EPA-3W1-89-001.
HOSPITAL WASTE  INCINERATOR FIELD INSPECTION
         AND SOURCE EVALUATION MANUAL
                    Prepared by:

             Midwest Research Institute
                     Suite 350
            401 Harrison Oaks Boulevard
            Gary, North Carolina  27513
              Contract Mo. 68-02-4463
               Work Assignment No. 6
                   Prepared for:

             James Topsale, Region III
             Pam Saunders, Headquarters

       U. S.  Environmental Protection Agency
       Stationary Source Compliance Division
    Office of A1r Quality Planning and Standards
              Washington, O.C.  20460
                   February 1989

-------

-------
                                DISCLAIMER

     This manual was prepared by Midwest Research Institute for the
Stationary Source Compliance Division of the U. S. Environmental
Protection Agency.  It has been completed in accordance with EPA Contract
No. 68-02-4463, Work Assignment 6.  It has been reviewed by the Stationary
Source Compliance Division of the Office of Air Quality Planning and
Standards, U. S. Environmental Protection Agency and approved for
publication.  Approval does not signify that the contents necessarily
reflect the views and policies of the U. S. Environmental Protection  ,
Agency.  Any mention of product names does not constitute endorsement by
the U. S. Environmental Protection Agency.
     The safety precautions set forth in this manual and presented at any
training or orientation session, seminar, or other presentation using this
manual are general in nature.  The precise safety precautions required for
any given situation depend upon and must be tailored to the specific
circumstances.  Midwest Research Institute expressly disclaims any
liability for any personal Injuries, death, property damage, or economic
loss arising from any actions taken 1n reliance upon this manual or any
training or orientation session, seminar, or other presentations based
upon this manual.

-------

-------
                              ACKNOWLEDGEMENT

     A  primary source of information for this manual is the Municipal
Waste Incinerator Field Inspection Notebook prepared by Richards
Engineering, Durham, North Carolina.  Much of this document, especially
Chapter 6  "Baseline Inspection Procedures for Hospital Incinerators," has
been drawn extensively from the Richard's document.
     The authors acknowledge the guidance and contributions provided by
the EPA work assignment managers, James Topsale, Region III and Pam
Saunders,  Stationary Source Compliance Division.
     Additionally, the authors acknowledge the contributions of the
following  individuals who provided useful comments on the initial draft of
this document:  Christopher A. James, EPA/Region X; Jim Eddinger,
EPA/OAQPS; David Painter, EPA/OAQPS; Justine Push, EPA/OECM; Gary Gross,
EPA/Region III; Roger Pfaff, EPA/Region IV; Jay M. Willenberg, State of
Washington, Department of Ecology; Wallace E. Sonntag, New York State,
Department of Environmental Conservation; Carl York, State of Maryland,
Air Management Administration; and Frank Cross, Cross/Tessitore and
Associates.
                                    iii

-------

-------
                             TABLE OF CONTENTS
                                                  .                    Page
CHAPTER 1.0  INTRODUCTION	..	    1-1
             1.1  BACKGROUND	    1-1
             1.2  PURPOSE..	.    1-1
             1.3  SCOPE..	    1-1
             1.4  ORGANIZATION	;...	    1-2
             1.5  REFERENCES FOR CHAPTER  1		    1-3
CHAPTER 2.0  GENERAL INSPECTION CONSIDERATIONS.....	    2-1
             2.1  LEGAL AUTHORITY OF THE  INSPECTOR	    2-1
                  2.1.1  Scope	    2-1
                  2.1.2  State Authority	    2-1
                  2.1.3  Authorized  Representatives	    2-1
                  2.1.4  Off site Inspections	    2-2
             2.2  REGULATIONS UNDER  THE CLEAN AIR ACT...	    2-2
                  2.2.1  Existing Regulations	    2-2
                  2.2.2  Possible Future  Regulations	    2-6
             2.3  INSPECTOR RESPONSIBILITIES AND  LIABILITIES	    2-7
                  2.3.1  Legal Responsibilities	    2-7
                  2.3.2  Procedural  Responsibilities	    2-8
                  2.3.3  Safety Responsibilities	    2-9
                  2.3.4  Professional and Ethical
                           Responsibi 1 ities	    2-9
                  2.3.5  Quality Assurance  Responsibilities........    2-11
                  2.3.6  Potential Liabilities	    2-11
             2.4  GENERAL INSPECTION PROCEDURES..	    2-12
                  2.4.1  Preinspection Preparation	    2-12
                  2.4.2  Preentry Observations	    2-15
                  2.4.3  Entry		    2-16
                  2.4.4  Contents and Timing...	    2-20
             2.5  REFERENCES FOR CHAPTER  2..	    2-25
                                    IV

-------
                       TABLE OF CONTENTS (continued)
                                                                      Page
 CHAPTER 3.0  INSPECTION SAFETY	   3-1
             3.1  SCOPE	„	„	   3-1
             3.2  SAFETY GUIDELINES	„		   3-1
             3.3  EQUIPMENT-SPECIFIC SAFETY CONSIDERATIONS	   3-5
                  3.3.1  Incineratbrs	„	   3-5
                  3.3.2  Wet Scrubbers	   3-6
                  3.3.3  Dry Scrubbers	   3-7
                  3.3.4  Fabric Filters	   3-8
 CHAPTER 4.0  VISIBLE EMISSION OBSERVATION	   4-1
             4.1  EPA REFERENCE METHOD 9	   4-1
             4.2  CONTINUOUS EMISSION MONITORING FOR OPACITY	   4-2
             4.3  SPECIAL CONSIDERATIONS FOR OPACITY
                    OBSERVATIONS AT HOSPITAL INCINERATORS	   4-9
                  4.3.1  Tall Stack/Slant Angle	   4-9
                  4.3.2  Steam (Condensing Water Vapor) Plumes	   4-9
                  4.3.3  Evaluating Visible Emissions	   4-9
                  4.3.4  Fugitive Emissions	   4-10
             4.4  REFERENCES FOR CHAPTER 4	   4-10
CHAPTER 5.0  HOSPITAL INCINERATION SYSTEMS	   5-1
             5.1  INTRODUCTION	   5-1
             5.2,  TYPES OF HOSPITAL INCINERATOR SYSTEMS	   5-1
                  5.2.1  Principles of  Air Supply,	   5-3
                  5.2.2  Hospital  Incinerator Descriptions	   5-9
             5.3  AIR POLLUTION  CONTROL SYSTEMS...,		   5-22
                  5.3.1  Wet Scrubbers	   5-22
                  5.3.2  Dry Scrubbers	   5-30
                  5.3.3  Fabric  Filters	   5-39
                  5.3.4  Electrostatic  Precipitators	   5-45
             5.4  REFERENCES FOR CHAPTER 5	   5-45

-------
                       TABLE OF CONTENTS  (continued)

                                                                      Page

CHAPTER 6.0  BASELINE INSPECTION PROCEDURES FOR HOSPITAL
               INCINERATORS	   6-1

             6.1  BASELINE INSPECTION TECHNIQUE	,	   6-1

                  6.1.1  Basic Principles	   6-2
                  6.1.2  Counterflow Technique	   6-4
                  6.1.3  Co-current Technique...	   6-4

             6.2  LEVELS OF INSPECTION	   6-7

                  6.2.1  Level 4 Inspections	   6-7
                  6.2.2  Level 3 Inspections.	   6-9
                  6.2.3  Level 2 Inspections	   6-9
                  6.2.4  Level 1 Inspections....	   6-10

             6.3  COMMON INSPECTION ACTIVITIES.	   6-10

                  6.3.1  Prepare a System Flowchart	   6-11
                  6.3.2  Identify Potential Safety Problems	*..   6-11
                  6.3.3  Evaluate Locations for Measurement Ports..   6-12
                  6.3.4  Evaluate Visible Emissions	   6-12
                  6.3.5  Evaluate Double-Pass  Transmlssometer
                           Physical Condition	   6-13
                  6.3.6  Evaluate Double-Pass  Transmlssometer
                           Data	   6-13
                  6.3.7  Sulfur Dioxide,  Nitrogen Oxides,  and
                           Hydrogen Chloride Monitor  Physical
                           Conditions	   6-14
                  6.3.8  Sulfur Dioxide,  Nitrogen Oxides,  and
                           Hydrogen Chloride Emission Data....	   6-14

             6.4  CHARACTERIZATION OF WASTE	   6-15

                  6.4.1  Waste Characteristics That Affect
                           Incinerator Operation	   6-20
                  6.4.2  Handling of Infectious Wastes	   6-22
                  6.4.3  Waste Inspection	   6-23

             6.5  EVALUATION OF COMBUSTION EQUIPMENT	   6-28

                  6.5.1  Particulate Matter and Particulate
                           Metals			   6-28
                  6.5.2  Acid Gases	   6-29
                  6.5.3  Organics	   6-30.
                  6.5.4  Infectious Agents	   6-30
                  6.5.5  Inspection of Combustion Equipment........   6-31
                                    vi

-------
                        TABLE  OF  CONTENTS  (continued)

                                                                       Page

              6.6  INSPECTION  OF  AIR POLLUTION CONTROLS	    6-41

                   6.6.1  Inspection of Wet Scrubbers	    6-41
                   6.6.2  Inspection of Dry Scrubbers	    6-51
                   6.6.3  Inspection of Fabric Filters	    6-58

              6.7  REFERENCES  FOR CHAPTER  6	    6-66

 CHAPTER 7.0  SPECIAL CONSIDERATIONS	    7-1

              7.1  INCINERATOR OPERATOR TRAINING AND OPERATOR
                     EXPERIENCE	,	    7-1

              7.2  EMERGENCY OPERATING PLAN	    7-2

              7.3  CROSS-MEDIA INSPECTIONS....	    7-2

                   7.3.1 A1r  Pollution	    7-3
                   7.3.2 Solid Waste	    7-3
                   7.3.3 Inspector  Multimedia  Responsibilities	    7-4

              7.4  STARTUP AND SHUTDOWN PROCEDURES  FOR  HOSPITAL
                     WASTE INCINERATORS AND ASSOCIATED  AIR
                     POLLUTION CONTROL DEVICE	    7-6

                   7.4.1 Batch Feed Starved-Air Incinerator	    7-6
                   7.4.2 Intermittent-Duty, Starved-A1r
                           Inci nerators	    7-9
                   7.4.3 Continuous-Duty,  Starved-A1r
                           Inc1 nerators	    7-10
                   7.4.4 Excess-Air Incinerators..	    7-11
                   7.4.5 Wet  Scrubbers	    7-12
                   7.4.7 Fabric  Filters	    7-15

              7.5   WASTE HEAT  BOILERS	    7-17

              7.6   CITIZENS COMPLAINT  FOLLOWUP...	    7-18

              7.7   REFERENCES  FOR CHAPTER 7	    7-18

CHAPTER 8.0  GLOSSARY	    8-1
                                    vii

-------
                       TABLE OF CONTENTS (continued)
APPENDIX A.
APPENDIX B.
APPENDIX C.
APPENDIX 0.
APPENDIX E.
APPENDIX F.
APPENDIX G.
                                                                      Page
INSPECTION CHECKLIST FOR WASTE CHARACTERIZATION	  ,A-1
INSPECTION CHECKLIST FOR INCINERATORS	,
INSPECTION CHECKLIST FOR POLLUTION CONTROL SYSTEMS...,
METHOD 9 WORK SHEET		
SAFETY CHECKLIST	,
CITIZEN COMPLAINT FORM	,
EXAMPLE INSPECTION REPORT.	,
B-l
C-l
D-l
E-l
F-l
G-l
                                   vm

-------

-------
                              LIST OF TABLES
TABLE 2-1.  GUIDELINE EMISSION LIMITS FOR INCINERATORS BURNING
              HOSPITAL WASTE	  2-5
TABLE 4-1.  SUMMARY OF METHOD 9 REQUIREMENTS	  4-3
TABLE 4-2.  PERFORMANCE SPECIFICATIONS FOR OPACITY MONITORS	  4-7
TABLE 5-1.  CLASSIFICATION OF HOSPITAL INCINERATORS...	  5-4
TABLE 5-2.  WET SCRUBBER PERFORMANCE PARAMETERS	  5-23
TABLE 6-1.  ULTIMATE ANALYSES OF FOUR PLASTICS	  6-19
TABLE 6-2.  INCINERATOR INSTITUTE OF AMERICA SOLID WASTE
              CLASSIFICATIONS	  6-21
TABLE 6-3.  MATRIX OF MEDICAL WASTE INSPECTION ACTIVITIES
              ASSOCIATED WITH INSPECTION LEVELS 1, 2, 3, AND 4.	  6-24
TABLE 6-4.  MATRIX OF COMBUSTION EQUIPMENT INSPECTION ACTIVITIES
              ASSOCIATED WITH INSPECTION LEVELS 1, 2, 3, AND 4	  6-32
TABLE 6-5.  MATRIX OF AIR POLLUTION CONTROL DEVICE INSPECTION
              ACTIVITIES ASSOCIATED WITH INSPECTION
              LEVELS 1, 2, 3, AND 4	  6-43
TABLE 7-1.  LIST OF HAZARDOUS WASTES THAT MAY BE GENERATED AT A
              MEDICAL FACILITY	  7-5
                                    IX

-------

-------
                              LIST OF FIGURES
 Figure  4-1.    Typical  transmissometer  installation  for measuring
Figure 5-1.
Figure 5-2.
Figure 5-3.
Figure 5-4.
Figure 5-5.
Figure 5-6.

Control of temperature as a function of excess air....
Schematic of a batch/starved-air incinerator.. 	
Operating sequence of a waste charging hopper/ram
Intermittent/control! ed-air incinerator with vertical
primary chamber and horizontal secondary chamber....
Schematic of a continuous operation control! ed-air
5-5
5-7
5-10
5-12
5-14
                incinerator with mechanical charging  and
                ash removal .........................
Figure 5-7.

Figure 5-8.
Figure 5-9.
Figure 5-10.
Figure 5-11.
Figure 5-12.
Figure 5-13.

Figure 5-14.

Figure 5-15.

Figure 5-16.
Figure 5-17.
Figure 5-18.
Retort multiple-chamber, excess-air  incinerator for
  pathological wastes ............... . ...............
In-line excess air  incinerator	
Drawing for rotary  kiln incinerator....,
Venturi configuration	
Spray venturi with  rectangular throat...
Vertically oriented packed-bed scrubber.
Components of a spray dryer absorber system  (semiwet
  proces s).«	,
Components of a dry injection absorption system
  (dry process)	,
Components of a combination spray dryer and  dry
  injection absorption system (semiwet/dry process)..,
Schematic of pulse jet baghouse	
Top access pulse jet fabric filter.	;...
Cross sectional sketch of pulse jet fabric filter.
5-16

5-17
5-19
5-21
5-25
5-26
5-29

5-32

5-33

5-34
5-40
5-41
5-43

-------
                        LIST OF FIGURES (continued)
                                                                      Page
Figure 6-1.   Counterflow inspection approach	  6-5
Figure 6-2.   Co-current inspection approach	  6-6
Figure 6-3.   The biological hazard symbol	  6-16
                                    XI

-------
                              1.0  INTRODUCTION

 1.1  BACKGROUND
      Hospitals have long used"incineration for the disposal of all or part
 of the wastes they generate; the practice is expected to grow in the near
 future.  Many States recently have established regulations governing the
 disposal of infectious wastes; other States are considering such regula-
 tions.  The trend in these regulations is away from direct landfilling and
 toward treatment to render wastes innocuous prior to land disposal.  The
 primary treatment method is expected to be incineration.
      At the same time that infectious waste disposal considerations are
 creating pressures for increased incineration of hospital wastes,  interest
 in the regulatibn of air emissions from these sources is also rising.
 Recent investigation into emissions from municipal  waste incinerators  has
 heightened the awareness of the  potential  for emissions of fine particu-
 late  matter,  acid gases, and toxic compounds (e.g., chlorinated dioxins
 and furans) from hospital  incinerators.   This has stimulated  interest  in
 these sources  that once were considered  too  small to be closely
 regulated.  A  number of States have enacted  or are  considering new
 regulations for  hospital waste incinerators  (HWI's).
      As  new, more stringent regulations  affecting HWI's raise control
 costs, the economic  viability of  larger  commercial  units  built to  serve a
 number of hospitals  increases.  Such  facilities can take  advantage  of  the
 economies of scale of  incineration  and pollution  control  equipment  and
 likely will be much  more able to  profitably  recover energy profitably  than
 will  a small HWI  with  its characteristic load fluctuations.
 1.2   PURPOSE
      These trends in the use  and  regulation of HWI's provide  the impetus
 for this manual.  The purpose of  this manual  is to  meet the growing need
 for specialized information on this source of air pollution.
      This manual provides air program inspectors with a concise body of
 information pertinent to the  inspection of hospital waste incinerators.
 1.3  SCOPE
     This manual  is not intended  to provide detailed information on
general inspection procedures and techniques.  These subjects have been
                                  V

                                    1-1

-------
 well covered elsewhere.1'2  These  subjects will be touched upon as
 necessary to present  an  integrated approach to HWI inspections, but the
 focus of this manual  will be on those subject areas with greatest
 relevance to HWI's.   Special emphasis will be placed on matters unique to
 HWI's.
     Much of the information relative to the components and operating
 principles of hospital waste incineration systems was taken from
 "Operation and Maintenance of Medical Waste Incinerators" which is
 currently under development by the U. S. Environmental Protection
 Agency.  Inspectors should refer to this document for detailed information
 on.the proper operation  and maintenance of hospital waste incinerator
 systems.
 1.4  ORGANIZATION
     In Chapter 2, general inspection information is presented. Topics
 include legal authority, regulations under the Clean Air Act, inspector
 responsibilities and  liabilities,  and general inspection procedures.
 Chapter 3 discusses safety during  inspections, with emphasis on hazards
 specific to HWI's and the control  devices expected at such facilities.
 Visible emission observation procedures are presented in Chapter 4.
     In Chapter 5, background information on HWI types is presented.
 Excess-air, starved-air, and rotary kiln units are discussed.  Background
 is also given for the types of control devices currently in use at HWI
 facilities and those expected to come into use as more stringent
 regulations are adopted.  These include wet and dry scrubbers and fabric
 filters.
     The heart of this manual is presented in Chapter 6.  Inspection
 checklists and detailed  inspection procedures are provided for Levels 2,
 3, and 4 inspections of HWI's and control devices..
     Special considerations are addressed in Chapter 7.  These include HWI
operator training, emergency operating plans, cross-media inspections,
citizen complaint followup, waste heat boilers, and startup and shutdown
procedures.   Finally, a number of appendices present supplementary
materials such as inspection checklists.
                                    1-2

-------
1.5  REFERENCES FOR CHAPTER 1

1.  U. S.  EPA Stationary Source Compliance Division, "Air Compliance
    Inspection Manual," U. S. Environmental Protection Agency.
    Publication No. 340/1-85-020.  September 1985.

2.  Richards, J.  R., and Segal!, R. R., "Baseline Source Inspection
    Techniques,"   U. S. Environmental  Protection Agency.  Publication
    No. 340/l-85-022a.   June 1985.
                                   1-3

-------

-------
                   2.0  GENERAL INSPECTION CONSIDERATIONS

 2.1  LEGAL AUTHORITY OF THE INSPECTOR1        '
      Section 114 of the Clean Air Act (CAA)  provides the Administrator of
 EPA or his authorized representative with the authority, upon presentation
 of his credentials, to enter the  premises of facilities  subject to
 regulations under the Act for the purpose of conducting  onsite inspections
 to monitor compliance with these  regulations.
 2.1.1  Scope
      Inspections conducted under  Section 114 extend  to all  things  relating
 to compliance with the requirements  of the CAA which are within the
 premises being Inspected.   These  may include:
      1.  Records;
      2.  Files;
      3.  Processes;
      4.  Monitoring  equipment;
      5.  Controls;
      6.  Sampling methods;  and
      7.  Emissions.
 2.1.2  State  Authority                                 ;
      In accord with  the Intent of the  CAA, much of the compliance
 monitoring,  including onsite inspections,  is  accomplished at the State
 level.   Section  114  of the Act allows  Federal authority to be delegated to
 the States to carry  out that Section.  Where  a State has been delegated
 full  Section  114 authority from EPA, the same authority EPA has to
 monitor,  sample, inspect or copy records, and any other authority under
 Section 114 can, in  like manner, be exercised by the State.  No
 representative of EPA need accompany the State officials.
 2.1.3   Authorized Representatives
     The EPA does not always have the staff available to conduct all of   ,
 the compliance monitoring functions on its own.  In order to accomplish
 these functions, EPA frequently hires private contractors to provide
 technical support for onsite inspections and  sampling, among other
things.  The EPA maintains that such contractors  upon proper designation
are "authorized representatives" of the Administrator within the meaning
                                    2-1

-------
 of Section 114; however, the courts have not unanimously upheld EPA's
 position.  For this reason, EPA has adopted a policy that duly-authorized
 contractors are used to conduct onsite inspections only in those Circuits
 where Courts of Appeals' decisions have not been against the use of
 contractors as authorized representatives.
      The EPA's current policy on the use of contractors to conduct onsite
 inspections is as follows:
      1.  First, Second, Third, Fourth, Fifth, Seventh, Eighth, Eleventh,
 and District of Columbia Circuits.  Authorized contractors may be
 designated to provide technical  support for inspection of facilities owned
 by anyone other than Stauffer Chemical Company.
      2.  Ninth Circuit.  Authorized contractors  may be designated to
 provide technical  support for any inspections.
      3.  Sixth and Tenth Circuits.  Absent express permission from
 Headquarters,  authorized contractors should not  be designated to provide
 technical  support  for any inspections.
 2.1.4  Offsite Inspections
      The EPA  also  has  the authority to conduct unannounced,  off-the-
 premlses inspections,  such  as  visible  emission observations.
 2.2   REGULATIONS UNDER THE  CLEAN AIR ACT
 2.2.1  Existing Regulations
      2.2.1.1   New  Source Performance Standards (NSPS).2  At  this  time,  no  NSPS
 is applicable  specifically to HWI's.   However, two  existing  NSPS  could
 apply to very  large facilities.  The standard for  industrial,  commercial,
 and institutional  steam generating  units (40 CFR Part 60, Subpart  Db)
 applies  to facilities with a heat  input capacity of 100 million Btu/h or
 greater  that recover heat to generate  steam or heat water.  This  heat
 input is greater than the capacity of  any onsite HWI available at  this
 time but is not out of  the question for a regional commercial facility.
 For this NSPS to be applicable, a facility burning Type 0 waste with a
 heating value of 8,500 Btu per pound would have to have a capacity of
nearly 12,000 pounds per hour (140 tons/d) or more.  The standard
regulates opacity and emissions of PM, NOX, and S02.
                                   2-2

