_ (31)
ft3
MWmean is the mean molecular weight of the gas as
calculated in equation 32:
MW
/ m. —
l
m
,
(32)
mean
and U is the gas velocity calculated from equation 33:
(lmi-mash) (33)
U = 4
pD2n
Radiation is the dominant mode of heat transfer at
typical incineration temperatures. The general
equation for emitted radiation is:
Radiation = eAoT4
(34)
where o is the Stefan-Boltzmann constant. Emitted
radiation can come from the gas, in which case e is
the emissivity of the gas, A is the total area of the
incinerator unit, and T is the gas temperature; or it
can come from the refractory wall (cooled surfaces
are assumed to be too cold to radiate significantly), in
which case £ is the emissivity of the refractory, A is
the refractory area, and T is the refractory wall
temperature.
Wall emissivity is assumed to be 0.8, typical of many
dirty refractories. Gas emissivity is calculated by
Johnson's (1973) (5) gray gas approach as described
by Richter (1981) (6) where the emissivity of the
absorbing gases is characterized as the sum of the
emissivities of three weighted gray components:
e = £a. 1-expf-K.BLJ (35)
L ^ » J
where BL is the mean beam length of the incinerator
and the weighting factor a; is a function of
c.
a. =b. + -
(36)
The absorption coefficient Kj is a function of the
partial pressures of the absorbing gases H20 and
C02:
where:
M
H2°
(37)
(38)
and
M
co
PC02 =
(39)
Values of b, c, and d are tabulated in Table E-4.
The emissivity due to soot is calculated as described
by Sarofim (1978) (7):
(40)
where FV is the volume of soot per volume of gas
and is calculated from:
FV =
(41)
J / m.—
sooty 4- i
m
ash
where Psoot >s assumed to be 2 g/cm3 and msoot is
assumed to be 2 percent of the volatile carbon.
(42)
m = 0.02 Y m.CxVol
soot ^- \ i
The emissivity of the composite gas is:
BL is the mean beam length of the incinerator. The
mean beam length is approximated by a curve fit to
beam lengths of a gas radiating to cylinders of
different dimensions:
130
-------
BL = 0.30 + 0.65 l-exp( :—J (44)
The radiative heat transfer calculation begins with
emissions from the gas. The emitted radiation strikes
the walls. The proportion which strikes the refractory
wall is determined by the ratio of the refractory area
to the total area with the remainder striking cooled
surfaces. The proportion of the radiation which is
absorbed by the wall is the same as the wall
emissivity, assumed to be 0.8 for both refractory and
cooled surfaces, the remainder being reflected. The
reflected radiation, along with radiation emitted from
the walls, passes through the gas. The proportion of
the radiation which is absorbed by the gas is the
same as the gas emissivity with the remainder
passing through to strike the far wall. Radiation is
followed in this manner, reflecting and being absorbed
by refractory walls and cooled surfaces and being
transmitted through and being absorbed by the gas
until a negligible proportion remains. Radiative heat
transfer from each element (gas, wall, and cooled
surface) is determined by:
Radiative Heat Transfer = Emission
— ^T Absorption
Table E-4. Weighted Gray Gas Constants
i b ; c, "R-i d. (ft-atm)-i
(45)
1
2
3
0.13
0.595
0.275
0.000147
-0.0000833
-0.0000639
0
0.258
8.107
Heat transfer from the outer shell to the ambient
surroundings is the sum of the heat transfer due to
free convection and radiation. Free convection is
calculated from a correlation for free convection from
a horizontal cylinder taken from McAdams (1953) (8):
Free Convection = 0.18
Btu/hr
°R
~ Tambient/ X Ashell
(46)
A Newton Raphson iterative technique is used to
solve equations 11 and 12 for an initial outer shell
temperature guess. Initial gas and wall temperatures
are estimated, and the left-hand sides of the
equations and their derivatives are solved. Revised
gas and wall temperatures are estimated from
equations 47 and 48:
T = T
gas new gas old
8(11)
8T
wall
8(12)
8T
(47)
wall
8(12) 8(11)
x
8T
gas
8T
wall
8(11)
8T
gas
8(12)
8T „
wall
T = T
wall new wall old
8(12) 8(11)
-(12)x
(48)
8T
8T
8(12) 8(11)
x
8T
gas
8T
wall
8(11) 8(12)
8T
8T
wall
The iterative process is continued until Tgas and Twa|l
yield solutions to the left hand sides of equations 11
and 12 with absolute values less than 1/10,000 of the
sensible heat in the unit. If the outer shell temperature
is not given, the outer shell temperature estimate is
revised, and the process is repeated until the
absolute value of the left-hand side of equation 13 is
also less than 1/10,000 of the sensible heat in the
unit. At this point, the energy balance is complete.
For fluidized-beds, heat transfer between the gas and
walls is assumed to be fast; thus, gas temperature
and wall temperature are assumed to be the same.
Equations 11 and 12 are combined so that only two
equations must be solved for Tgas and TShei|.
£.7.4 Residence Time
Mean residence time in a unit is calculated from the
temperature, volume, and volumetric flow of the unit:
Volumetric Flow (@T )
T + 460°R
(49)
= Volumetric Flow (@ 70°F) x
70°F
and radiation is calculated from equation 34 using 0.7
as the outer shell emissivity.
Volume
(50)
Volumetric Flow I
131
-------
£.1.5 Units In Series
For units in series, the products of complete
combustion along with the sensible heat they carry
are passed from one unit to the next and are added
to all the new inputs to the next unit. If ash drops out
of the first unit, its mass flow and sensible heat are
subtracted out and not passed to the second unit.
£.1.6 APCE
The APCE calculations in the current version of the
energy and mass balance simply determine the flow,
acid loading, and quench water requirement of the
effluent passing to the APCE. Developments are
currently underway to allow more detailed evaluations
of specific equipment performance such as ESPs,
venturi scrubbers, packed tower, cyclones, and FFs.
These will be incorporated into the software in future
updates.
Flow is calculated in terms of dry volumetric flow from
the last unit at standard conditions:
Dry Volumetric Flow (@ TOT)
Molar Flow. -M _x 386.7
2
o
sft
u _ .
H° Ibmole/
Acid loading is simply the mass flow of HCI from the
last unit:
Acid Loading = m
(52)
HCI
Quench water requirement is the amount of water
necessary to quench the effluent from the exit
temperature of the last unit to the temperature at
which the gas is saturated with water. All cooling is
assumed to occur by evaporation and changes in
sensible heat.
First, the saturation temperature is estimated. The
energy required to cool the gas to the saturation
temperature is calculated:
Sensible Heat
, t
exhaust p mean
T —T
exhaust saturated,
(53)
where the mean heat capacity is calculated from
equations 19 and 20. Then the amount of water
necessary to cool the exhaust gas is calculated:
Sensible Heat
rp m 1 ATT
p water saturated watery vap water
(54)
The water content of the effluent is compared with
the vapor pressure curve of water to determine how
close the effluent is to saturation. The saturation
temperature estimate is adjusted and equations 53
and 54 are recalculated. This iterative process
continues until the effluent is within 0.5°F of
saturation.
As the effluent cools from the quenched temperature
to the stack temperature, the vapor pressure of water
decreases and the excess water is assumed to drop
out so that the effluent remains saturated. Thus, the
total flow at the stack is calculated by .equation 55:
Stack Volumetric Flow (@70°F)
Dry Volumetric Flow (@ 70°F)
1 a tin — Vapor Pressure of Water
(@ stack temperature)
(55)
£.7.7 Limitations of the Current Procedure
The June 1987 version of the energy and mass
balance procedure is subject to the following
limitations:
1. It is only applicable to fuel-lean incinerators.
The complete combustion assumption is no
longer valid under fuel-rich situations.
2. It tends to overpredict temperatures in high-
temperature, nearly stoichiometric conditions
where significant equilibrium concentrations of CO
and OH exist.
3. It is not applicable to cold-wall, flame-
dominated incinerators where waste destruction
may be controlled by mixing and by flame
temperature which is very different from exit
temperature.
4. It is of limited value for incinerators which cannot
be characterized by a single mean temperature,
such as a long incinerator with a significant
temperature profile.
5. It does not account for unquantified heat losses
which are not evident in the input data. Heat
losses from often overlooked sources such as
water-cooled burners and probes, view ports,
gaps in the refractory, etc., may account for most
of the heat loss in some incinerators. Thus, the
program tends to overpredict temperatures in
incinerators with significant, unquantified heat
losses.
E.2 References
1. Daniels, F. and R.A. Alberty. Physical Chemistry.
New York: John Wiley and Sons. 1967, p. 53.
2. Hougen, O.A., K. Watson, and R.A. Ragatz.
Chemical Process Principles, Part I: Material and
132
-------
Energy Balances. New York: John Wiley and
Sons. 1967.
3. Perry, R.H. and C.H. Chilton. Chemical
Engineers' Handbook • Fifth Edition. New York:
McGraw-Hill. 1973.
4. Field,' MA, D.W. Gill, 8.B. Morgan, and P.G.W.
Hawksley. Combustion of Pulverised Coal.
Leatherhead: The British Coal Utilisation
Research Association. 1967, p. 119.
5. Johnson, T.R. and J.M. Beer. The Zone Method
Analysis of Radiant Heat Transfer: A Model for
Luminous Radiation. J. Inst. Fuel. 46:388. 1973.
6. Richter, W. Assessment of Pulverized Coal Fired
Combustor Performance—Models for Coal
Combustor Performance, Analytical Tool
Verification. Topical Report. DOE Contract No.
DE-AC-80PC30297. 1981.
