S-EPA
United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati OH 45268
Center for Environmental
Research Information
Cincinnati OH 45268
Technology Transfer
EPA/625/9-88/008
Experience in
Incineration Applicable
to Superfund Site
Remediation
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EPA/625/9-88/008
December 1988
Experience in Incineration
Applicable to
Superfund Site Remediation
Risk Reduction Engineering Laboratory
and
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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Notice
The information in this document has been funded wholly or in part, by the
U.S. Environmental Protection Agency (EPA) under Contract No. 68-03-
3312, Work Assignment No. 1-03, to PEER Consultants, P.C. This document
has been subject to the Agency's peer and administrative review and has been
approved for publication as an EPA document. Mention of trade names or
commercial products does not constitute endorsement or recommendation for
use.
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Abstract
This document is intended for use as a reference tool for hazardous waste
site remediation where incineration is a treatment alternative. Its purpose is to
provide the user with a collection of information garnered from the experiences
of those using incineration. With an understanding of those practices which
were successful or which failed, the user can be better prepared to avoid
known pitfalls in future site activities.
The document presents: useful lessons applicable to the evaluation and
selection process as it pertains to incineration; guidance for good operating
practice; and information useful in the planning and initiation of remedies based
on incineration technology.
The data and information used in the preparation of this document were
collected from personnel who have been involved in the selection and
application of incineration techniques to hazardous waste disposal as well as
from a comprehensive literature search.
in
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Contents
Notice jj
Abstract iii
Figures vj
Tables vjj
Acknowledgements viii
Acronyms jx
1. Introduction 1
2. Background Information on Incineration Technology 3
Rotary Kiln Incineration 3
Fluidized Bed Incineration 4
Liquid Injection Incineration 4
Infrared Incineration 4
3. The Effect of Waste Characteristics on Technology Selection 5
Characterizing Waste Constituents 5
Determining the Physical Characteristics of the Waste 6
Sampling to Characterize the Variability of the Wastes 7
4. Operating Experience 9
Operating Concerns Related to Waste Feed 9
Experience Gained in the Operation of Incinerators 10
Experience Related to Incinerator Emissions and Residues 12
5. Issues Affecting the Implementation of Incineration 19
Permitting Requirements 19
The Use of Risk Assessment as a Tool in Evaluating
Waste Management Alternatives 19
Health and Safety Considerations 20
References 23
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Figures
Page
, 3
Number
2-1 Incineration system concept flow diagram
3-1 Waste matrices as reported in records of decision for
Superfund sites recommending incineration 6
VI
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Tables
Number
Page
1-1 General Combustion Chamber Conditions Favorable to the
Destruction of Hazardous Waste 2
1-2 Stack Emission Characteristics Observed During Successful
Combustion of Hazardous Waste 2
4-1 Analysis of Soil Matrices at a Site Contaminated with
Explosive Waste 10
4-2 Technologies Applicable to Dioxin Decontamination 11
4-3 Concentration of Volatile and Semivolatile Organics in Incinerator
Ash Residuals and their EP III Leachates 13
4-4 Concentration of Priority Metals in Incinerator Residuals 15
4-5 Summary of Data on Particulate Concentration and HCI Removal Efficiency
for Incinerators Burning Wastes Containing Chlorinated Compounds 17
5-1 Steps in Trial Burn Procedures 19
5-2 Regulatory Requirements for Off-Site Incineration Permits 20
5-3 Total Excess Lifetime Cancer Risk to the Maximum Exposed Individual 20
VII
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Acknowledgments
This document was prepared under Contract No. 68-03-3312 by PEER
Consultants, P.C., under the sponsorship of the U.S. Environmental Protection
Agency. Clarence A. demons of the U.S. EPA, Office of Research and
Development, Center for Environmental Research Information was the project
officer responsible for the preparation of this document. Special
acknowledgement is given to H. Douglas Williams, Donald A. Oberacker, Frank
Freestone, Robert Mournighan, Ivars Licis, Gregory Carroll and Robin
Anderson of the U.S. EPA for their assistance and comments and to Fred Hall
of PEI Associates, Inc., Joseph Santoleri of Four Nines, Inc., Wayne Westbrook
of Research Triangle Institute and Lawrence Doucet of Doucet and Mainka,
P.C. for the technical review of early drafts of this report. Participating in the
development of this document for PEER Consultants, P.C. were Richard E.
Frounfelker, Edward J. Martin and Joseph T. Swartzbaugh.
VIII
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Acronyms
APCD
ARAR
CERCLA
CHEAP
CRF
D/D/R
ORE
HHE
HW
IEPA
KPEG
MIS
NPDES
NPL
PAH
PCB
PCDD
PCDF
PIC
PNA
POHC
QA/QC
RCRA
ROD
SARA
SCC
SITE
TCDD
TCLP
THC
TSCA
U.S. EPA
USATHAMA -
VOC
Air Pollution Control Device
Applicable or Relevant and Appropriate Requirement
Comprehensive Environmental Response, Compensation and Liability Act
Combustion High Efficiency Air Filter
Combustion Research Facility
Destruction/Detoxification/Removal
Destruction and Removal Efficiencies
Human Health and Environment
Hazardous Waste
Illinois Environmental Protection Agency
Potassium Polyethylene Glycol
Mobile Incinerator System
National Pollutant Discharge Elimination System
National Priority List
Polycyclic Aromatic Hydrocarbon
Polychlorinated Biphenyl
Polychlorinated Dibenzo-p-dioxin
Polychlorinated Dibenzo-p-furan
Product of Incomplete Combustion
Polynuclear Aromatics
Principal Organic Hazardous Constituents
Quality Assurance/Quality Control
Resource Conservation and Recovery Act
Record of Decision
Superfund Amendments and Reauthorization Act
Secondary Combustion Chamber
Superfund Innovative Technology Evaluation Program
Tetrachlorodibenzo-p-dioxin
Toxicity Characteristics Leaching Procedure
Total Hydrocarbons
Toxic Substances Control Act
United States Environmental Protection Agency
United States Army Toxic and Hazardous Materials Agency
Volatile Organic Compound
IX
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CHAPTER 1
Introduction
The Superfund Amendment and Reauthorization
Act (SARA) of 1986 reauthorized the Comprehensive
Environmental Response, Compensation and Liability
Act (CERCLA), and together they are popularly
known as the Superfund program. When SARA was
enacted, it specifically emphasized the use of
permanent remedies in effecting site cleanups. As a
result, technologies which achieve detoxification of
waste through destruction are being chosen for
Superfund actions at an increasing frequency.
Incineration, which is technology utilizing an
integrated system of components for waste
preparation, feeding, combustion and emissions
control, has been proven to achieve acceptable levels
of destruction of the organic portion of hazardous
wastes. Therefore, incineration is being proposed and
adopted for the remediation of several Superfund
sites. A review of the Superfund Records of Decision
(ROD) indicated that as of February 1988, 34 National
Priority List (NPL) sites had selected thermal
destruction as a possible remediation alternative.
Clearly, the application of incineration in the
Superfund program is in the planning stage. Full scale
field applications of this technology on-site at
Superfund sites is now in the planning and initial
implementation stages. However, off-site incinera-
tion of waste from Superfund actions and from
analogous RCRA Corrective Actions are occurring. In
addition, the EPA's Superfund Innovative Technology
Evaluation (SITE) program has demonstrated the
application of infrared technology. The EPA's mobile
test incinerator has been used for large scale pilot
evaluations of on-site incineration, and the EPA
Combustion Research Facility has demonstrated the
application of rotary kiln technology to the remediation
of specific types of wastes found at Superfund sites.
From these early applications and from the broad
experience gained in the destruction of hazardous
wastes at commercial incinerators for purposes of
RCRA compliance, some useful information and
guidance can be obtained which is directly applicable
to the use of incineration for the remediation of
Superfund sites.
It should always be remembered that the
application of new technology, as well as the
utilization of established technology for new purposes
always exposes new and unexpected problems. It is
common for engineers and technologists to speak of
this period of learning about, and addressing new
problems, as "being on the learning curve." However,
appropriate application of as much information as
possible about analogous problems will serve to
minimize the extent and duration of this learning
curve.
Various types of incineration systems are
commercially available and are well demonstrated
technologies for the disposal of hazardous wastes in
the RCRA context. Considerable design and operating
experience exists, and both design and operating
guidelines are available for the proper implementation
and use of such systems. The most common
incinerator designs incorporate one of four major
combustion chamber design concepts: liquid injection,
rotary kiln, fixed hearth, or fluidized bed.