-------
      The standard for incinerators (40 CFR Part 60, Subpart E) applies to
 incinerators with a capacity of 50 tons/d or greater that burn more than
 50 percent "municipal type waste."  Under the definitions of the standard,
 HWI's would seem to qualify.  Even so, only the largest onsite units or
 regional facilities would qualify.  Currently, this standard regulates PM
 emissions; the standard is being revised.
      2.2.1.2  National Emission Standards for Hazardous Air Pollutants
 (NESHAP's).  Standards for emissions of radionuclides to the atmosphere
 have been promulgated for DOE facilities (.40 CFR Part 61, Subpart H) and
 for other facilities (40 CFR Part 61, Subpart I).   Some medical  research
 facilities are licensed to incinerate their radioactive wastes.   At these
 facilities, these wastes likely will  be incinerated along with the
 facility's Infectious wastes, and the incinerator  will  be subject to the
 applicable NE5HAP.   It is unlikely that most hospital  incinerators will  be
 licensed to Incinerate radioactive wastes,  so incinerators at  these
 facilities are unlikely to be subject to the NESHAP's.
      2.2.1.3   State  Implementation Plans (SIP's).   Under the CAA, a State
 wishing  to administer its own air quality control  programs must  receive
 approval  from  EPA of Its SIP.   10 be  approved,  the SIP  is required to
 Include  a number  of  specific  programs,  including prevention of significant
 deterioration  (PSD)  in attainment areas,  new source review (NSR)  in
 nonattainment  areas,  and air  quality management plans and emission
 limitations to maintain  (or progress towards) attainment  of national
 ambient  standards.
      Incinerators located  at  hospitals are too small for  PSD and  NSR
 programs  to apply.  These  programs, particularly NSR, could apply to  very
 large regional commercial  HWI's.
     Some States are now regulating emissions from  HWI's  specifically, but
most have no specific requirements for these sources.  Where emission
 limits have been adopted,  they are generally quite  stringent.  For
 instance, Pennsylvania has recently (January 1988)   adopted  standards that
 limit emissions of participate matter fron the largest HWI's (capacity
>2,000 pounds per hour) to 0.015 gr/dscf, corrected to 7 percent  02.  This
limitation is based on the best demonstrated technology (BDT) determined
for municipal  waste Incinerators, the use of a dry  scrubber followed by a
                                    2-3

-------
 fabric filter or ESP.  Emissions of CO, HC1, and S02 are also regulated,
 as  is the opacity of the visible emissions.  Several States have imposed
 regulations on new HWI's similar to those governing hazardous waste
 incinerators under the Resource Conservation and Recovery Act (RCRA):
 0.08 gr/dscf (corrected to 12 percent C02) for particulate matter, 100 ppm
 for CO, and 99 percent control or 4 pounds per hour for HC1, whichever is
 higher.2  (These standards are essentially the same as the Pennsylvania
 regulations for the smallest HWI's, those with capacities <500 pounds per
 hour.)  Although current Interest in infectious waste is creating a trend
 towards specific regulations, 1n many States the only existing regulations
 that apply to HWI's are general prohibitions on excessive opacity and
 odor.  Table 2-1 presents emission limit guidelines currently promulgated
 for several States that represent the trend towards specific HWI emission
 limits.
     2.2.1.4  State Air Toxics Programs.  Most States have relatively new air
 toxics programs to regulate toxic emissions based on the ambient
 concentrations that result from operation of the source.  For Instance,
 the Pennsylvania regulations require ambient impact analyses for a number
 of  inorganic and organic substances using dispersion modeling.
     2.2.1.5  Construction and Operating Permits.  Because there currently are
 no NSPS regulations governing HWPs, many states are promulgating
 regulations of their own that impose both emission limitations and minimum
 operating conditions on the Incinerator and air pollution control
 devices.  These types of regulations are included as part of the HWI's
 construction and operating permit.
     Most states require that emission sources apply for a combined
 construction and operating permit; other states require both a
 construction permit and an operating permit.  The inspector should become
 familiar with the limitations and conditions included in the facility's
permit prior to Inspecting the HWI.  Table 2-1 presents examples of the
types of emission limitations that have been promulgated 1n some states.
Operating condition limits may include minimum primary and secondary
chamber temperatures, minimum gas retention time in the secondary chamber,
and minimum pressure drop across the venturi section.
                                    2-4

-------








CM
£

<:
^
^j
g
Q.
=
C9
£^j


OS
CO
oo
f^
o
Hr
^
LU
1—4
O
jjj
g
u_
t—

»— 1
o
1-4
CO
00
LU
LU
i— i
LU
a
1—4
3
CO

•
T— 4
CM
LU
^ j
CO
^_
^™


































JJ
1
I



























1
(






CM
a








o
o












5






>»
*
J
3




1
1
•
I
1
1
',
|




^
•>

J
L.
J
S







1 '
1


.*»
§
b
a.
••i*
|_
s°~
*+

*
(M
O
U 1
" u g
§ 8 S
S fe 3
^ tt ^
^ *^ 5
U « ^
^ V
CM -O
«i a w> .«*
u a w» «—
!s fe
s v
..
1 .
a.
o
V
%
S
il
I
14.
a
•O
^ (j
3 ?
U»
»_3_
- aT0 o~
•— c In e
u S -2 S
.2 fc£ fc
A ••» flt

*h> ** «k *»
M  U •—
*> « e=
(A M O
P"
at u 3s .e
« o ^> o»
SfMW V
o « 5
-* - 3 >.
1 &J! 8
> r^ -. fc

s""""

«>
4»
fe
a
^ ^
3 "m
I2-.
8.-0~.




o> S >, S
io~sf
** 3 >*

?§*•«
£ £ £ 8
>>•».— «;
tt * "* 0
s~-s
„
-1
S f -
fe"-
°-s g
7 | K

S 8 7
S « «.
- 1 S1
i- fe
i33

5"
g
s
&
•*•
2»
fc
a
u
M
O
O
•— o
u

•^ A , -.
^~ f
*9 _ ^
sa-
> A O
Wl 4rf •
C •*- . £
2^-°5»
So^S $
19 U
** 3 >*
1 &£ 8
U
a5.-i S
S : : i

§•
«
i»
3 o0*
** **
Si
1:
s-2- • ,
•M III




§» <5 >» £
 1^ ^ «
1 » 5 ""
Si 1 1
i 1 1
•s
₯ i
I9?
23%
v 5 2
S 8 S
S . S t£
^i g 8
i- g i CL
JB 1*1
: : 8

-^ 5^ o^ o^
O U U <-»
1 1 I I
Q. 0.0.
^ - - •
•"• i 2. '•
•s r r
« -3-3
« ? ?
o* o*
— » ^- >^
~ ~ S , o - ^

gg.— 5 3 """ S1^
>t.co at u *o.eo
§^- p* e ^- i- (^
« A si S ^ T
Of u o ^II>
a. i O —




\ .


!


^j
s
l

^ >*
*J -^ .C
»
H. i^

§ 1
•s.0
C JR
1*
2-5

-------
 2.2.2  Possible Future Regulations
      2.2.2.1  NSPS.   The EPA  is  considering  an NSPS  for smaller boilers,
 perhaps with a cutoff as low  as  10 million Btu/h  heat  input.2  Such a
 regulation has potential  applicability  to HWI's with capacities as low as
 1,200 pounds per hour (assuming  Type 0  wastes  with a heating value of
 8,500 Btu/lb) that produce  steam or hot water.
      2.2.2.2  SIP's.   With  the establishment of an ambient standard for
 respirable particulate matter (PM10), SIP revisions  are required for a
 number of  areas.  As  a source of PM10,  HWI's may  be  addressed in these SIP
 revisions  with new emission limits.  This may  also result in new emphasis
 on-HWI's under NSR provisions.
      2.2.2.3  The Medical Waste  Tracking Act of 1988.  The Medical Waste
 Tracking Act of 1988  was  signed  into, law by  President  Reagan on
 November 1,  1988. House  Rule (HR) 3515 created a pilot program to track
 infectious medical wastes in  10  states  including  New York, New Jersey,
 Connecticut,  and the  States contiguous  to the  Great  Lakes (Wisconsin,
 Illinois,  Michigan, Indiana,  Ohio, Pennsylvania,  and Minnesota).
 Additionally,  HR 3515 listed  the following 10  categories of waste that
 must  be Included in the tracking system:
      •   Cultures and stocks  of  Infectious agents and  associated
 biologlcals,  such as  cultures from laboratories;
      •   Pathological wastes, such as tissues,  organs, and body parts;
      •   Human blood  wastes and other blood  products,  including serum,
 plasma,  and other blood components;
      •   Sharps  that  have been used in  patient  care, medical research, or
 industrial laboratories;
      •   Contaminated animal carcasses, body part;;,  and animal bedding
                                                   *
 exposed to Infectious agents during research;
      •   Surgery or autopsy wastes that came in contact with infectious
 agents;
      •   Laboratory wastes from medical, pathological, pharmaceutical, or
other research,  coiwercial,  or industrial laboratories that were in
contact with infectious agents;
      •   Dialysis wastes that were in  contact with the blood of patients
undergoing hemodlalysis;
                                    2-6

-------
          Discarded medical  equipment and parts  that were in contact with
 infectious  wastes; and
          Biological  wastes  and discarded materials contaminated with
 blood,  excretion,  or secretions from human  beings  or animals that are
 isolated  to protect others  from communicable  diseases.
      Additional wastes may  be added by the  EPA  administrator.  The
 10 wastes must be  segregated  at the point of  generation and must be placed
 in appropriately labeled  containers that will protect waste handlers and
 the public  from exposure.   Additionally, a  waste manifest system will  be
 implemented for generators  who have their waste disposed offsite.  For
 waste generators who treat  their waste through  onsite incineration and who
 do not  track their waste  as outlined above, a recordkeeping and reporting
 requirement will be  Implemented that requires the  generator to report  the
 volume  and  types of  medical waste  incinerated on site for 6 months after
 the effective date of the tracking system.  The EPA expects to publish
 proposed  regulations in early February 1989.  Depending on the success of
 the pilot program, the medical  waste tracking system may be implemented
 nationwide.
 2.3  INSPECTOR RESPONSIBILITIES AND LIABILITIES1
   .  ..          '&, -    .	'...„	 , ..        .        .   -   .   .   -
     The  primary role of the  air compliance Inspector 1s to gather
 information  needed for the  determination of compliance  with applicable
 regulations  and for  other enforcement-related activities,  such as case
 development.  Closely coupled with  the accomplishment of these functions
 are certain  responsibilities of the air  compliance  inspector,  which
 include:  (1) knowing  and abiding  by the legal  requirements of the
 inspection,   (2) using  proper procedures  for effective Inspection  and
 evidence collection,  (3) practicing  accepted safety  procedures,
 (4) maintaining certain quality assurance standards,  and  (5)  observing the
professional and ethical responsibilities of the government employee.
Additional important considerations  for the inspector are  any potential
 liabilities  of his  position.
2.3.1  Legal Responsibilities
     It is essential that all  inspection activities  be conducted  within
the legal  framework established by the CAA.   In particular,  this
includes:
                                    2-7

-------
      1.  Proper handling of confidential  business  information;
      2.  Presentation of proper credentials  and  plant entry  at  reasonable
 times;
      3.  Protection of the company's  and  its personnel's  legal  rights
 under the U.S.  Constitution;
      4.  Knowledge of all  applicable  statutes, regulations,  and permit
 conditions;  and
      5.  Use of notice(s)  and  receipts, if appropriate.
 2.3.2  Procedural  Responsibilities
    •  The Inspector must be familiar with  and adhere  to, when possible, all
 general inspection procedures  and evidence gathering techniques.   This
 will  ensure  accurate inspections and  avoid the possibility of endangering
 a legal proceeding on procedural grounds.
      2.3.2.1 Inspection Procedures.   Inspectors should observe standard
 procedures for  conducting  each  portion of the inspection, when  possible.
 All deviations  should be clearly documented.  The  accepted general
 inspection procedures are  covered in  detail  in Section 2.4 of this
 chapter.
      2.3.2.2 Evidence Collection.  Inspectors must  be familiar with general
 evidence  gathering techniques.  Because the  government's case in an
 enforcement  action depends on the evidence gathered  by the inspector, it
 is  imperative that the inspector keep detailed records of each
 inspection.  These records will serve as an  aid in preparing  the
 inspection report,  in determining the appropriate enforcement response,
 and in  giving testimony  in an enforcement case.  Documentation  of evidence
 is covered in'Chapter 2.0  of this manual.   Several responsibilities
 Involved  in evidence  collection and presentation should be addressed
 here.   Specifically,  inspectors must:
      1.  Know how  to  substantiate facts with items of evidence, including
 samples, photographs,  document copies, statements from persons, and
personal observations.
     2.  Know how  to  detect lack of good faith during interviews with
company personnel.
     3.  Be familiar with all applicable regulations and what type of
information is required to determine compliance with each.
                                    2-8

-------
      4.   Be able to evaluate what documentation is necessary (routine
 inspection).
      5.   Collect evidence in a manner that will be incontestable in legal
 proceedings.
      6.   Be able to write clear, informative inspection reports.
      7.   Know how to testify in court and at administrative hearings.
 2.3.3 Safety Responsibilities
      The  inspection of air pollution control equipment and related work in
 other areas of Industrial facilities generally involves potential exposure
 to numerous hazards.  The inspector must, at all times, avoid putting
 hi.m/herself or any plant personnel at unnecessary risk.  To accomplish
 this, it  1s the Inspector's responsibility to:
      1.   Know and observe all plant safety requirements, warning signals,
 and emergency procedures.
      2.   Know and observe all agency safety requirements, procedures, and
 policies.
      3.   Remain current 1n safety practices and procedures by regular
 participation 1n agency safety training.
      4.   Use any safety equipment required by the facility being inspected
 1n addition to that required by the agency.
      5.   Use safety equipment in accordance with agency guidance and label
 instructions.
      6.   Maintain safety equipment in good condition and proper working
 order.
      7.   Dress appropriately for each inspection activity, including
 protective clothing, if appropriate.
      Chapter 3.0 of this manual and listed references address inspection
 safety procedures and other safety-related questions in more detail.
 2.3.4  Professional and Ethical Responsibilities
     As professionals and employees of Federal, State, or local
 authorities, inspectors are expected to perform their duties with
 integrity and professionalism.  , Procedures and requirements ensuring
ethical actions have been worked out through many years of governmental
 inspection activities.   These procedures and standards of conduct have
evolved for the protection of the individual and the Agency, as well as
                                    2-9

-------
 industry.   The Inspector is constantly in a position to  set  an  example  for
 private industry, to encourage concern for health  and safety in the
 environment,  and to promote compliance with the laws that  protect the
 environment and the health and safety of employees.
      Specifically, the inspector should always  consider  and  observe  the
 following  11st of responsibilities.
      2.3.4.1   U.S. Constitution. All  investigations are to  be  conducted within
 the framework of the U.S.  Constitution and with due  regard for  individual       "-
 rights  regardless of race, sex,  creed, or national origin.
      2.3.4.2   Employee Conduct.   Inspectors are to conduct themselves at all
 times in accordance with the regulations prescribing EPA Employee
 Responsibilities and Conduct, codified in 40 CFR Part 3.
      In the absence of specific  guidelines regarding conduct during  an
 inspection, it is recommended that State and local agency  inspectors
 become  familiar with these regulations and conduct themselves in a similar
 manner.
      2.3.4.3   Objectivity.   The  facts  of an investigation  are to be  developed
 and reported  completely, accurately,  and objectively.  In  the course of an
 investigation,  any act or  failure to  act motivated by reason of private
 gain 1s  Illegal.   Actions  which  could  be construed as such should be
 scrupulously  avoided.
      2.3.4.4   Knowledge.  'A continuing effort to improve professional knowledge
 and  technical  skill  in the Investigation field  should be made.  The
 inspector should  keep  abreast of changes in the  field  of air pollution,
 including current  regulations, EPA and  other agency  policies, control
 technology, methodology, and  safety considerations.
     2.3.4.5  Professional  Attitude.   The  inspector  is a representative of EPA
 or State or local  government  and is often  the initial  or only contact
 between the appropriate agency and industry.  In dealing with facility
 representatives and employees, inspectors  must be dignified,  tactful,
 courteous,  and diplomatic.  They should  be  especially  careful not to
 infringe on union/company agreements.  A firm but responsive  attitude will
 help to establish  an atmosphere of cooperation and should  foster good
working relations.  The inspector should always  strive to  obtain the
                                   2-10

-------
 respect of,  inspire  confidence  in, and maintain good will with industry
 and  the public.
      2.3.4.6 Attire.   Inspectors should dress appropriately, including wearing
 protective clothing  or  equipment, for the activity in which they are
 engaged.
      2.3.4.7 Industry, Public, and Consumer Relations.  All information
 acquired in  the course  of an inspector's duties is for official use
 only.  Inspectors should not speak of any product, manufacturer, or person
 in a derogatory manner.
      2.3.4.8 Gifts. Favors. Luncheons.  Inspectors should not accept favors or
 benefits under circumstances that might be construed as influencing the
 performance  of governmental duties.  The EPA regulations provide an
 exemption whereby an Inspector could accept food and refreshment of
 nominal value on infrequent occasions in the ordinary course of a luncheon
 or dinner meeting or other meeting, or during an inspection tour.
 Inspectors should use this exemption only when absolutely necessary.
      2.3.4.9  Requests for Information.  Although EPA has a general "open-door"
 policy on releasing information to the public, this policy does not extend
 to information related to the suspicion of a violation, evidence of
 possible misconduct, or confidential  business information.
 2.3.5  Quality Assurance Responsibilities
     The Inspector assumes primary responsibility for ensuring the quality
 of data generated as a result of the inspection.  The inspector should
 thus adhere to quality assurance, procedures appropriate to the type of
 data being generated.  In general, quality assurance procedures are
 developed concerning the following elements:
     1.  Valid data collection;
     2.  Approved, standard methods;
     3.  Control of service, equipment, supplies;
     4.  Quality analytical  techniques; and
     5.  Standard data handling  and reporting.
2.3.6  Potential Liabilities
     In addition to their responsibilities, inspectors should also be
aware of potential  personal  liabilities.   Some examples of the most common
liabilities are listed below.  The inspector should consult his/her
                                   2-11

-------
 supervisor or agency legal  staff for exact  legal  determinations  on
 personal  liability.
      2.3.6.1   Confidential  Business  Information.   Under Section  1905 of
 Title 18  of the  United  States  Code,  Federal  employees can  be  fined,
 imprisoned, or both  for disclosure of confidential business information.
      2.3.6.2   Waivers/Visitor  Releases.  Some companies waivers  or visitor
 releases,  if-signed,  purport to  make the person signing liable for certain
 acts  he or she might  commit on plant property.  These must never be signed
 by the Inspector.
      2.3.6.3   Authority.  In some cases, the inspector could  be  held liable for
 actions committed beyond the scope of his/her authority; the  inspector
 roust  always know exactly what  his/her authority is.
 2.4  GENERAL  INSPECTION PROCEDURES
      This  section briefly describes  some of  the legal and  administrative
 procedures  common to most air  compliance inspections.  More complete
 discussion  of  the legal and administrative procedures common  to  most
 Inspections can  be found 1n Chapter  3 of the A1r Compliance Inspection
 Manual, EPA-340/1-85-020, September  1985.  These procedures will  help to
 ensure that technical Inspections  are complete, current, and  legally
 defensible and that the data gathered can be used effectively in later
 compliance monitoring and determination.
     These general inspection  procedures can be categorized by the order
 1n which they occur in the inspection process:   (1) preinspection
 preparation, (2)  preentry observations, (3)  entry, and (4) contents and
 timing.  These categories are discussed below.
 2.4.1  Preinspection Preparation
     Preinspection preparation is always necessary to ensure effective use
of the Inspector's time and  the facility personnel's time and to ensure
that the  inspection is focused properly on collecting relevant data and
 Information.  Preinspection  preparation involves:
     1.  Review of facility  background;
     2.  Development of an  inspection plan;
     3.  Notifications;  and
     4.  Equipment preparation.
                                   2-12

-------
     2.4.1.1  Review of Facility Background.  A review of the available
background information on the infectious waste incinerator to be inspected
is essential to the overall success of the inspection.  The review should
enable the inspector to become familiar with the incinerator's design,
operating procedures, and emission characteristics; conduct the inspection
in a timely manner; minimize inconvenience to the facility by not
requesting unnecessary data such as that previously provided to EPA or
another agency; conduct an efficient but thorough inspection; clarify
technical and legal Issues before entry; and prepare a useful inspection
report.  The types of information that should be reviewed are listed
below.
     1.  Basic facility information.
         a.  Names, titles, and phone numbers of facility representatives;
         b.  Maps showing facility location and geographic relationship to
             residences,  etc.,  potentially impacted by emissions;
         c.  Incinerator  type and capacity;
         d.  Types of wastes incinerated;
         e.  Flowsheets Identifying control devices and monitors; and
         f.  Safety equipment requirements.
     2.  Pollution control  equipment and other relevant equipment data.
         a.  Description  and design data for control  devices;
         b.  Baseline performance data for control  equipment;
         c.  Continuous emission  monitoring system(s)  data;
         d.  Previous inspection  checklists (and reports);  and
         e.  Information  on maintenance program,  if available.
     3.   Regulations,  requirements,  and limitations.
         a.  Most  recent  permits  for facility sources;
         b.   Applicable Federal,  State,  and local regulations and
             requirements;
         c.   Special  exemptions and  waivers,  if  any;  and
         d.   Acceptable operating conditions.
     4.   Facility  compliance  and  enforcement  history.
         a.   Previous  inspection  reports;
         b.   Complaint  history including reports, followups,  findings,
             remedial action;
                                  2-13

-------
          c.   Past conditions of  noncompliance;
          d.   Previous  enforcement  actions;
          e.   Pending enforcement actions, compliance schedules, and/or
              variances;  and
          f.   Self-monitoring data  and  reports.
      2.4.1.2   Background Information Sources.  The recommended sources for
 obtaining the background information outlined in Section 2.4.1.1  include:
      1.   Inspector's "working" file.   The inspector's own concise file for
 a facility containing  basic information on the incinerator, flowsheets,
 baseline performance data for control  equipment and the incinerator,
 chronology of enforcement-related  actions, recent permits, and safety
 equipment requirements.
      2.   Regional  office files and data bases.  These files should include
 much  of  the information  needed including inspection reports, permits and
 permit applications, compliance  and enforcement history, exemption or
 waiver Information, and  some self-monitoring data.
      3.   State/local files and contacts.  These should be used to
 supplement and update the information  available in the EPA Regional office
 files.
      4.   Laws and  regulations.  The CAA and related regulations establish
 emission standards, controls, procedures, and other requirements
 applicable to a facility.  State and local laws and regulations also
 should be considered.
      5.   Technical reports, documents, and guidelines.  These can often be
 valuable in providing information and/or guidance concerning incineration,
 control  techniques, performance advantages and limitations of particular
 types of  control equipment, and specific inspection procedures.
     2.4.1.3  Development of An Inspection Plan.  Based on the review of
the facility background information and the intended purpose of the
 inspection, the Inspector should develop an inspection plan that should
address the-following items:
     1.   Inspection objectives.   Identify the precise purpose of the
inspection in terms of  what it will accomplish.
                                   2-14

-------
      2.   Tasks.   Identify the specific tasks that will  accomplish  the
 inspection objectives including the exact information that must be
 collected.
      3.   Procedures.   Specify the procedures to be used in completing  the
 tasks, especially special or unfamiliar procedures.
      4.   Resources.   List the equipment and  identify the personnel  that
 will  be  required.
      5.   Schedule.  Present an estimate of the  time  required  to conduct
 the inspection;  suggest  a feasible date for  the inspection (when the
 incinerator will  be operating at representative conditions).
      2.4.1.4  Notification of the Facility.   The policies of  EPA Regional
 offices  vary concerning  giving a facility advance notification  of  an
 inspection.  In  a recent EPA policy memo entitled "Final  Guidance  on Use
 of  Unannounced Inspections,"  however,  the Stationary Source Compliance
 Division recommends that all  Regional  inspection programs incorporate
 unannounced inspections  as part of their overall  inspection approach.1
 The advantages of unannounced inspections are:   (1)  the source  can  be
 observed under normal operating conditions because the  source does  not
 have  time to prepare  for the  inspection;  (2)  visible emissions  and
 O&M-type problems and violations  can be  detected;  (3) the source's  level
 of  attention to its compliance  status  is  increased;  and (4) the
 seriousness of the Agency's attitude toward  surveillance  is emphasized.
     The  potential negative aspects of performing unannounced inspections
 are:  (1)  the source may  not  be operating or  key  plant  personnel may not
 be  available; and (2) there could  be an  adverse  impact  on EPA/State or
 EPA/source relations.  However,  it has been demonstrated  by the Regional
 offices that already use  unannounced inspections  that,  in the majority of
 cases, these drawbacks can be overcome.
 2.4.2  Preentry Observations
     Two types of observations conducted prior to facility entry have been
 shown to be valuable in the determination of facility compliance:
observations of the facility surroundings and visible emission
observations.
                                   2-15