7. Sarofim, A.F. and H.C. Hottel. Radiative Transfer
in Combustion Chambers: Influence of Alternative
Fuels. Washington: Hemisphere Publishers/
1978 pp. 199-217.
8. McAdams, W.H. Heat Transmission. New York:
McGraw-Hill. 1953, p. 177.
133
-------
-------
APPENDIX F
Example Reporting Forms
This appendix contains copies of blank forms that
may be used as a format guide to summarize the
results of the trial burn. These forms are only
intended to summarize certain, fundamental,
information in a format which will facilitate review of
the report. They do not call for all of the information
which is needed in a full trial burn report. Because
every incinerator system is somewhat different, in
many cases additional information will be necessary.
Conversely, some of the information listed on the
forms may not be needed for the evaluation. The
applicant should, however, be aware that using as
consistent as possible a format, for summarizing the
trial burn results will make it easier for the reviewer to
evaluate the report and, hence, expedite the
permitting procedure.
Table F-1 lists the forms and how they are to be
used. The forms are grouped into the following
categories:
1. Facility and design information, Forms 1 and 2--
This information should be included in the trial burn
plan as well as in the report.
2. Listing of the target settings for the trial burn,
Forms 3, 4, 5, and 6--This information can be
included in the trial burn plan as well as in the
report.
3. Summary of the system's operating conditions and
performance during the trial burn, Forms 3, 4, 5, 6,
7, 8, 9, 10 and 11--These forms can be used to
summarize the data for each run, they can also be
used to present a summary of the information for
each test of the trial burn. In this way, the reviewer
can evaluate the summary of the results of the trial
burn and if additional information on the runs for
that test is desired, it is it can be found on the
same form summarizing the results of each run.
4. Recordkeeping, Forms 10 and 12--These forms
can be used to keep the log of the monitoring
parameters required by the permit during operation
and during the trial burn, if needed.
These forms should be presented in the report on
only one side of the paper-no two-sided copies.
This allows the permit reviewer to spread them out
and compare the entries.
I
135
-------
Table F-1. Recommended Usage of Sample Forms In Trial Burn Report
Form no.
Tide
Number of copies/Purpose
1
2
3
4
5
7
8a
8b
9a
9b
9c
10
11
12
Summary of Facility Information
Summary of Design Information
Description of Waste Streams
Summary of Test Conditions (Waste Feed)
Summary of Operating Parameter Values
Summary of System Performance
Method 5 and Paniculate Results
Input Rates
Chloride Emissions
POHC Emissions (May be used for volatiles and semivolatiles
or use Form 9c for semivolatiles separately.)
POHC Input Rates
Semivolatile POHC Emissions (May be used in lieu of Form 9a
for semivolatile emission results.)
Monitoring Data for Halides and Inorganic Ash
and Operations
List of Samples
Emergency Shutdown and Permit Compliance Record
I/a
I/a
I/a
1 per test/b*
1 per test/b
1 per run/c
1 per test/b
1 per run/c
1 per run/c
1 per run/c -VM
1 per run/c
1 per run/c
1 per run/c
1 per run/c
1 per run/c
1 per test/d
I/Operation only
Note: Submit pages that have been copied on one side only to facilitate evaluation and review.
a To indicate the range of values that would be encountered during operation or to describe the facility.
b To summarize the results of each test, i.e., average of the runs for that test condition.
c To summarize the results of each run. (The average of these data for each test constitute to input to "b,"
above.)
d As a QA/QC check on the samples taken during the test.
*If waste composition changes for each run then Form 3 should be included to identify the actual composition of the
wastes burned during each run.
136
-------
Form 1. Summary of Facility Information
k
EPA facility ID No.
Facility name
Contact Person
Telephone No.
Facility Address
FJ*A Region
Person responsible for trial
burn report
Telephone No.
Company name
Address
Date -
Have proper QA/QC procedures
been followed? Yes No.
Person responsible for QA/QC
Title . __
Address •• •
Telephone No.
137
-------
Form 2. Summary of Design Information
Parameter Units
Incinerator ID
Installation date (year)
Type of incinerator
PCC SCC System
Inside dimensions :- ,_
(dia. x length or height x width x length)
Cross sectional area
Combustion chamber volume
Design heat release rate
Refractory thickness^
Refractory conductivity*1
Refractory surface areaa
I Cooled surface area3
Design pressure
ID fan capacity
Stack diameter
Stack height
APCE design information (as applicable)
Type(s) (quench, Venturi, ESP, etc.)
Maximum inlet temperature
Minimum inlet temperature
Maximum inlet pressure
Minimum inlet pressure
Design pressure drop (range)
Design liquid flow (range)
Design gas flow (range)
Surface area (bags, plates)
Voltage (specify AC/DC)
Current
HC1 removal capacity
Burner Waste Atomizing Type atomizing
identificationb Type stream(s) fluid pressures fluid
aRequired for mass and energy balance,
bQnly need to identify burners used for waste.
cif different from design specifications, explain.
138
-------
Form 3. Description of Waste Streams
Complete one of the following three columns:
Expected operating conditions Run results Test results, Test #.
(check) Run number Average of runs
Date Nos. •
Waste stream identifiers
Parameter Units
Type*
Typeoffeedb
Location of feed
Nominal feed ratec
Container size
Container typed
Container Frequency6
Physical state
HHV
Density
Viscosity
Ultimate Analysis
Water
Ash
Carbon!
Hydrogen!
Oxygen!
Chlorine^
Sulfur!
Nitrogen!
(continued)
-------
Form 3. Description of Waste Streams (concluded)
Waste stream identifiers
Parameter
Units
Organic Constituents (list)f
Metals and salts (list)
$Only organic and acid or acid-forming compounds of these fed to incinerator.
aHigh BTU liquid, aqueous waste, sludge, containerized solids, etc.
bSteam atomizing nozzle, ram feed, etc.
cLb/h, kg/h, etc.
dpiber drum, steel dram, etc.
&One container every 5 min.
fIdentify POHC's with an .asterisk (*).
-------
Form 4. Summary of Test Conditions-(Waste Feeds)
Test No.
(if data for a run)
Parameter
Data from each run or average for each test
(min. 3 runs = 1 test)
Units
Test Dates
Elapsed time average
Feed rate of each waste burned
1.
Size of containers
Maximum
Minimum
Mean
2.
Size of containers
Maximum
Minimum
Mean
3.
Size of containers
Maximum
Minimum
Mean
4.
Size of containers
Maximum
Minimum
Mean
5. _____
Size of containers
Maximum
Minimum
Mean
Total (mean) feed rate of all wastes to PCC
Total (mean) feed rate of all wastes to SCC
Auxiliary fuel used (total)
Fuel
Fuel
Fuel
(continued)
141
-------
Form 4. Summary of Test Conditions (Waste Feeds) (concluded)
Test No. Data from each run or average for each test
(if data for a run) (tnin. 3 runs = 1 test)
Parameter Units
Metals and salts
Organic Chloride
Other materials of concern
142
-------
Form 5. Summary of Operating Parameter Values
Test No. Data from each run or average for each test
(if data for a run) (min. 3 runs = 1 test)
Parameter Units
PCC temperature
Maximum
Minimum
Mean
SCC temperature
Maximum
Minimum
Mean
Combustion gas flowrate (identify on P&I or schematic where measured)
Actual T = ,P =
Maximum
Minimum
Mean
@STP T = ,P = .
Maximum
Minimum
Mean
Waste feed pressure
Atomizing fluid pressure
Combustion air blower power
ID fan power
PCC pressure
Maximum
Minimum
Mean
SCC pressure
Maximum
Minimum
Mean
APCE operating conditions
Quench
Inlet temperature mean
Outlet temperature mean
Water feed rate
Maximum
Minimum
Mean
(continued)
143
-------
Form 5. Summary of Operating Parameter Values (concluded)
Test No. Data from each ran or average for each test
(if data for a ran) (min. 3 runs = 1 test)
Parameter Units
APCE (as applicable)
Water/liquor flowrate
Maximum
Minimum
Mean
Inlet temperature mean
Exit temperature mean
Pressure drop
Maximum
Minimum
Mean
L/G ratio
Maximum
Minimum
Mean
Influent pH
Maximum
Minimum
Mean
Effluent pH
Maximum
Minimum
Mean
Scrubbant blowdown rate
Nozzle pressure
Maximum
Minimum
Mean
Plate voltage
Maximum
Minimum
Mean
Current
Maximum
Minimum
Mean
Sparking rate mean
144
-------
Form 6. Summary of System Performance
Test No. Data from each run or average for each test
(if data for a ran) (min. 3 runs = 1 tCSt)
Parameter Units
Performance
Flue gas
Flowrate (actual), mean
Flowrate (STP), mean
Velocity (actual), mean
Velocity (STP) mean
Flue gas composition (by volume)
H2O
O2 (by volume, dry)
N2 (by volume, dry)
CO2 (by volume, dry)
CO (by volume, dry)
Total unburned hydrocarbons
SOX
NOX
CO (corrected to 7% O2)
Maximum
Minimum
Mean
Paniculate emissions
Actual emission rate
Actual concentration
% Isokinetic
Concentration corrected to 7% O2
Metal
Metal
Metal
Metal
Emission rate
IntoAPCE
Out from APCE
% removal
(continued)
145
-------
Form 6. Summary of System Performance (concluded)
Test No.
(if data for a ran)
Parameter
Units
Data from each run or average for each test
(min. 3 runs = 1. test)
HCL
Emission rate
Into APCE
Out from APCE
% removal
POHC input
POHC emissions
DRE for POHC
146
-------
Form 7. Method S and Particulate Results3
Test or Run No.