If off-site incineration is chosen as a treatment
option for the remediation of a Superfund site, then
the commercially accessible, RCRA permitted
facilities are candidates which are presently available
for accepting wastes removed from Superfund sites.
The operators of these facilities know their facilities
well and are competent in their operation. It can be
expected that the operators will carefully analyze the
characteristics of any candidate wastes to be
received prior to their agreeing to accept such wastes
for destruction in their units. Note that the acceptance
of a new waste by a commercial facility may require
modification of their permit or other "nontechnical"
concerns that the proposed facility is unwilling to deal
with. Since there are, at present, a limited number of
permitted incinerator facilities, a "sellers market"
condition prevails and operators may pick and choose
which waste streams they will accept. Thus, for sites
proposing off-site incineration, the most important
point of guidance that can be offered is that a clear-
cut understanding of the nature of the waste and of
the commercial facility's ability, as well as their
willingness, to accept that waste must be agreed
upon before final remedy selection.
On-site incineration will most often utilize a
mobile or transportable technology rather than a unit
to be permanently constructed at a site. The
distinction between mobile and transportable units is
that mobile units are truck mounted (on one or more
semi-trailers) and can be rapidly connected and
assembled in the field, often without removal from the
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truck beds. Thus, the design of mobile units is limited
by the size of road-usable trailers, and this limiting
restriction may not always be consistent with optimum
incinerator design practice. In contrast, transportable
units consist of a set of compatible modules which
can be readily disassembled at one site, transported
to a new site and reassembled on a concrete pad or
other stable base and utilized for several weeks or
months as necessary for site remediation activities.
Design limits on a transportable unit are more
forgiving and, in general, the transportable units can
be constructed of stronger materials and can be
designed to more closely meet optimum incinerator
design requirements. Capacities of mobile and
transportable technologies presently available are in
the 2-10 tph range, although some of the operating
experience reported herein was gained in first
generation units having capacities of approximately
500 pounds per hour. Such units can, and have
demonstrated, adequate destruction of hazardous
wastes in tests and trials performed to date.
Conditions for effective disposal of hazardous
wastes in incinerators have been well established and
are presented in Table 1-1. Note that tests on many
different types of combustors being fed different types
of wastes have all shown consistent results (see
Table 1-2). For incineration systems, the destruction
and removal efficiencies observed have been
between 99.99% and 99.9999%, as required for
destruction of specific toxic materials under RCRA
and TOSCA. In addition, control efficiency
requirements for HCl emissions also have been met.
In fact, one of the most difficult requirements to meet
in any test burns of Superfund wastes was the
particulate emission standard of 0.08 gr/dscf.
However, this difficulty was probably related more to
the fact that tests reported herein were performed in
an attempt to gain a range of design information
rather than to actually utilize specific incinerators for
long term remediation of Superfund sites. Properly
designed air pollution control devices can meet
current state-of-the-art emission levels of 0.03 to
0.04 gr/dscf. It should also be noted that it is not
always possible to demonstrate that solid residues
from hazardous waste incineration would pass tests
for delisting purposes.
Although only limited information exists about the
specific application of incineration technology to
Superfund wastes, guidance does exist about the
selection, operation and implementation of
incineration technology, and this guidance is directly
applicable to utilization of such technology in
Superfund site remediation. In general, this guidance
exists in the areas of identifying the type of data and
information necessary to properly select and evaluate
incinerator technologies; probable best operating
practice for incinerators receiving wastes (such as
contaminated soils) which could be expected from
Superfund site remediation; and specific regulatory
and safety concerns which will effect the timing and
cost of the implementation of incineration technology
to Superfund site cleanups. These topic areas are the
foci of the following chapters of this document.
Table 1-1. General Combustion Chamber Conditions Favorable to the Destruction of Hazardous Waste
Combustion chamber temperature level:
Residence time:
Excess combustion air:
820°C - 1500°C (1500°F - 2700°F)
0.2 - 6.5 sec for gases and liquid/vapors several minutes to 1/2 hour for solids/sludges
60 -130%
(Oppelt, 1986)
Table 1-2. Stack Emission Characteristics Observed During Successful Combustion of Hazardous Waste
Stack gas characteristics:
Oxygen:
Carbon dioxide:
Carbon monoxide:
Total hydrocarbons:
Stack particulate emissions:
Units without control devices:
Units with control devices:
8 -15%
6 - 10%
0-50 ppm (rare exceptions up to 500 ppm or more)
0-5 ppm (rare exceptions up to 75 ppm or more)
60 - 900 mg/dscm (0.03 - 0.39 gr/dscf)
20 - 400 mg/dscm (0.01 - 0.17 gr/dscf)
(Oppelt, 1986)
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CHAPTER 2
Background Information on Incineration Technology
This chapter presents brief descriptions of the
types of incinerator technology presently in use (or
planned to be used in the near future) for CERCLA
site remediation. It is not the intent of this document
to serve as a design guide or a textbook on
incineration. There are several excellent texts and
reference documents presently available which supply
a wealth of information about different incineration
technologies. The technologies described herein
include the most widely used technology for
hazardous waste incineration, namely the rotary kiln
incinerator. In addition, brief descriptions of liquid
injection incinerators, of fluidized bed and circulating
bed combustors and of infrared incinerators are
presented.
An incinerator is a complex system of interacting
pieces of equipment and is not just a simple furnace.
A generic concept diagram indicating the type of
operations which make up an incineration system is
presented in Figure 2-1. In considering whether an
incinerator can combust a specific hazardous waste
stream, one must take into account the waste feed
mechanism of the incinerator, the size and
configuration of the furnace itself, the nature of the
furnace's refractory material and the design of its ash
handling mechanism. Many operators and hazardous
waste incineration experts consider that the feed
mechanism is the most critical aspect of an
incinerator. This is because experience has shown
that the feed mechanism is one of the major sources
of problems in actual operation of incinerators. It is
obvious that, if a waste is to be burned, there must
be a viable mechanism for introducing the waste into
a combustion system. The limitations of the feed
mechanism as well as limitations of the ash removal
mechanism set the requirements for any preproces-
sing of the waste. In fact, because Superfund sites
often contain such a varied mix of waste types and
matrices, preprocessing requirements may be so
extreme that the preprocessing could turn out to be
the most extensive (and possibly the most expensive)
operation in the entire remediation process. Feed
mechanisms for the different types of incinerator
systems are presented in the discussion of each
specific incinerator type.
Any discussion of incineration as an option for
treatment of wastes, usually includes mention of the
three T's of incineration: time, temperature and
Waste
4
Waste
Processing
X
Waste
Feeding
To Atmosphere
t
Aux. Combustion
Fuel Air
\ 4
Combustion
^ Chamber
4- -
Ash
Removal
Acid Gas
k
r
T
Particulate Remova
^
T
->
Gas Cor
A
->
•
k
Residue Treatment
L
^ — '
Wastewater
J U
To
Disposal
Figure 2-1. Incineration system concept flow diagram.
turbulence. Specifically, these are the temperature at
which the furnace is operated, the time during which
the combustible material is subject to that
temperature and the turbulence required to ensure
that all the combustible material is exposed to oxygen
to ensure complete combustion. Different combustion
systems utilize different mechanisms for addressing
the three T's.
Rotary Kiln Incineration
A rotary kiln incinerator is essentially a long
inclined tube that is mounted in such a way that it can
be slowly rotated. Rotary kilns are intended primarily
for combustion of solids but liquids, sludges and
gases may be co-incinerated with solids. Wastes
and auxiliary fuels are introduced into the high end of
the kiln and the kiln's rotation constantly agitates any
solid materials being burned to expose the solids to
oxygen and to improve heat transfer. However,
because the solids are being agitated, there is a high
likelihood that solids will be entrained in the gas
stream and this will require post-combustion control.
Any ash residues from the combustion process are
discharged and collected at the low end of the kiln.
Exhaust gases from a kiln typically pass to a
secondary combustion chamber or afterburner for
further oxidation. Exhaust gases typically require acid
gas removal and particulate removal. Note that the
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ashes and air pollution control process residues from
an incinerator may require further treatment before
being deposited in the land. Most types of solid,
sludge and liquid organic wastes can be combusted
with this technology. Solids are usually introduced
into the rotary combustor by a ram feeder or an auger
conveyer feeder. Sludges are introduced into the
combustion chamber by a cooled tube injected into
the flame zone and liquids are injected either into the
primary chamber or the secondary chamber by
means of liquid injection nozzles.
Fluidized Bed incineration
Fluidized bed incinerators utilize a very turbulent
bed of inert granular material to improve the transfer
of heat to the waste streams to be incinerated. Air is
blown through the granular bed material until the
granules are suspended and able to move and mix in
a manner similar to a fluid. The bed is preheated
using an auxiliary burner and wastes and auxiliary fuel
are introduced in a manner that will facilitate their
intimate contact with the the heated bed particles.