-------
      2.4.2.1  Facility Surroundings Observations.  Observations of areas
 surrounding the facility  prior  to  entry may reveal problems related to
 operational practices  and pollutant emissions.  These observations can
 include:
      1.   Odors downwind of the  facility;
      2.   Deposits on cars parked nearby;
      3.   Other signs of "soot"  downwind of the facility; and
      4.   Conditions around the  waste storage area.
 If odors  are observed,  weather  conditions, including wind direction,
 should be noted for inclusion in the inspection report.
      2.4.2.2  Visible  Emissions Observations.  In addition to observing the
 facility  surroundings  prior to  entry, the inspector may also perform
 visible emission observations at that time.  The incinerator/control
 device stack outlet may not be  visible from a location outside the plant
 property  lines,  but those that  are may be conveniently read before
 entry.  In  cases where  the Incinerator has an emergency bypass stack, the
 observer  should  note whether the bypass stack was "activated."  Visible
 emission  observation procedures are discussed further in Chapter 4.
      It 1s  appropriate  for the  inspector to inform facility officials if
 excess visible emissions  are observed.  At the same time, the Inspector
 should identify  the cause  of the excess emissions to enable facility
 personnel to promptly evaluate, respond to, and correct the problem.
 There may be State statutes that require notifications; the inspector
 should be aware  of these before visiting the plant.
 2.4.3  Entry
     This section describes the accepted procedures under the CM for
 entry to a facility to conduct an onslte Inspection.  Detailed procedures
 for obtaining an inspection warrant in the case of refusal  of entry are
 not presented because refusal  is not prevalent and this subject is covered
 1n detail  1n other publications.  However, should entry be refused, the
 Inspector should consult the EPA Regional  Counsel's office for assistance.
     2.4.3.1  Authority.  The  CAA authorizes plant entry for the purposes
of inspection.   Specifically,  Section 114 of the Act states:1
      .  .  .  the Administrator  or his authorized representative, upon
      presentation of his  credentials shall  have a right of entry
                                   2-16

-------
       to,  upon  or through  any  premises  of  such person or  1n which
       any  records required to  be  maintained  .  .  . are located,  and
       may  at  reasonable times  have access  to and copy any records,
       inspect any monitoring equipment  or  method .  . .  and sample
       any  emissions which  such person is required to sample  .  .  .  ."
      2.4.3.2  Arrival.  The inspector must arrive at the  facility
 (hospital) during normal working  hours.  Entry through  the main lobby  is
 recommended unless the inspector  has been  previously instructed
 otherwise.  As  soon as the inspector arrives on the premises he should
 locate a responsible hospital  official  usually the hospital administrator,
 environmental manager, or  chief engineer.  In the case  of an announced
 inspection, this person would  most probably  be the official to  whom
 notification was made.  The inspector should note the name and  title of
 this  plant representative,,
      2.4.3.3  Credentials.  Upon  meeting the appropriate  official, the
 inspector should introduce himself or herself as an EPA inspector, present
 the official with the proper EPA  credentials, and state the reason for
 requesting entry.  The credentials provide the official with the assurance
 that  the inspector is a lawful  representative of the Agency.  Each office
 of the EPA issues Its own  credentials; most  include the inspector's photo-
 graph,  signature, physical  description, (age, height, weight, color of
 hair  and eyes), and the authority for the  inspection.   Credentials must be
 presented whether or not identification is requested.1  After facility
 officials have examined the credentials, they may telephone the
 appropriate EPA office for  verification of the inspector's identifica-
 tion.   Credentials should  never leave the  sight of the  inspector.
      2.4.3.4  Consent.  Consent to  inspect the premises must be given by
 the owner,  operator,  or his representatives at the time of the
 inspection.  As long  as the inspector is allowed to enter, entry is
considered  voluntary  and consensual, unless the inspector  is expressly
told to leave the premises.  Express consent is not necessary; absence of
an express  denial constitutes consent.1
     2.4.3.5  Inspection Documentation.   The air compliance inspection is
generally conducted to achieve one or more of the following three major
objectives:
                                   2-17

-------
      1.  To provide data and other information for making a compliance
 determination;
      2.  To provide evidentiary support for some type of enforcement
 action; and
      3.  To gather data required for other Agency functions.
 Taking physical samples, reviewing records, and documenting facility
 operations are the methods used by the inspector to develop the
 documentary support required to accomplish these objectives.  The
 documentation from the inspection establishes the actual conditions
 existing at the time of the -Inspection so that the evidence of these
 conditions may be objectively examined at a later time 1n the  course of  an
 enforcement proceeding or other compliance-related activity.
      Documentation 1s a general  term referring to all  print and mechanical
 j«dia produced, copied, or taken by an Inspector to provide evidence of
 facility status.   Types of documentation include the field notebook,  field
 notes and checklists,  visible emission observation forms,  drawings,
 flowsheets,  maps,  lab analyses of samples,  cha1n-of-custody records,
 statements,  copies of records, printed matter,  and photographs.  Any
 documentation  gathered or produced 1n the course of the inspection process
 •ay eventually become  part of an enforcement  proceeding.   It is the
 Inspector's  responsibility to recognize this  possibility and ensure  that
 all documentation  can  pass  later legal  scrutiny.
      2.4.3.5.1  Inspector's  field  notebook  and  field notes.  The core  of all
 documentation  relating to an inspection is  the  inspector's  field notebook
 or field  notes, which  provide accurate  and  inclusive documentation of  all
 field activities.   Even if certain data or  other documentation  is not
 actually  Included  in the  notebook or  notes, reference  should be made in
 the notebook or notes  to  the  additional  data  or documentation such that it
 is completely  identified  and  it  is clear how  it fits into the inspection
 scheme.
     The field notebook and/or notes  form the basis for both the
 inspection report and the evidence package  and  should contain only facts
and pertinent observations.   Language should be objective, factual, and
free of personal feelings or terminology that might prove inappropriate.
                                   2-18

-------
     Because the inspector may eventually be called upon to testify in an
enforcement proceeding, or field data gathered during the inspection may
be entered into evidence, it is imperative that the inspector keep
detailed records of inspections, investigations, samples collected, and
related inspection functions.  The types of information that should be
entered into the field notebook or notes include:
     1.  Observations.  All conditions, practices, and other observations
relevant to the inspection objectives or that will contribute to valid
evidence should be recorded.
     2.  Procedures.  Inspectors should list or reference all procedures
followed during the inspection such as those of entry, sampling, records
inspection, and document preparation.  Such information could help avoid
damage to case proceedings on procedural grounds.
     3.  Unusual conditions and problems.  Unusual conditions and problems
should be recorded and described in detail.
                                          • 4
     4.  Documents and photographs.  All documents taken or prepared by
the inspector should be noted and related to specific inspection
activities.  (For example, photographs taken at a sampling site should be
                                                         *
listed, described, and related to the specific sample number.)
     5.  General information.  Names and titles of facility personnel and
the activities they perform should be listed along with other general
information.  Pertinent statements made by these people should be
recorded.  Information about a facility's recordkeeping procedures may be
useful  in later inspections.
     The field notebook is a part of the Agency's files and is not to be
considered the inspector's personal record although copies may be made for
the inspector's "working file."  Notebooks are usually held indefinitely
pending disposition instructions.
     2.4.3.5.2  The visible emission observation form.  Since visible
emission (VE) observations are such a frequently used enforcement tool, a
separate form has been developed for recording data from the VE observa-
tion (see Appendix D).  This form has been designed to include all the
supporting documentation necessary, in most cases, for VE observation data
to be accepted as evidence of a violation.  Thus, it is recommended that
the inspector utilize this form for recording opacity observations; an
                                   2-19

-------
 appropriate reference  should  be made  to  the form  in  the field  notebook or
 notes.
 2.4.4  Contents and Timing
     During the inspection, the inspector collects and  substantiates
 inspection data that may  later  be  used as evidence in an enforcement
 proceeding.  Upon returning to  the office, the  inspector is  responsible for
 ensuring that these data  are  organized and arranged  so  that  other Agency
 personnel may make maximum use  of  them.  Thus,  the file update and
 inspection report preparation are  an  important  part  of  the inspection
 process.  These should both be  done as soon as  possible after  the
 inspection to ensure that all events  of  the inspection  are still fresh in
 the inspector's memory.   The  inspector must be  able  to  confirm during a
 later enforcement proceeding  that  the information contained  in the
 inspection report is true.
     2.4.4.1  File Update.  The U. S. EPA and its Regional offices utilize
 several types of "files"  for  facility information storage, including
 computer data bases (the  Compliance Data System [COS] and the  National
 Emissions Data System  [NEDS]) and  hard copy storage  (the Agency source
 files).  The inspector should review the relevant CDS files  for the
 inspected facility to determine if any of the data gathered  during the
 inspection can be used to fill  gaps in the files or  to  update  file
 entries.   The CDS data form the basis for virtually  all  Agency reporting on
 compliance status, and, therefore, a current data base  is absolutely
 essential to Agency programs for use in making  air management  planning and
 budgetary decisions.  The NEDS  files-and any State files equivalent to CDS
 and NEDS  also should be reviewed and updated with information  gathered
during the inspection.
     The  Agency files, particularly those at the Regional offices, usually
contain the hard copies of all  information, correspondence,  reports, etc.,
relevant  to a particular facility.  Examples of such items are listed
below.
      1.   General  facility information;
      2.   Correspondence to facility;
      3.   Correspondence from facility;
      4.   Permit applications;
                                   2-20

-------
       5.  Permits;
       6.  Facility  layout;
       7.  Flowcharts;
       8.  Raw data  from inspections;
       9.  Inspection reports;
      10.  Source test  reports;
      11.  Excess emission reports;
      12.  Case development workups; and
      13.  Agency notes,  etc., on  compliance  actions,         *
 The inspector's data should  be  used to update  the general facility
 information including  plant  contact,  correct address, changes  in production
 rates, new flowcharts, layouts, etc.; of  course, the inspector's raw data
 and inspection report  will be added to the file.
      At this time,  the inspector's "working" file on the facility (see
 description in Section 2.4.1.2.)  should also be updated.  This task should
 not require much effort  because the "working"  file  is a summary file for
 the inspector's use; and updating the "working" file will enable the
 inspector  to retrieve  information on  a particular facility quickly in the
 future.
      2.4.4.2  Report Content and  Preparation.  The  inspector's inspection
 report serves two very important  purposes in Agency operations:  (1) it
 provides other Agency  personnel with  easy access to the inspection
 information,  which  is  organized into  a comprehensive, usable document; and
 (2)  it constitutes  a major part of the evidence package on the inspection
 and  will be available  for subsequent  enforcement proceedings and/or other
 types  of compliance-related followup  activities. To serve these purposes,
 the  information contained in the  inspection  report must be:
      1.  Accurate.  All  information must be  factual and based on sound
 inspection  practices.  Observations should be  the verifiable result of
 firsthand knowledge.   Compliance  and  enforcement personnel must be able to
 depend on the  accuracy of all information.
     2.  Relevant.  Information in an inspection report should be pertinent
 to the objectives of inspection.  Irrelevant facts and data will clutter a
report and may  reduce  its clarity and usefulness.
                                   2-21

-------
      3.  Comprehensive.  Suspected violation(s) should be substantiated  by
 as much factual, relevant information as is feasible to gather.   The more
 comprehensive the evidence is, the better and easier the outcome of any
 enforcement action will be.
      4.  Coordinated.   All information pertinent to the subject  should be
 organized into a complete package.  Documentary support (e.g., photographs,
 statements, sample documentation, etc.) accompanying the report  should be
 clearly referenced so  that anyone reading the report will  get a  complete,
 clear overview of the  situation.
      5.  Objective.   Information  should be objective and factual; the
 report should not speculate  on the ultimate result of any factual
 findings.
      6.  Clear.   The information  in the report should be presented in a
 clear, well-organized  manner.
      7.  Neat and legible.   Allow time to prepare a neat,  legible report.
      2.4.4.2.1  Elements  of  the inspection report.  Although  specific
 information contained  in  the inspection report will  vary depending upon  the
 inspection  objectives,  most  reports will  contain the same  basic  elements:
      1.  Cover page;
      2.  Narrative report; and
      3.  Documentary support.
      Cover  page.  The  cover  page  provides easily accessible basic facility
 information.   It  should include:
      1.   Facility name  and address;
      2.   Facility identification  number;
      3.   Facility contact and/or  representative (including phone  number);
      4.   Type  of  inspection;
      5.   Date  of  inspection; and
      6.   Inspector's name.
      Narrative report.  The  narrative  portion  of an  inspection report
should  be a concise, factual summary of observations  and activities.  The
narrative should  be logically organized,  legible,  and supported by specific
references to  accompanying documentary support.
                                   2-22

-------
      Documentary support.  The documentary support is all  evidence referred
 to in the inspection report.   It  will  include:
      1.   Inspector's field notes, forms,  checklists;
      2.   Drawings, charts, etc.;
      3.   Photographs;
      4.   Analysis results for samples  collected;
      5.   Statements taken; and
      6.   Visible emission observation  forms.
      2.4.4.2.2  Inspection report preparation.  The general work plan
 presented below will simplify preparation of  the  inspection report and will
 help  ensure  that information  is organized and in  a useable form.  The basic
 steps in  writing the narrative report  include:
      Reviewing the information.   The first step in preparing the narrative
 is  to collect  all  information gathered during the inspection.  The
 inspector's  field  notebook should be reviewed in  detail.   All evidence
 should be reviewed for  relevance  and completeness.  Gaps may need to be
 filled by a  phone  call  or,  in unusual circumstances,  by a  followup visit to
 the facility.
      Organizing  the material.  The information may be organized in any one
 of  several ways  depending on  individual preference but, whatever
 organization is  selected,  the material should be  presented in a logical,
 comprehensive  manner.   The  narrative should be organized so that the
 information will be easily  understood by  the  reader.
      Referencing accompanying material.   All  documentary support
 accompanying a narrative  report should be clearly referenced so that the
 reader will be able to  locate these documents easily.  All documentary
 support should be  checked for clarity prior to writing the report.
     Writing the narrative  report.  Once  the  material  collected by the
 inspector has  been reviewed, organized, and referenced, the narrative can
 be written.  The purpose  of the narrative  is  to record factually the
procedures used in,  and findings resulting from,  the  evidence-gathering
process.  The  inspector need only refer to routine procedures and practices
used during the inspection but should describe in detail facts relating to
potential  violations and discrepancies.
                                   2-23

-------
     If the inspector follows the steps presented, the report should
develop logically from the organizational framework of the inspection.   In
writing the narrative, the inspector should keep the following in mind:
     1.  Keep sentences short, simple, and direct;
     2.  Use an active, rather than passive style:  (e.g., "He said
that ..." rather than "It was said that ...");
     3.  Keep paragraphs brief and to the point;
     4.  Avoid repetition; and
     5.  Proofread the narrative carefully.
     2.4.4.2.3  Outline of narrative report.  A basic format which can be
adapted for most narrative reports is outlined below.
     1.  General inspection information.
         a.  Inspection objectives;
         b.  Facility selection scheme; and
         c.  Inspection facts (date, time, location, plant official, etc.).
     2.  Summary of findings.
         a.  Factual compliance findings (include problem areas);
         b.  Compliance status with applicable regulations;
         c.  Administrative problems (as with entry, withdrawal of consent,
             etc.); and
         d.  Recommendation for future action (if appropriate).
     3.  Facility information.
         a.  Incinerator type and size;
         b.  Source/type of infectious waste;
         c.  Operating schedule
         d.  Control equipment;
         e.  Applicable regulations; and
         f.  Enforcement history.
     4.  Inspection procedures and detail of findings.
         a.  Reference to standard inspection procedures used;
         b.  Description of nonroutine inspection procedures used;
         c.  Reference to attached inspection data;
         d.  Reference to any statements taken;
         e.  Reference to photographs, if relevant;
         f.  Reference to any drawings, charts, etc., made;
                                   2-24

-------
         g.  Reference to visible emission observation forms; and
         h.  List of records reviewed and inadequacies found.
     5.  Sampling.
         a.  Reference to methods used;
         b.  Reference to analytical results attached; and
         c.  Chain of custody information.
     6.  Attachments—list of all documentary support attached.
     2.4.4.2.4  Confidential business information.  Data or information for
which the source requests treatment as confidential business information
must be placed in the Agency's confidential  files in accordance with 40 CFR
Part 2 and cannot be Included in the report.  The report should, however,
refer to the fact that a particular type of  information has been placed in
the confidential files.   Alternatively, the  report may include the
confidential information; however, the entire inspection report must then
be treated as a confidential document (see Section 3.8 in Reference 1 for a
more complete discussion).
2.5  REFERENCES FOR CHAPTER 2
1.  U.  S.  EPA Stationary Source Compliance Division, "A1r Compliance
    Inspection Manual,"  U, S. Environmental  Protection Agency.  Publication
    No. 340/1-85-020.   September 1985.
2.  Hospital Waste Combustion Study Data Gathering Phase.  Final Report.
    U.  S.  Environmental  Protection,Agency, Office of Air Quality Planning
    and Standards, Research Triangle Park, N.C.   EPA-450/3-88-017.
    December 1988.
                                   2-25

-------

-------
                           3.0  INSPECTION SAFETY

 3.1  SCOPE
      It 1s not the purpose of this chapter to present an exhaustive
 discussion of potential health and safety hazards,  EPA safety policies,  or
 general safety procedures.  While these subjects are important to  every
 inspector, they have been well covered in the Air Compliance Inspection
 Manual  (EPA-340/1-85-020).  Inspection personnel are encouraged
 to consult this manual  and become familiar with these subjects.
      The information presented in this chapter is divided into two
 sections.   The first consists of  general  inspection guidelines applicable
 to hospital waste  Incinerator (HWI)  facilities.  These are presented
 briefly in a  list.   The second section is subdivided by the type of
 equipment  to  be inspected and gives  safety considerations specific to
 each.
      Although the  information presented in this chapter is tailored to the
 inspection of HWI  facilities,  no  manual  can encompass every health or
 safety  hazard that might be  encountered at a  given  facility.   Inspectors
 must  take  the responsibility for  recognizing  site-specific hazards and
 taking  appropriate action to minimize  the danger.   Nothing should  be done
 that may endanger the inspector or plant  personnel.
 3.2  SAFETY GUIDELINES
      1.   Exercise extreme caution in  the vicinity  of infectious wastes.
 Never handle  infectious  wastes.   Treat  all wastes as  infectious wastes,
 even those wastes not identified  as such  (i.e.,  not  in  a  red bag).
 Puncture by infected needles, broken glass, or  other  sharp  objects
 ("sharps") poses the single  greatest hazard at  a hospital  incinerator.
 Treat all waste bags as  though they contain sharps, even  if sharps  are
 typically handled separately.  Assume any  spillage  in the waste handling
 area is infectious and avoid contact.
      2.  Exercise extreme caution in the vicinity of incinerator  ash.  Do
not handle the incinerator ash.  During some inspections,  it may be
necessary to obtain a sample of the incinerator ash for analysis.   In such
 instances, the inspector should ask the incinerator operator or other
facility personnel  familiar with the hazards associated with the handling
                                    3-1

-------
 of infectious wastes and sharps to take a sample of the ash.   The
 inspector should recommend safety precautions to be taken by  the sampler
 and should provide sampling tools (e.g., a sterile plastic trowel)  and
 sample jar.  The sampler should wear protective clothing, thick rubber or
 plastic gloves, eye protection, and a respirator or dust mask filter.   If
 the ash has not been quenched with water, the sampler should  carefully
 spray the ash both to douse any hot spots and to. prevent fugitive
 emissions.  In taking the sample, the sampler should use the  sampling
 trowel with care in removing material from different areas of the ash  pile
 so as not to cause'fugitive dust emissions or cause puncture  wounds from
 sharps.  Although the ash is theoretically decontaminated, safety
 precautions still should be followed because the possibility  of
 injury/Infection exists  due to the presence of sharps.
       3.   Determine whether a radioactivity hazard exists and take
 appropriate protective measures.  Medical  research facilities,  including
 those at  hospitals,  may  be licensed to incinerate radioactive wastes.    At
 these facilities, such wastes are typically incinerated along with  other
 wastes.   Prior to the inspection, determine whether the facility is
 licensed  to Incinerate radioactive wastes.   If so,  ascertain  the
 appropriate safety procedures and equipment, if applicable, from facility
 personnel  or the radiation enforcement agency (NRC  or analogous State
 agency).   If possible, arrange a joint inspection with  the radiation
 enforcement agency.   Individuals required  to enter  the  radioactive  waste
 incinerator area to  perform their jobs (this would  include air  agency
 inspectors)  are entitled  by law to see the  incineration license.  Examine
 the license to  determine  what materials may be incinerated and  any  waste
 or ash  handling requirements.   If the terms of the  license are  being
 violated,  the Inspection  should be terminated  immediately, and  the
 radiation  enforcement  agency  should  be notified.
      4.   Internal inspections  are unnecessary.   Offline  equipment  at
 incinerator  facilities including  the  incinerator  and  air  pollution  control
devices may  have  a variety  of  infection,  inhalation,  asphyxiation,  thermal
burn, chemical  burn, eye,  and  falling  hazards.  During  a  normal
 inspection,  regulatory agency  inspectors should not enter equipment  even
when it appears to be properly  locked  out and/or  It is  occupied  by  plant
                                    3-2

-------
 maintenance personnel.  All necessary inspection information can be
 obtained from outside the equipment.  Sufficient time and appropriate
 safety equipment are not normally available during an inspection to ensure
 safety.
      While it is not usually possible to gain entrance inside equipment,
 an inspector may wish to schedule a visit or followup visit while
 regularly scheduled preventive maintenance is being performed.  All safety
 precautions should be strictly adhered to including lockout of all
 equipment and disconnection of the power supply.
       5.  Take all personal safety equipment.  The minimum safety
 equipment for inspecting incinerators consists of gloves, safety glasses,
 safety shoes,  sterile eye wash bottles,  and a hard hat.   In some cases,
 more sophisticated safety equipment (e.g., half-face respirator with acid
 gas cartridges or disposable dust masks)  is necessary.
       6.  Use  protective clothing and gloves.  This equipment is needed
 when there is  a risk  of  contact with infectious wastes,  incinerator ash,
 air pollution  control  device solids, alkaline materials,  or waste
 sludges.  Gloves  are  also needed for climbing abrasive and/or hot
 ladders.  Contaminated work clothes  should either be discarded or washed
 separately from personal  cloths.
       7.  Wear hearing protection.   Hearing protection should be used
 whenever required  by the  facility and whenever it is  difficult to hear
 another  person speaking normally from a distance  of  3 feet.
       8.  Avoid areas  of  suspected high pollutant concentration.   Avoid
 areas  such  as  malfunctioning  incinerators  operating  at slight positive
 pressures,  leaking expansion  joints  downstream of induced draft  fans,
 fugitive emissions from positive  pressure  equipment, and  any  area with
 poor ventilation.  Assume that any fugitives  or stack emissions  may
 contain  infectious agents or acid gases.   Even if a respirator  is  worn,  it
 provides only  limited protection.
      9.  Flush eyes contacted by alkaline materials.  It is  important to
 flush eyes as soon as possible after alkaline materials such  as  calcium
 hydroxide or quick limes are contacted.  Flush for 15 to 30 minutes.  Get
medical attention even if you think the exposure was minor.      f
                                    3-3