Parameter
Units*
Sample time
Sample volume0
Stack gas volumetric flowrate
Stack gas volumetric flowrate0
Stack gas temperature
Stack gas moisture
Oxygen concentration0
Carbon dioxide concentration0
Percent isokinetic
Particulate collected
Paniculate concentration
Particulate concentration corrected
to 7% oxygen
% vol.
a Either metric or English units are acceptable as long as consistency is maintained throughout the report
b Dry standard basis.
c From Orsat analysis.
-------
Form 8a. Chlorine Input Rates
Test or ran no.
Test or run no.
Test or run no.
Waste/fuel stream
Feedrate
(kgAnin)
Chlorine
concentration
(%)
Chlorine
input rate
(gAnin)
Feedrate
(kgAnin)
Chlorine
Concentration
(*)
Chlorine
input rate
(gAnin)
Feedrate
(kgAnin)
Chlorine
concentration
(ft)
Chlorine
input rate
(gAnin)
•tx
00
Total
-------
Form 8b. HCI Emissions3.1* and Removal Efficiency
Sample Sample HCI Stack gas Cl* emission HCI emission HCI removal
Run No. period volume^ HCI collected*! concentratione flowratef rate rateg effciency(%)
CO
Blank value
a Either metric or English units are acceptable as long as consistency is maintained throughout (he report.
b This table is formatted to use chloride results from a single MM5 train (only one chloride emission sample is required per run). If two MM5 trains are run,
both sets of HCI data should be reported.
c Sample volume is dry standard liters of stack gas.
d Show value corrected for blank in parentheses.
e Blank corrected as applicable.
f Stack gas flow rate is dry normal (standard) m3/min.
g Chloride emissions (lb/h) x 1.03.
-------
Form 9a. POHC Emissions
Run No.
Trap pair
(for VOST)
Sample
period
Sample
(
Mass of each POHC collected
V> ( V> ( )»
( V» ( *« (
V»
Total/average*1
POHC concentration (
Stack gas flow rate (
Emission rate (
Oi
O
Total/averaged
POHC concentration (
Stack gas flow rate (
Emission rate (
Jb
)b
Average blank valued (
Standard deviationd (
Range of blank values^ (_
)b
Note: This format is structured for VOST results. It may be used for MM5, a similar format would be used for integrated bag sampling for volatiles. Guidance for blank correction is provided in the
"Practical Guide—Trial Bums for Hazardous Waste Incinerators," Final Report, EPA-600/2-86-050,1986.
Note: Use parentheses to present results if two collectors are used in series (i.e., dual adsoprtion tubes on VOST).
a Either metric or English units are acceptable as long as consistency is maintained throughout the report.
b Sample volume is dry standard liters of stack gas. d totals for sample period, volume, and amount collected; averages for concentration, flowrate, and emissions rate.
c Stack gas flowrate is dry nornial (standard) m^Anin. e Indicate whether all (both field blanks and trip blanks) are used or whether only field blanks are used.
-------
Form 9b. POHC Input Rate, [Test Run] No.
Waste/Fuel stream
Waste feedrateb
(kg/min)a
POHC concentration0 (%)a/feedrate (g/min)a
ORE
d
e
d
e
d
e
d
e
d
e
d
e
Total POHC feedrate
d
e
a Give units.
b Give feedrate measured during this run/test.
c Give concentration measured from sample taken during this test/run.
d Give concentration at POHC in each waste.
e Give feedrate of each POHC.
-------
Form 9c. Semivolatile POHC Emissions3
Run No.
Sample
period
Sample
volumeb
POHC collected
SV POHC No. 1 SV POHC No. 2
POHC concentration
SV POHC No. 1 SV POHC No. 2
Stack gas Emission rate
flowratec SV POHC No. 1 SV POHC No. 2
CD
ho
Average blank value
Standard deviation
Range of blank values
a Eilher metric or English units are acceptable as long as consistency is maintained throughout the report
b Sample volume is diy at standard conditions (specify),
c Slack gas flowrate is dry al standard conditions (specify).
NOTE: This form may be used in lieu of Form 9b for summarizing emission results for semivolatile compounds.
-------
&
Form 10. Monitoring Data for Halides and Inorganic Ash Inputs
Run/Test No.
Part A. Waste analysi
Waste name
Pumpable wastes
PL
P2.
P3.
Containerized wastes
Cl. _
C2. _
C3. _ _
Sample ID no(s).c
Maximum halides input rate =
Maximum inorganic ash input rate =
Total halides (%)
(F, Cl,Br, I)
Inorganic
ash(%)
Specific gravity
(continued)
-------
Form 10. Monitoring Data for Halides and Inorganic Ash Input9
01
PaitB. Calculation of input rates
Pumpable wastes Containerized wastes
Time period
0000-0400
0400-0800
0800-1200
1200-1600
1600-2000
2000-2400
Waste Avg. flowrate Mass feed
No. for period rate
PI
P2
P3
Total for pumpable wastes
PI
P2
P3
Total for pumpable wastes
PI
P2
P3
Total for pumpable wastes
PI
P2
P3
Total for pumpable wastes
Pi
P2
P3
Total for pumpable wastes
PI
P2
P3
Total for pumpable wastes
No.
Halide input Ash input Waste containers Total mass
rate rate No. charged charged
Cl
C2
C3
Total for containerized wastes
Cl
C2
C3
Total for containerized wastes
Cl
C2
C3
Total for containerized wastes
Cl
C2
C3
Total for containerized wastes
Cl
C2
C3
Toial for containerized wastes
Cl
C2
C3
Total for containerized wastes
Total Total
Mass feed Halide input Ash input Halide input Ash input
rate rate rate rate rate
_ _
_ _
_ —
_ —
_ _
_ _
_ _
_ _
- _
_ _
_ _
- _
(continued)
-------
CJ1
Form 10. Monitoring Data for Halides and Inorganic Ash Input3 (concluded)
Equations:**
Pumpable waste average flowrate (L/min) = Time-weighted average from continuously monitoring data logger
or
Volume at end of period (L) - volume at beginning of period (L)
240 min
Pumpable waste mass feed rate = average flowrate (L/min) x specific gravity (kg/L) x 60 min/h
n
Containerized waste total mass charged (KG) = £ Gross weight (kg) - container tare weight (kg)
en where n = number of containers charged during 4-h period
Total mass charged (kg)
Containerized mass feed rate =
4h
% Halide/ash
Halide/ash input rate = x Mass feed rate
100
a Either metric or English units are acceptable as long as consistency is maintained throughout the report.
" Begin new form for each new set of analysis results.
c If more than one sample is involved, list sample numbers and provide average results.
d For clarity metric units are shown; English units can be used if desired as long as consistency is maintained throughout the report.
-------
Form 11. List of Samples
Test No. Run No. Type sample ID no. Date taken Date analyzed Notesa
CJl
01
^Note any problems, i.e., broken sample (by whom or where), damaged samples, questionable data, problems with analytical equipment, etc.
-------
Form 12. Emergency Shutdown and Permit Compliance Record
Facility ID No._
Month Year
Automatic shutdown—check (V)
as appropriate Regulatoiy
Permit Minimum/maximum PCC waste SCC waste Time(min) authorities
exceedence value recorded automatic automatic Thermal relief waste Check (V) if notified
No. Date Time Description of problem (worst case) shutdown shutdown vent opened3 shut-off no shutdown^ Description of corrective action (yes/no)
1
2
3
^ 4
cn
•* 5
6
7
9
10
a This example form describes the information generally needed for an emergency shutdown and permit compliance record. However, more space should be provided in actual forms if
needed for adequate descriptions of problems and corrective actions.
b Exceedance based upon facility operational records (no automatic waste shutdown triggered); corrective actions to address any malfunction of automatic waste feed shutoff system
should also be described)
-------
APPENDIX G
Example Reporting Forms
Filled Out for Data from Example Problem
General Facility Information
159
-------
Form 1. Summary of Facility Information
EPA facility ID No.
Facility name
Contact Person
Telephone No.
Facility Address
12345G739
XYZ Chemical Company
John F. Smith
(111) 555-5555
13 Pumpkin Lane
Smith City, ST 12345
EPA Region
Person responsible for trial
burn report
Telephone No.
Company name
Address
XI
John F. Smith
see above
see above
Date
Have proper QA/QC procedures
been followed?
Person responsible for QA/QC
Title
Address
Telephone No.
June 13, 1988
Yes XX
Mary Jane Doe
No
Quality Assurance Manager
Chemical Laboratory Consultants
1313 Gourd Street
Juice City, ST 54321
(111) 555-6666
160
-------
Form 2. Summary of Design Information
Parameter
Units
Incinerator ID
Installation date (year)
Type of incinerator
Rotarv Kiln or RKI
1981
Rotar Kiln with STH
m _iy_
10° kJ/h 72
cm
m
Inside dimensions m x m
(dia. x length-wherghr/x-width-x-iength)
Cross sectional area
Combustion chamber volume
Design heat release rate
Refractory thickness^
Refractory conductivity^
Refractory surface area3
Cooled surface areaa
Design pressure
ID fan capacity
Stack diameter /area
Stack height
APCE design information (as applicable)
Type(s) (quench, Venturi, ESP, etc.)
Maximum inlet temperature
Minimum inlet temperature
Maximum inlet pressure
Minimum inlet pressure
Design pressure drop (range)
Design liquid flow (range)
Design gas flow (range)
Surface area (bags, plates)
Voltage (specify AC/DC)
Current
HC1 removal capacity
PCC
3.4 x 6.7
8.8
sec
3.G x 7.5
10.3
36
15
15
kj/stn- c n.nni44
kV
88
106
0
0
slightly neg. slightly neg,
System
108
570
0.61/1.17
4&^3-
3-stage wet ionizing scrubber
N/A-gas 4-water
N/A
NA
N/A
1 /mi' n
m /mi n
400-80n
4on_Rnn
30
variable, dependent on loading
unknown—to be determined by test
Burner
identificationb
B-l
B-2 a,b,c
Type
Air atomiz.