The technology is particularly appropriate for liquids
and sludges and can be used for solids having small
particle sizes. However, fluidized bed combustion is
not appropriate for bulky or for viscous wastes.
Wastes having high sodium levels or wastes which
are not uniformly mixed can cause bed agglomeration
problems (i.e., particles in the bed will stick together
and become too large to be able to be fluidized).
Fluidized beds require frequent attention for
maintenance and for cleaning of the bed. Typically
these units operate at low combustion temperatures
(e.g., 750-1000°C) and therefore, organic wastes
that are especially refractory may not be fully
destroyed.
The circulating bed combustor (CBC) is an off-
shoot of the fluidized bed combustor. Circulating bed
combustor systems operate at higher velocities and
with finer particles in the bed than fluidized bed
systems. Bed materials are carried up through the
first combustion chamber and typically are passed
through to a second, more quiescent chamber, where
they are collected for reinjection into the first
chamber. The use of higher velocities and finer bed
materials permits the construction of a unit that is
more compact while still achieving great turbulence.
Manufacturers claim that the high turbulence
achieved allows especially efficient destruction of all
types of halogenated hydrocarbons including PCB's
and other aromatic materials at temperatures lower
than 850°C. The required 99.9999% ORE has been
demonstrated in a trial burn of a commercial size
CBC unit (Vrable, 1985). Wastes must be fairly
homogeneous in composition when fed to a CBC
since most designs utilize only a single feed point.
Liquids and sludges can be introduced into
fluidized bed combustors by injection nozzles or
cooled wands into locations within the bed. Solid
materials can be introduced pneumatically or through
an air lock into the freeboard above the bed in the
fluidized bed combustor or at a point approximately
1/3-1/2 of the height of the first chamber in the
circulating bed combustor.
Liquid Injection Incineration
Liquid materials with solids contents below 10-
12 percent can be combusted in a relatively simple
furnace which usually has no provisions for ash
capture other than fly ash removal. Typically,
combustible liquid waste material is introduced to the
combustion chamber by means of specially designed
nozzles. Different nozzle designs result in various
droplet sizes which then mix with air and auxiliary fuel
as needed. Pre-treatment such as blending and
filtration, may be required for feeding some wastes to
specific nozzles in order to achieve efficient mixing
with the oxygen source and to maintain continuous
homogeneous flow of waste into the combustion
chamber. Liquid injection incineration can be applied
to all pumpable organic wastes, including wastes with
high moisture content. However, it is absolutely
necessary that care be taken En matching the waste
characteristics to specific nozzle design. Solids in the
waste stream can easily clog nozzles and it should be
noted that abrasive solids (even at low
concentrations) can cause pump wear, even in
progressing cavity pumps which are specifically
designed to handle high solids content liquids.
Infrared Incineration
Infrared radiators can be used as a heat source to
destroy hazardous wastes. The infrared incineration
system recently tested within the Superfund
Innovative Technology Evaluation (SITE) Program
was made up of a primary chamber consisting of a
rectangular carbon steel box lined with layers of a
lightweight ceramic fiber blanket. Energy is provided
to the system as infrared radiation from silicon
carbide resistance heating elements. The wastes to
be destroyed are conveyed through the furnace on a
open wire belt. This technology is intended to be
used to treat solids, sludges and contaminated soils.
Any solid materials and soils must be crushed or
shredded and then screened to a size less than
approximately 1 inch. Liquid and gaseous injection
feed systems may be added to this technology. Solid
waste is carried through the furnace on the belt until
reaching the discharge end of the furnace where it
drops off into a hopper. These incinerators typically
require further treatment of the gaseous emissions,
such as secondary combustion, acid gas control, and
particulate removal.
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CHAPTER 3
The Effect of Waste Characteristics on Technology Selection
The evaluation and selection of a technology to
be used in a CERCLA remedial action must be based
on complete and accurate analyses of the
contaminants that exist at the site. The effectiveness
of any technology, including incineration, is
dependent upon the waste's chemical and physical
characteristics and often upon the uniformity of those
characteristics. Therefore in order to assess whether
incineration is a valid treatment technology to be
utilized in the remediation of a Superfund site, it is
necessary to have a thorough chemical analysis of
the characteristics of the wastes to be disposed in the
incinerator. It is also necessary to have a complete
characterization of the physical form of the waste and
to have a sampling plan adequate to determine the
uniformity of the waste material to be fed to the
incinerator.
Incineration is applicable to the full range of
organic waste constituents. Information published in
the RODs for the 34 sites at which incineration is an
alternative indicated that VOCs and PCBs were
contaminants in 50% of the sites. Other major
contaminants were reported as metals (41%),
organics (35%), PAH compounds (27%) and
inorganics (18%). No single contaminant or
contaminated media was common to all sites. Note
that wastes containing organics but which also
contain metals may be burned, but in such cases,
care must be taken to properly control stack
emissions as well as to properly dispose of all
residues.
Characterizing Waste Constituents
There are several purposes for which the
analytical data will be utilized in selecting and
evaluating incineration. An understanding of all of
these purposes will better enable the site engineer to
plan the sampling and analytical program necessary
to allow an appropriate evaluation of the incineration
option. Obviously the first and foremost purpose of
any analytical plan is to assess whether or not the
waste present is amenable to destruction or
detoxification by thermal processes. Further,
information is necessary to determine the incinerator
design to be utilized, as well as to determine the
appropriate feed mechanism, stack gas cleaning
equipment, and solid residue removal equipment that
will be necessary. Thus, it is necessary to know:
• The organic hazardous constituents of the waste,
especially whether the waste contains highly toxic
materials ,such as PCBs or chlorinated dioxins
and furans.
• The more refractory of the organic hazardous
constituents, in order to properly design a test
burn protocol if and when the assessment of
incineration as an option proceeds to that point.
• The toxic heavy metal constituents of the waste
stream, especially the more volatile of these
metals such as lead, in order to assess the need
for appropriate air pollution control devices should
the incineration option be chosen. Certain other
inorganic constituents must be identified. For
example, high levels of sodium can cause serious
problems of bed agglomeration in a fluidized bed
combustor.
• The presence and concentration of any acid gas
precursors, such as sulfur or halogens in the
waste material, so that appropriate air pollution
control measures can be incorporated into the
incineration option.
• The moisture content of the material to be
incinerated. High moisture content wastes can be
incinerated, but the amount of moisture present
has a significant impact on furnace volume
requirements and especially on auxiliary fuel
requirements. Furthermore, the impact of any
high moisture levels in the exhaust gas stream
must be taken into consideration in determining
the proper downstream air pollution control
equipment.
It is always important that any remediation option
be evaluated on the basis of actual analytical data for
the waste as it exists at the site. There have been
situations where inappropriate or less than optimum
treatment strategies have been utilized because
improper or incomplete analytical programs were
established and the true nature of the waste to be
remediated was not known. One example of such a
situation is the Peak Oil Site in Florida at which the
decision was made to perform field-scale evaluation
of an infrared incineration system based on
knowledge of the site's history. Since some PCB-
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laden oils had been disposed at the site, it was
believed that this was the most significant constituent
in the waste stream. Therefore, the system vendor
proposed the use of the infrared destruction
technology as part of the Superfund Innovative
Technology Evaluation (SITE) program and
proceeded to install and implement equipment prior to
a full evaluation of the waste material. Analyses of the
waste feed performed at the time of incinerator
process evaluation showed that the total PCB content
in the waste material averaged about 5 mg per gram
and other toxic organic materials were also present.
Incineration would usually be considered appropriate
for such wastes. However, the lead content in the
waste was approximately 0.5 percent. The system
was operated without proper planning for, or control
of, volatile metal emissions. Measurement of the lead
in the stack emissions from the process showed
releases of 0.78 to 2 kilograms per hour of lead from
the system during operation. Zinc and mercury
emissions were also detected, although at much
lower levels than the lead emissions. (Oberacker,
1988)
At the Laskan Poplar Site in Ashtabula, Ohio
(Engineering Science, 1987), PCB-contaminated oils
and oily sludges were evaluated as being appropriate
candidates for incineration. However, the lead content
seen in the oil ranged from 30-543 mg per kilogram
and the lead content in the oily sludges ranged from
69-12,400 mg per kilogram. Although it was
originally believed by the site engineer that the high
lead content would not require special incineration
considerations, it was found that off-site commercial
incineration facilities would not accept the waste
sludges because of limiting condition in their existing
RCRA permits or because of concerns that lead
concentration in their scrubber water effluent would
exceed the requirements of the incinerator facility's
NPDES permit. Therefore, the decision was made to
incinerate the waste sludges on site using a
commercially available, transportable incinerator. Note
that this decision was made for regulatory concerns
and not on a strictly technical basis.