-------
      10.   Shower immediately  if  contacted  by alkaline materials.  In the
 unlikely  event that you are splashed with  alkaline material, remove
 affected  clothing and  shower  immediately for a period of at least
 15 minutes.
      11.   Use  grounding/bonding  cables on  probes.  This is especially
 important downstream of electrostatic precipitators due to the
 possibilities  of injuries resulting from severe muscle spasms caused by
 contact with high static voltages.
      12.   Avoid severely vibrating equipment.   Equipment such as fans can
 disintegrate suddenly.  Notify plant personnel  immediately of the
 condition and  leave the area.
      13.   Facility personnel must be present during the inspection.  Never
 conduct Inspections alone.  Facility personnel  accompanying you must be
 knowledgeable  in incinerator operations, general safety procedures, and
 emergency procedures.
      14.   Follow all facility and agency safety requirements.  Limit the
 inspection as  necessary to ensure that you completely adhere to all
 facility  and agency requirements.
      15.   Do not ask facility personnel to take unreasonable risks.
 Common problem areas include sampling high pH  liquors, testing gas
 streams, working near hot ductwork, and working in areas with high
 pollutant  concentrations.
      16.   Do not do anything which appears dangerous.  If you think that
 1t may be  dangerous, it probably is.  Do not abdicate your safety judgment
 to facility personnel who may or may not be  safety conscious.
      17.   Never  hurry during inspections.  This causes careless walking
 and climbing accidents.
      18.   Interrupt the inspection if you feel  sick.  Interrupt the
 inspection immediately whenever you feel any of the following symptoms:
 headache, nausea,  dizziness, drowsiness, loss of coordination, chest
pains, shortness  of breath,  vomiting, and eye or nose irritation. These
 symptoms may be  caused by exposure to toxic  pollutants even though there
 Is no odor.
                                    3-4

-------
 3.3  EQUIPMENT-SPECIFIC SAFETY CONSIDERATIONS
      Incinerators and add-on control devices are typically operated at
 negative pressure, I.e., the system uses an induced draft fan located
 downstream from the equipment.  However, this is not always the case; the
 inspector should not assume negative pressure.  Before beginning the
 inspection of the equipment, the inspector should discuss the
 configuration of the system to determine if any components are under
 positive pressure.  Inhalation hazards are much greater around equipment
 under positive pressure because the direction of flow at any leaks will  be
 from within the equipment to the outside.   These hazards are diminished  at
 negative pressure components because outside air is drawn into the
 equipment at any openings,,   In the material that follows, inhalation
 hazards  are discussed as if the equipment  is at positive pressure.  Where
 the equipment is under negative pressure,  these hazards should be
 considered but are not likely to pose a grave threat.   Inhalation hazards
 associated with HWI  facilities include but are not limited to infectious
 microorganisms, hydrogen chloride,  toxic organic compounds,  carbon
 monoxide,  and heavy  metal enriched  flyash.   At facilities licensed to
 incinerate radioactive wastes,  gas  streams  may also carry radioactive
 materials.
 3.3.1  Incinerators
     3.3.1.1   Waste  Storage  and Handling Areas.   All wastes  should be
 treated  as  infectious  wastes,  regardless of labeling.   Any liquids spilled
 in  storage or handling areas  should  be  considered  infectious.  All  bags
 and other waste containers should be assumed  to  contain sharps,  even  when
 standard procedures call for  sharps  to  be segregated from other  wastes or
 contained within special rigid  containers.
     Direct skin contact with wastes  should be scrupulously  avoided.
Gloves, protective clothing, and impermeable footware are  required when
there is any possibility of contact.   The  inspector should  not  open
 infectious waste containers or otherwise handle  the wastes.  At  facilities
 licensed to incinerate radioactive wastes, the inspector  should  be
thoroughly familiar with any special waste storage or handling
requirements and should carefully observe all protective equipment and
safety requirements.
                                    3-5

-------
      In addition to the normal safety precautions taken around moving
 machinery, inspectors evaluating incinerator feed mechanisms should  take
 precautions to avoid exposure to infectious agents that could be emitted
 to the atmosphere during charging.  Never peer into hoppers or ram feeders
 as flying objects could result in injury or exposure.
      3.3.1.2  Eye Hazards in Observing Combustion.  Never open observation
 doors or charging doors to peer into the incinerator during operation.
 Ideally, the incinerator will have sealed (i.e., glass) view ports that
 can be used for viewing the combustion chamber.   However, if the
 incinerator does not have sealed viewports, do not open inspection or
 cleanout doors.
      3.3.1.3  Burns.  Incinerators operate at very high temperatures, and
 the potential  for hot surfaces is high.   Contact with  the incinerator
 chamber walls,  heat recovery equipment,  ductwork, and  stack surfaces
 should be avoided.   Also,  sampling probes may be very  hot when removed
 from hot stacks  and vents.
      3.3.1.4  Incinerator  Ash.   While  the incinerator  ash from a properly
 operated HWI is  not likely to be infectious or otherwize hazardous,
 caution still  should be exercised to avoid skin  contact or inhalation.
 Residues of  incomplete combustion may  be infectious or,  more likely,
 toxic.   The  ash  of  incinerators  licensed for radioactive wastes  may  be
 radioactive  and  require special  handling.   The inspector should
 familiarize  him/herself with  any special  safety  procedures and  equipment
 needs  and  should  avoid contact with  the  ash.
 3.3.2   Wet Scrubbers
     3.3.2.1  Venturi's at  High  Pressure.   Positive pressure venturi
 scrubbers may operate  at much higher positive  static pressures  than  other
 types of air pollution control systems.   Furthermore,  there  is  a signifi-
 cant potential for  corrosion  and  erosion  of  the  scrubber vessel  and  duct-
work.   For these reasons, fugitive  leaks  are a common  problem.   The
 inhalation hazards  can include asphyxiants,  toxic  gases,  toxic particu-
 late, and, at facilities licensed for radioactive  wastes,  radioactive
materials.   Inspectors should avoid  all areas  with obvious  leaks  and any
areas with poor ventilation.  Additionally, access hatches or viewing
ports should not be  opened during the inspection because of  the  risk of
                                    3-6

-------
 eye Injuries.  During Level  3 and Level 4 inspections,  only small-diameter
 sampling ports should be used.
      3.3.2.2  Slip Hazards.   Extreme care is often necessary when  walking
 around the scrubber and.when climbing access ladders.   Slip hazards can be
 created by the water droplets reentrained in the exhaust  gas, by the
 liquor draining from the pumps,  and by the liquor seeping from pipes and
 tanks.  These slip hazards are not always obvious.  Furthermore, freezing
 can occur in cold  weather,,
      3.3.2.3  Fan  Imbalance.   A  few systems are  subjected to fan imbalance
 conditions due to  the buildup of sludge on the fan blades,  the corrosion
 of  the fan blades,  the erosion of the fan blades,  and a variety of other
 factors.   The inspection should  be terminated immediately whenever an
 inspector observes  a severely vibrating fan.  A  responsible representative
 of  the facility should be notified once the inspector reaches a safe
 location.   Severely vibrating fans can disintegrate suddenly.
      3.3.2.4  Sampling Liquors and Sludges.   All  liquor or  sludge  samples
 necessary  for Level  3 or  Level 4 inspections  should be  taken by the
 facility personnel,  not  the  inspector.   Furthermore, the  inspectors should
 only  ask responsible and  experienced  plant personnel to take the
 samples.   Eye injuries and chemical burns (1n some cases) are possible  if
 the samples  are  taken incorrectly.  Also, the liquor or sludge may contain
 infectious agents.
 3.3.3  Dry Scrubbers
      3.3.3.1   Inhalation  Hazards.   Poorly ventilated areas  in  the  vicinity
 of positive pressure  dry  scrubber  absorbers,  particulate  control systems,
 and/or ductwork  should be avoided.  There are a variety of  inhalation
 hazards associated with HWI's, including  but  not limited  to  asphyxiants,
 toxic gases,  toxic particulate,  and,  at facilities  licensed  for
 radioactive wastes, radioactive materials.
     Concentrations of these pollutants (particularly HC1) can exceed the
maximum allowable use levels of air-purifyirig respirators.   Inspectors
must be able to recognize and avoid areas of potentially  significant
exposure to fugitive emissions from the dry scrubbing system.  A simple
flowchart that indicates the locations of all fans is a useful starting
                                    3-7

-------
 point in identifying portions of the system that operate at  positive
 pressure.
      3.3.3.2  Chemical  and Eye Hazards.   The strong alkalis  used  in dry
 scrubbing have the potential  to cause severe eye damage.  While the
 probability of eye contact and skin contact is relatively small for Agency
 inspectors, it is nevertheless important to keep in mind the general  first
 aid procedures.  These  are briefly summarized below.
      1.   After eye contact, flushing should be started  immediately;
      2.   Eyes should be flushed for 15 to 30 minutes;
      3.   After skin contact,  all  affected clothing should be removed,  and
 the inspector should shower for a minimum of 15 minutes; and
      4.   Medical  attention should be obtained in all situations.
      During the routine inspection, agency personnel should  note  the
 locations of any  eye wash  stations and showers.  These  are generally
 located  in the immediate vicinity of chemical  handling  areas.  After  the
 first aid procedures are completed, it is especially important to get
 qualified medical  attention regardless of the presumed  seriousness of  the
 exposure.   All  inspectors  should  have full  first aid and safety training
 before conducting  field inspections of HWI's or any other type of air
 pollution source.
 3.3.4 Fabric Filters
      Most fabric filters installed at HWI facilities likely  will  be
 coupled with  some  sort  of  dry  scrubber because of  the concern with HC1 and
 condensible metal  emissions.   However, at least one existing facility  is
 equipped  with a stand-alone fabric filter.   The information  presented  in
 this  section  will  generally be applicable in either of  these cases.  Where
 there  is  differentiation between  fabric  filters with and without  an
 upstream  scrubber,  these differences  will  be pointed out.
      3.3.4.1  Hot  Surfaces.  Stand-alone  fabric filters  serving HWI's  must
 operate at  high gas  temperatures  in excess  of  300"F to  avoid condensation
 of the HC1  gas  found  in  the gas stream.   Even  fabric filters located
 downstream  from a  dry scrubbing system are  expected  to  operate at
 relatively  high gas  temperatures  of 250°  to  350°F,.   (These systems are not
yet typical at HWI facilities; the  temperature  range given is based on
 typical municipal  waste  incineration  systems.)   Thus, uninsulated baghouse
                                    3-8

-------
roofs  can  be  a serious  burn  hazard.  Unfortunately,  it  is important to
 inspect  this  area  of  pulse jet fabric filters  to  identify possible air
 infiltration  problems and to check the diaphragm  valves and the compressed
 air pressure  gauge.
     3.3.4.2   Inhalation Hazards.  Fugitive emissions from positive
 pressure fabric filter  systems can accumulate  in  poorly ventilated areas
 around the baghouse.  The inhalation hazards, can  include asphyxiants,
 toxic gases/vapors, toxic particulate, and, at facilities licensed for
 radioactive wastes, radioactive materials.
     3.3.4.3   Opening Hatches.  It is sometimes helpful to have plant
personnel  open one or more hatches of fabric filter  compartments which are
 isolated for  inspection.  However, the discharge  hopper hatches should not
be opened  during the  inspection because hot, free-flowing dust can be
released and  cause severe burns.  Opening of hopper  hatches can also
create the potential  for hopper fire if the combustible content of the ash
is high.
     3.3.4.4   Flyash  Storage and Handling.  All materials collected by a
fabric filter  should  be considered hazardous.  At HWI facilities
controlled with a stand-alone fabric filter, flyash may contain hazardous
levels of metals, dioxins/furans, acids, and,  at poorly operated units,
infectious agents.  At HWI facilities equipped with a dry scrubber
upstream from  the fabric filter, the same hazards exist, except that the
possibility of exposure to acids is replaced by caustic exposure
hazards.   These hazards should be considered during inspection of flyash
handling and disposal  facilities, and skin contact and inhalation of
fugitive dust  should be avoided.
                                   3-9

-------

-------
                     4.0  VISIBLE EMISSION OBSERVATION

      The  observation of  the  stack visible  emissions  from  hospital waste
 incinerators  is  an 'important part of-the air  compliance inspection.
 Visible emission observations are important for  two  reasons.   First, many
 State regulations stipulate  opacity limits or the construction/operating
 permit likely will stipulate an opacity limit.   Consequently,  visual
 observation of the emissions provides a direct means of establishing
 compliance/noncompliance with a provision  of  the regulation.
      Second,  the presence of visible emissions provides an  indication of a
 combustion/control problem.   The cause of  the emissions can be further
 investigated  and evaluated to determine if a  violation exists  and to
 determine what corrective action is warranted.   For  example, a detached
 plume (i.e.,  a plume that forms in the atmosphere after exiting the stack)
 at a  hospital incinerator likely is caused by condensing  hydrogen chloride
 (HC1).  A black  plume is due to incomplete combustion of  carbonaceous
 matter.  The  possible causes for various plume appearances are further
 discussed in  Section 4.3.
     Two primary methods of  determining stack gas opacity are  used.  The
 first method  is  visible observation of the plume at  the point  of
 detachment from  the stack by a qualified observer (i.e.,  the inspector)
 per EPA Reference Method 9.   The second method is an instrument method,
 which employs a  transmissometer that continuously monitors stack gas
 opacity.   Each of these methods is briefly discussed below.
 4.1  EPA REFERENCE METHOD 9
     The EPA Reference Method 9~Visual  Determination of  the Opacity of
 Emissions from Stationary Sources—is the  EPA method for  determining
 opacity of visible emissions  by a qualified observer.  Method  9 involves
 observations of  a hospital waste incinerator stack plume  at the point of
 detachment and provides a simple means of assessing  incinerator
 performance.  The only problem with application of the method  to hospital
 incinerators is  that for incinerators controlled by wet scrubbers, the
combustion gas likely will be saturated  with moisture and a condensed
water plume will  be  present.   Although Method 9 may still  be used for
observing  opacity in such cases, application of the method is more
                                    4-1

-------
 difficult than in  cases where the incinerator  Is controlled with  a  "dry"
 control  device.
      Method  9  is published  in 40  CFR  Part  60,  Appendix A;  an  inspector
 must be  certified  and  should  be familiar with  all aspects  of  the  method.
 The requirements of Method  9  are  summarized  in Table 4-1.  A  Method 9
 visible  emission form  is presented  in Appendix D.  Method  9 specifies that
 the opacity  readings taken  by the observer are used to calculate  the
 average  opacity for 6-minute  intervals.  Some  State and  local  regulations
 may specify  other  averaging periods or different data reduction methods
 (i.e., maximum opacity limit  never to be exceeded) for determining
 compliance.  Nonetheless, the method  of observation is the same.
 4.2  CONTINUOUS EMISSION MONITORING FOR OPACITY
      Either  State  law or the  construction/operating permit might  require
 that the facility  continuously monitor the combustion gas  opacity.
 Obviously, the advantage of a continuous emission monitoring  system (CEMS)
 is  that  the  opacity can be  determined at all times during  operation of the
 incinerator.   The  information provided by  the  CEMS can be  used by the
 operator to  identify operating problems on a real-time basis; conse-
 quently,  immediate corrective action can be taken.  The CEMS  data records
 also can be  used by the regulatory agency  to assess historical
 performance.
      A transmissometer is used to monitor  stack gas opacity.  The
 operating principle of a transraissometer involves measurement of  the
 absorbance of  a light beam  across the stack or duct.  Transmissometers use
 a light  source directed across the stack towards a detector,  or reflector,
 on the opposite side.   The  amount of light absorbed or scattered  is a
 function of the particles in  the  light path, path length (duct diameter),
 and  several other variables that are considered in the design and
 installation.  Figure 4-1 is  a schematic of a dual-pass transmissometer
 system.  Additional detailed  information on transmissometers  is available
 in Reference 1.
     The EPA has promulgated performance specifications for opacity
monitoring systems  (Performance Specification 1—Specification and Test
Procedures for Opacity Continuous Emission Monitoring Systems in
Stationary Sources; 40 CFR Part 60,  Appendix B).   These specifications are
                                    4-2

-------
                TABLE 4-1.  SUMMARY OF METHOD 9 REQUIREMENTS
 Observer

 1.  Must be qualified (certified)  by procedures established in Method 9
 2.  Certification valid for 6 months

 Position of Observer

 1.  At sufficient distance  to provide a clear view
 2.  Sun in 140° sector to observer's back
 3.  Line of vision approximately perpendicular to plume direction and to
     longer axis of rectangular outlets
 4.  Line of sight does not  pass through more than one plume where there
     are multiple outlets

 Field Records

 1.  Plant name
 2.  Emission location
 3.  Type of facility
 4.  Observer's name and affiliation
 5.  Sketch  of observation position relative  to source
 6.  Date
 7.  Data to be recorded both  at  start  and end of  observation period:

        Time
        Estimated  distance to  source
        Approximate  wind direction and  speed
        Sky  condition  (presence and color  of  clouds)
        Plume  background

Observations

 1.   Read at point of greatest opacity where  condensed water  vapor  is  not
     present

     •  For attached steam plumes, read at the  point of greatest opacity
       after the condensed water vapor has evaporated and record the
       approximate distance from the outlet;
     •  For detached steam plumes, read at the  outlet before water vapor
       condenses

2.  Observe the plume momentarily for a reading at 15-second intervals
                                                               (continued)
                                   4-3

-------
                         TABLE 4-1.   (continued)
Recording Observations
1.  Record readings to nearest 5 percent opacity at 15-second intervals
2.  Take a minimum of 24 readings
Data Reduction
1.  Reduce the data by averaging each set of 24 consecutive readings
2.  Sets may consist of any 24 consecutive readings but may not overlap
                                   4-4

-------
    Transceiver
                                                                  Retro reflector
                                                                    a.wmbiv
    Presepmtor
                                                           Blower
                 Ambient
                    air
                       Blower
Figure  4-1.  Typical transmissometer  installation for measuring opacity.
                                       4-5

-------
 applicable for opacity CEMS applied at sources regulated by new source
 performance standards (MSPS).  Table 4-2 presents a summary of these
 performance specification requirements.  Hospital incinerators do not fall
 into this category, but typically, State regulations also will require
 that a performance test be conducted at the time of initial installation
 and startup.  Typically, a transmissometer system will  have a means of
 automatically checking instrument calibration on a regular schedule (e.g.,
 dally) by placing a filter of known light absorbance in the light path.
 Calibration requirements for transmissometers subject to NSPS are
 specified in 40 CFR 60.13; daily calibration checks are required.
      Prior to the inspection, the inspector should review the source file
 to determine the opacity monitoring requirements, if any, for the
 facility.  The calibration requirements and recordkeeping requirements
 should be identified.   The results of the last performance specification
 test or quality assurance audit should be reviewed.
      Transmissometers  are sophisticated electronic instruments;
 consequently,  evaluation of the performance of the monitor (e.g.,
 calibration accuracy)  is not easily assessed by the inspector.   However,
 gross operational,  maintenance,  and recordkeeping problems can be
 identified  during an inspection.   If problems are suspected,  a complete
 performance audit of the system can be conducted at a later date by
 qualified personnel.   Performance  audit procedures for  opacity monitors
 are  presented  and discussed  in  an  EPA document entitled  "Performance Audit
 Procedures  for Opacity Monitors"  (Reference 2);
      During the inspection,  the  inspector should:
      1.   Determine  that  the  monitor is operating;
      2.   Review historical calibration records to  assess  calibration
 problems;
      3.   Review the opacity  data records  to assess  recordkeeping
 procedures;  and
      4.   Review historical data to  assess  frequency of excess  emissions.
      The  inspector should locate the monitor  and visually  inspect  its
 condition including, for example, the  operation  of  accessories such  as
 blowers designed to keep lenses clean.  This  initial visual inspection
will give the  inspector a general idea  of whether the monitor  is well
                                    4-6

-------
       TABLE 4-2.   PERFORMANCE SPECIFICATIONS FOR
                   OPACITY MONITORS

 Parameter                          Specifications


 Calibration errora                 <3 percent opacity
 Response time                      <10 seconds

 Conditioning period13               >168 hours

 Operational  test periodb           >168 hours

 Zero drift  (24-hour)a              <2 percent opacity
 Calibration drift (24-hour)a       <2 percent opacity

 Data recorder resolution           <0.5 percent opacity

 Expressed  as the sum of the absolute value of the mean
 .and the absolute value of the confidence coefficient.
 During the  conditioning and operational test periods,
 the CEMS must not require any corrective maintenance,
 repair, replacement, or adjustment other than that
 clearly specified as routine and required in the
 operation and maintenance manuals.
Source:  40 CFR Part 60, Appendix B.
                          4-7

-------
 maintained.  The monitor data display/recorder should be located  and  the
 following questions asked:
      1.  Is the monitor online and recording data?
      2.  Are any system failure warning lights illuminated?
      3.  Is the data recording system operating and does the  strip  chart
 appear normal (e.g., values less than zero are not normal)?
      4.  Does the current indicated opacity level appear correct  based
 upon visual observation?  For example,  if the monitor indicates a steady
 baseline reading of 0 percent opacity,  but visual inspection  indicates
 excursions of up to 20 percent opacity, a problem exists.
      The inspector should ask to review the most recent calibration data
 to  assure that:
      1.  Calibration frequency is at least that specified  in  the
 regulations or construction/operating permit;
      2.  The value being used as the calibration value is  the same  as the
 calibration level  identified  during the most recent performance test; if
 not,  an explanation of how the new calibration value was determined should
 be  available; and
      3.  Corrective action has been taken (i.e., the instrument has been
 recalibrated) when calibration checks indicated the monitor was out of
 calibration.
 The  inspector should review the opacity data records to  determine:
      1.   If recordkeeping procedures  are consistent with those required in
 the regulations  and or construction/operating permit (e.g., continuous
 strip chart record  on a real-time  basis or data logger/recorder of
 6 minute  averages,  etc.);
     2.   The  frequency of  excess emissions;  and
     3.   Instrument availability.
 Finally,  the  inspector should  request to  see the maintenance  log for the
monitor (if required  by the regulations  or operating permit).  The
maintenance log  should  be  reviewed  to determine the frequency of
maintenance and  the presence of any major  operational  problems that are
recurring and are affecting instrument  availability.
     The  identification  of serious problems  or  deficiencies with the
opacity CEMS  by  the  inspector  indicates  that  a  complete  system/performance
audit of the  CEMS should be considered.