Air atomiz.
Waste
stream(s)
<;i
L1-L5 in PCC
L2-L5 in SCC
Atomizing
fluid pressures
'
20-50 psi
20-50 psi
Type atomizing
fluid
-N
/fl
Air
Air
^Required for mass and energy balance.
b(Dnly need to identify burners used for waste.
cif different from design specifications, explain.
161
-------
Form 3. Description of Waste Streams
O)
10
Complete one of the following three columns:
Expected operating conditions XX
(check)
Parameter
Typea
Typeoffeedb
Location of feed
Nominal feed ratec
Container size
Container typed
Container Frequency6
Physical state
HHV
Density
Viscosity
Ultimate Analysis
Water
Ash (wet basis)
Carbon:}: (wet basis)
Hydrogen:}: (wet basis)
Oxygen:}: (wet uasis)
Chlorine:}: (wet basis)
Sulfur! (wet basis)
Nitrogen^ (wet L>as i s )
Units
kq/min
gal
min
kJ/kg
% wt
% wt
% wt
% wt
°L wt
% wt.
% wt.
% wt.
Run results
Run number
Date
SI
solids
drum
PCC
18.6
SS
steel drum
1/6 min
solid
20,900
4
45
36
q
3.8
7.7
S2
solids
bulk
PCC
8.4
solid
20,600
20
39
28
11
7
Testn
Avera
Nos.
esults,Test#
ige of runs
Waste stream identifiers
LI L2 L3
Lo Btu liq
nozzle
PCC/SCC
31
liquid
nil
98.67
0.07
0.05
0.01
1
0.?
Hi Btu liq
nozzle
PCC/SCC
2
liquid
32,700
15
1
50
16
3
15
Hi Btu liq
nozzle
PCC/SCC
0.4
liquid
35,460
2
2
78
in
8
L4
Hi Btu Liq
nozzle
PCC/SCC
6
liquid
31,500
2
0.8
52.2
15
4
?fi
L5
Hi Btu Liq
nozzle
PCC/SCC
0.4
liquid
34,600
10
3
48
?n
14
5
(continued)
-------
IP
Form 3. Description of Waste Streams (concluded)
Parameter
Organic Constituents (list)f
Carbon
tetrachloricie
Trichloro-
ethylene*
Toluene
Chloroform
Perrhlorn-
et.hylenp*
R-Kt/'-rhlnrn)-
ethvlether
Tri <~hl nyn-
|->pr|7prip*
Phenol
Metals and salts (list)
Waste stream identifiers
Units SI S2 LI L2 L3 L4 L5
% wt (wet) 1.1 6.8 1R
°L wt (wet) l.fi - - - -- — fi
% wt (wet.) . n.i n_n? ifi
°L wt (wet) - — n Id _
°L wt (wet) in ,._
% wt (we1") - — — - l
% wt (wet) — -- — "5
% wt (wet) - - 26
$OnIy organic and acid or acid-forming compounds of these fed to incinerator.
aHigh BTU liquid, aqueous waste, sludge, containerized solids, etc.
bSteam atomizing nozzle, ram feed, etc.
CLb/h, kg/h, etc.
dfiber drum, steel drum, etc.
eQne container every 5 min.
fldentify POHC's with an asterisk (*).
-------
Form 3. Description of Waste Streams
Form 3. Description of Waste Streams
Complete one of the following three columns:
Expected operating conditions XA RUn results
(check)
. Run number
Date
Test results, Test #.
Average of runs
Nos.
en
Parameter
Waste stream identifiers
Units
SL
Type*
Typeoffeedb
Location of feed
Nominal feed ratec
Container size
Container typed
Container Frequency6
Physical state
HHV
Density
Viscosity
Ultimate Analysis
Water
Ash
Carbon:}:
Hydrogen:):
Oxygen}
Chlorine}
Sulfur!
Nitrogen}
kg/mi n
oal
kJ/ka
% wt
% wt
% wt
% wt
% wt
% wt
sludge
Lance
y
_
sludge
6.200
_ _-
__...._
70
14
10
3
2.99
0.01
(continued)
-------
Form 3. Description of Waste Streams (concluded)
Waste stream identifiers
Parameter
Units
en
in
Organic Constituents (list)f
Chlorobenzene % wt (wet) 0.03
Metals and salts (list)
$Only organic and acid or acid-forming compounds of these fed to incinerator.
aHigh BTU liquid, aqueous waste, sludge, containerized solids, etc.
bSteam atomizing nozzle, ram feed, etc.
cLb/h, kg/h, etc.
dpiber drum, steel drum, etc.
eQne container every 5 min.
fldentify POHCs with an asterisk (*).
-------
rr
Form 4. Summary of Test Conditions (Waste Feeds)
Test No. target
(if data for a run)
Parameter
Data from each run or average for each test
(min. 3 runs = 1 test)
Units Tests 1,2.3
Test Dates
Elapsed time average
Feed rate of each waste burned
l. SI (drummed waste)
Size of containers
Maximum
Minimum
Mean
2. SI (Ondgp)
Size of containers
Maximum
Minimum
Mean
3. LI (aqueou?)
Size of containers
Maximum
Minimum
Mean (PCC)
4. L2 (Hi Btu)
Size of containers
Maximum
Minimum
Mean (SCC)
5. L$ (Hi Btu)
Size of containers
Maximum
Minimum
Mean
N/A
55 gal dDjm_
Total (mean) feed rate of all wastes to PCC
kg/mln
Total (mean) feed rate of all wastes to SCC
kg/mi n
Auxiliary fuel used (total)
Fuel
Fuel
Fuel
kg/mi'n ?7
kg/min JL
kg/min 31
kg/min 2.3
kg/mi n 6
JZS_
a<; needed to maintain temperatures
(continued)
166
-------
Form 4. Summary of Test Conditions (Waste Feeds) (concluded)
Test No. target Data from each run or average for each test
(if data for a nm) (min. 3 runs = 1 test)
Parameter Units IPS t.s 1 .9,3
Metals and salts
Organic Chloride S/"11'" 2»650
Other materials of concern
Nnnp
167
-------
Form 5. Summary of Operating Parameter Values
Test No. target
.(if data for a run)
Parameter
Data from each run or average for each test
(min. 3 runs = 1 test)
Units Tests 1.2,3
PCC temperature
Maximum
Minimum
Mean
SCC temperature
Maximum
Minimum
Mean
900
i .nnn
Combustion gas flowrate (identify on P&I or schematic where measured)
Actual T= ftnrr .P= 1 atm
Maximum
Minimum
Mean m /min
@STP T=
Maximum
Minimum
Mean
Waste feed pressure
Atomizing fluid pressure
Combustion air blower power
ID fan power
PCC pressure
Maximum
Minimum
Mean
SCC pressure
Maximum
Minimum
Mean
APCB operating conditions
Quench
Inlet temperature mean
Outlet temperature mean
Water feed rate
Maximum
Minimum
Mean
.P= 1 a tin
*C
m /min 500
N/A
N/A
N/A
-80
L/rmn UOTT
(continued)
168
-------
Form 5. Summary of Operating Parameter Values (concluded)
Test No. target
(if data for a run)
Parameter
Units
Data from each run or average for each test
(min. 3 runs = 1 test)
APCE (as applicable)
Water/liquor flowrate
Maximum
Minimum
Mean
Inlet temperature mean
Exit temperature mean
Pressure drop
Maximum
Minimum
Mean
L/G ratio
Maximum
Minimum
Mean
Influent pH
Maximum
Minimum
Mean
EffluentpH
Maximum
Minimum
Mean
Scrubbant blowdown rate
Nozzle pressure
Maximum
Minimum
Mean
Plate voltage
Maximum
Minimum
Mean
Current
Maximum
Minimum
Mean
Sparking rate mean
Stage 1 Stage 2 Stage 3 Total APCE
I /min
Idfi
Tb
.2
.2
L/min
N/A
-161-
-80-
N/A
7.0
N/A
15
N/A
30
169
-------
Form 6. Summary of System Performance
Test No. t.argpt
(if data for 8 run)
Parameter
Units
Data from each run or average for each test
(min. 3 runs = 1 test)
Performance
Flue gas
Flowrate (actual), mean
Flowrate (STP), mean
Velocity (actual), mean
Velocity (STP) mean
•3
HI /min 614 614
m3/min 510 510
RgQ
490
Flue gas composition (by volume)
H2O
O2 (by volume, dry)
N2 (by volume, dry)
CO2 (by volume, dry)
CO (by volume, dry)
Total unbumed hydrocarbons
SOX
NOX
ta b lished— by
cnndi'f"l'np(;
CO (corrected to 1% O2)
Maximum
Minimum
Mean
Paniculate emissions
Actual emission rate
Actual concentration
% Isokinetic
Concentration corrected to 1% O2
Metal
Metal
Metal
Metal •
Emission rate
Into APCE
Out from APCE
% removal
ppm
<100
<100
<100
To be measured.
(continued)
170
-------
Form 6. Summary of System Performance (concluded)
Test No. target
(if data for a run)
Parameter
Data from each run or average for each test
(min. 3 runs = 1 test)
Units Tests 1,2,3
HCL
Emission rate
IntoAPCE
Out from APCE
% removal
POHC input
tn'chloroethylene
perchloroethvlene
trichlorobenzene
To be measured.