Determining the Physical Characteristics
of the Waste
Determination of the form of the waste to be
treated is much more involved than a more visual
assessment that the waste is a solid, liquid or a
sludge. The physical characteristics of a waste
determine whether and how a waste can be moved
and fed into any treatment system, whether the
treatment be chemical, biological or thermal
treatment. The most common types of Superfund
wastes which will be candidates for treatment by
incineration are contaminated soils and liquid wastes.
Different problems exist when characterizing such
different wastes.
Characterization of the contaminants in the soil
across a Superfund site is complex because the
waste and waste 'matrix are probably not
homogeneous (either horizontally or vertically) in the
soil at the site. Conversely, liquid organics in tanks,
drums, and lagoons are easier to identify and are
more homogeneous, at least within each container.
Liquids can be pumped and mixed to produce a
nearly homogeneous feedstock prior to.injection into
an incinerator. Liquid feedstocks are .therefore easier
to control than soil feedstocks and result in more
uniform operation.
Both liquids and soils can be expected to have
some "trash" intermingled. In this context, "trash" is
any major extraneous material (even if inert) which
can complicate the handling and feeding of the waste.
Examples include rocks or small pieces of wood in
liquids, or wire, scrap metal, pieces of rubber or large
rocks and boulders in contaminated soils.
As shown in Figure 3-1, 80 percent of the
Superfund sites recommending incineration have
contaminated soils to treat. The material handling of
soils can cause significant problems to the incinerator
(although many of these problems are common to
other remedial actions). Of the sites reporting solid
wastes, forty percent have less than 10,000 cy of
solid waste, 32% have between 10,000 and 50,000
cy and only 12% have more than 100,000 cy to
incinerate.
Figure 3-1. Waste matrices as reported in Records of
Decision for Superfund sites recommending •
, incineration.
Soil characteristics affect the method of
excavation, the possible requirement for and selection
of pretreatment technologies, and the selection of the
incineration technology itself.
-------
1. Soils with a high moisture and clay content
can agglomerate into balls or clumps.
Reduction of the size of this agglomerated
material is very difficult. A large percentage of
this type soil must be screened out of the
feed stream for many types of incinerator
technologies.
2. The contaminants are usually not uniformly
spread throughout the soil. Therefore, the
concentration of contaminant in the feed to
the incinerator will vary as the excavation
moves across the site. Overloading of the
incinerator feed with organic contaminant can
reduce the ORE of the contaminant, while
feeding very low concentrations of
contaminant would waste time and money.
3. Moist or "sticky" soils affect the waste
handling system. Wet soil can stick and jam
numerous types of conveying, screening and
feeding equipment. Highly variable moisture
content can affect the attainable ORE in the
combustor.
4. Gravel and rocks in the soil can cause
problems with material handling equipment.
Screw and belt conveyors are affected by the
abrasive, sharp edges as well as by the size
of different types of gravel. Screens can be
plugged or damaged by a combination of
gravel, rocks, and other debris.
5. High loam content soils can produce large
amounts of contaminated fugitive dust and
VOC emissions during handling and
conveyance to the incinerator.
Sampling to Characterize the Variability
of the Wastes
It is probable that the characteristics of any waste
at a Superfund site will be highly non-uniform.
Liquids and sludges in surface impoundments will
have stratified, solids will have settled and some
liquids will have seeped into soils. Wastes disposed in
the ground were probably not applied in a uniform
manner, and the liquid and soluble portions of such
wastes will migrate from the original point of deposit
with the passage of time.
It is a critical need in determining waste feed rate
to an incinerator to attempt to maintain .relatively
constant heat input. Non-uniform feeding can result
in carbon monoxide spikes and insufficient oxygen to
attain proper destruction of the organic constituents.
Thus, it is necessary for proper incinerator operation
that some measure of uniformity of the waste in the
waste matrix be known. If the wastes to be fed to an
incinerator are fairly uniform, then uniform feed and
heat input rates can be attained through operator
training. However, if the waste is highly variable, then
there is probably some need for mixing, blending,
shredding, or even more extensive pretreatment of
the waste material to achieve higher uniformity prior
to feeding it into the incineration system.
Non-uniformity of wastes to be fed to an
incinerator is an especially important concern for
fluidized bed and circulating bed combustors.
Unexpected changes in the heat input rate, as well as
unexpected changes in the inorganic constituents in a
waste stream, can result in bed agglomeration or in
bed material degradation. Bed agglomeration
problems were observed on a fairly regular basis
during extended test burnings of hazardous waste at
the fluidized bed combustor system at the Franklin,
Ohio, Solid Waste Resource Recovery Demonstration
Project facility. Although the waste being fed was a
blended liquid waste (more typical of a RCRA waste),
slight changes in waste composition and especially in
moisture content of the input waste stream resulted in
several bed agglomeration episodes. Finally, the plant
operator decided to accept no more of the liquid
industrial waste for incineration in the system
(Ackerman, 1978).
-------
-------
CHAPTER 4
Operating Experience
Operating Concerns Related to Waste
Feed
The incinerator system itself must be selected to
'"fit" the waste type and as-found matrix of the
waste in the field. For example, a rotary kiln
incinerator can be charged with hazardous wastes
which are widely variable in nature. The size of kiln-
fed wastes is only limited by the size of the opening
in the unit. However, other types of incinerators may
be very limited; for example, the waste fed to a
fluidized bed type must be very homogeneous. In
such a system, some form of a pretreatment is
necessary to assure that the feedstock is
homogeneous and compatible with the incinerator
technology.
Pretreatment, including screening, shredding,
metal separation and size separation, dewatering, or
other processing, is often costly. Pretreatment costs
can even equal or exceed the cost of the primary
treatment itself. Therefore, pretreatment costs must
be considered when making the project cost
estimates. Failures in pretreatment equipment have
caused significant system downtime. Almost
continuous attention to these devices is required,
especially when the original feed material is
nonhomogeneous.
Numerous problems have been identified with
waste feed systems:
• Soil has been fed into rotary kilns by means of
screw conveyors. Screw conveyors work well for
uniform sandy soils but they have experienced
problems when conveying gravel-bearing soil
and soil mixed with scrap. Excessive wear of the
screws can require weekly shutdown for
replacement. Jams are often caused by pieces of
metal wire or other scrap.
* Soils have sometimes been fed into an incinerator
by means of a ram feeder. The fines in some
soils (e.g., sandy river loam) can spill around the
ram. The volume of spilled material can become
so great that it can prevent the ram from fully
retracting past the feed hopper. To correct this, a
small tubular conveyor (screw) can be installed
beneath the loading hopper to remove the spillage
buildup from behind the ram and carry the fines
into the incinerator.
• Dump trucks used to haul excavated soil to an
incinerator feeding system are frequently Jined
with large sheets of plastic film. The plastic is
then dumped with the soil. During pretreatment
processing, the plastic film has been found to
cause jamming of the feed system. The plastic
does not shred into small pieces but rather
shreds into strips and then rolls up into balls.
These become entangled in screens and around
belt pulleys. Introduction of large pieces of plastic
into the incinerator causes a rapid increase in
temperature and decrease in excess oxygen. This
could trigger a system shutdown.
• The use of shearing-type shredders can result in
long strings of plastic, wire or cloth as well as
large wood splinters. These stringers jam the
system conveyor, screens and feeders.
• Sludges, oils, and tars typically are fed
continuously to combustors by means of
progressing cavity pumps. Some debris (sticks,
rocks, and waste) can be handled by such
pumps. However, abrasive debris can cause rapid
wear in progressing cavity pumps. Soils and
nonpumpable gels have been packed into fiber
packs or plastic drums and then successfully fed
one at a time through a ram into the combustor.
Steel drums of waste have also been successfully
fed one at a time into rotary kilns.
Sometimes, unique wastes present unique
problems in feeding the waste to an incinerator. For
example, the U.S. Army Toxic and Hazardous
Materials Agency (USATHAMA) used a transportable
rotary kiln to successfully burn explosive-
contaminated soil dredged from red and pink water
lagoons (Noland, 1984). The technology (developed
by Therm-All, Inc.) had been used in industry for
destruction of solid wastes. The normal screw feed
system was not used due to fear of an explosion
during the extruded plug feed process. Therefore, the
soil was placed in combustible buckets and
individually fed by a ram into the incinerator. The feed
rate was 300 to 400 Ib/hr and the operational
temperature was 1200 to 1600°F in the kiln and 1600
to 2000°F in the secondary chamber. A ORE of 99.99
-------
percent was reported. Analysis of the soil
contaminants is presented in Table 4-1.