                                    4-8

-------
 4.3  SPECIAL CONSIDERATIONS FOR OPACITY OBSERVATIONS AT HOSPITAL INCINERATORS
 4.3.1  Stack Location
      At some facilities,  the incinerator is located on the roof.  This
 location may present an observer on the ground with a line of  sight  at  an
 extreme angle upward through the plume, possibly biasing opacity readings
 high.   Under these circumstances, it is preferable  that the observer
 determine opacity from an adjacent building or from the roof of  the  HWI
 facility.
      Because the  incinerator may be located in a confined space, it  may be
 difficult to obtain an appropriate line of site that is in the proper
 orientation  with  the sun  and/or that is a sufficient distance  away from
 the source.   Additionally,  the  stack may be shorter than the adjacent
 building causing  shadow and orientation problems.
 4.3.2   Steam (Condensing  Water  Vapor)  Plumes
     At HWI  facilities equipped with wet scrubbers,  the plume  typically
 will be saturated  with water and will  contain  condensed water  vapor  as  it
 leaves  the stack  (an attached steam plume).  Under  these circumstances,
 the observer must  read the  plume's  opacity at  a point  after the  condensed
 water vapor  has dissipated.   In most cases,  such readings  at an  HWI
 facility  will not  be meaningful  because the  plume will  be  diluted  at the
 point of  observation.
     At uncontrolled  facilities  and  those  equipped with  a  spray  dryer/
 fabric  filter or stand-alone  fabric  filter,  depending  upon  atmospheric
 conditions (temperature and relative  humidity), water  vapor  may  condense
 in the plume after it  leaves  the  stack  (a  detached steam plume).   Opacity
 readings must be made  in the  section of  the  plume prior  to this  condensa-
 tion.    If other condensibles  (e.g., HC1  or metals) are  in  the gas  stream,
 they will not be included in  these opacity readings.
 4.3.3   Evaluating Visible Emissions
    Common opacity problems  at hospital waste  incinerators  and  their
 typical  causes are discussed below.
    4.3.3.1  Dense Black Smoke.  Dense black smoke is due to incomplete
combustion of carbonaceous material.  The  probable cause is  insufficient
secondary chamber combustion air.  Either  the combustion air to the
secondary chamber is improperly set, or volatile matter  is being generated
in excess of the incinerator's secondary chamber capacity.

                                    4-9

-------
     4.3.3.2  Detached White  Plume.  A detached hazy white plume is
probably caused by HC1 condensing in the cooling gas stream.  This
situation cannot be controlled by modifying operation of the incinerator,
other than by decreasing the  quantity of chlorine-containing wastes fed to
the incinerator.
     4.3.3.3  Attached White  Plume.  An attached white plume indicates the
presence of subraicron aerosols in the gas stream.  Possible causes are
insufficient secondary combustion chamber temperature or the presence in
the waste of noncombustible inorganic materials that volatilize and are
emitted to the atmosphere.
4.3.4  Fugitive Emissions
     Fugitive emissions may be generated during ash handling or by the
action of wind on improperly  stored ash at HWI facilities.  These
emissions are typically intermittent and extremely variable, presenting
some difficulties with regard to characterization by the observer.
     The observer should note the location of the fugitive emissions and,
as specifically as possible, quantify the duration and magnitude (e.g.,
fugitive emissions from ash removal  door; constant emissions for
45 seconds; dense plume of approximately 75 percent opacity at 5 feet from
door; some flames also emitted).
4.4  REFERENCES FOR CHAPTER 4
1.  Jahnke, J.  A.  APTI Course SI: 476A Transmissometer Systems—Operation
    and Maintenance, and Advanced Course; EPA 450/2-84-004.
    September 1984.
2.  Entropy Environmentalists, Inc.   1983.   Performance Audit Procedures
    for Opacity Monitors.   EPA 340/1-83-010.
                                   4-10

-------
                    5.0  HOSPITAL INCINERATION SYSTEMS

 5.1  INTRODUCTION
      Incineration is  the process by which  combustible materials  are
 burned,  producing combustion  gases and  noncombustible ash.   The  product
 combustion  gases  are  vented directly to the  atmosphere or to the
 atmosphere  after  treatment in an air pollution control device.   The
 noncombustible  ash is removed from the  incinerator  system and is disposed,
 usually  in  a  landfill.   Incineration provides  the advantage  of greatly
 reducing the  mass and volume  of  the waste.   Typically, mass  is reduced by
 as. much  as  75 percent, and volume can be reduced by 95 percent or more.
 This  reduction  substantially  reduces transportation and disposal  costs.
 For infectious  hospital  wastes,  another major  objective of the
 incineration  process  is  the destruction of infectious organisms  (path-
 ogens) that may exist in the  waste.  The pathogens  are destroyed by
 exposure to the high  temperatures which exist  within  the incinerator.
 Incineration  of hospital wastes  also is attractive  aesthetically because
 it  destroys organic components of the waste  that the community often finds
 objectionable when wastes are disposed  of in landfills.
     Two additional objectives achievable through proper operation of
 hospital waste  incinerators are minimizing the organic content in the
 solid residue and controlling emissions to the atmosphere to  acceptable
 levels.  Generally, tight control on organics  in the ash, i.e.,  good
 burnout, promotes waste  reduction and pathogen destruction.   Reduction of
 atmospheric emissions of constituents that are potentially harmful to
 human health  and the environment is a prerequisite to acceptance of
 hospital incineration as a feasible disposal  alternative by the  community.
 5.2  TYPES OF HOSPITAL INCINERATOR SYSTEMS
     The terminology used to  describe hospital incinerators that has
evolved over the years is quite varied.   Multiple names have  been used for
the same basic types of  incinerators,  and much of the terminology does not
enhance precise definitions.   Historically, however, most incinerators
were grouped into one of three types—"controlled air,"  "multiple
chamber," and  "rotary kiln."
                                    5-1

-------
     Before the early 1960's, the incineration systems used were primarily
 "multiple-chamber" systems designed and constructed according to Inciner-
 ator Institute of America (HA) (now defunct) incinerator standards.  The
 multiple-chamber incinerator has two or more combustion chambers.  The two
 traditional designs used for multiple-chamber incinerators are the "in-
 line" hearth and "retort" hearth designs  (these designs are further
 explained 1n Section 5.2.2.4).  These "multiple-chamber" systems were
 designed to operate at high excess-air levels and hence are often referred
 to as "excess-air" Incinerators.1  These  units will be referred to as
 "multiple-chamber Incinerators" throughout this manual.  Multiple-chamber,
 excess-air Incinerators are still 1n operation at some hospitals; their
 use typically is for pathological wastes.2  Note that although the
 singular term "multiple-chamber" Incinerator is often used to describe
 this type of incinerator, in reality, the typical controlled-air modular
 unit 1s also a multiple-chamber incinerator.
     The incineration technology that has been used most extensively for
 hospital wastes over the last 20 years generally has been called
 "controlled-air" Incineration.  This technology is also called "starved-
 a1rM combustion, "modular" combustion, and "pyrolytic" combustion.  These
 units will be referred to as "controlled-air incinerators" throughout this
 manual.  Most systems are prefabricated units transported to the site in
 parts; hence the name "modular."  The systems were called "controlled air"
 or "starved air" because they operate with two chambers in series and the
 primary chamber operates at substolchlometric conditions.  Similar modular
 "controlled-air" units which operate with excess-air levels 1n the primary
 chamber are also manufactured and sold for combustion of municipal solid
waste, but are not as widely used.
     Rotary kiln incineration systems have been widely used for hazardous
waste Incineration in the U.S.  As with the other units, the rotary kiln
 incinerator has two combustion chambers.  The primary chamber is a hori-
zontal  rotating kiln that operates with excess air.  The waste is charged
to the elevated end of the kiln and moves through the kiln to the discharge
end at a rate determined by the angle of  inclination and speed of rotation.
The exhaust gases exit the kiln to a fixed secondary chamber.  There are a
few applications in the U.S. and Canada where the rotary kiln incineration
technology Is being applied to hospital waste incineration.

                                    5-2

-------
      This historical grouping is of some assistance in  understanding  how
 hospital incinerators operate,  but it is limited because  it does  not
 address the complete combustion "system."  Three parameters define  the
 hospital incinerator system—the method of  air supply and distribution,
 the method of charging waste  and moving waste through the system, and the
 method of ash removal.  In  hospital  incinerators, air supply/distribution
 systems generally are one of  two types, depending on whether  the  primary
 chamber operates under substoichiometric (i.e.,  starved-air)  or excess-air
 conditions.   Charging can be  accomplished in  one of three modes—batch,
 intermittent, or continuous.  Ash is removed  on  a batch or a  continuous
 basis.  Table 5-1 identifies  the major types  of  incinerators  that are
 likely to be found at U.S.  hospitals and characterizes them with  respect
 to  the three key factors  desribed above.  Because air supply  is
 particularly important to achieving  good combustion,  the  basic principles
 of  systems that  operate at  substoichiometric  (starved-air) and excess-air
 levels 1n the primary chamber are described in detail in  the  first
 subsection below.   The second subsection describes  each of the types of
 incinerators that  are Identified  in  Table 5-1.
 5.2.1   Principles  of Air  Supply
     5.2.1.1  Controlled-AIr Incineration.  The  principle of  controlled-
 air  incineration involves sequential combustion  operations carried out in
 two  separate chambers.  Figure 5-1 is  a  simplified  schematic  of an
 incinerator  that operates on controlled-air principles.
     The  primary chamber  (sometimes referred to  as  the ignition chamber)
 receives  the waste,  and the combustion process is begun  in a
 substoichiometric  oxygen atmosphere.  The amount of combustion air added
 to the primary chamber  is strictly regulated ("controlled").   The
 combustion air usually  is fed  to the system as underfire air.   Three
 processes occur  in the primary chamber.  First, the moisture   In the waste
 is volatilized.  Second, the volatile organic fraction of the  waste is
 vaporized, and the volatile  gases are directed to the secondary chamber.
 Third, the fixed carbon remaining in the waste is combusted.
     The combustion gases containing the volatile combustible  materials
 from the primary chamber are directed to the secondary chamber (sometimes
referred to as the "combustion chamber").  There, the combustion air is
                                   5-3

-------



















00
as
o
J—
2
LU
z
>"*
u
z
>"«•

— 1
*x
H-
1—4
OL
OO
O

u.
o

z
o
>«4
Hr
O
1—4
U.
t—t
OO
00
u


,_!
LO
LU
_J
CO

f—































r—

i
cu


Jim
C/)
^^






















TD
CU
CU
J,
**"
CU

(/)
id
3


id

o.
0.
3

J_

5



i.
o

(d
1.
S
•r-
(J
C




•^
CU
c
o





































c
$_
.a

<4w
O
1
cu

ts

JC
u

*o
ca



>

3 3
c g
03





•a
§1
l»
0
4-»

•VM
V?
f*~
o
j_

c
o
CJ
I-*
c
cu

^J
•^
e
C t"
cu •»-

c
1— 1
1
c

c
o
u c
J_
O J3

^ o»
c*u
CU 3

-M
C r"*
SM (/)
CU 3
•M O
C
1—4









tn
3
O

c -o
f- CU
+J CU
C <4-
o
U JC
•r- CJ
E -M
cu id

^
 1-
c id
o
CJ




c

J3

M-
o
•a
cu

-M
id

•£• •
u

id
ca '






^ir""%
^»
id
o

"c
id
J^
u
(Ij
5
t-
o

fmm
id
i
fd

***'
f^
y
^1
id
ca





v»
cu
u
X
LU








JC
4->
s-
id
cu
^

l__^
s_
o

cu





c
S-
J[

14-
o
•g
cu

-M
id

JC
u
•M
id
ca






^^
f*nm
id
u

*£
id
JC
u

p£
t-
o

1^"
id

id

^^
JC
u
-M
id
ca





M
cu
u
X
LU








JC
s-
id
cu
JC

cu
c

r™ •
1
c
•"<











V*
3
o
c

.*->
c
o









"O
cu
cu
t*-

Crt
3
o
3
c
•4"*
c
o
u

id
u
*^^
id
JC
u
cu






I/I
cu
u
X
LU










c
^—
*^l»
_^

>J
J_
id
4^
o
a£ .


i-
"5

0

^>
cu

JC
o

"o
trt

J« l»
V)
V)
cu
u
X
cu

cu
>
0
J3
id

J_
o

^•%
•o
cu
>
Is
^J
(/>
^^^

g
1^—
cu

^Jt
id

(/)
cu
2
cu
EX
o
cu
1
id
JC
u

id
n
a.

J-
cu
^J
-M
cu
"%

in
cu
4^ •
id tn
O r-
^- CU
•o >
c cu
••^ r*~
id
5-4

-------
CO
111
CO

O

I

CO

03

O
o
tr
LU
CO

<

u
>
                        o o
                        il
                        ffl §
o
o
HI
CO
o 8
   tii
                           O
                                 o
                                O
                                (W
                             CO
I
CD
                                                                                                 o
                                                                                                 •M
                                                                                                 (T3



                                                                                                 I
                                                                                                 13
                                                                                                 id
                                                                                                •o
                                                                         o
                                                                         o
o
(J
                                                                         
-------
regulated to provide an excess of oxygen and is introduced to the chamber
in such a manner as to produce turbulence to promote good mixing of the
combustion gases and combustion air.  This gas/air mixture is burned,
usually at high temperatures. .The burning of the combustion gases under
conditions of high temperature, excess oxygen, and turbulence promotes
complete combustion.
     Figure 5-2 is a diagram showing the relationship between the"
temperature in the primary and secondary chambers and the combustion air
level.  This figure illustrates that the temperatures in the chambers can
be controlled by modulating the combustion air supply.  Combustion control
for a controlled-air incinerator is usually based on the temperature of
the primary (ignition) and secondary (combustion) chambers.  Thermocouples
within each chamber are used to monitor temperatures continuously; the
combustion air rate to each chamber is adjusted to maintain the desired
temperatures.  An alternative control mode is to monitor the oxygen level,
which is an indication of the excess-air level, within the combustion
chamber.  The combustion air level is then set or modulated to maintain   ;
the desired excess-air (oxygen) level.  Systems operating under
"controlled-air" principles have varied degrees of combustion air
control.  In many systems, the primary and secondary combustion systems
are automatically and continuously regulated or "modulated" to maintain
optimum combustion conditions despite varying waste composition and
characteristics (e.g., moisture content, volatile content, Btu value).5
In other systems (particularly batch or intermittent systems), the
combustion air level control is simplified and.consists of switching the
combustion air rate from a "high" to a "low" level setting when
temperature setpoints are reached or at preset time intervals.
     The controlled-air technique has several advantages over an excess
air mode.   Limiting air in the primary chamber to below stoichiometric
conditions prevents rapid combustion and allows a quiescent condition to
exist within the chamber.  This quiescent condition minimizes the
entrainment of particulate matter in the combustion gases which ultimately
are emitted to the atmosphere.  High temperatures can be maintained in a
turbulent  condition with excess oxygen in the secondary chamber to assure
complete combustion of the volatile gases emitted from the primary
                                    5-6

-------
TEMPERATURE
              PRIMARY      •*-
              CHAMBER OPERATING  I
              RANGE              |


              MAXIMUM
              TEMPERATURE
SECONDARY
CHAMBER OPERATING
RANGE
                 DEFICIENT AIR
                                I
 EXCESS AIR
                        PERCENT EXCESS AIR
    Figure 5-2.  Control of temperature as a function of excess air.6
                             5-7

-------
 chamber.   The temperature of the secondary chamber can  be  maintained  in
 the desired  range (hot enough for complete combustion but  not  so  hot  to
 cause refractory damage)  by separately  controlling the  excess-air level  in
 the secondary chamber; as the excess-air level  is  increased, the
 temperature  decreases. Additionally, control  of the  primary chamber
 combustion air to below stoichiometric  levels  maintains primary chamber
 temperatures below the melting and fusion temperatures  of  most metals,
 glass, and other noncombustibles,  thereby minimizing  slagging  and clinker
 formation.
      For controlled-air combustion, the capacity of the secondary chamber
 dictates (i.e.,  limits) the burning or  charging rate.   The secondary
 chamber must have a volume such that the volatile  gases, as they  are
 released from the primary chamber, are  retained in the  chamber for
 sufficient time  and at sufficient  excess oxygen levels  to  ensure .their
 complete combustion.   The volatile gases'  retention times  may  range from
 less  than  %  second to  more than 3  seconds.   In  order  to maintain  the
 designed retention time,  waste must be  charged  at  the designed rate;      >
 overcharging  can cause excessive primary chamber temperatures, high
 combustion gas velocities,  and shorter  retention times, while
 undercharging can cause lower  primary chamber.temperatures, lower
 combustion gas velocities,  and longer retention times.
      5.2.1.2  Multiple-Chamber Incineration.  The  significant  difference
 between multiple-chamber  incineration and controlled-air incineration is
 that  the primary chamber  in  the excess  air unit is  operated with  above
 stoichiometric air levels.   The waste is dried,  ignited, and combusted in
 the primary chamber.   Moisture  and uncombusted  volatile components pass
 out of the primary chamber and  through  a flame  port into the secondary
 chamber.   Secondary combustion  air is .added through the flame  port and is
 mixed with the volatile components in the secondary chamber where
 combustion is completed.  Multiple-chamber incinerators are designed for
 surface combustion of  the waste which is achieved by predominant use of
overfire  combustion air and  by  limiting the amount of underfire air.
Multiple-chamber,  excess-air incinerators operate with an overall excess-
air range of  300 to 600 percent.7  In older units,  combustion air
typically was provided by natural draft via manually adjusted dampers and
                                    5-8

-------
 air in-leakage through charging or ash removal  doors.  Newer multiple-
 chamber incinerators often use forced draft combustion air blowers to
 provide the combustion air to the combustion chambers.
      Because of the predominant use of overfire air,  high excess air rate,
 and surface combustion, turbulence and gas  velocities are high in the
 primary chamber.   These conditions result in relatively high particulate
 generation and entrainment.   Therefore, multiple-chamber units have higher
 particulate emission rates than controlled-air  units.
 5.2.2  Hospital  Incinerator Descriptions
      5.2.2.1  Batch/Contro11ed-Air Incinerators.   The least complex
 hospital  incinerators are  the batch/controlled-air units.  The operation
 of these  units is  relatively simple in that the incinerator is charged
 with  a  "batch" of  waste, the waste is incinerated,  the incinerator is
 cooled, and  the ash is  removed  through the  charging door; the cycle is
 then  repeated.   (For this  manual,  the term  "batch  feed"  is used to refer
 to an incinerator  that  is  loaded with one batch of  waste during the
 combustion cycle;  the term "intermittent duty"  is used to refer to units  j
 where multiple charges  are made.)   Incinerators designed for this type of
 operation range in  capacity  from about 50 to  500 Ib/h.   In the smaller
 sizes, the combustion chambers  are often vertically oriented with the
 primary and  secondary chambers  combined  within  a single  casing.
 Figure 5-3 is  a schematic  of  a  smaller  controlled-air incinerator intended
 for batch operation.  This unit's  combustion chambers  are rectangular in
 design and are contained within the same casing.
     Batch/control!ed-air units can be  loaded manually or mechanically.
 For the smaller units up to about  300  Ib/h, manual  waste  feed  charging •
 typically is used.  Manual  loading  involves having  the operator  load  the
waste directly to the primary chamber without any mechanical  assistance.
Typically, for a batch-type unit, one loading cycle per day  is used.   The
 incinerator is manually loaded; the incinerator is  sealed; and the
 incineration cycle is then  continued through burndown, cooldown,  and  ash
removal  without any additional charging.  Ash is removed manually at  the
end of the cycle by raking  or shoveling the ash  from the primary chamber
through  the charging door.
                                    5-9

-------
                                                   o
                                                   2
                                                   a>
                                                   i_
                                                  •t—
                                                    i
                                                  JD
                                                   
-------
      5.2.2.2  Intermittent/Controlled-Air Incinerators.  When mechanical
 feeders  are employed,  the charging procedures  of  an  incinerator that could
 operate  in  batch mode  often are varied  to include multiple charges
 (batches) during the 12 to 14 hour operating period  before final burndown/
 cooldown is initiated.  These intermittent units  typically operate  in  the
 50 to 1,000 Ib/h range.  The intermittent charging procedure allows the
 dally charge to the incinerator to be divided  into a number of smaller
 charges  that can be introduced over the combustion cycle... Consequently, a
 more  uniform gas stream is fed to the secondary chamber, and complete
 burnout  of  the residue in the primary chamber  can be achieved more
 easily.  Figure 5-4 is a drawing of a small incinerator which is intended
 for intermittent operation when fitted  with the proper manual or automatic
 charging system to assure operator safety and  limit  air in-leakage.
      A typical daily operating cycle for a controlled-air batch type
 incinerator is as follows:
         Operating step                           Typical duration
                                                                          s
      1.  Cleanout of ash from previous  day       15  to 30 minutes
      2.  Preheat of incinerator                   15  to 60 minutes
      3.  Waste loading/combustion                 Up  to 14 hours
      4.  Burndown                                 2 to 4 hours  :
      5.  Cooldown                                 5 to 8 hours
 For intermittent-duty operation, the daily combustion cycle of the
 incinerator is limited to about a 12- to  14-hour  period.  The remainder of
 the 24-hour period is required for burndown, cooldown, ash cleanout, and
 preheat.
      For units in the 300 to  500 Ib/h range, mechanical waste feed systems
 are often employed, and for units above  500 Ib/h, mechanical  waste feed
 systems are normally employed.   The typical mechanical waste feed system
 is a  hopper ram assembly.  In a mechanical hopper/ram feed system, waste
 is manually placed into a charging hopper, and the hopper cover is.
closed.  A  fire door isolating the hopper  from the incinerator opens,  and
 the ram moves forward to push the waste  into the  incinerator.   The ram
reverses to  a location behind the fire door.  After  the fire door closes,
the ram retracts to the starting position and  is  ready to accept another
charge.  Water sprays typically are located just  behind the fire door  and
                                   5-11

-------
                      START
                      WASTE LOADED INTO HOPPER
                      3TEP1
                      FIRE DOOR OPENS
                     STEP 2
                     RAM COMES FORWARD
                     STEP 3
                     RAM REVERSES TO CLEAR FIRE DOOR
                     STEP 4
                     FIRE DOOR CLOSES
                     STEPS
                     RAM RETURNS TO START
Figure 5-4.   Operating  sequence of  a waste charging  hopper/ram system.
                                       5-12

-------
 are used to cool the ram prior to retraction in order to prevent ignition
 of the waste by the ram in the hopper/ram assembly.  The entire charging
 sequence is normally timed and controlled by an automatic sequence.  For
 batch type incinerators, the sequence would be set up to be manually
'started by the operator.  Figure 5-5 schematically presents the charging
 sequence of a mechanical ram charging system.
      Mechanical loading systems have several advantages.  First, they
 provide added safety to the operating personnel by preventing heat,
 flames, and combustion products from escaping the incinerator during
 charging.   Second,  they limit ambient air infiltration into the
 incinerator;  ambient air infiltration works against the controlled-air
 combustion principal of controlling combustion rate by strictly        *
 controlling the quantity of available combustion air.  Third, they enable
 incinerators  to be  safely charged with smaller batches of waste at    •
 regulated  time  intervals.
      Note  that  even with intermittent-duty incinerators, a limiting factor
 for the incinerator operations  is ash removal.   As with the batch-operated^
 units,  the  waste loading/combustion cycle must  stop,  and the incinerator
 must  pass through burndown  and  cooldown cycles, before the incinerator can
 be opened for daily ash  removal.   The ash usually  i-s  manually removed  by
 raking  and/or shoveling  from  the  primary  chamber.   Consequently,  a major
 improvement in  operations can be  achieved by using continuous, or
 intermittent ash removal as described in  the subsection  below.
      5.2.2.3  Continuous/Controlled-Air Incinerators.   Controlled-air
units intended  for  continuous operation are  available  in the  500  to
3,000 Ib/h operating range.   Continuous/controlled-air units  operate
according to the controlled-air principles of the  systems described
earlier.  However,  continuous operation or combustion requires  a mechanism
for automatically removing ash from the incinerator hearth.   The ash must
be moved across the hearth, collected, and removed from  the combustion
chamber.  Continuous ash removal while the incinerator is operating
removes the requirement for burndown and cooldown cycles.
     Continuous-operation units typically will  have mechanical waste
feeding systems.  For large continuous-operation units, the charging
sequence may be fully automatic.  The incinerator then can be
                                   5-13