353
/mm
/min
/min 835
220
POHC emissions
To be measured.
ORE for POHC
Tn
k
171
-------
Summary of Results of Tests 1,2, and 3
(Results of each test are means of the results of the three runs for that test.)
172
-------
Form 3. Description of Waste Streams
CJ
Complete one of the followin
Expected operating condition
Parameter
Type*
Typeoffeedb
Location of feed
Nominal feed rateC
Container size
Container typed
Container Frequency^
Physical state
HHV
Density
Viscosity
Ultimate Analysis
Water
Ash
Carbon!
Hydrogen!
Oxygen$
Chlorine!
Sulfur^
Nitrogen!
ig three columns:
IS
(check)
Units
kq/min
% wt
% wt
% wt
% wt
% wt
% wt
% wt
% wt
Run results
SI
solids
drum
PCC
27
55 qal.
steel drum
I/minutes
4
45
36
9
3.8
2.2
Run number
Date
SL
sludqe
lance
PCC
9
N/A
70
14
10
3
2.99
0.01
Test i
Aven
Nos. .
esults. Test #1,2,3
igeof runs
1 2 3
Waste stream identifiers
LI L2 L4
water
nozzle
PCC
30
N/A
98.67
0.07
0.05
0.01
1
0.2
Hi Btu lid)
nozzle
PCC
2.3
N/A
15
1
50
16
3
15
Hi Btu liq
nozzle
sec
6
N/A
2
0.8
52.2
15
4
26
(continued)
-------
__
o
u
7T
£
s
w
o
Form 3. Description of Wast
^
0 ^
•a
c
g
Crt
Jj
—
t/
^
a
'S
>-)
Parameter
Organic Constituents (list/
Carbon-
CO
'-'
00
VD
•-
4->
0)
4J
3
S3
tetrachloride
Trirhloro-
*-°
10
i — i
O
1
1
1
1
1
OJ
o
0
0)
4J
2
&S
OJ
cu
-3
h-
^
i — 1
O
OJ
2
4->
2
&s
Chloroform
Perchloro-
O
i — i
0)
.(_>
2
6-S
ethvlene*
0
0
^=
o
OJ
to
•I—
CO
1 — 1
1
1
1
1
tu
4J
3
&«
ethvlether
i
o
o
u
•r—
S-
h-
LO
4J
Ol
2
+j
2
s«
benzene*
Ol
4J
2
&«
Phenol
;
i
1
ro
O
O
4J
Ol
2
4J
2
5«
Chlorobenzene
Metals and salts (list)
tH
§
TO
fe
.S
•S .
2 ^
S «"
**H *O
O UH
*i3 *rt
o .9
1! :
u So
e5^ H
'g "w °. *^
to M
& •#
- •* e S
•« S S . «
tOnly organic and acid or a<
aHigh BTU liquid, aqueous
bSteam atomizing nozzle, ra
CLb/h, kg/h, etc.
dpiber drum, steel drum, etc
eOne container every 5 min.
fidentify POHC's with an as
174
-------
Form 4. Summary of Test Conditions (Waste Feeds)
Test No. summary of test results
(if data for a run)
Parameter Units
Data from each run or average for each test
(min. 3 runs = 1 test)
Test 1 Test 2 Test 3
Test Dates
Elapsed time average
Feed rate of each waste burned
l. SI drummed
Size of containers
Maximum
Minimum
Mean
2. SL sludge
Size of containers
Maximum
Minimum
Mean
5/1?-13/87 5/13-14/87 5/15-16/87
kg/mi n 277D~
kg/min S7T
3- LI aqueous
Size of containers
Maximum
Minimum
Mean
4- 12 Hi Btu liq (PCC)
Size of containers
Maximum
Minimum
Mean
5. 14 Hi Btu liq (SCC)
Size of containers
Maximum
Minimum
Mean
kg/min 30.0
kg/min 2.2
kg/min 5.9
Total (mean) feed rate of all wastes to PCC
kg/min 72.6
Total (mean) feed rate of all wastes to SCC
kg/min 5.9
120
7TF"
27T
6.0
73.2
6.0
Auxilliary fuel used (total) (mean per run for each test)
Fuel natural gas kg/min 5.71 5.65
Fuel
Fuel
120
'd/.O
T7b
?ft ft
~6TO~
69.0
6.0
5.60
(continued)
175
-------
Form 4. Summary of Test Conditions (Waste Feeds) (concluded)
Test No. summary of test results
(if data for a run)
Parameter Units
Data from each run or average for each test
(min. 3 runs = 1 test)
Test 1 Tpst. ? Tpst. 3
Metals and salts
Organic Chloride
Other materials of concern
g/min
176
-------
Form 5. Summary of Operating Parameter Values
Test No. summary of test results Data from each run or average for each test
(if data for a run) (min. 3 runs = 1 test)
Parameter Units Test 1 Test 2 Test 3
PCC temperature
Maximum
Minimum
Mean
SCC temperature
Maximum
Minimum
Mean
Combustion gas flowrate (identify on
Actual T = 7] -P= J.
Maximum
Minimum
Mean
(S>STP T= 20*C .P =
Maximum
Minimum
Mean
Waste feed pressure
Atomizing fluid pressure
Combustion air blower power
ID fan power
PCC pressure
Maximum
Minimum
Mean
SCC pressure
Maximum
Minimum
Mean
APCE operating conditions
Quench
Inlet temperature mean
Outlet temperature mean
Water feed rate
Maximum
Minimum
Mean
*C 916
'C 910
•C 914
T. 1 304q
r i arun
821
804
814
i jOin
QR4
qR?
804
733
fiOO
Q71
qR4
qtiR
P&I or schematic where measured)
atia
m /min 8Q2
m /min 8^0
m /min RfiK
1 atm
m /min 515
m.r/min 481
m /min 501
Dsi "3Q
|J J 1 U
N/A
mm H-,0 -l.fi
MUM •"2': * • •
mrri H->0 -7.7
2
mm H_0 -7.fi
/_'
mm H/jO -R.fi
mm H ^0 -8.?
2
•r
1 OdO
^ 78
965
852
L/min 910
892
830
Sfifi
518
496
508
-IP measured,
30
N/A
-2 n
-? n
-?.n
-R.q
-R q.1
-R.q
032
80
927
840
886
8^8
813
097
4Q8
484
4Q2
30
N/A
-2 fi
-? n
-9 4
-R.I
-R.fi
-R 4
Q58
79
958
8/1
91b
(continued)
177
-------
Form 5. Summary of Operating Parameter Values (concluded)
TestNo. summary Of test results Data from each run or average for each test
(if data for a ran) (min. 3 TUHS = 1 test)
Parameter , Units Jest I Jest 2 Jest ? •• -
APCE (as applicable)
Water/liquor flowrate
Maximum
Minimum
Nozzle pressure
Maximum
Minimum
Plate voltage
Maximum
Minimum
Mean
Current
Maximum
Minimum
Mean
Sparking rate mean N/A
Mean l/mln 606 606 606
Inlet temperature mean 'C 78 80 79
Exit temperature mean i*- '_± '*•
Pressure drop
Maximum
Minimum
Mean N/fl N/fl
Mean N/A N/A
L/G ratio
Maximum
Minimum _
Mean 0.70 0.70 HTTP"
Influent pH (into IWS) .
Maximum P_H 6.8 7.5 7.3
Minimum P_H 6.3 6.7 6.9
Mean P_H 6.6 7.1 7.1
EffluentpH (out of IWS) .
Maximum P_H 4.7 3.1 4.1
Minimum Pjj 2.9 2.9 3.3
Mean P_H 3.8 3.0 3.7
Scrubbant blowdown rate
178
-------
Table G-1. Response to APCE Parameters, Form 6 "Summary of Test Results"
Test No.
Parameter Units 1
IWS water flowrates
1st stage IWS water flowrate L/min 322 322 321
2nd stage IWS water flowrate L/min 142 142 142
3rd stage IWS water flowrate L/min 142 142 142
Total L/min 606 606 606
IWS current and voltage
IWS Unit 1A-DC Current mA 23.3 23.2 23.5
IWS Unit 1A-DC Voltage kV 30.5 30.0 29.1
IWS Unit IB-DC Current mA 16.1 14.9 15.6
IWS Unit IB-DC Voltage kV 31.2 30.8 29.4
IWS Unit 2A-DC Current mA 104.9 94.5 109.8
IWS Unit 2A-DC Voltage kV 27.9 29.0 26.2
IWS Unit 2B-DC Current mA 101.1 94.2 94.2
IWS Unit 2B-DC Voltage kV 28.8 29.0 25.9
179
-------
Form 6. Summary of System Performance
Test No. summary of test results
(if data for a run)
Parameter Units
Data from each run or average for each test
(min
Test 1 Test 2
(min. 3 runs = 1 test)
" " Test J
Performance
Flue gas
Flowrate (actual), mean
Flowrate (STP), mean (wet)
Velocity (actual), mean( wet)
ppra—
CO (corrected to 1% 02)
Maximum
Minimum
Mean
Paniculate emissions
Actual emission rate
Actual concentration
% Isokinetic
Concentration corrected to 1% O2
Metal
Metal
Metal
Metal
Emission rate
Into APCE
Out from APCE
% removal
501
IZ7T
Velocity (STP)mean (wet) m/s 10.5
Hue gas composition (by volume)
H20
O2 (by volume, dry)
N2 (by volume, dry)
CO2 (by volume, dry)
CO (by volume, dry)
Total unburned hydrocarbons
SOX
NOX
32
10
8i
1 .