Table 4-1. Analysis of Soil Matrices at a Site
Contaminated with Explosive Waste
Descriptor
Soil type
Moisture content
Ash content (as received)
Explosives content (dry basis)
- TNT
- RDX
- HMX
- Other
- Total explosives
Heating value (as received)
Sand
12-26%
44-83%
9-41%
0.02%
Not detected
0.03%
9-41%
50-2400 Btu/lb
Clay
25-30%
54-66%
5-14%
3-10%
0.6-1.4%
0.06%
10-22%
600-1200
(Noland
Btu/lb
, 1984)
Experience Gained in the Operation of
Incinerators
General process control systems and strategies
exist to control incinerator performance. However,
none of the real time monitoring performance
indicators appear to correlate with actual organic
compound ORE. No correlation between indicator
emissions of CO or unburned hydrocarbons and ORE
has been demonstrated for field-scale incinerator
operations, although CO may be useful as an
estimator of a lower boundary of acceptable ORE
performance. It may be that combinations of several
potential real-time indicators (CO, THC, surrogate
compound destruction) may be needed to more
accurately predict and assure ORE performance on a
continuous basis. In any case, even the approach of
using real-time indicators to control ORE suffers a
response time lag due to the time required to sample,
analyze and transmit the sample analysis to the
controller.
Typically, a high volume of excess air is passed
through the system to control the chamber
temperature and to assure sufficient oxygen for the
combustion of the waste. However, large volumes of
excess air reduces the system waste processing
capacity and increases the need for auxiliary fuel to
heat the air. Better design to control air leakage and
better operator control of air levels will yield improved
system effectiveness. The use of a burner that uses
oxygen, rather than air, can reduce the effective
volume of gases to be heated. This volume reduction
effectively increases the throughput capacity of the
system and lowers the auxiliary fuel cost. However,
oxygen production systems can be very costly, and
care must be exercised in properly performing cost
analyses prior to their selection.
In the use of an incinerator for soil treatment,
much of the energy produced is used for heating
and/or drying the soil, since the amount of cpn-
tamination is usually much smaller than the mass of
soil. Once the soil is dried and its contaminants
volatilized, soil particles can readily be lofted to
become paniculate emissions which must be
controlled. High solids processing in rotary kilns is
accomplished using a downstream cyclone separator,
or by using indirect calcining type kilns to reduce the
solids carryover in the flue gases. The approach of
using a cyclone separator has been used for wastes
which are predominantly soil.
Sites with contaminated soil of 5000 tons or less
can be considered small sites. At such sites, units
with throughput capacities of less than 5 tons per
hour (tph) can be used, even though the cost per unit
processed is high: $1000 to $1500/ton. A site with
soil volume of 5000 to 30,000 tons to be treated is a
medium-sized site. System with capacities between
5 and 10 tph, can keep the time for remedial action
short. The cost per ton for this size unit can range
from $300 to $800 per ton. Sites with more than
30,000 tons of soil to be processed are considered
large sites, and high-capacity technologies (greater
than 10 tph) may be considered for application under
these conditions. Costs of cleanups for such units
could range from $100 to $400 per ton (Cudahey,
1987). The above cost information compares closely
with actual bid prices for incineration projects as
published in various news reports appearing' in
Hazardous Waste News, Waste Age and the Journal
of the Air Pollution Control Association.
Compounds that are difficult to burn, such as
PCBs and dioxin-contaminated soils, have been
successfully incinerated to a ORE of 99.9999 percent.
However, some tests have been conducted which
have failed various regulatory requirements. Early
tests of incinerators indicated less than 99.99 percent
ORE, and in addition, some particulate emissions
exceeded permit limits. Some recent testing of
contaminated (PCB) soil showed 99.999 percent
rather than 99.9999 percent ORE. Possible reasons
for these apparent failures include faulty or
contaminated equipment (Weston, 1988). In other
tests, insufficient concentrations of input POHCs have
resulted in failure to demonstrate the required DREs
because of high detection limits in stack emissions
analyses. Dioxin wastes, including dioxin-containing
soils, often contain only low levels of dioxins and
furans. Nonetheless, it is necessary to treat the entire
waste matrix in order to manage these toxic
compounds. Technology which is applicable to clioxin
decontamination is expected to be applicable to
Superfund site wastes, which may be mixed solids,
sludges and liquids containing a range of organics.
The summary of treatment processes in Table 4-2
also shows that potentially contaminated air stream
cleaning residues are produced. These thermal
treatment by-product streams require further
treatment and thus additional costs are incurred.
10
-------
Table 4-2. Technologies Applicable to Dioxin Decontamination
Process Name
Stationary Rotary
Kiln Incineration
Mobile Rotary Kiln
Incineration
Liquid Injection
Incineration
Fluidized-bed
Incineration
High Temperature
Fluid Wall (Huber
AER)
Infrared Incinerator
(Shirco)
Molten Salt
(Rockwell Unit)
Supercritical Water
Oxidation
Plasma Arc
Pyrolysis
In Situ Vitrification
Applicable Waste
Streams
Solids, liquids,
sludges
Solids, liquids,
sludges
Liquids or sludges
with viscosity
< ssu (i.e.,
pumpable)
Solids, sludges
Primarily for
granular
contaminated
soils, but may also
handle liquids
Contaminated
soils/sludges
Solids, liquids,
sludges; high ash
content wastes
may be
troublesome
Aqueous solutions
or slurries with
less than 20
percent organics
can be handled
Liquid waste
streams (possibly
low viscosity
sludges)
Contaminated soil
- soil type is not
expected to affect
the process
Stage of
Development
Several approved
and commercially
available units for
PCBs; not yet used
fordioxins
EPA mobile unit is
permitted to treat
dioxin wastes;
ENSCO unit has
been demonstrated
on PCB waste
Full scale land-
based units permitted
for PCBs; only ocean
incinerators have
handled dioxin wastes
G A, Technologies
mobile circulating bed
combustor has a
TSCA permit to burn
PCBs anywhere in
the nation; not tested
yet on dioxin
Huber stationary unit
is permitted to do
research on dixoin
wastes; pilot scale
mobile reactor has
been tested at
several locations on
dioxin-contaminated
soils
Pilot scale portable
unit tested on waste
containing dioxin; full
scale units have been
used in other
applications; not yet
permitted for TCDD
Pilot scale unit was
tested on various
wastes - further
development is not
known
Pilot scale unit tested
on dioxin-containing •
wastes - results not
yet published
Prototype unit (same
as full scale) currently
being field tested
Full scale on
radioactive waste;
pilot scale on
organic-contamined
wastes
Performance/Destruction
Achieved .
Greater than Six nines ORE for
PCBs; greater than five nines
ORE demonstrated on dioxin at
combustion research facility
Greater than six nines ORE for
dioxin by EPA unit; process
residuals delisted
Greater than six nines ORE on
PCB wastes; ocean incinerators
only demonstrated three nines
on dioxin containing herbicide
orange
Greater than six nines ORE
demonstrated by GA unit on
PCBs
Pilot scale mobile unit
demonstrated greater than five
nines ORE on TCDD-
contamjnated soil at Times
Beach (79. ppb reduced .to ,
below detection)
Greater than six nines ORE on
TCDD-contaminated'soil-
Up to eleven nines ORE on
hexachlorobenzene; greater
than six nines ORE .on PCB >
using bench scale reactor
Six nines ORE on dioxin-
containing waste reported by
developer, but not presented in
literature; lab testing showed
greater tha'n 99.99%
conversion of organic chloride
for wastes containing PCB
Greater than six nines
destruction of PCBs and CCI4
Greater than 99.9% destruction
efficiency (DE) (not offgas
treatment system) on PCB-
contaminated soil
Cost
$0.25-
$0.70/lb for
PCB solids
NA".
$200-
$500/ton
$60-
$320/ton for
GA unit
: $300-
$600/ton
Treatment
costs are
$200-
$l,200/ton
,..
NA
• $0.32-
$2.00/gal
$77-480/ton .
$300-
$1,400/ton
$120-
$250/m3 ..