-------
    STACK
 CHARGING
   DOOR
SECONDARY CHAMBER
                                      SECONDARY BURNER
                                      PRIMARY CHAMBER
IGNITION BURNER
Figure 5-5.  Intermittent/controlled-air incinerator wit^vertical
       primary chamber and horizontal secondary chamber.
                           5-14

-------
 automatically charged with relatively small batches (in relation to the
 primary chamber capacity) at frequent, regulated time intervals.  The use
 of frequent, small charges promotes, relatively stable combustion
 conditions and approximates steady-state operation.  For large systems,
 the mechanical charging system may include waste loading devices such as
 cart dumpers, which automatically lift and dump the contents of carts,
 which are used to collect and contain the waste, into the charge
 hoppers.   Use of these loading devices reduces the operators need to
 handle Infectious waste and, consequently, further improves worker safety.
      For  smaller units, the mechanical charging ram is sometimes used to
 move the  ash across the hearth.  As a new load of waste is pushed into the
 incinerator, the previous load is pushed forward.  Each subsequent load
 has the same effect of moving the waste across the hearth.  The waste
 should be fully reduced to ash by the time it reaches  the end of the
 hearth.   For larger systems,  one or more special  ash rams are provided to
 move the  waste across  the hearth.
      Typically,  when the ash  reaches  the end of the hearth, It drops off  >
 into a discharge chute.   One  of two methods for collecting ash is usually
 used.   The ash can  be  discharged directly into an ash  container positioned
 within an  air-sealed chamber.   When the  container is full,  it 1s removed
 froa the chamber and replaced  with  an  empty ash container.   The second
 method  is  for  the ash  to be discharged into a  water pit.   The water  bath
 quenches the ash, and  it also  forms an air seal with the  incinerator.   A
 mechanical device,  either  a rake or a  conveyor, is  used to  remove the  ash
 from the quench  pit  intermittently or  continuously.  The  excess water  is
 allowed to drain from  the  ash  as  it is removed  from the pit,  and  the
 wetted ash is discharged  into  a  container for  transport to  a  landfill.
 Figure 5-6 is a drawing  of a continuous-operation controlled-air  unit  with
 automatic mechanical ash removal  and a mechanical hopper/ram  charging
 assembly.
     5.2.2.4  Multiple-Chamber Incinerators.  Two traditional designs  that
 are used for multiple-chamber incinerators  are the  "in-line"  hearth  and
 "retort" hearth.  Figure 5-7 depicts the  retort design multiple-chamber
 incinerator.   In the retort design, the combustion gases turn in the
vertical direction (upward and downward)  as in the  in-line  incinerator,
                                   5-15

-------
Figure 5-6.  Schematic of a continuous operation contrailed-air
    incinerator with mechanical charging  and ash removal.
                              5-16

-------
                                                            01
                                                           .(->
                                                            S/l
                                                            
                                                           a>
                                                           IT>



                                                           S_
5-17

-------
 but also turn sideways as they flow through the incinerator.   Because the
 secondary chamber is adjacent to the primary chamber (they share a wall)
 and the gases turn in the shape of a U, the design of the incinerator is
 more compact.  Figure 5-8 depicts the in-line hearth design.   For the in-
 line hearth, flow of combustion gases is straight through the incinerator
 with turns in the vertical direction only (as depicted by the arrows  in
 Figure 5-8).  The retort design performs more efficiently than the in-line
 design 1n the capacity range of less than 750 Ib/h.  In-line  incinerators
 perform better 1n the capacity range greater than 750 Ib/h.   The retort
 design more typically 1s used 1n hospital waste applications.
      Multiple-chamber Incinerators may have fixed hearths or  grates or a
 combination of the two 1n the primary chamber.   The use of grates for a
 system incinerating infectious waste is not recommended because liquids,
 sharps, and small  partially combusted items can fall  through  the grates
 prior to complete  combustion or sterilization.
      Like the controlled-alr unit, combustion in the  multiple-chamber
 incinerator occurs 1n two combustion chambers,  but the primary chamber   .;
 operates with excess  air.  Ignition of the waste (initially by a primary
 burner), volatilization  of moisture, vaporization of  volatile  matter,  and
 combustion of the  fixed  carbon occur in the primary chamber.   The
 combustion air for these processes is controlled on old units  by natural
 draft,  manually adjusted dampers,  or by forced  draft  combustion  air
 blowers on newer units.   The combustion gases containing the volatiles
 exit the primary chamber through a flame port into a  mixing chamber and
 then pass  into  the secondary combustion chamber.   Secondary combustion air
 is added  at the flame port  and  is  mixed with the combustion gases  in  the
mixing  chamber.  A secondary burner  is  provided  in the  mixing  chamber  to
maintain  adequate  temperatures  for complete combustion  as the  gases pass
 into and through the  secondary  combustion  chamber.
     Today, new multiple-chamber,  excess-air Incinerators are  not widely
installed for the  destruction of hospital  wastes  for  the  following
reasons.  First, operating  in the  surface-combustion  excess-air mode
results 1n fly ash carryover which causes  excessive particulate matter
emissions.  Second, operating with high  levels of  excess air can require
high auxiliary fuel usage to maintain secondary combustion chamber
                                   5-18

-------
                 CHARGING DOOR
                 "TH OVERFIRE
                 HO PORT
                                                                             SECONDARY
                                                                             COMBUSTION
                                                                             CHAMBER
                                LOCATION Of
                                SECONDARY
                                BURNER
MATES
          -CIEANOUT ODORS IITH
           UNOERGRATE AIR PORTS
                                  MIXING CHAMBER
                                                                         CURTAIN
                                                                         IAU PORT
                      Figure  5-8.    In-line excess  air  incinerator.
                                                                                  13
                                                    5-19

-------
 temperatures.  Third, use of manually adjusted natural draft combustion
 air dampers does not provide the  level of control desirable for assuring
 complete combustion of the variable waste constituents found in hospital
 wastes, and good burnout can be more difficult to achieve.
     Multiple-chamber incinerators frequently are designed and used
 specifically for incinerating pathological ("Type 4" anatomical) wastes.
 Pathological waste has a high moisture'content and may contain liquids;
 consequently, a pathological waste incinerator always will be designed
 with a fixed hearth.  A raised lip at the charging door often is designed
 Into the hearth to prevent liquids from spilling out the door during
 charging.  Because the heating value of pathological waste is low and is
 not sufficient to sustain combustion, the auxiliary burner(s) provided in
 the primary chamber of pathological incinerators are designed for
 continuous operation and with sufficient capacity to provide the total
 heat Input required to complete combustion.
     5.2.2.5  Rotary Kiln Incinerators.1**  Like other incinerator types,
 rotary kiln Incineration consists of a primary chamber in which waste is
 heated and volatilized and a secondary chamber in which combustion of the
 volatile fraction is completed.   In this case, however, the primary
 chamber consists of a horizontal, rotating kiln.  The kiln 1s inclined
 slightly so that the waste material migrates from the waste charging end
 to the ash discharge end as the kiln rotates.  The waste migration, or
 throughput, rate is controlled by the rate of rotation and the angle of
 incline, or rake, of the kiln.  Air is Injected into the primary chamber
 and mixes with the waste as 1t rotates through the kiln.  A primary
 chamber burner is generally present both for heat-up purposes and to
maintain desired temperatures.  Figure 5-9 is a schematic of a rotary kiln
with a mechanical auger feeder system.
     VolatHes and combustion gases from the primary chamber pass to the
secondary chamber where combustion is completed by the addition of air
together with the high temperatures maintained by a secondary burner.  Due
to the turbulent motion of the waste in the lower primary chamber,
particle entrainment in the flue gases is higher for rotary kiln
incinerators than for controlled-air or excess air incinerators.
                                   5-20

-------
                                                                STACK
Figure 5-9.  Drawing for rotary kiln Incinerator.
                                                  15
                        5-21

-------
 5.3  AIR POLLUTION CONTROL SYSTEMS
      Add-on pollution control  systems may  be  required  to meet the  air
 pollution limits  of some States.   Pollutants  of  concern  include
 particulate matter, metals, toxic organics, acid gases and  radionuclides.
      The pollution control  systems which might be used to control  hospital
 waste incinerator emissions include wet scrubbers,,  dry scrubbers,  and
 fabric filters.   These systems are described  briefly in  the following
 subsections.
 5.3.1  Wet Scrubbers
      Venturi  and  packed-bed scrubbers are  the most  common types of wet
 scrubber systems  used on hospital  incinerators.   Venturi  scrubbers are
 used  primarily for particulate matter control and packed-bed scrubbers  are
 used  primarily for acid  gas control.   However, both types of systems
 achieve some  degree of control  for both particulate matter  and acid gases.
      Most of  the  scrubber systems  recently installed or  currently  being
 installed on  hospital  incinerators consist of a  variable  throat venturi
 followed  by a packed-bed scrubber  and mist elimineitor.   These systems
 operate at a  constant pressure drop in the range of 20 to 40 inches of
 water column  (in.  w.c.),  depending on performance or permit condition
 requirements.  The variable throat venturi design accommodates varying  gas
 flow  rates while maintaining a constant pressure drop  by  changing  the
 venturi throat area.   A  pH  controller system, including a pH electrode  and
 transmitter,  adjusts  the flow  of a caustic solution (sodium hydroxide or
 sodium  carbonate)  to  the scrubber  system to accommodate varying acid gas
 concentrations and  gas flow rates.  Typical performance parameters for
 this  system are summarized  in  Table 5-2.
      Operation and  maintenance  problems associated with wet scrubbers
 include fan imbalance, nozzle wear or plugging,  pump seal leaks, pH
 controller drifts,  pH electrode fouling, and wet-dry interface buildup.
 Specific problems associated with  HWI's stem from batch loading and
 nonsteady state combustion  conditions  that result in varying gas flow
 rates, gas temperatures, particle  size distribution, particle
concentration, and  acid gas concentrations.
     5.3.1.1  Venturi Scrubber  Operating Principles.  A venturi  scrubber
consists of a liquid sprayed upstream from a vessel containing  converging
                                   5-22

-------
              TABLE 5-2.  WET SCRUBBER PERFORMANCE PARAMETERS
                        Hospital Waste  Incinerators
Parameter
Typical range
Units of measure
Venturi scrubbers

  Pressure drop              20 to 50
  Liquid feed rate           >35
  Liquid to gas rate         7 to 10
  Liquid feed pressure       20 to .60
  Turbidity                  1 to 10
  Gas flow rate              >5,000

Packed-bed scrubbers

  Pressure drop              1-3
  Liquid feed rate           >5
  Liquid feed pH             5.5 to 10
  Liquid to gas rate         1-6
  Liquid feed pressure       20 to 60
  Gas flow rate              >5,000
                    in. w.c.
                    gal/min
                    gal/Macf
                    psi
                    Percent suspended solids
                    acfm
                    in. w.c.
                    gal/min
                    PH
                    gal/Macf
                    psi
                    acfm
                                   5-23

-------
 and diverging cross sectional areas as illustrated in Figure 5-10.   The
 portion of the venturi that has the smallest cross sectional area and
 consequently the maximum gas velocity is commonly referred  to as the
 throat.  The throat can be circular as shown in Figure 5-10 or rectangular
 as shown in Figure 5-11.  Liquid droplets serve as the particle collection
 media and can be created by two different methods.  The most common method
 is to allow the shearing action of the high gas velocity in the throat to
 atomize the liquid in the droplets.  The other method is to use spray
 nozzles to atomize the liquid by supplying high pressure liquid through
 small orifices.
      Impaction is the primary means for collection of particles in  venturi
 scrubbers.  To attain high collection efficiency, venturi scrubbers need
 to achieve gas velocities in the throat in the range of 10,000 to 40,000
 feet per minute.   As the gas stream approaches the venturi  throat,  the gas
 velocity and turbulence increases.   These high gas velocities atomize the
 water droplets and create the relative velocity differential  between the
 gas and the droplets to effect particle-droplet collision.   The          ;
 effectiveness of  a venturi  scrubber is related to the square of the
 particle diameter and to the difference in velocities of the liquor
 droplets and the  particles.
      The performance of a venturi  scrubber is  strongly affected by  the
 size distribution of the particulate matter.   For particles  greater than 1
 to  2 ym in diameter,  Impaction is  so effective that  penetration (emis-
 sions)  is  quite low.   However,  penetration of  smaller particles,  such as
 the  particles  in  the  0.1  to  0.5  urn  range  is very  high.   Unfortunately,
 hospital waste  incinerators  can  generate  substantial  quantities of  partic-
 ulate matter in this  submicron  range.   The small  particle size  distribu-
 tion  is  typical for fuel  combustion  sources and results  from  the  condensa-
 tion of  partially  combusted  organic  compounds  and  the  condensation  of
metallic vapors.
     Collection efficiency in a  venturi scrubber  system  increases as the
 static pressure drop  increases.  The  static pressure drop is  a  measure of
the total amount of energy used  in the  scrubber to accelerate the gas
stream,  to atomize the  liquor droplets, and to overcome  friction.   The
pressure drop across the venturi is a function of the gas velocity  and
                                   5-24

-------
                            Converging
                              section
                          - Throat
                            Diverging
                              section
Figure 5-10.  Venturi  configuration.
                                16
               5-25

-------
Liquid inlet
          Figure 5-11.  Spray venturi with  rectangular throat.
                                                               17
                                   5-26

-------
 liquid/gas ratio and in practice acts as a surrogate measure for gas
 velocity.     ,
      Other variables that are important to venturi  scrubber performance
 are the liquid surface tension and liquid turbidity.  If surface tension
 is too high, some small particles which impact on the water droplet will
 "bounce" off and not be captured.  High surface tension also has an
 adverse impact on droplet formation.  High liquid turbidity, or high
 suspended solids content, will cause erosion and abrasion of the venturi
 section and ultimately lead to reduced performance  of the system.
      Most venturi scrubbers are designed to operate at liquid-to-gas (L/G)
 ratios between 7 and 10 gallons per thousand actual  cubic feet
 (gal/Macf).  At L/G ratios less than 3 gal/Macf, there is an inadequate
 liquid supply to completely cover the venturi  throat.   At the other
 extreme, L/G ratios above 10 gal/Macf are seldom justified because they do
 not increase performance but do increase operating  costs.
      A list of the  major components of commercial scrubber systems is
 provided below.
      1.   Venturi  section;
      2.   Spray nozzles;
      3.   Liquor  treatment  equipment;
      4.   Gas  stream demister;
      5.   Liquor  recirculation  tanks,  pumps,  and  piping
      6.   Alkaline addition  equipment;
      7.   Fans, dampers,  and  bypass  stacks; and
      8.   Controllers for venturi  throat  area, caustic feed,  make  up water,
and emergency water quench  for temperature excursions.
      5.3.1.2  Venturi Scrubber Operating Problems. A problem can  be caused
by the adjustable throat being opened  too far, and the result  is  a
reduction in pressure drop.  Reduced pressure drop levels  can  also be
caused by a loss or reduction  in the scrubber liquid supply.   The  liquid
flow rate will drop when there is pluggage in the nozzles, pipes, or
flowmeters, causing the pressure drop to decrease and the gas  flow rate to
increase.  Pump failure, or cavitation of a pump due to a  low  liquid level
in the recirculation tank, can also be responsible for a  loss  or reduction
in the liquid supply.  These problems are identifiable from routine record
keeping and inspection, and can be readily resolved  by maintenance.

                                   5-27 '

-------
      The venturl throat can be damaged  by erosion or  abrasion caused by a
 high level  of suspended solids in  the recirculated scrubbing liquid.
 Reducing the suspended solids  by increasing  the blowdown  (water makeup)
 rate in the system will help solve erosion problems.
      Another common problem with venturi  scrubbers is a solids buildup at
 the  wet-dry interface.  The wet-dry interface  is the  transition region
 where the gas stream changes from  an unsaturated to a saturated
 condition.   As the hot gas  stream  comes  into contact  with jthe scrubbing
 liquid and  becomes cooled and  saturated,  there is a tendency for the
 suspended particulate to accumulate on  the walls.  Scrubber design can
 help reduce this solids buildup, but gradual accumulation of deposits will
 occur.   Routine maintenance to remove this buildup is typically the only
 solution.   Sometimes a reduction in the  suspended solids content will
 reduce the  rate of the buildup, but routine  maintenance will still be
 required  at less frequent intervals.
      5.3.1.3  Packed-Bed Scrubber  Operating  Principles.  A packed-bed
 scrubber  generally is  used  for add  gas removal.   The large liquor surface/
 area created as the liquor  gradually passes  over the  packing material
 favors  gas  diffusion and absorption.  Packed-bed scrubbers are not
 effective as stand-alone scrubbers  for collection of  fine particulate
 matter  (less than 2.5  urn) since the  gas velocity through the bed(s) is
 relatively  low.   However, packed beds are  effective for the removal of
 particle-laden  droplets  or  charged  particles when used as a downstream
 collector behind a venturi  or  electrostatically-enhanced wet scrubber.
      Packed  beds can be  either vertical  or horizontal.  Figure 5-12
 illustrates  a vertically oriented  scrubber.  Regardless of the orientation
 of the bed,  the  liquor  is sprayed from the top and: flows downward through
 the bed.  Proper liquor distribution is  important  for efficient removal of
gases.
     Absorption  is  the primary means of  collection of add gases in
packed-bed scrubbers.  The effectiveness of absorption in packed beds is
related to the uniformity of the gas velocity distribution,  the surface
area of the packing material, the amount and uniform distribution of
scrubber liquid,  and the pH and turbidity of the  scrubbing liquid.
                                   5-28

-------
                               CLEAN GAS
                                  OUT
SCRUBBING UQUIO
      IN
           PACKING
  DIRTY  GAS
      IN
                                                      CLEAR LIQUID WASH
                                                  QEMISTER
HOLD DOWN PLATE
                                                  INTERMEDIATE PACKING
                                                  SUPPORT PLATES AND / OR
                                                  UOUlO REOISTRIBUTOR
                                                  PACKING SUPPORT PLATE
        Figure 5-12.  Vertically oriented packed-bed scrubber.
                                 5-29

-------
     Gas  absorption  is effected  by  the  extensive  liquid  surface contacted
 by the gas  stream  as the liquid  flows downward over  the  packing
 material.   A variety of available packing materials  offer a  large exposed
 surface area to  facilitate  contact  with and absorption of acid gases.  The
 packing materials  range in  size  from 0.5 to 3 in.  and are randomly
 oriented  in the  bed.
     Typically,  sodium hydroxide (NaOH) or occasionally  sodium carbonate
 (Na2C03)  is used with water to neutralize the absorbed acid  gases in a
 packed-bed  scrubber.   These two  soluble alkali materials are preferred
 because they minimize the possibility of scale formation in  the nozzles,
 pump, and piping.  For the  typical  system using NaOH as  the  neutralizing
 agent, the  HC1 and S02 collected in the scrubber  react with  NaOH to
 produce sodium chloride (NaCl) and  sodium sulfite  (Na2S03) in an aqueous
 solution.
     One of the  major problems with these scrubbers  is the accumulation of
 solids at the entry  to the  bed and  within the bed.   The  dissolved and sus-
 pended solids levels  in the liquor  must be monitored carefully to maintain'
 performance.
     5.3.1.4  Packed  Bed  Operating  Problems.  One  common problem is
 partial or  complete pluggage of  the bed due to deposition of the collected
 solids and/or precipitation of solids formed by reaction of  the
 neutralizing agent with acid gases.  Another problem is  settling of the
 packing material which leaves an opening at the top  of the packed
 section.  Both of these situations  reduce the performance of the scrubber
 by disturbing the uniform flow of the liquid and gas streams.
     Another common problem occurs  when the pH of  the scrubbing liquid
 routinely falls outside the normal   range of 5.5 to 10.   Corrosion and
 erosion of the packed  bed vessel, ducting, and piping can occur when the
 scrubber liquid  is not  in the range for which the  system was designed.
 5.3.2  Dry Scrubbers
     Dry scrubbers utilize  absorption and adsorption for the removal of
 sulfur dioxide, hydrogen chloride,   hydrogen fluoride, and other acid
gases.   Some adsorption of  vapor state organic compounds  and metallic
compounds  also occurs  in  some dry scrubber applications.  This relatively
new control  technology  is presently in use on pulverized  coal-fired
                                   5-30

-------
  boilers and municipal waste incinerators.  Dry scrubbers are anticipated
  to be used on some large hospital waste incinerators in the near future.
  Because there are no current dry scrubber applications on hospital  waste
  incinerators, information available on municipal  waste incinerators will
  be transferred and presented in this report.  Much of the presently
  available information applicable to municipal  waste incinerators has been
  drawn from European installations operating for the last 3 to 5 years and
  U.S. installations operating for the last 1 to 2 years.  Changes and
  refinements in municipal  and hospital waste incinerator dry scrubbers
  should be anticipated as  more experience with  these systems is gained.
       5.3.2.1  Components  and Operating Principles of Dry Scrubber
  Systems.  There is considerable diversity in the variety of processes
  which are collectively termed dry scrubbing.  This is partially because
  the technology is relatively new and Is still  evolving.  The diversity
  also exists because of the differing control requirements.   For purposes  •
  of this field inspection  manual, the various dry  scrubbing  techniques have
  been grouped into three major categories:   (1)  spray dryer  absorbers,
  (2) dry Injection adsorption systems, and  (3)  combination spray dryer and
  dry Injection systems.  Specific types of  dry  scrubbing processes within
  each group are listed below.   Alternative  terms for these categories used
  in some publications  are  shown in parentheses.
       1.   Spray/dryer  absorption (semiwet)
           •  Rotary atomizer spray dryer systems
           •  Air atomizing  nozzle spray dryer systems
       2.   Dry injection  adsorption (dry)
           •  Dry injection  without recycle
           •  Dry injection  with recycle (sometimes  termed  circulating fluid
              bed  adsorption)
       3.   Combination  spray dryer and  dry injection (semiwet/dry)
       Simplified  block diagrams of the three  major  types of  dry scrubbing
  systems  are  presented in Figures 5-13,  5-14, and 5-15.  The main  differ-
  ences between  the  various  systems are the  physical  form of  the alkaline
  reagent  and  the  design of  the  vessel  used  for contacting  the acid gas
  laden stream.  The alkaline feed requirements are  much  higher for the dry
-  injection  adsorption than  the  other two  categories.  Conversely,  the spray
                                     5-31

-------
                                           Puwp
Figure 5-13.  Components of a spray dryer absorber system
                    (semiwet process).
                           5-32

-------
Figure 5-14.  Components of a dry injection absorption system
                        (dry process).
                             5-33

-------
Figure 5-15.  Components of a combination spray dryer and dry injection
                absorption system (semiwet/dry process).
                                  5-34

-------
 dryer absorption and combination systems are much more complicated.  It
 should be noted that the participate control devices shown on the right
 hand side of the figures are generally fabric filters or electrostatic
 precipitatprs.  It also is possible that one and two stage wet scrubbing
 systems will be used in certain cases.
      The pollutant removal efficiencies for all three categories of dry
 scrubbing systems appear to be very high.  In most cases, outlet gas
 stream continuous monitors provide a direct indication of the system
 performance.
      5.3.2.1.1  Spray dryer absorbers.  In this type of dry scrubbing
 system,  the alkaline reagent is prepared as a slurry containing 5 to
 20 percent by weight solids.20"22  This slurry is atomized in a large
 absorber vessel  having a residence time of 6 to 20 seconds.23»2lf
      There are two main ways of atomization:   (1) rotary atomizers and
 (2) air  atomizing nozzles.   There is generally only one rotary atomizer.
 However,  a few applications have as many as three rotary atomizers.
      The  shape of the scrubber vessel  must be different for the two  types
 of atomizers to  take into  account the  differences in the slurry spray
 pattern and  the  time required for droplet evaporation.   The length-to-
 diameter  ratio for rotary  atomizers is  much smaller than that for absorber
 vessels using air  atomizing nozzles.
      It is important that all  of the slurry droplets evaporate to dryness
 prior to  approaching the absorber vessel  side walls  and  prior to  exiting
 the absorber with the gas streaa.   Accumulations  of  material  on the  side
 walls or  at  the bottom of the  absorber would  necessitate  an outage since
 these deposits would further  impede drying.   Proper  drying  of the slurry
 is  achieved  by the generation of  small  slurry droplets, by  proper flue  gas
 contact,  and  by use of moderately hot flue  gases.
     Drying  that is too rapid can reduce  pollutant collection efficiency
 since the primary removal mechanism is absorption into the  droplets.
 There must be sufficient contact time for the absorption.   For this
 reason, spray dryer absorbers are operated with exit gas temperatures 90°
 to  180°F above the saturation temperature.25'27  The absorber  exit gas
 tengjeratures are monitored to ensure proper approach-to-saturation which
 is simply the difference between the wet bulb and dry bulb temperature
monitors  at the outlet of the absorber vessel.