.4
./
.6
/
31. Z
48
mg/rm'B 12.9
-- /l'-J 38.2
59.5
508
12.3
10.5
32.4
8T74
71
22.1
64.4
100.4
492
TT78
10,1
32.4
TTTl
bU.b
80
15.8
47.5
75.4
(continued)
180
-------
Form 6. Summary of System Performance (concluded)
Test No. summary of test results Data from each run or average for eaeh test
(if data for a run) (min. 3 runs = 1 test)
Parameter Units Test 1 Test 2 Test 3
HCL
Emission rate
IntoAPCE
Out from APCE
% removal
ka/h
kg/h
%
1.06
200
99.47
0.64
156
99.59
1.29
153
99.16
POHC input
tn'rhlnrnpthylpnp g/min 353
tptrachlnrnpthylene g/min 222
tn'rhlnrnbpnzene g/min 82S_
POHC emissions
tri rhlnropt.hyl PPP g/min 0.0082
tptrar.hlnrnpthyl pnp g/mi n 0.0036
trirhlnrobpnzenp g/min 0.0166
DRE for POHC
trirhlnrnPthylene % 99 998 99,998 99,997
t.P.t.rarhl nrnpthyl pnp % 99.998 99.997 99.998
tHrh1r>rnhpn7pnP % 99.998 99.996 99.996
181
-------
Summary of Results
Runs 1-1,1-2, and 1-3
182
-------
Form 4. Summary of Test Conditions (Waste Feeds)
Test No. ]
(if data for a run)
Parameter each
Test Dates
Elapsed time average
Units 1~1
Data from each run or average for each test
(min. 3 runs = 1 test)
1-2V 1-3
5/12/88 5/12/88 5/13/88
min 120
120 120
Feed rate of each waste burned
l. SI drummed (PCC)
Size of containers
Maximum
Minimum
Mean
2. SL sludge (PCC)
Size of containers
Maximum
Minimum
Mean
3. LI aquoeous (PCC)
Size of containers
Maximum
Minimum
Mean
4. 12 Hi Btu (PCC)
Size of containers
Maximum
Minimum
Mean
5. L4 Hi Btu (SCC)
Size of containers
Maximum
Minimum
Mean
Total (mean) feed rate of all wastes to PCC
Total (mean) feed rate of all wastes to SCC
55 gal
Auxiliary fuel used (total)
Fuel natural gas
Fuel
Fuel
kg/min
27.2
kg/mi n
8.32
kg/min
30.3
kg/min
2.19
kg/min
€C
5.90
68.0
CC
5.90
kg /min
5.71
55 gal
26.5
8.32
30.3
2.23
5.75
67.4
5.75
5.70
55 gal
25.7
9.08
28.8
2.27
5.9B
65.9
5.98
5.71
(continued)
183
-------
Form 4. Summary of Test Conditions (Waste Feeds) (concluded)
Test No. 1 Data from each run or average for each test
.(if data for a run) (min. 3 runs = 1 test)
Parameter each Units 1-1 1-2 1-3
Metals and salts
none
Organic Chloride
Other materials of concern
184
-------
Form 5. Summary of Operating Parameter Values
JL
Test No..
(if data for a run)
Parameter
Units
Run 1-1
Data from each run or average for each test
3 runs = 1 test)
Run 1-3
Run
PCC temperature
Maximum
Minimum
Mean
SCC temperature
Maximum
Minimum
Mean
942-
94S-
9i€-
•c
•c
1,118
1,115
1,022
1,113
•c
1,020
1,049
1,019
1.038
1,032
Combustion gas flowrate (identify on P&I or schematic where measured)
• Actual T = .p= 1 atm
Maximum? quench outlet
Minimum ->
Mean
@STP T= 2Q'C
Maximum
Minimum
Mean
Waste feed pressure
Atomizing fluid pressure
Combustion air blower power
ID fan power
PCC pressure
Maximum
Minimum
Mean
SCC pressure
Maximum
Minimum
Mean
APCE operating conditions
Quench
Inlet temperature mean
Outlet temperature mean
Water feed rate
Maximum
Minimum
Mean
m /min 931
.p= 1 atm
956
845
m /min
psi _~
867 891
Not measured.
30 30
N/A N/A
787
30
N/A
Not measured.
-T75~
-2.6
-2.5
mm FLO -8.0
-8.4
-7.6
Same as SCC temperature.
"C 79 79 77
L/min 852
912
965
(continued)
185
-------
Form 5. Summary of Operating Parameter Values (concluded)
1
Test No. __
(if data for a run)
Parameter
Units
Data from each run or average for each test
(min, 3 runs = 1 test)
Run 1-1 Run 1-2 Run 1-3
APGE (as applicable)
Water/liquor flowrate
Maximum
Minimum
Mean
Inlet temperature mean
Exit temperature mean
Pressure drop
Maximum
Minimum
Mean
L/G ratio
Maximum
Minimum
Mean
Influent pH
Maximum
Minimum
Mean
Effluent pH
Maximum
Minimum
Mean
Scrubbant blowdown rate
Nozzle pressure
Maximum
Minimum
Mean
Plate voltage
Maximum
Minimum
Mean
Current
Maximum
Minimum
Mean
Sparking rate mean
See next page.
L/min 603
603
PH
PH
PH
71
72
I/in 0.65
0.63
pH 6.3
6.9
6.6
6.3
6.7
4.1
4.3
2.9
3.5
3.6
4.0
N/A
See next page.
SPP npxt pagp.
603
71
0.71
6.6
6.1
6.5
4.2
3.5
3.8
N/A
186
-------
Table G-2. Response to APCE Parameters, Addendum to Form 5
Parameter
IWS water flowrate
1st stage IWS water flowrate
2nd stage IWS water flowrate
3rd stage IWS water flowrate
Total
IWS current and voltage
IWS Unit 1A-DC Current
IWS Unit 1A-DC Voltage
IWS Unit IB-DC Current
IWS Unit IB-DC Voltage
IWS Unit 2A-DC Current
IWS Unit 2A-DC Voltage
IWS Unit 2B-DC Current
IWS Unit 2B-DC Voltage
Units
L/min
L/min
L/min
L/min
mA
kV
mA
kV
mA
kV
mA
kV
1-1
321
142
142
605
33.8
30.0
21.1
•31.1
94.2
28.2
105.4
28.8
Run No.
1-2
322
142
142
606
21.8
30.5
16.5
30.6
126.1
27.8
116.2
29.0
1-3
322
142
142
606
14.2
31.0
10.7
31.8
94.4
27.7
81.7
28.5
187
-------
Form 6. Summary of System Performance
Test No.
(if data for a run)
Parameter
Units
Data from each run or average for each test
(min. 3 runs = 1 test)
1-1 1-2 1-3
Performance
Flue gas
Flowrate (actual), mean
Flowrate (STP), mean
Velocity (actual), mean
Velocity (STP) mean
Flue gas composition (by volume)
H20
O2 (by volume, dry)
N2 (by volume, dry)
CO2 (by volume, dry)
CO (by volume, dry)
Total unbumed hydrocarbons
SOX
NOx
3
m /min 866
m3/min 501
m/«s 7.1
t 3?.0
1 10.55
' «L 89.3
°L 7 ?
nnm 4^,2
866
508
12.3
7.2
33.0
10.60
RI .3
R.I
?0 3
827
492
11.8
7.0
32.2
10.81
81.3
7.9
34. Q
nnm
rr"1
CO (corrected to 7% O2)
Maximum
Minimum
Mean
Paniculate emissions
Actual emission rate
Actual concentration
% Isokinetic . % -
Concentration corrected to 7% O2 mg/Nm
Metal
Metal :
Metal
Metal
Emission rate
Into APCE
Out from APCE
% removal
P.? n
98.7
80.2
9Q.Q
97.1
65.5
98.8
32.8
(continued)
188
-------
Form 6. Summary of System Performance (concluded)
Test No.
(if data for a run)
Parameter
Units
1-1
Data from each run or average for each test
(min. 3 runs = 1 test)
1-2 _ 1-3
HCL
Emission rate
IntoAPCE
Out from APCE
% removal
g/min
g/mi n
Q.34
9,520
13. ft
qq.43
7, ssn
17.fi
qq.31
pprrhlnrnpthylpnp
r
g/min 353
g/mi n
g/mip
345
360
7Qd
POHC emissions
trichloroethylene g/min 0.014
pprchloroethylene g/min 0.0022
t.n'r.h1ornhp7pnp g/mi n 0.0418
0:0069
0.0066
0.0017
0.0036
0.0020
0.0064
tnchloroethyl
ene
99.9960 99.9980 99.9990
perchloroethylene
tnchlorobenzene
yy.yyyb
189
-------
Form 7. Method 5 and Paniculate Results3
CO
o
Parameter
Sample time
Sample volume^
Stack gas volumetric flowrate
Stack gas volumetric flowrate^
Stack gas temperature
Stack gas moisture
Oxygen concentration0
Carbon dioxide concentration0
Percent isokinetic
Paniculate collected
Paniculate concentration
Paniculate concentration corrected
to 7% oxygen
Unitsa
min
Mm3
3. .
m /mm
Nm /min
•c
% vol.
%
%
%
mq
mq/Nm
mg/Nm
1-1
120
2.013
875
507
71
32.0
10.8
7.2
98.7
117. 0
58.1
80.?
Test or Run No.
1-2
120
2.015
892
515
72
33.0
10.6
8.1
97.1
98.?
48.7
fifi.fi
1-3
120
1.914
830
481
71
32.2
10.7
7J9
98.8
4fi.3
?4 ?
M. 8
a Either metric or English units are acceptable as long as consistency is maintained throughout the report.
b Dry standard basis.
c From Orsat analysis.