Residuals Generated •
Treated waste material
(ash), scrubber
wastewater, particulate
from air filters, gaseous
products of combustion
Treated waste material
(ash), scrubber
wastewater, particulate
from air filters, gaseous
products of combustion
Same as above, but
ash is usually minor
.because solid feeds are
not treated
Treated waste (ash),
particulates from air
filters
Treated, waste solids
(converted to glass
beads), particulates
from baghouse
gaseous effluent
(primarily nitrogen
Treated material (ash),
particulates captured
by scrubber, (separated
from scrubber water)
Spent molten salt
' containing ash,
particulates from
baghouse
High purity water,
inorganic salts, carbon
dioxide, nitrogen
Exhaust gases (H2 and
CO) which are flared •
and scrubber water
containing particulates,
Stable/immobile molten
glass; volatile organic.
combustion products
(collected and treated) •
(Breton, 1987)
11
-------
There are significant quantities of brominated
wastes requiring disposal. Testing has been done
using the EPA mobile incinerator, but DREs were not
determined. Particulate results were consistently
below RCRA standards of 0.08 gr/dscf. Rotary kiln
temperatures were maintained within the operating
range of the testing protocol. The waste burned was
a brominated sludge, with bromine content between 1
and 12 percent. Moisture varied between 35 and 42
percent and the heating value between 3200 and
4600 Btu/lb. By-product streams were tested for
delisting purposes, and the purge water, cyclone ash,
and kiln ash failed the initial testing. Subsequent
process modifications and operation changes resulted
in successful delisting of these by-product streams.
Test burning of ethylene dibromide wastes was
performed at a commercial hazardous waste
incinerator for the purpose of assessing an innovative
approach to bromine emissions control. Sulfur was
added to the combustion chamber to force', the
formation of hydrogen bromide which is readily
scrubbed from stack gases. Successful destruction of
all POHCs were observed with no significant bromine
stack emission (Oberacker, 1988).
Experience Related to Incinerator
Emissions and Residues
Testing of incinerators has shown them capable
of performing at or above RCRA and TSCA
requirements for organic destruction or removal.
Although hazardous wastes may be burned in
incinerators, boilers and industrial furnaces, other
thermal processes have also been shown to be highly
effective. Limited data on incinerator ash and air
pollution control residues suggest that organic
compound levels are low and that destruction is the
primary reason for high DREs, not removal. Metal
concentrations in ash and residues vary widely,
depending upon metal input rate and process
operation (e.g., scrubber water recycle and make-up
rates). Data in Tables 4-3 (organics) and 4-4
(metals) illustrate that the residual concentrations of
toxic metals after leach testing are very low. These
concentrations are acceptable values according to the
EP Toxicity test requirements.
Incinerators equipped with appropriate air pollution
control devices (APCD) can meet HCI and particulate
emission requirements. Typical test results are given
in Table 4-5. Air cleaning systems significantly affect
the air flow balance and vacuum balance of the
incineration system as a whole. These systems are
important to meet air pollution permit requirements
and must be carefully designed to operate within
system constraints and design factors.
High solids content in wastes is of concern
because of the potential for solids entrainment and
carryover to downstream devices. As much as 10 to
25 percent of the soil solids fed can be carried over
into the secondary combustion chamber and then into
the APCD. The effect of such carryover can
significantly reduce on-stream availability of the
entire system.
In systems utilizing a horizontal, secondary
combustion chamber with tangential firing burners,
solids accumulating in the chamber can effectively
"reshape" the gas flow path. This can result in poor
gas mixing in the chamber, as well as increased load
on the induced draft fan. Such systems need frequent
cleanout to ensure operation as designed.
Lead concentrations in the kiln ash and blowdpwn
solids for the tests on combustion of soil and soil plus
sludge performed at the EPA's Combustion Research
Facility (CRF) clearly reveal partitioning of this metal
to the fly ash rather than the kiln ash. The partitioning
is not evident for other metals. Kiln leachate analyses
and blowdown liquids indicate concentrations typically
less than 1 mg/L, or well below the EP toxicity test
requirement. Antimony was evenly distributed
between the particulate and vapor phases in flue gas
samples taken at the afterburner exit. The same was
generally true for arsenic, although a somewhat
greater fraction was found in the particulate phase for
a greater number of tests. Most, if not all, of the
antimony and arsenic was found in the particulate
catch of the sampling trains run at the scrubber exit.
Comparable fractions of the input antimony and
arsenic were accounted for in the scrubber exit flue
gas and the scrubber blowdown. No clear
dependence of the distribution of arsenic and
antimony discharges with the primary test variables
was apparent. When chlorine was present in the
waste, the distribution of metals increased in the flue
gases. The metals are reported to partition more into
the vapor phase than into particulate in these
situations. (Actually, the test protocol called for
analysis of the impinger catch and of filterable
particulates from EPA Method 5 sampling trains.)
(Waterland, 1987b)
Often, air cleaning systems are not "matched" to
system removal requirements. Contaminated soil or
soil-laden wastes are likely to result in high sotids in
the off gases and may require high efficiency flue gas
cleaning systems to remove particulate emissions. Air
cleaning systems, especially scrubbers, generate
large quantities of wastewater. Wastewater treatment
facilities must be designed to "match" other system
capacities.
12
-------
Table 4-3. Concentration of Volatile and Semivolatile Organics in Incinerator Ash Residuals and their EP III Leachates
Site Number 1 2 • 3 3 4
Stream Description Kiln asn Kilnas^ Kiln as^ Boiler ash Cyclone ash
Concentrations3'13 Concentrations3'13 Concentrations3'15 Concentrations3.b Concentrations3'13
Ash EP ill Ash EP III Ash EP III Ash EP III Ash EP III
Leachate Leachate Leachate Leachate Leachate
(mg/kg) (ug/L) (mg/kg) (ng/L) (mg/kg) (ng/L) (mg/kg) (ng/L) (mg/kg) (ng/L)
Volatile Organics0
Nominal Detection Limit
Chloromethane
trans-1,2-Dichloroethane
1,1,1 -Trichloroethane
Trichloroethane
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzened
Carbon Disulfided
2-Butanoned
4-Methyl-2-Pentanoned
Styrened
Total Zylened
Semivolatile Organics0
Nominal Detection Limit
Acenaphthene
1,2,4-Trichlorobenzene
Fluoranthene
Isophorone
Naphthalene
2-Nitrophenol
4-Nitrophenol
N-Nitrosodiphenylamine
Phenol
Bis(2-ethylhexyl) phthalate
Benzyl butyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Diethyl phthalate
Dimethyl phthalate
Benzo(b) fluoranthene
Chrysene
Anthracened
Phenanthrened
Pyrened
Benzoic Acidd
2-Methylphenold
2-Methylnaphthalened
Anilined
Comments: Wet or Dry Ash
100
34
0.1
0.1
0.61
56
0.35
0.31
24
0.5
2.5
0.5
2.8
4.3
1.5
0.1
0.17
3
4.4
0.28
0.41
0.76
0.1
0.5
1.1
3.7
5.4
16
6.4
0.1
2 0.01 2
116
0.4
30
Wet
0.2
0.2
0.48
0.66
Wet
.12
Wet
Wet
Dry
a means not detected, hence less than nominal detection limit.
b Volatile organics data for EP III leachate not available.
c RCRA Appendix VIII unless otherwise noted.
d Not RCRA Appendix VIII compound.
(Van Buren, 1988)
13
-------
Table 4-3. (Continued)
Site Number
Stream Description
- .•
5 - 6
Small Incinerator Incinerator
Bottom "Ash' Bottom Ash
Concentrations3'13 Concentrations3.13
, Ash ; EP III - Ash
EP III
Leachate Leachate
Volatile Organics0
Nominal Detection Limit
Chkxomethanc
lrans-1 ,2-Dtchloroethane
1,1,1-Trichtoroethane
Tfichloroethane
Tetrachloroethene
Toluene
Chlorobcnzene
Ethylbenzened
Carbon Disulfided
2-Butanoned
4-Methyl-2-Pentanoned
Styrened
Total Zy!ened
Scmivolatile Organics<=
Nominal Detection Limit
Acenaphthene
1 ,2,4-Trichlorobenzene
Fluoranlhene
Isophorone
Naphthalene
2-Nitropnenol
4-Nitrophenol
N-Nitrosodiphenylamine
Phenol
8is(2-ethylhexyl) phthalate
Benzyl butyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Diolhyl phthalate
Dimethyl phthalate
Benzo(b) fluoranthene
Chrysene
Anthracene11
Phenanthrened
Pyroned
Benzoic Acidd
2-Methylphenold
2-Methylnaphthalened
Anilined
Comments: Wet or Dry Ash
(mg/kg) (ug/L) (mg/kg)
100 - 100
- - -
' u
"-
-
-
•
-f
_
-
-
-
-
- - -
0.1 2 0.1
0.26
- - 10
0.23
1,1
6J8
-
"'•
. -' - .