                                   5-35

-------
      In rotary  atomizers, a thin film of  slurry is fed to the top of the
 atomizer disk as  it rotates' at speeds of  10,000 to 17,000 revolutions per
 minute.  These  atomizers generate very small  slurry droplets having
 diameters  in the  range of 100 microns.  The spray pattern is inherently
 broad due  to the  geometry of the disk.
      High  pressure air is used to provide the physical energy required for
 droplet formation in nozzle type atomizers.   The typical air pressures are
 70 to 90 psig.  Slurry droplets in the range  of 70 to 200 microns are
 generated.  This  type of atomizer generally can operate over wider
 variations of the gas flow rate than can  be used in a rotary atomizer.
 However, the nozzle atomizer does not have the slurry feed turndown
 capability of the rotary atomizer.  For these reasons, different
 approaches must be taken when operating at varying system loads.
      The alkaline material generally purchased for use in a spray dryer
 absorber is pebble lime.  This material must  be slaked in order to prepare
 a reactive slurry for absorption of acid  gases.  Slaking is the addition
 of water to convert calcium oxide to calcium  hydroxide.  Proper slaking
 conditions are important to ensure that the resulting calcium hydroxide
 slurry has the proper particle size distribution and that no coating of
 the particles has occurred due to the precipitation of contaminants in the
 slaking water.
     Some of the  important operating parameters of the lime slaker are the
 quality of the slaking water, the feed rate of lime, and the slurry exit
 temperature.  However, it is difficult to relate present operating
 conditions or shifts from baseline operating  conditions to possible
 changes in the absorption characteristics of  the dry scrubber system.  A
 variety of subtle changes in the slaker can affect the reactivity of the
 liquor produced.
     One of the problems which has been reported for spray dryer absorber
type systems is the pluggage of the slurry feed line to the atomizer.
Scaling of the line can be severe due to the  very high pH of this
 liquor.  The flow rate of the liquor to the atomizer is usually monitored
by a magnetic flow meter.  However,  this instrument also is vulnerable to
scaling since the flow sensing elements are on the inside surface of the
pipe.  To minimize the pluggage problems, the lines must be well sloped
                                   5-36

-------
 and include the capability for flushing of the lines immediately after
 outages.  Also, there should not be abrupt line changes, sharp bends, or
 adjacent high temperature equipment.  During the inspection, it is
 essentially impossible to identify emerging slurry line problems.
      Recycle of the solids collected in the absorber vessel is important
 in most systems.  It increases the solids content of the slurry feed to
 the atomizer and thereby improves the drying of the droplets.  Recycle
 also maximizes reagent utilization.  The rate of solids recycle is
 monitored on a continuous basis.  The rest of the spent absorbent
 typically 1s sent to a landfill.
   .   5.3.2.1.2  Dry injection adsorption systems.  This type of dry
 scrubber uses finely divided calcium hydroxide for the adsorption of acid
 gases.   The reagent feed has particle sizes which are 90 percent by weight
 through 325 mesh screens.  8   This is approximately the consistency of
 talcum  powder.   This size  is important to ensure that there is*adequate
 calcium hydroxide surface  area for high efficiency pollutant removal.
      Proper particle sizes are maintained by transporting the lime to the
 dry  scrubber system by means of a positive pressure pneumatic conveyor.
 This pneumatic conveyor  provides the initial  fluldlzation necessary to
 break up  any clumps of reagent which have formed  during storage.   The air
 flow rate  in the  pneumatic conveyor  is  kept  at  a  constant level  regardless
 of system  load in order  to ensure  proper  particle sizes.
     Fluidlzation 1s completed  when  the calcium hydroxide is  injected
 countercurrently  Into the gas  stream.  A  venturi  section  is used  for  the
 contactor due to the turbulent  action available for mixing  the gas  stream
 and  reagent.  The gas stream containing the entrained calcium hydroxide
 particles and fly ash is then vented to a fabric  filter.
     Adsorption of  acid gases and organic compounds  (if present)  occurs
 primarily while the gas stream passes through the dust cake (composed  of
 calcium hydroxide and fly ash) on the surface of  the filter bags.
 Pollutant removal efficiency is dependent on the  reagent particle size
 range, on the adequacy of dust cake formation, and on the quantity of
reagent injected.
     The calcium hydroxide feed rate for dry injection systems is three to
four times the stoichiometric quantities needed.29'30  This is much higher
                                   5-37

-------
 than the spray dryer absorber type systems and "it makes this approach
 unattractive for very large systems.
      In one version of the dry injection system, solids are recycled from
 the participate control device back into the flue gas contactor (sometimes
 termed reactor).  The primary purpose of the recycle stream is to increase
 reagent utilization and thereby reduce overall calcium hydroxide costs.
      5.3.2.1.3  Combination spray dryer and dry injection systems.  A
 flowchart for this system is provided in Figure 5-15.  The acid gas laden
 flue gas is first treated in an upflow type spray dryer absorber.  A
 series of calcium hydroxide sprays near the bottom of the absorber vessel
 are used for droplet generation.
      After the upflow chamber, the partially treated flue gas then passes
 through a venturi contactor section where it is exposed to a calcium
 silicate and lime suspension.  The purpose of the second reagent material
 is to improve the dust cake characteristics in the downstream fabric
 filter and to optimize acid gas removal in this dust cake.  The calcium
 silicate reportedly improves dust cake porosity and serves as an adsorbent/
 for the acid gases.
      Solids collected in the fabric filter may be recycled to the venturi
 contactor.  This improves reagent utilization and facilitates additional
 pollutant removal.
      5.3.2.2  General Comments.  Corrosion can present major problems for
 all types of dry scrubbers used on applications with high hydrogen
•chloride concentrations such as hospital  waste incinerators.  The calcium
 chloride reaction product formed in the dry scrubbers and any unreacted
 hydrogen chloride are both very corrosive and cause damage in any areas  of
 the absorber vessel or particulate control  device where cooling and water
 vapor condensation can occur.  Two common reasons for low localized gas
 temperatures include air infiltration and improper insulation around
 support beams.   Due to the potential  problems related to corrosion, the
 inspections should include checks for air infiltration and a visible
 evaluation of common corrosion sites.
                                    5-38

-------
 5.3.3  Fabric Filters
      Fabric filters are used on a limited number of  hospital  incinerators
 for control of particulate matter emissions.   They have some  advantages
 over wet scrubbers  in that they are highly efficient at removing fine
 particles if they are properly operated and maintained.  However, their
 performance can deteriorate rapidly in situations where poor  O&M result in
 bag blinding,  bag corrosion, or bag erosion.
      Generally, fabric filters are classified  by the type of  cleaning
 mechanism that is used to  remove the dust from the bags.   The three types
 of units are mechanical  shakers, reverse air,  and pulse jet.   To date,  the
 only hospital  incinerators that have been identified as having fabric
 filters  use pulse jet units.   The paragraphs below briefly describe the
 design and operating  characteristics of pulse  jet filters and identify  key
 design parameters.
      A schematic of a pulse  jet fabric filter  is  shown  in Figure 5-16.
 Bags 1n  the fabric filter  compartment are supported  internally by rings or
 cages.   Bags are held  firmly  in place at the top  by  clasps and have an
 enclosed bottom  (usually a metal  cap).   Dust-laden gas  is filtered through
 the  bag,  depositing dust on  the outside surface of the  bag (an exterior
 filtration system).   The fabric filter is  divided into  a  "clean"  side and
 "dirty"  side by the tube sheet  which  is mounted near the  top  of the
 unit.  The dust-laden gas  stream enters below this tube sheet  and the
 filtered  gas collects  in a plenum above the tube  sheet.   There are holes
 in the tube sheet for each of the  bags.  The bags are normally arranged in
 rows.  The bags and  cages hang  from the tube sheet.  Most  pulse jet
 filters use bag tubes that are  4  to 6  in.  in diameter.  Typically the bags
 are  10 to  12 ft long, but they can be  as long as 25 ft.
     There are two major types of pulse  jet fabric filters:   (1)  top
 access, and (2) side access.  Figure 5-17  illustrates the  top  access
design which includes a number of  large hatches across the top  of the
fabric filter for bag replacement and maintenance.  Another major type  has
one  large hatch on the side for access  to the bags.   The side  access  units
often have a single  small hatch on the top of the shell for routine
 inspection of the fabric filter.
                                   5-39

-------
                         TUM SHEET
 CLEAN AIM PLENUM

 PLENUM ACCESS'
TO CLEAN AIH OUTLET
  AND IEXHAUSTEM
OtltTY AIM INLET * OimJSEft
 Figure 5-16.  Schematic of pulse jet baghouse.
                                                       29
                           5-40

-------
  TOP ACCESS HATCHES
GAS OUTLET
  FAN
                                                           IAPHRAGM VALVES
                                                          AIR MANIFOLD
                                                          GAS INLET
                                                      OPPERS
        Figure 5-17.  Top  access pulse jet fabric  filter.
                               5-41

-------
     Like most small units, the pulse jet collector depicted in
 Figure 5-17 1s not divided into compartments.  These are not needed on
 small units that operate intermittently since bags are cleaned row-by-row
 as the unit continues to operate.  A few of the large units are divided
 Into separate compartments so that it is possible to perform maintenance
 work on part of the unit while the other part continues to operate.
     Pulse jet cleaning is used for cleaning bags in an exterior
 filtration system.  The dust cake is removed from the bag by a blast of
 compressed air injected into the top of the bag tube.  The blast of
 compressed air stops the normal flow of air through the filter.  The air
 blast develops into a standing or shock wave that causes the bag to flex
 or expand as the shock wave travels down the bag tube.  As the bag flexes,
 the cake fractures and deposited particles are discharged from the bag.
 The shock wave travels down and back up the tube in approximately
 0.5 seconds.  The compressed air is generated by an air compressor and
 stored temporarily in the compressed air manifold.  When the pilot valve
 (a standard solenoid valve) 1s opened by the controller, the diaphragm
 valve suddenly opens to let compressed air Into the delivery tube which
 serves a row of bags.  There are holes in the delivery tube above each bag
 for injection of the compressed air into the top of each bag.  The
 cleaning system controller can either operate on the basis of a
 differential pressure sensor as shown in Figure 5-18, or it can simply
 operate as a timer.  In either case, bags are usually cleaned from once
 every 5 minutes to once every hour.  Cleaning is usually done by starting
with the first row of bags and proceeding through the remaining rows in
 the order that they are mounted.
     The blast of compressed air must be strong enough for the shock wave
 to travel the length of the bag and shatter or crack the dust cake.  Pulse
 jet units use air supplies from a common header which feeds into a nozzle
 located above each bag.  In most fabric filter designs, a venturi sealed
at the top of each bag is used to create a large enough pulse to travel
down and up the bag.  The pressures involved are commonly between 60 and
 100 psig.  The importance of the venturi is being questioned by some pulse
jet fabric filter vendors.  Some fabric filters operate with only the
compressed air manifold above each bag.
                                   5-42

-------
      •LOW TUB
                                  LOT VALVE ENCLOSURE





                                          DIAPHRAGM VALVE
                         «— AIR MANIFOLD  —
                                                        PULSE TIMER
                                                  J
                                   DIFFERENTIAL PRESSURE-SWITCH
                                    IRTY GAS .INLET
                                   OTARY  VALVE
Figure 5-18.   Cross sectional sketch of pulse jet fabric filter.
                               5-43

-------
      The presence of a row of  diaphragm valves  along  the  top of  the  fabric
 filter indicates  that the  fabric filter is  a  pulse  jet unit.  These  valves
 control the compressed airflow into each row  of bags  which  is used to
 routinely clean the  dust from  the bags.   On a few units,  the diaphragm
 valves cannot  be  seen since they are in an  enclosed compartment  on the top
 of the unit.   In  these cases,  the pulse jet fabric:  filter can be
 recognized by  the distinctive,  regularly occurring  sound  of the  operating
 diaphragm valves.
      The key design  and operating parameters  for a  pulse  jet filter  are
 the air-to-cloth  ratio (or the  filtration velocity),  the  bag material,
 operating temperature,  and operating pressure drop.
      The air-to-cloth  ratio is  actually a measure of  the  superficial gas
 velocity through  the  filter medium.   It  is  a  ratio  of the flow rate  of gas
 through the fabric filter  (at actual  conditions) to the area of  the  bags
 and is usually measured in units  of  acfm/ft2.   No operating data were
 obtained for hospital  incinerators,  but  generally,  the air-to-cloth  ratio
 on  waste combustion units  is in  the  range of  5  to 10  acfm/ft2 of bag      >
      31
 area.
      Pulse  jet units do not  necessarily  operate  at the design average gas-
 to-cloth ratio.  When  incinerator operating rates are low, the prevailing
 average gas-to-cloth ratio could be  substantially below the design
 value.   Conversely, the average gas-to-cloth  ratio could be well above the
 design  value if some of the bags are  inadequately cleaned or if  sticky or
wet material blocks part of the fabric surface.  Very high gas-to-cloth
 ratio conditions can lead to high gas flow resistance which, in  turn, can
result  in both seepage of dust through the bags and fugitive emissions
from the  incinerator or upstream dry  scrubber.
     Bag material  generally is based on prior experience of the  vendor.
Key factors that generally are considered are cleaning method, abrasive-
ness of the particulate matter and abrasion resistance of the material,
expected operating temperature, potential chemical  degradation problems,
and cost.  To date, no information has been obtained on types of material
typically used for hospital incinerator applications.
     The operating temperature of the fabric filter is of critical
importance.  Since the exhaust gas from hospital incinerators can contain
                                   5-44

-------
 HC1, the unit should be operated at sufficiently high temperatures to
 assure that no surfaces drop below the acid dewpoint.  Otherwise,  conden-
 sation of HC1 will  result in corrosion of the housing or bags.   The
 boiling point of HC1 (aqueous hydrochloric acid) is 110°C (230°F); gas
 temperatures should be maintained at 150°C (300°F)  to ensure  that  no
 surfaces are cooled below the dewpoint.   Above a maximum temperature  that
 is  dependent on filter type,  bags will  degrade or in some cases  fail
 completely.   Gas temperatures should be kept safely below the allowed
 maximum.
      Pressure drop  in fabric  filters generally is maintained  within a
 narrow range.   (For pulse jet filters the upper end of the range typically
 is  8 to 10  in.  w.c.).   Pressure  drops below the minimum indicate that
 either:   (1)  leaks  have developed,  or (2)  excessive cleaning  is  removing
 the base cake  from  the bags.   Either phenomena results in reduced
 performance.   Pressure drops  greater than the  maximum indicate that either
 (1)  bags  are  "blinding,"  or (b)  excessive cake is building on the  bags
 because  of insufficient  cleaning.   The primary result of  excessive       j
 pressure  drop  is reduced  flow through the  system and  positive pressure at
 the  incinerator.  Over time, operating at  high  pressure drops also lead to
 bag erosion and degradation.
 5.3.4  Electrostatic Precipitators
     A discussion on electrostatic precipitators was  not  included  in  this
 inspection manual because, currently, they are  not used to control
emissions from hospital waste incinerators.  In general,  ESP's are used to
control emissions from larger sources such as municipal waste
incinerators.  Information on the application of ESP's to municipal
incinerators may be found in Reference 21.
5.4  REFERENCES FOR CHAPTER 5
 1.   Doucet, L. C.  Controlled Air Incineration:  Design, Procurement and
     Operational Considerations.   Prepared for the American Society of
     Hospital Engineering, Technical Document No. 55872.  January 1986.
 2.   Ontario Ministry of the Environment.  Incinerator Design and
     Operating Criteria, Volume II-Biomedical Waste Incineration.
     October 1986.
 3.   Reference 1, p. 1.
                                   5-45

-------
 4.  Ecolaire Combustion Products, Inc., Technical Article:  "Principles
     of Controlled Air  Incineration."

 5.  Reference  1.

 6.  McRee, R.   "Operation and Maintenance of Controlled Air
     Incinerators."

 7.  Air Pollution Control District of Los Angeles County.  Air Pollution
     Engineering Manual, AP-40.  U.S. EPA.  May  1973.

 8.  Ecolaire Combustion Products, Inc., Technical Data Sheet for E Series
     Incinerator.

 9.  Consumat Systems,  Inc.  Technical Data Sheet for Consumat Waste
     Handling System.

10.  Ashworth R.  Batch Incinerators—Count Them In; Thermal Paper
     Prepared for the National Symposium of Infectious Waste.
     Washington, D.C.  May 1988.

11.  Ecolaire Combustion Products, Inc.  Technical Sheet for the ECP
     System.

12.  Reference 7, p. 490.                                 .               >

13.  Reference 7, p. 439.

14.  Hospital Waste Combustion Study:  Data Gathering Phase.  Final
     Report.  U. S. Environmental Protection Agency, Office of Air Quality
     Planning and Standards, Research Triangle Park, North Carolina.  EPA
     450/3-88-017.  December 1988.

15.  Technical Data Form:  Consertherm Systems,  Industronics, Inc.

16.  Joseph, J. 6. and D. S. Beachler.  APTI Course SI:412C, Wet Scrubber
     Plan Review - Self-Instructional Guidebook.  U. S. Environmental
     Protection Agency.  EPA 450/2-82-020.  March 1984.

17.  Ibid.   p. 3-4.

18.  Donnelly, J. R., Quach, M. T., and Moller, J. T.  "Design Considera-
     tions  for Resource Recovery Spray Dryer Absorption Systems."
     Presented at the 79th Annual Meeting of the Air Pollution Control
     Association, Minneapolis, Minnesota.  June 1986.

19.  Ferguson, W. G., Jr., Borio, D.  C., and Bump, D. L»  "Equipment
     Design Considerations for the Control of Emissions From Waste-to-
     Energy Facilities."  Presented at the 79th Annual Meeting of the Air
     Pollution Control Association, Minneapolis, iMinnesota.  June 1986.
                                   5-46

-------
 20.   Sedman,  C. B.,  and  Brna, T. G.   "Municipal Waste  Combustion  Study
      Flue  Gas Cleaning Technology.   U.  S.  Environmental  Protection
      Agency.   Publication  No. 530-SW-87-021d.  June  1987.

 21.   Reference 19.               __

 22.   Reference 20.

 23.   Reference 19.

 24.   Moller,  J. T.,  and  Christiansen, 0. B.  "Dry Scrubbing of MSW
      Incinerator Flue Gas  by Spray Dryer Absorption:   New Developments in
      Europe."  Presented at the 78th Annual Meeting of the Air Pollution
      Control  Association,  Detroit, Michigan.  June 1985.

 25,   Foster,  J. T.,  Hochhauser, M. L.,  Petti, V. J., Sandell, M.  A., and
      Porter,  T. J.   "Design and Startup of a Dry Scrubbing System for
      Solid Particulate and Acid Gas Control on a Municipal Refuse-Fired
      Incinerator."   Presented at the A1r Pollution Control Association
      Specialty Conference on Thermal Treatment of Municipal, Industrial,
      and Hospital  Wastes.  Pittsburgh,  Pennsylvania.   November 4-6, 1987.

 26.   Ibid.

 27.   Reference 25.

 28.  Reference 26.

 29.  PEI Associates,  Inc.  Operation and Maintenance Manual for Fabric
     Filters.   U.  S.  Environmental  Protection Agency, Air and Energy
     Engineering Research Laboratory, Research Triangle Park, North
     Carolina. June  1986.   EPA 625/1-86-020.  p.  2-14.