-------
Form 8a. Chlorine Input Rates
CD
Test or run no. 1 ~ 1
Waste/fuel stream
Drummed waste
(SI)
Sludae (SL)
Organic liciuid-
kiln (L2)
Organic liquid-
scc (L4)
Wa«;tpwat.pr-
kiln (LI)
Natural qas
Feedrate
(kg/min)
27.2
8.32
2.19
5.90
30.. 1
5.71
Chlorine
concentration
(%)
2.29
0.0098
15.4
?fi.6
0.200
N/A
Chlorine
input rate
(g/min)
624
0.9
1,570
fii
Test or run no. 1-2
Feedrate
(kg/min)
26.5
8.32
JL23_
5.75
30.3
S 70
Chlorine
Concentration
(%)
2.21
0.0096
15.2
2fi.?
n IQQ
N/A
Chlorine
input rate
(gMin)
585
0.8
329_
1 , 530
fin
Test or run no. 1-3
Chlorine .
Feedrate concentration
(kgAnin) (%)
25 7 2 22
9.08 0.0094
2.27 14.7
FJ.QR 2fj.5
?ft.R 0 200
5.71 N/A
Chlorine
input rale
(g/min)
570
0.8
337
i .RQO
fin
Total
2.590
78.8
2.520
2,550
-------
Form 8b. HCI Emissions3.13 and Removal Efficiency
CO
ro
Sample Sample HCI Stack gas Cl~ emission
Run No. period volumec HCI collectedd concentratione flow ratef rate
1-1 120 2.013 9.15 ( 18.4 ) 507 9.34 0.560
1-2 120 2.015 13.35 ( 26.9 ) 515 13.8 0.831
1-3 120 1.914 19.14 (36.6 ) 481 17.6 1.057
HCI emission HCI removal
rateg effciency (%)
1.24 99.64
1.83 99.45
2.33 99.31
( ,
( }
( }
( >
( }
( }
( )
( }
Blank value 0.12
a Either metric or English units are acceptable as long as consistency is maintained throughout the report.
b This table is formatted to use chloride results from a single MM5 train (only one chloride emission sample is required per run). If two MM5 trains are run,
both sets of HCI data should be reported.
c Sample volume is dry standard liters of stack gas.
d Show value corrected for blank in parentheses.
e Blank corrected as applicable.
f Stack gas flow rate is dry normal (standard) m3/min.
g Chloride emissions (Ib/h) x 1.03.
-------
Form 9b.POHC Input Rate, [RunJ No. 1-1
CO
CO
Waste feedrate
Waste/Fuel stream (kg/min)a
SI drummed 27.2
SL sludge 8.32
LI aqueous 30.3
12 Hi Btu lid (PCC) 2.19
b POHC concentration0 (%)a/feedrate (g/min)a DRE
TCE PCF. TCB
d <0.0002 <0.0002
e
d < 0.0003 <0.0004
e ~
d <0.0017 <0.0019
d <0.0016 10.0
1.97
536
<0.0006
< 0.0028
<0.0024
e 220
L4 Hi Btu liq (SCCl 5.90
Auxiliary fuel, natural 5.71
qas
d 5.98
-------
Form Sb.POHC Input Rate, [Run] No. 1-2
Waste feedrateb POHC concentration0 (%)a/feedrate (g/min)a ORE
Waste/Fuel stream flcp/muOa TCE PCE TCB
SI drummed 26.5 d < 0.0002 < 0.0002
SL sludae 8.32 d <0.0003 ^0.0004
e
11 aqueous 30.3 d /O.D017 <0.001Q
e
1.97
522
<0.0006
CO.OD2R
i? ni Rtu liq (prr.) '.?.? d
-------
Form Sb.POHC Input Rate, [Run] No. 1-3
CO
Ul
Waste feedrate1
Waste/Fuel stream (kg/min)a
SI drummed 25.7
SL sludge 9.08
LI aqueous 28.8
L2 Hi Btu liq (PCC) 2.27
b POHC concentration0 (%)a/feedrate (g/min)a DRE
TCE PCE TCB
d 0.0002 0.0002
e
d 0.0003 0.0004
e
d 0,0017 0.0019
e ~
d 0.0016 10.0
1.97
506
0.0006
0.0028
0.0024
e 227
L4 Hi Btu liq (SCO) 5.98
Auxiliary fuel, natural 5.71
gas
d 5.98 0.0018
e 347
d
e
5.06
293
d
e
Total POHC feedrate
347 227
799
a Give units.
b Give feedrate measured during this run/test.
c Give concentration measured from sample taken during this test/run.
d Give concentration at POHC in each waste.
e Give feedrate of each POHC.
-------
Figure G-1. Strip chart recording of combustion temperatures - run 1-1.
1000
1500
^^
£ 2000
o
Y~r'~A^^
J? K. ••.
8
8
S
2500
I I t 1 I i i I I I I I I i I I III
196
-------
Figure G-2. Plot of corrected CO readings from data logger 1-min averages - run 1-1;
,- 100'
90-
CO (Corrected 7% OJ vs Time
1250 1300 1310 1320 1330 1340 1350 1400 1410 1420 1430 1440 1450 1500 1510 1520 1530 1540 1550
Minutes
197
-------
I
"8
o
2
S*N^
CO
CTi
01
Lf)
co
00
CM
r-.
o
in
a e
I 8
CTi
CO
CTi
en
—1 CS M
I
CM
CTl
CM
o
o
ID
s^
\ 3
a>
3^
d E
a .1
£ "8
.a
S
198
-------
Form 9a. POHC Emissions
Form 9a. POHC Emissions
Sample Sample
Trap pair period volume
Ron No. (forVOST) (min )b (J Jb
Mass of each POHC collected
TC-E-
J» (_
J" L
-M 19.a _135_<
2 4Q 19.9 67 (
3 _4Q_ 20.0
Total/average* 120 59.7
POHC concentration f JJfl/1 ft 4.?
Stack gas flow rate (pm /min
Emission rate (J
7fi
if nm /min ft
i/min ft
CD
CD
Total/average*1
POHC concentration (
Stack gas flow rate (
Emission rate (
J>
Average blank value^ (
Standard deviation1* (
Range of blank values^ (_
Jb
Note: This format is structured for VOST results. It may be used for MM5, a similar format would be used for integrated bag sampling for volatiles. Guidance for blank correction is provided in the
"Practical Guide—Trial Bums for Hazardous Waste Incinerators," Final Report, EPA-600/2-86-Q50,1986.
Note: Use parentheses to present results if two collectors are used in series (i.e., dual adsoprtion tubes on VOST).
a Either metric or English units are acceptable as long as consistency is maintained throughout the report.
b Sample volume is dry standard liters of stack gas. d totals for sample period, volume, and amount collected; averages for concentration, flowrate, and emissions rate.
c Stack gas flowrate is dry normal (standard) m3/min. e Indicate whether all (both field blanks and trip blanks) are used or whether only field blanks are used.