- 1,7
- 500
- " ' 5
39
2.5
- ' - T
31
-
,- _ ,:.
0.15
. ' 1.3
0.34
• 46 • 2:4
'• T
- - 6:2
T
Dry Dry
(M/L)
-
-
-
-
-
-
- :•
-
-
-
-
-
-
-
2
-
10
-
20
8
60
90
•- •
,30
-.
-
14
-
-
580
-
-
-
-
-
-
-
4 '
-
._
7
Incinerator,
Bottom Ash
Concentrations3. b
, Ash' EP III
Leachate
(mg/kg) (jig/L)
100
- . - .
-
-
-
-
- •
_ ,
-
-
-
-'
-
-
0.1 2
-
-
-
11 62
0.75
-
-
1.5 - - '
6
150
7
7
-
-
-
-
-
- . -
-
-
-
-
0.3
20
Wet
.•;-•',•
8
'•..• Kiln Ash
, Concentrations8'15
Ash .. EP 111 . ,
Leachate
.(mg/kg) (ug/L)
1 \, •••
,0.5
.1.7
. - -
6.2 -
5.3
3.6 -:
.120
2.5
7.6
-
- '
29
-
• 15
0.5 2
-
-
-
2.5
2.3
-
. _
. . - . , -
.400 1800
.-•..,
-
. - -•
- -
•:• - - ':"
-
-i '
'
-
0.9 --•,.
1;3
., •• - — .
•i _
15
-
Wet, ,
8
Incinerator ,.. . .
Bottom Ash
Concentrations3.13
Ash EP III
Leachate
(mg/kg) (ug/L)
0.5
-
-
-
-
.-
2.1
-
.-
-
-
-
•',•-
— •• —
0.1 2
-
-
—
-
- ,
-
-
-
120
-
- -
-
- - .
-
—
—
-
-
-
- •
-
-
-
. Dry
.(Van Buren, 1988)
a means not detected, hence less than nominal detection limit.
b Volatile organics data for EP III leachate not available. ':
c RCRA Appendix VIII unless otherwise noted.
d Nol RCRA Appendix VIII compound.
14
-------
Table 4-4.
Concentration of Priority Metals in Incinerator Residuals
Site Number 1
Stream Description Kiln Ash Concentrations
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Comments
Wet or Dry Ash
Sample
(mg/kg)
2
4
<1
<2
120
6900
220
<0.05
190
<1
11
<1
160
EP
Leachate
(mg/L)
<0.05
0.23
<0.01
<0.01
0.10
8.6
2.3
< 0.001
0.49
<0.05
<0.01
<0.01
0.14
Wet
EP III
Leachate
(mg/L)
0.04
<0.01
<0.01
<0.01
0.22
16
3.5
< 0.001
0.45
0.02
<0.01
0.02
0.42
2
Kiln Ash Concentrations
Sample
(mg /kg)
6
2
<2
-------
Table 4-4.
(Continued)
Site Number
Stream Description
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Comments
Wet or Dry Ash
Small Incinerator Bottom Ash
Concentrations
Sample
(mq/kg)
<1
<2
<1
100
40
<1
<0.1
3
<1
54
6
200
EP
Leachate
(mg/L)
<0.01
0.12
<0.01
<0.01
0.03
0.02
<0.01
< 0.001
0.04
<0.1
<0.01
<0.01
0.31
Dry
EPIII
Leachate
(mq/L)
0.10
0.54
<0.01
<0.01
2.7
0.07
<0.01
< 0.001
0.27
0.12
<0.01
<0.02
0.17
Incinerator Bottom Ash
Concentrations
Sample
(mq/kq)
<1
8
<2
<1
110
120
!1300
; 0.1
22
12
; 21
<1
810
EP
Leachate
(mg/L)
0.07
<0.01
<0.01
0.04
0.03
1.9
3.3
< 0.001
0.33
0.03
<0.01
0.05
16
Dry
EPIII
Leachate
(mq/L)
0.06
<0.01
<0.01
<0.01
<0.02
0.64
12
< 0.001
0.49
0.02
<0.01
<0.02
9.5
Incinerator Bottom Ash
Concentrations
Sample
(mq/kq)
49
12
<1
<1
120
2000
160
0.25
650
19
9
4
850
EP
Leachate
(mq/L)
<0.01
<0.06
<0.01
<0.01
<0.03
13
0.11
< 0.001
13
<0.05
<0.01
<0.01
65
Wet
EP III
Leachate
(mg/L)
0.02
<0.01
<0.01
<0.01
<0.02
11
0.50
< 0.001
4.0
0.02
<0.01
0.02
98
Site Number
Stream Description
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Load
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Comments
Wet or Dry Ash
Kiln Ash Concentrations
Sample
(mq/kq)
240
11
<1
36
250
2900
1600
0.1
100
<40
3
3
2500
EP
Leachate
(mg/L)
0.49
0.06
<0.01
0.12
<0.03
0.33
0.11
< 0.001
0.42
<0.05
<0.01
<0.01
12
Wet
EPIII
Leachate
(mq/L)
0.36
0.02
<0.01
0.19
<0.02
1.8
<0.01
< 0.001
0.71
0.04
<0.01
0.18
35
Incinerator Bottom Ash Concentrations Kiln Ash Concentrations
Sample
: (mq/kg)
32
27
! <1
; 3
110
! 14
280
<0.05
15
8
<1
; 4
'2200
EP
Leachate
(mq/L)
<0.05
0.22
<0.01
0.03
0.63
0.09
<0.07
< 0.001
<0.03
<0.05
<0.01
<0.01
8.5
Dry
EPIII
Leachate
(mq/L)
<0.01
<0.01
<0.01
<0.01
0.28
0.05
<0.01
< 0.001
<0.01
<0.01
<0.01 ,
<0.02
20
Sample
(mq/kq)
<0.8
2
<1
<1
29
120
490
<0.05
21
<4
9
6
44
EP
Leachate
(mq/L)
<0.01
<0.06
• <0.01
<0.01
0.08
<0.02
<0.07
< 0.001
2
<0.05
0.09
<0.01
0.67
'i
• 'Wet
EP III
Leachate
(mci/L)
<0.02
<0.01
<0.01
<0.01
<0.02
0.67
<0.50
< 0.001
0.49
<0.01
<0.01
<0.02
1.9
(Van Buren, 1988)
16
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Table 4-5. Summary of Data on Paniculate Concentration and HCI Removal Efficiency for Incinerators Burning
Wastes Containing Chlorinated Compounds
Plant
A
B
C
D
E
F
Scrubbing System
75-cm water column
(w.c.) AP venturi -
sieve tray tower
Packed tower -
1 -stage electrified
scrubber (ES)
Packed tower -
packed tower -
2-stage (ES)
300 cm w.c. AP
venturi - 3 packed
towers in, series
1 packed tower
1 packed tower
Alkaline Scrubbing
Media
Caustic
Lime
Caustic
H2O only
Once-through H2O .
Once-through H2O
Mist Eliminator
See last column
Yes
Yes
Yes
.
Yes
Yes
Avg HCI Removal
EFficiency and pH of
Scrubber Effluent
>99% atpH4;
<99% at pH 1
>99% at pH 2
>99% at pH 5
>99%*
>99% atpH 1
>99% atpH 1.5
Avg Paniculate
Emissions mg/Nm3
(gr/dscf) at 7% O2
1520 (0.666) (no mist
eliminator)
220 (0.095) (with mist
eliminator)
78 (0.034)
150 (0.066)
23 (0.010)
200 (0.088)
4 (0.002)
(PEER, 1984; Gorman, 1988)
* pH of final effluent was 2 but is not comparable,to other systems since this plant'used three scrubbers in series with feed-
forward water flow.
17
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-------
CHAPTER 5
Issues Affecting the Implementation of Incineration
Permitting Requirements
The steps required to conform to environmental
protection regulations are different for on-site and
off-site incinerators. Off-site incineration is typically
performed in a commercial incinerator which should
already be permitted under a RCRA Part B to accept
a wide variety of hazardous wastes. In order to
accept a waste stream different from those for which
it is permitted, any such incinerator will probably be
required to perform a trial burn (i.e. a test burn
utilizing a (spiked) sample of the candidate waste with
sampling and analyses performed to demonstrate a
ORE of 99.99% for the identified POHCs).
Preparation of the trial burn plan, including the
sampling and analysis plan, and the quality assurance
plan, can take the majority of predesign time. Time
required to plan and execute trial burns varies from 4
to 9 months. Steps in the trial burn procedures are
presented in Table 5-1. It may be possible to meet
TSCA and RCRA requirements simultaneously in the
case of burning PCBs. Applicants should be aware of
this and should consider business ramifications.
Technical requirements for successful trial burns at
off-site incinerators are shown in Table 5-2.
Table 5-1. Steps in Trial Burn Procedures
• Prepare trial burn plan and submit to appropriate state or
federal agency (required 6 months after notification).
• Prepare responses to EPA on any questions or deficiences in
the trial burn plan (1 month).
• Make any additions or modifications to the incinerator that may
be necessary (1 to 3 months).
• Prepare for trial burn.
> Prepare for all sampling and analysis (S&A) (2 to 3 months).
> Select date for trial burn, in concert with S&A staff or
contractor (completed 1 month prior to test).
> Notify all appropriate regulatory agencies (1 month).
> Obtain required quantities of waste having specified
characterisitics.
> Calibrate all critical incinerator instrumentation (2 weeks).
• Conduct trial burn sampling (1 week).
• Conduct sample analysis (1 to 1-1/2 months).
• Calculate trial burn results (1/2 month).
• Prepare results for submittal to EPA (1/2 to 1 month). Include
requested permit operating conditions.
• Obtain permit to accept candidate waste.
(U.S. EPA, 1987)
During the planning process it is necessary to
select trial burn conditions that (1) provide the plant
adequate operating flexibility, (2) assure the trial burn
will be conducted in a manner acceptable to
regulatory agencies, (3) make the trial burn cost-
effective, and (4) represent worst case conditions
under which the incinerator may be expected to
operate. Failure to meet the trial burn requirements
on the first series of tests is common and this is just
one of many reasons why trial burns frequently take
more time and effort than an operator anticipates.
Note that it is often necessary to "spike" trial burn
wastes with significantly higher concentrations of
some POHCs in order to ensure adequate
measurement of DREs. If a POHC is not detected,
then the ORE is calculated using the analytical
detection limit and this results in misleadingly poor,
apparent DREs.
On-site incineration has somewhat different
requirements. Superfund site remediation is exempt
from specific compliance with other regulations.
However, the requirement that actions at a CERCLA
site comply with all applicable or relevant and
appropriate requirements (ARARs) means that any
technology (including incineration) must meet the
technical requirements (but not the administrative
requirements) of federal and state laws. Thus, a trial
burn will be necessary even at a Superfund site. The
technical requirements are the same as described
above and so the time requirements, including
planning, are approximately the same.
The Use of Risk Assessment as a Tool in
Evaluating Waste Management
Alternatives
If hazardpus organic waste is fed to an
incinerator, the RCRA regulations require the
achievement of "four-nines" (99.99%) minimum
destruction and removal efficiency (DRE). This
technical requirement constitutes an ARAR for
incineration at a CERCLA site. This means that for
every 10,000 pounds of a POHC fed, no more than
one (1) pound may be released from the stack. Using
the amount of waste fed, the DRE for the incinerator,
and the available toxicity data for compounds in the
waste, estimates can be made of risk of exposure to
organic emissions. Similarly, estimates of risk to
human health can be made for products of
19
-------
Table 5-2. Regulatory Requirements for Off-Site Incineration Permits
RCRA
TSCA
POHC Destruction and Removal Efficiency (ORE) 99.99%
Temperature per trial burn or per the permit
Residence Time
Combustion Efficiency
Stack O2
HCI Control
Particulates
' per trial burn or per the permit
; none
: per trial burn or per the permit
, 4 Ib/hr max or 99% control*
180 mg/dscm* ,
99.9999%
1200°C min (PCB liquids)
per trial burn (non-liquids)
2 sec min (1200b C)
1.5 sec min (1600° C
non-liquid per trial burn
99.9%
3% min (PCB Liquids)
2% min (1600° C)
non-liquid per trial burn
per regional administrator
per regional administrator
" May be subject to more stringent state or local standards
(Oberacker, 1988)
incomplete combustion (PICs) and for inorganic
emissions, including heavy metals.
There are risks to human health and the
environment associated with any approach for
remediating a contaminated site (even the "no-
action" alternative). One way of comparing
remediation alternatives is to perform a risk
assessment of each alternative prior to remedy
selection. Risk assessment can also be a useful tool
for risk management when used to identify the source
of greatest risk in any action.
There are uncertainties in the risk assessment
process. These arise from a number of sources
including toxicity data, source emissions estimates or
measurements, and dispersion modeling. To deal with
such uncertainties, conservative assumptions can be
made during the risk analysis process. Such
assumptions provide large factors of safety in the
process. Being conservative in the risk estimating
process means that overestimating risk is encour-
aged. Risk estimates are usually made for a 70 year
average total lifetime exposure, even though persons
living near disposal facilities are exposed for much
less time. The values used for compound toxicity are
derived from conservative assumptions about
chemical dose resulting in specific effects.
Atmospheric dispersion models have been developed
so as to overestimate ambient air concentrations to
which possible receptors are exposed. For example,
continuous exposure to ambient outdoor air
concentrations is assumed, while most people spend
a large portion of time indoors.
Risks may occur for a remediation activity from
any one of three different mechanisms: 1) normal
operations, 2) abnormal operations (upsets), arid 3)
accidents. Normal operations refer to the day-to-
day operational procedures when systems are work-
ing properly. Upsets and accidents are unexpected
conditions leading to higher concentrations of toxics,
but only for relatively short periods of time.
Partitioning in this way helps to characterize
scenarios in the risk estimating process.
The results of application of accepted risk
analysis includes three steps, i.e., estimating the
amount of material escaping from the source, analysis
of the movement (direction and amount) of the toxics
from the source to a potential point of exposure (say
a human "receptor"), and estimating the toxicity of
the compound(s) once a receptor is reached.
The Regulatory Impact Analysis (RIA) developed to
support RCRA hazardous waste incineration
regulations, contained a "worst case" risk
assessment for hazardous waste incineration
performed for a wide range of possible scenarios
(PEER, 1984). The range included normal and upset
conditions. Calculations were performed assuming
DREs for organics of 99 percent, 99.9 percent and
99.99 percent (the required DRE), and also assuming
zero removal of metals by air pollution control devices
(APCDs). These "worst case" assumptions simulate
incinerator upsets. The results of these analyses are
presented in Table 5-3. As can be seen, the risks of
metals are likely to be higher than those from POHCs
and PICs. When the risks from metals are added to
the risk from POHCs and PICs, the total risk did not
exceed one in 100,000 (1 X 10-5).
Table 5-3. Total Excess Lifetime Cancer Risk to the
Maximum Exposed Individual
Emission Item Risk Range Probability Statement
POHCs ;
PICs
Metals
Total
10'7 to 10"10
10-7 to 10-11
10-5 to 10-8
10-5 to 10-8
1 in 10,000,000 to 1 in 10 billion
1 in 10,000,000 to 1 in 100 billion
1 in 100,000 to 1 in 100,000,000
1 in 100,000 to 1 in 100,000,000
(PEER, 1984)
Health and Safety Considerations
On-site incineration actions often involve
excavation of contaminated soils, special materials
handling of wastes, crushing or other size reduction
20
-------
operations, other pretreatments, the combustion
process itself and finally, disposal (and possibly
treatment) of residues. All of these actions require
special consideration of the volatility and flammability
(or even explosiveness) of the wastes which are
candidates for incineration. As with any remedial
activity, a zone of decontamination is needed to store
soils or wastes prior to processing. Furthermore, the
residues also require zone of decontamination
storage prior to final treatment and/or disposal.
There is a need for contractual commitments
between contractors and subcontractors regarding
health and safety requirements. The site health and
safety plan which is developed early in the program
does not always have input from the site
subcontractors. Making the plan available during
contract negotiations would make the subcontractors
aware of the requirements earlier. Personnel turnover
also makes enforcement of the plan difficult. There is
a continuing need for health and safety training
throughout remediation activities.
The health and safety plan should take into
account the wide variations in temperature and other
weather conditions which could be encountered at a
site. As an example, respirators have been found to
fog during operations. They can require modifications,
and this in turn can cause significant project delays.
Similarly, heat stress during the summer months,
caused by required heavy protective clothing can be
a major concern and can cause significant delays.
This problem can be exacerbated when work near a
hot combustion chamber is required.
The general health and safety plan developed
during the early phases of site remediation needs to
be upgraded as the work proceeds. It is necessary to
do this to meet changing conditions and changing
project demands. A flexible plan which takes into
account the need for possible changes is very useful
and eliminates, or at least mitigates, significant project
delays.
21
-------
-------
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AU.S. GOVERNMENT PRINTING OFFICE: 1989-648-163/87056
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