-------
Table G-3. Combustion Temperature Data Taken From Strip Chart - Run 1 '••"
Time
(niin)
1250
1251
1252
1253
1254
1255
1256
1257
1258
1259
1300
1301
1302
1303
1304
1305
1306
1307
1308
1309
1310
1311
1312
1313
1314
1315
1316
1317
1318
1319
1320
1321
1322
1323
1324
1325
1326
1327
1328
1329
1330
1331
1332
1333
1334
1335
sec
Temp
(°F)
1889
1894
1893
1872
1913
1925
1898
1901
1906
1917
1918
1892
1904
1919
1899
1889
1898
1919
1923
1889
1906
1927
1932
1903
2004
1936
1920
1893
1904
1921
1922
1899
1899
1896
1911
1878
1880
1901
1901
1885
1880
1887
1900
1886
1890
1885
Kiln
Temp
(°C)
1688
1689
1623
1595
1693
1730
1661
1616
1613
1743
1699
1653
1677
1693
1699
1660
1678
1700
1710
1682
1693
1710
1679
1564
1685
1743
1670
1591
1613
1741
1722
1671
1669
1702
1694
1649
1679
1695
1703
1693
1674
1724
1624
1589
1603
1685
Time
(min)
1336
1337
1338
1339
1340
1341
1342
1343
1344
1345
1346
1347
1348
1349
1350
1351
1352
1353
1354
1355
1356
1357
1358
1359
1400
1401
1402
1403
1404
1405
1406
1407
1408
1409
1410
1411
1412
1413
1414
1415
1416
1417
1418
1419
1420
1421
sec
Temp
(°F)
1894
1891
1885
1894
1927
1929
1941
1967
2045
1985
1980
1973
1985
1983
1955
1971
1961
1956
1946
1969
1966
1964
1936
1954
1961
1948
1931
1924
1926
1940
1899
1900
1905
1909
1882
1903
1911
1901
1898
1922
1921
1905
1877
1900
1893
1908
Kiln
Temp
(°C)
1686
1633
•1563
1670
1710
1679
1602
1646
1736
1705
1666
1694
1688
1674
1650
1689
1694
1682
1680
1695
1714
1694
1569
1675
1727
1649
1612
1620
1738
1705
1671
1680
1680
1667
1644
1678
1722
1680
1663
1674
1687
1683
1635
1599
1602
1674
(continued)
200
-------
Table G-3. Combustion Temperature Data Taken From Strip Chart - Run 1 (concluded)
Time
(min)
1422
1423
1424
1425
1426
1427
1428
1429
1430
1431
1432
1433
1434
1435
1436
1437
1438
1439
1440
1441
1442
1443
1444
1445
1446
1447
1448
1449
1450
1451
1452
1453
1454
1455
1456
1457
1458
1459
1500
1501
1502
1503
1504
1505
1506
1507
1508
sec
Temp
(°F)
1888
1881
1909
1895
1888
1894
1895
1892
1880
1878
1909
1908
1923
1932
1927
1926
1903
1906
1921
1925
1933
1920
2030
1954
1942
1918
1915
1936
1947
1931
1929
1947
1928
1910
1910
1932
1932
1911
1930
1934
1934
1907
1929
1944
1947
1909
1918
Kiln
Temp
(°C)
1692
1624
1577
1656
1746
1646
1601
1639
1736
1705
1675
1694
1673
1674
1647
1712
1696
1706
1681
1685
1716
1703
1562
1661
1748
1670
1628
1645
1763
1726
1659
1702
1679
1673
1663
1711
1687
1699
1675
1677
1722
1692
1682
1584
1572
1573
1590
Time
(min)
1509
1510
1511
1512
1513
1514
1515
1516
1517
1518
1519
1520
1521
1522
1523
1524
1525
1526
1527
1528
1529
1530
1531
1532
1533
1534
1535
1536
1537
1538
1539
1540
1541
1542
1543
1544
1545
1546
1547
1548
1549
1550
AVG
MIN
MAX
sec
Temp
(°F)
1926
1936
1910
1901
1925
1984
1921
1915
1930
1934
1909
1912
1908
1935
1921
1910
1931
1945
1939
1942
1940
1956
1954
1917
1936
1945
1950
1886
1898
1892
1876
1904
1918
1891
1893
1911
1929
1920
1893
1908
1905
1914
1919.6
1872
2045
Kiln
Temp
(°C)
1564
1592
1607
1612
1608
1668
1701
1647
1570
1684
1737
1679
1615
1614
1738
1697
1676
1678
1709
1674
1643
1705
1709
1683
1687
1708
1702
1664
1573 '
1674
1714
1671
1628
1614
1760
1715
1661
1704
1707
1672
1663
1704
1670.2
1562
1763
201
-------
Table G-4. GEM Data From Data Logger Files -
Time
(min)
1250
1251
1252
1253
1254
1255
1256
1257
1258
1259
1300
1301
1302
1303
1304
1305
1306
1307
1308
1309
1310
1311
1312
1313
1314
1315
1316
1317
1318
1319
1320
1321
1322
1323
1324
1325
1326
1327
1328
1329
1330
1331
1332
1333
1334
1335
1336
Run 1
02
(%)
10.59
10.49
10.45
10.35
10.47
10.30
10.20
10.31
10.37
10.27
10.38
10.63
10.64
10.61
10.52
10.50
10.59
10.51
10.54
10.55
10.55
10.47
10.64
10.46
10.59
10.63
10.50
10.49
10.48
10.50
10.77
10.60
10.72
10.51
10.62
10.56
10.36
10.33
10.51
10.32
10.45
10.34
10.50
10.36
10.45
10.37
10.42
CO
(ppm)
51.46
52.03
53.70
57.74
51.96
53.85
53.29
52.87
52.15
54.04
56.07
54.78
48.36
55.18
56.03
57.69
51.60
54.98
52.38
51.18
51.94
56.09
51.96
57.20
51.50
54.47
57.91
57.77
54.84
51.92
56.53
51.07
56.17
53.73
48.40
51.48
52.99
52.73
51.69
53.52
47.68
47.09
45.75
52.35
48.23
48.42
46.15
CorrCO
(ppm)
69.2
69.7
71.1
76.4
68.8
70.4
69.7
69.1
68.2
70.7
74.2
73.4
64.8
73.9
75.1
77.3
69.1
73.7
70.2
68.6
69.6
75.2
69.6
76.6
69.0
73.0
77.6
77.4
73.5
69.6
76.7
69.3
76.2
72.0
64.8
69.0
70.1
69.8
68.4
70.8
63.1
62.3
60.5
69.3
63.8
64.1
61.1
(continued)
202
-------
Table 6-4. GEM Data From Data Logger Files
Time
(min)
1337
1338
1339
1340
1341
1342
1343
1344
1345
1346
1347
1348
1349
1350
1351
1352
1353
1354
1355
1356
1357
1358
1359
1400
1401
1402
1403
1404
1405
1406
1407
1408
1409
1410
1411
1412
1413
1414
1415
1416
1417
1418
1419
1420
1421
1422
1423
- Run 1 (continued)
02
(%)
10.51
10.50
10.64
10.47
10.50
10.59
10.44
10.50
10.35
10.41
10.34
10.53
10.62
10.88
10.85
10.80
10.75
10.64
10.63
10.62
10.64
10.62
10.58
10.60
10.64
10.45
10.64
10.37
10.48
10.45
10.37
10.49
10.67
10.82
10.71
10.60
10.66
10.90
10.81
10.62
10.51
10.59
10.52
10.64
10.54
10.64
10.63
CO
(ppm)
47.93
49.63
47.48
52.55
51.55
47.49
50.99
47.09
48.07
47.82
42.47
47.40
47.14
55.84
49.51
47.90
51.62
46.26
52.20
47.81
48.16
48.14
42.87
44.69
49.88
45.63
49.40
48.55
46.77
47.17
45.82
45.31
50.20
43.31
46.15
48.64
43.15
42.37
42.05
48.53
49.76
44.14
41.78
45.32
45.50
36.92
38.69
CorrCO
(ppm)
63.4
65.7
63.6
70.4
69.1
63.6
67.5
62.3
63.6
63.3
56.2
63.5
63.9
76.7
68.9
65.8
70.9
62.7
70.8
64.8
65.3
65.3
58.1
60.6
66.8
61.1
66.2
64.3
61.9
62.4
60.6
60.0
68.1
59.5
62.6
66.0
58.5
58.2
57.8
65.8
66.7
59.1
56.0
60.7
61.0
49.5
51.8
(continued)
203
-------
Table G-4. CEM Data From Data Logger Files
Time
(min)
1424
1425
1426
1427
1428
1429
1430
1431
1432
1433
1434
1435
1436
1437
1438
1439
1440
1441
1442
1443
1444
1445
1446
1447
1448
1449
1450
1451
1452
1453
1454
1455
1456
1457
1458
1459
1500
1501
1502
1503
1504
1505
1506
1507
1508
1509
1510
- Run 1 (continued)
02
(%)
10.54
10.60
10.57
10.61
10.61
10.61
10.77
10.61
10.56
10.62
10.43
10.51
10.46
10.51
10.42
10.49
10.65
10.47
10.50
10.57
10.56
10.62
10.55
10.61
10.51
10.54
10.52
10.63
10.45
10.58
10.57
10.46
10.68
10.60
10.61
10.59
10.74
10.75
10.72
10.62
10.70
10.58
10.63
10.47
10.56
10.48
10.56
CO
(ppm)
40.80
38.17
41.49
38.45
42.41
40.68
40.86
43.21
41.75
39.76
37.22
36.14
37.02
45.39
40.65
39.62
37.28
36.91
43.00
35.95
43.24
40.83
42.15
41.04
36.05
38.97
37.61
37.12
39.85
38.83
39.44
42.01
47.83
42.34
41.65
35.56
46.86
41.75
38.39
48.95
37.16
35.39
36.67
39.52
54.24
40.96
38.23
Corr CO
(ppm)
54.7
51.1
55.6
51.5
56.8
54.5
55.4
58.6
55.9
.53.3
49.3
47.8
49.0
60.1
53.8
53.1
50.0
49.5
57.6
48.2
57.9
54.7
56.5
55.0
48.3
52.2
50.4
49.7
53.4
52.0
52.8
56.3
64.9
57.4
56.5
48.2
64.4
57.3
52.7
66.4
50.4
47.4
49.1
52.9
72.7
54.9
51.2
(continued)
204
-------
Table G-4. CEM Data From Data Logger Files
Time
(min)
1511
1512
1513
1514
1515
1516
1517
1518
1519
1520
1521
1522
1523
1524
1525
1526
1527
1528
1529
1530
1531
1532
1533
1534
1535
1536
1537
1538
1539
1540
1541
1542
1543
1544
1545
1546
1547
1548
1549
1550
MINIMUM
MAXIMUM
AVERAGE
- Run 1 (concluded)
02
(%)
10.48
10.49
10.48
10.47
10.53
10.63
10.55
10.21
9.94
10.09
9.96
10.12
10.25
10.33
10.45
10.73
10.86
10.84
11.02
10.86
10.98
10.75
10.80
10.77
10.74
10.71
10.77
10.74
10.62
10.74
10.63
10.64
10.49
10.41
10.51
10.47
10.34
10.35
10.61
10.56
9.94
11.02
10.55
CO
(ppm)
38.05
46.51
39.53
41.92
36.59
38.05
40.40
38.37
38.21
39.88
39.82
51.09
49.26
44.63
49.42
52.33
41.34
48.58
50.81
49.02
48.69
47.68
49.45
42.01
46.30
44.89
44.68
46.89
43.02
43.36
44.23
45.70
43.04
43.45
47.26
44.25
41.33
46.39
46.71
45.59
35.39
57.91
46.23
CorrCO
(ppm)
51.0
62.3
53.0
56.2
49.0
51.0
54.1
49.6
48.2
50.9
50.8
66.0
63.6
58.4
65.4
71.0
56.8
67.6
70.7
68.2
67.7
65.5
67.9
57.7
63.6
60.9
60.6
63.6
58.3
59.6
60.0
61.2
57.0
57.5
62.5
58.6
54.7
61.4
62.6
61.1
47.4
77.6
62.0
atl.S. GOVERNMENT PRINTING OFFICE: 1989*48-163/87067
205
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