30.  Reference 20,  p. 2-17.
                                   5-47

-------

-------
        6.0  BASELINE INSPECTION PROCEDURES FOR HOSPITAL INCINERATORS

      The primary objective of control agency insoections is to minimize
 air pollution through promoting adherence to promulgated emission
 regulations and permit stipulations.  The inspection provides data for
 determining the compliance status, helps identify sources of violation,
 and provides information indicating the underlying causes of excess
 emissions.  .The latter can be used in detailed negotiations with the
 operators or in support of enforcement actions.  The inspection also
 provides a stimulus'to the regulated industry by demonstrating the control
 agency's determination to ensure continuous compliance.  The baseline
 inspection technique has been developed by EPA's Stationary Source
 Compliance Division to aid both EPA Regional  Offices and other control
 agencies in conducting- effective and complete inspections of air pollution
 control  systems.      .                   •
      The primary  purpose of this chapter is to describe the baseline
 inspection technique and illustrate how it should be applied to hospital  ,
 incinerators and  control  devices.   In the part of the chapter devoted to
 the baseline technique,  a methodical  approach is presented  so that
 Inspectors  can  obtain  all  the relevant  data in an organized fashion.
 These procedures  are organized  into "levels of inspection"  (see
 Section  6.2)  reflecting  the fact that there are different degrees  of
 intensity  necessary  for  different  situations.   The  inspection procedures
 described  in  Sections  6.3  through  6.6 have  been developed to- ensure  that
 the  data obtained is as  accurate and  complete  as  possible.   These
                                                                    t
 procedures  should be used by  EPA field  personnel  unless  there are  •
 compelling  technical or  safety  factors  at  a specific  site-which  demand
 modified approaches.   In  such a  case, the  reasons  for  the deviation from
 the  standard procedures  should  be  briefly described  in  the  inspection
 report.
 6.1  BASELINE INSPECTION TECHNIQUE
     The baseline inspection technique can aid  both the  source  operators
 and the regulatory agency inspectors  in routine evaluations  of  incinerator
 and air pollution control equipment performance.  The procedure  is
designed to identify problems at an early stage, thereby  minimizing both
                                    6-1

-------
 periods of excess emissions and equipment deterioration.   By  utilizing
 similar evaluation approaches,  inspectors and operators  can communicate
 effectively regarding the nature of any problem detected..  This  should
 allow operating problems to be  quickly corrected and  reduce the  number of
 enforcement actions necessary.
 6.1.1  Basic Principles
      The fundamental  principle  underlying the baseline inspection
 technique is that incinerator and control device performance  be  evaluated
 primarily by comparison of present conditions with  specific baseline
 data.  In other words,  each separate incinerator system  should be
 approached initially  with the assumption that its operating character-
 istics  and performance  levels will  be  unique.  It is  necessary to  take
 this  position since there are a myriad of process variables and  control
 device  design factors which can singly or collectively influence operation
 and performance levels.   It is  often difficult to determine why  apparently
 similar units operate quite differently with  a limited amount of data.
 Thus, a prime requirement of  an. inspection method (i.e., the  baseline     ,
 technique)  in ensuring  the collection  of useful  data  is  the comparison of
 conditions  against  a  site-specffic  data base.  Each variable which has
 shifted  significantly is  considered  a  "symptom"  of possible operation
 problems.
      While  the  baseline  technique depends mainly  on the machine-specific
 data  and  shifts  in  performance  levels  over time,  it should not be  implied
 that  industry "norms" are  irrelevant.   There  are  cases in which deviations
 from  certain  typical  industry operating  conditions can be an  indication of
 operation and maintenance  problems.  However,  these data are considered
 secondary to  the  site-specific  data.   The industry data are often
 difficult to  compile, and  it  is sometimes difficult to establish the
 relevance of  the  data 'in enforcement proceedings.
     One of the major problems  in inspection  of an air pollution control
 system is that the  instruments  necessary  to monitor basic operating
conditions are often either nonexistent  or malfunctioning.   Data quality
problems are especially severe on those  units which are subject to
frequent excess emission incidents and are thereby of most  interest to
control  agencies.  The design deficiencies or  improper maintenance
                                    6-2

-------
 practices which have reduced the effectiveness  of  the  incinerator  or
 control  device usually have had a severe  disabling effect  on  whatever
 instrumentation is  on the control device.   For  these reasons,  it is rarely
 wise to  accept the  data from onsite gauges  at face value.   The  baseline
 technique includes  some routine checks  of these onsite  gauges.  When there
 is  a question  concerning the completeness or adequacy of the  available
 data,  the inspector must obtain the data  by means  of portable  instru-
 ments.   Such  instruments can either be  used by  plant operators  in  the
 presence of the inspector or can be used  by the inspector  directly.
      Performance,evaluations should be  done by  examination of  a number of
 different types of  information.   An emerging performance problem can often
 be  determined  better by evaluating the  set  of variables rather  than
 relying  on a shift  in a single  operating variable.  Also,  general
 observations concerning the  extent of corrosion, solids discharge  rate,-
 and  fan  physical conditions  can  be used to  support  preliminary  conclusions-
 reached  by examining the operating data.  Failure  characteristics  on
 materials removed from  the  collectors (e.g., bags,  discharge electrodes,  /
 nozzles)  can be used to determine the type  of corrective actions which
 have a reasonable chance of  being successful..   The'basel i.ne inspection
 technique incorporates  both  measurements and observations.
     It  is recognized  that  the control agency inspection represents an
 inconvenience  to source personnel  who must  accompany the inspector while
 he  is on  plant  property.  To minimize this  inconvenience,  EPA/State '
 inspectors should make  every reasonable effort  to  reduce the time
 necessary to complete the field  activities.   One means  to  accomplishing
 this goal is to organize  the data and observations  in a.coherent fashion
 during the inspection and to use  these data to  focus the field  work toward
 the specific problems,  if any, which appear to  exist.   If  the initial
 information clearly  suggests that  there are no  present or  emerging
 problems, the  inspection  should  be  terminated.   The baseline  inspection
 technique utilizes both counterflow and co-current  flow approaches in
order to organize and focus  inspection efforts.
                                    6-3

-------
 6.1.2  Counterflow Technique
      The counter-flow approach is appropriate when the EPA inspector is
 making a routine inspection of a facility for which baseline data is
 available.  Figure 6-1 illustrates the counterflow approach.  It starts
 with an observation of the stack opacity using Method 9 or equivalent
 procedures.   In addition to the changes in the average opacity since the
 baseline period, the inspector evaluates the pattern of opacity
 variability.   The inspector also checks for fugitive emissions from
                                                 *
 control  device equipment, incinerator chambers (e.g., charging door) and
 for emissions  from bypass stacks.   The next step is the evaluation of
 transmis'scmeter data (if applicable)  assuming that the monitor passes
 basic quality  assurance requirements.   The emphasis of the inspection is
 on  the operating conditions,  both  measured and observed.   The control
 device information qoupled with  the  stack  conditions can  be used to
 (1)  determine  if there  is a probaole  problem,  (2)  determine if the problem
 is  due primarily to control-device-related conditions,  and (3)  determine
 if  the problem is  due primarily  to  incinerator-related  factors.   If the   .,
 incineration process appears  to  be  important,  then the  inspection should
 continue with  an evaluation of any  relevant  portions of the incinerator.
 If  the problem is  simply  control device  related,  the time-consuming
 inspection of  process sources can  be either  abbreviated or eliminated.
 The counterflow  approach  should  only be  used when  the baseline  data is
 available and  the  basic  incineration process  is  well  documented  in the
 agency files.
 6.1.3  Co-Current  Technique
     The co-current  inspection starts with the preparation  of  a  flowchart
 of the incineration/control device system.   The  inspector  starts  with  the
waste  storage area  and follows the incineration  process in  a  co-current
 fashion.  The emphasis in  this type of inspection  is  on the waste  material
 and fuel characteristics,  charging rates and procedures, operating
 temperatures  and pressures, and other information  relevant  to  the
generation of air pollutants.  The co-current flow approach  is  illustrated
 in Figure 6-2.
     Due to the diversity of hospital incinerators and  control systems,  it
is important  that the inspection procedures incorporate some
                                    6-4

-------
   COUNTER FLOW APPROACH
PROCESS
GAS  STREAM
       CONTROL
        DEVICE
STACK
   Figure 6-1.  Counterflow inspection approach,
                   6-5

-------
CO-CURRENT APPROACH
 PROCESS
                 CONTROL
                 DEVICE
STACK
    Figure 6-2.  Co-current inspection approach.
                   6-6

-------
 flexibility.  The baseline inspection technique includes several  levels of
 intensity.  These can be preselected by agency personnel before the
 inspection, based on normal targeting criteria.  The level  also can be
 changed by the inspector during the field work based on preliminary data
 and observations.  This.flexibi1ity allows the agency to focus on actual
 emission problems instead of simply completing a prescribed number of
 inspections.  The flexibility built into the baseline technique.also must
 be exercised whenever,  in the- judgment of the inspector, 'the standard
 procedures would be unsafe or incorrect for a specific source.  It also
 should be noted that specific inspection activities can be  deleted.
 However, inspectors should not add  new.or different procedures without the
 express approval, of supervisory personnel.
 6.2  LEVELS OF INSPECTION
      Without any constraints  of Agency manpower and resources, it would be
•desirable to conduct detailed engineering oriented  inspections at all  .   "
 sources.   This is obviously impractical  due to the  large number of .air
 pollution sources inspected regularly  by EPA Regional  Off ices  and the
 State  and local  agencies.   Levels of  inspection have been incorporated
 into  the  inspection  program to  give control  agencies the opportunity to
 properly  allocate the limited  resources  available.   The  most complete and
 time consuming evaluations  are  done only when preliminary information
 indicates  that there  is or  will soon be  a significant  emission problem.
     The  levels of  inspection  are designated  as 1 through 4 with  the
 comprehensiveness of  the  evaluation increasing as the  number increases.
 The types  of activities normally associated  with each  level and the
 experience  levels necessary to  conduct the  different  levels vary
 substantially.
 6.2.1   Level 4  Inspections
     The  Level 4  inspection is  the most  comprehensive of  the four  levels.
 and is done explicitly to gather baseline information for use  later in
evaluating the performance of the specific  sources  at a  given  facility.
This type of inspection should be done jointly  by a  senior inspector  and
the EPA, State, or local agency personnel who will  be assigned
responsibility for the plant.
                                    6-7

-------
      The best  time  to  conduct a baseline  inspection  (Level  4  inspection)
 is during initial compliance  testing.   The  initial compliance test
 following the  installation  of the  incinerator  and/or control  equipment  is
 preferred because the  system  is new  and operating at conditions  designed
 and set  by the vendor.   Typically,  incinerators  and/or  air  pollution
 control  systems  (ARCS)  are  purchased with performance guarantees that
 require  emission tests  demonstrating a  prescribed performance level that
 ensures  compliance  with applicable emission regulations.  Data quality
 problems associated with instrumentation  (e.g.,  pressure  gauges, thermo-
 couples, and liquid flow meters) are minimized because  they are  new and
 the vendor has  ensured  that they are operating properly to  achieve
 guaranteed performance.   When baseline  inspections are  performed simul-
 taneously with  the  initial compliance tests, documentation  of the key
 operating levels is established with credibility and reliability for
 reference in followup Level 2 and 3  inspections.  Comparison  of  data
 collected on subsequent inspections  can be compared  to  the  baseline data
 and will  allow  the  inspector  to identify differences in operating
 conditions  that may be  causing  compliance problems.
     An  important part  of the Level  4 inspection is  the preparation of
 general  incinerator and  control device  flowcharts.   As  a  starting point,
 the inspector should request  the block  flow diagrams  or drawings for the
 incineration system.  Specific  flowcharts should be  prepared  so  that all
 of  the important information  concerning measurement  ports,  locations of
 bypass stacks,  and  locations  of all  monitoring devices are  clearly
 shown.   In addition to  the pollutants measured during the compliance test,
 the  performance of  the  hospital waste incineration system can be evaluated
 by  measuring stack effluent gases such as 02 and CO,  by observing stack
 gas opacity, by inspecting ash  quality, and by recording air  pollution
 control  device  and  incinerator  operating parameters  (e.g.,  temperature,
draft, and pressure drop).  Details  should be noted  on the  locations where
waste is generated,  the general composition (i.e., relative volumes of
 infectious waste/general refuse, liquid/solid waste,  plastic  content) of
the waste, the  charging frequency, the size of each  charge, and  the type
of waste charged in each charge.  Additionally, samples of  incinerator
ash, scrubber liquor,  fabric  filter  catch, and/or dry scrubber absorption
sorbent also should  be obtained for  analysis.

                                    6-8

-------
   6.2.2  Level 3 Inspections
        Level 3 inspections are conducted only on those units with apparent
   problems identified in a Level 2 inspection (discussed later).  Where
   necessary, portable gauges provided by, the inspector are used to measure
   certain operating parameters.  The most commonly used types of instruments
   are thermocouples and thermometers, combustion gas analyzers (02 and CO
   monitors), differential pressure gauges, pH meters-or paper, and pi tot.
   tubes.
        The Level  3 inspection includes an evaluation of stack effluent
   characteristics (02 and CO),  CEM data records, control device performance
   parameters, and the incinerator operating conditions (e.g., tempera-
   ture).   Infectious waste composition may be reviewed and samples of the
   scrubber liquor and incinerator ash may be obtained for later
   evaluation.' Failed fabric  filter.bags or electrostatic precipitator
   discharge  electrodes may be obtained to confirm that the plant has
   correctly  identified the general  type of problem(s).  In some cases, the
   Level 3 inspection will  include an  evaluation  of  the internal portions of
   an  air  pollution  control  device.   This is done simply by observing
   conditions  from an access hatch and under ,no circumstances  should  include
   entry by the  inspector  into the control  device.
   6.2.3   Level  2  Inspections
       Level  2  Inspections  are  the  most  frequent types of  inspections and
   are  important in  that the observations  made during  these  inspections
'   determine when  a  Level  3  inspection is  needed.
       The Level.2  inspection is  a  limited  walk  through  evaluation of the
   air  pollution source and/or the air pollution  control  equipment. Entry to
   the  facility  is necessary.  Therefore,  the administrative inspection
   procedures  specified in Chapter 2 of  this manual  should be  followed*  The
   inspection  can  be performed either  in  a co-current  or  countercurrent
   fashion depending on the anticipated  types of  problems..   In  either  case,
   the  inspection data gathered  is limited to that which  can be  provided  by
   onsite permanently mounted  instrumentation and observation of operating
   procedures.  An important aspect of this  type  of  inspection  is the
  evaluation of the accuracy of the data from this  instrumentation.   When
  control  devices  are not in service during the  plant  inspection, the
                                      6-9

-------
 Level  2  inspections can  include checks  on  their internal  condition.  This
 internal  check  is. particularly useful for  the evaluation  of fabric filter
 performance.  The insoection involves observations from access hatches and
 under  no  circumstances includes entry into the collector  by the
 inspector.  When the Level 1 data and/or the preliminary  observations
 during Level  2  inspections indicate problems, an inspector may wish to
 conduct the more detailed and complete  Level 3 inspection.
 6.2.4  Level  1  Inspections
     The  Level  1 inspection is a field  surveillance tool  intended to
 provide relatively frequent but very incomplete indications of source
 performance.  Because entry to the plan: grounds is usually unnecessary,
 the inspection  is never announced in advance.  The inspector makes visible
 emission  observations on the stacks which are visible from the plant
 boundary  and  which can be properly ooserved given prevailing
 •neteorological conditions.  Odor conditions are noted both upwind and
 downwind  of the facility.  Unusual conditions provide the stimulus for an
 in-plant  inspection in the near future.  If the visible emission observa- t
 tlons and/or  other ooservations provides the basis of a notice of viola-
 tion, the information should be transmitted to hospital administr. tive
 personnel immediately to satisfy due process requirements.
     The  following sections define the specific inspection points included
 in.Level   1, 2, and 3 inspections of hospital  waste incinerators and the
major types of air pollution control  systems.  Procedures involved in
 preparation of baseline data (Level  4 inspections)  also are covered since
 the procedures differ for each type of system..  Additionally, matrices are
 included  in each section on waste characterization, combustion equipment,
and air pollution control equipment *hich summarize and compare the types
of inspections included in each inspection level.
6.3  COMMON INSPECTION ACTIVITIES
     There are several  inspection activities that are common to the
different types of inspections (i.e., inspections of waste, combustion
equipment, and air pollution control  devices).  These common activities
are described in this, section to prevent their unnecessary repetition in
each of the following  sections where they .are applicable.
                                   6-10

-------
 6.3.1  Prepare  a  System  Flowchart
     System flowcharts are  prepared during  a  Level 4  inspection by agency
 management personnel  or  senior  inspectors for use  in  subsequent inspec-
 tions.  Even a  relatively simple chart  is helpful  both  in preparing for
 and during an inspection.   In general,  the  system  flowchart  is made up of
 three separate  flowcharts;  waste storage and  handling,  combustion equip-
 ment, and air pollution  control device(s).  The specific requirements for
 each of these flowcharts are presented  in the following section.
 6.3.2  Identify Potential Safety Problems
 Agency management personnel and/or senior inspectors  should  identify
 potential safety problems involved in standard Level  2/Level 3 inspections
 at this site. .  To the extent-possible,  the  hospital personnel should
 eliminate these hazards.  For those hazards which  cannot be  eliminated,
 •agency personnel should prepare notes on how  future inspections should be
 Halted and should prepare  a list of the necessary personnel safety
 equipment.  A partial list  of common health and safety  hazards' inclu4e the
 following:
      1.   Eye injuries whi le observing combustion  conditions through
 observations hatches;
      2.   Skin contact with sharps and  infectious wastes;
      3.   Thermal  burns due to contact with hot equipment.
      4.   Inhalation hazards due to fugitive  leaks from high static
 pressure  scrubber vessels and ducts;
      5.   Eye hazards during sampling of scrubber  liquor or  exposure to
dry scrubber alkali  solids and slurries;
      6.   Slippery walkways and ladders; -                    •
      7.   Fan disintegration;
      8.   Inhalation hazards due to fugitive  leaks from dry  scrubber inlet
breechings,  absorber vessels,  particulate control  systems, and alkaline
reagent storage/preparation/supply equipment;            •  ;
      9.   Corroded ductwork  and particulate control devices;
     10.   High  voltage in control  cabinets;
     11.   Inhalation hazards due to low stack  discharge points;
     12.   Weak  catwalk and  ladder  supports;
     13.   Hot fabric filter  roof surfaces;
                                   6-11

-------
      14.  Compressed air gauges in close proximity to rotating equipment
 sr hot surfaces;
      15.  Fugitive emissions from faoric f;'ter cystem; and
      16.  Inhalation nazards from adjacent stacks and vents.
 5.3.3  Evaluate Locations for Measurement Parts
      Many existing incinerators and air pollution control  devices  do  not
 have convenient and safe ports that can be used for static pressure,  gas
 temperature, oxygen, and carocn monoxide measurements.   One purpose of  the
 Level  4 inspection is to select (with the assistance of plan; personnel)
 locations for ports to  be installed at a later date to  facilitate  .Level  3
 inspections.  Information regarding possible sample port locations for
 incinerators and air pollution control  devices is provided in the  U.  S.
 EPA  Publication titled,  'Or-efer'-ed Measurement Pcrts for Air  Pollution
 Control  Systems,'  EPA 34C/I-c6-.:24.      '            '               '    .
 6.3.4   E/dluate Visible  Emissions
      If  weather conditions  pemit,  Determine, the  *et scruooer effluent
 average  opacity in accordance  with  EPA  Method  9 procedures (or other
 required  procedure).  The observation should be conducted  during routine
 process  operation  and snould  last  6  to  30  minutes for each itack and
 bypass vent.   The  observation  snould  be  made after .the  water  droplets
 contained  in  the plume vaoorize  («nere  the  steam  plume  ''breaks") or at  the
 stack discharge if there  is not  a  steam  plume  present,   ^he presence  of a
 particulate  plume  greater than  iO  percent  generally indicates  a scruboer
 operating problem  and/or  the generation  of  high concentrations  of  sub-
 micron particles in  the  process  ard/cr  tne  presence of  hign concentrations
 cf vaporous material  condensing  in  tne effluent gas stream.
     In addition to evaluating the  average  opacity,  inspectors  snould scan
 the visible emission  observation wcrksneet  to  identify  tne maximum.and
minimum short-term opacities,  "his  is especially  useful information  if
 there are variations  in the incinerator  operating  condition during
charging, scot  blowing of a *aste neat boiler, or  other  cyclic  activity.
The differences  in the minimum and maximum  opacities  provides  an
 indication of changing particle  size distributions.
     If weather conditions are poor, an  attempt should  still  be made  to
determine if there are any visible emissions.  Do  not attempt  to determine
                                   6-12

-------
 average opacity during adverse weather conditions.   The presence of a
 noticeable plume indicates air pollution control  device operating
 prool.ems.
 6.3.5- Evaluate Double-Pass Transmissometer Physical  Condition
       If a transmisscmeter is present, and if it is  in an accessible
 location, check the light source and retroreflector modules  to confirm
 that  these are in  good working order.  Check, that the main fan is working
 and that there is  a least one dust filter for the fan.   On many commercial
 models, it 1s also  possible to check the instrument alignment without
 adjusting the instrument.   (NOTE:  On seme models,  moving  the dial  to the
 alignment check position  will  cause an alarm in the control  room.  This  is
 to be moved only by plant  personnel and only when it  will  not disrupt
 plant operations).
      Some fabric filters  have  ore or more single  pass  transmissometers on
 outlet ducts.   While  these can provide seme  useful  information to the
 system_ operators, these  instruments do not  provide  data  relevant to the
 inspection.
 6.3.6   Evaluate  Double-Pass  Transmissometer  Data.   '                      • '
      Obtain  the  continuous opacity  records  and  quickly  scan  the data for
 the  previous  12  months to  determine time  periods  that  had  especially high
 and  especially  low  opacity.  Select the dry  scrubber  operating logs and
 the  process operating  logs  that  correspond with the  times  of  the
 monitoring  Instrument  charts/records  selected.  Compare  the dry scrubber
 operating data and  process operating  data against baseline  information to
 identify the general category  of  proolem(s)  causing  the  excess opacity
 incidents.  Evaluate the source's proposed corrective  actions  to minimize
 this problem(s)  in  the future.   During  the  inspection,  if  the  unit  is
working better than during other  periods,  it may  be advisable  to conduct
an unscheduled inspection  in the  near  future.
     As part of the review of  average  opacity,  scan the  data  to  determine
the frequency of emission problems  and  to evaluate how rapidly the
operators are able   to recognize  and eliminate the condition.
     Evaluate the average opacity data for selected' days since the  last.
Inspection, if the  transmissometer  appears to be working properly.
Determine the frequency of emission problems and evaluate how  rapidly  the
                                   6-13

-------
 fabric filter operators are able to recognize and  eliminate  the
 conditions.
 6.3.7  Sulfur Dioxide,  Nitrogen  Oxides,  and  Hydrogen  Chloride Monitor
        Physical  Conditions
      If the  monitors are in an accessible  location, confirm  that  the
 instruments  are  in good mechanical  operating condition  and that any sample
 Tines are intact.   Check calibration and zero check records  for all
 instruments.   Whenever  working in the areas  around the  continuous  emis-
 sions monitors,  inspectors  should be cautious about fugitive leaks of
 effluent  gas.
 6.3.8  Sulfur  Dioxide,  Nitrogen  Oxides,  and  Hydrogen  Chloride Emission Data
      An inspection of monitoring data, similar to  that  conducted  for
 transmisscmeters  (see Section 6.5.4.2.8),  also should be made of  the
 tionitoring data  for sulfur  dioxide,  nitrogen oxides,  and hydrogen  chloride
 monitors.
      High emission rates  of  either  sulfur  dioxide  or  hydrogen chloride
 indicate  significant problems with  the .dry scrubber system.  The general
 classes of problems include  but  are  not  limited  to poor alkaline reagent
 reactivity,  inadequate  approach-to-saturation (wet-dry  systems),  low
 reagent stoichiometric  ratios, low  inlet gas  temperatures, and makeup
 reagent supply problems.  If high emission rates of either sulfur dioxide
 or hydrogen chloride are  observed during the  inspection, facility
 personnel should be consulted to  determine both  the cause of the
 problem(s) and appropriate corrective action(s).
      High nitrogen  oxide  concentrations  indicate a problem with the
 combustion equipment operation,  an  increase  in  the waste nitrogen content,
 or a  problem with  the nitrogen oxides control  system.
 6.3.9  Modify Standard  Inspection Checklists
      Senior inspectors  and/or agency management personnel should modify,
 the checklists presented  in the Appendices of  this manual to match the
 specific conditions at  the facility  being  inspected.   Inspection points
which are irrelevant and unnecessarily time consuming sho.uld be omitted to
 reduce the inspection time requirements and reduce the disruption of the
 facility personnel's schedule.   Also, any inspection steps which involve
unreasonable risks  to the inspector, the plant personnel, or the equipment
                                   6-14

-------
  should be deleted.  In some cases, it may be necessary to add other
  inspection points not discussed in this manual.  At the conclusion of  the
  Level 4  inspection, the modified checklist should be included in the
  inspection file.
  6.4  CHARACTERIZATION OF WASTE
      Hospital wastes are heterogeneous, consisting of general refuse,
  laboratory and pharmaceutical chemicals and containers, and pathological
 wastes; all or some of these wastes may contain pathogens or infectious
 agents and may be considered infectious wastes.  While most States
 prohibit disposal of low-level  radioactive waste in incinerators (unless
  licensed for this use), there is also a potential for improper inclusion
 of these wastes in incinerator charge material.  General  refuse from
 hospitals is similar to generic wastes from residences and institutions,
 and include artificial  linens,  paper, flowers,  food, cans, diapers, -and
 plastic cups.-  Laboratory and pharmaceutical  chemicals can include
 alcohols, disinfectants,  antineoplastic agents, and heavy metals, such as
 mercury.   Infectious wastes include isolation wastes (refuse associated
 with Isolation  patients),  cultures and stocks of infectious agents and
 associated biologicals,  human blood and blood products, pathological
 wastes,  contaminated sharps,  and contaminated animal carcasses,  body parts
 and bedding.    In the  U.S., infectious wastes are required to be discarded
'in orange or red  plastic  bags or containers.  Containers  should  be marked
 with the  universal  biological  hazard  symbol  (Figure 6-3).   Often these
 "red bag"  wastes  may contain  general  refuse discarded  along with the
 infectious waste.
      The  purpose  of  characterizing waste during an  inspection is to
 identify  the  types of waste being  burned in order to assess whether the
 was.tes are within any  limitations  stipulated  in the operating permit or
 State regulations.   Furthermore, characterization of the  waste will assist
 in  evaluating the potential impacts on pollutant  formation,  proper incin-
 erator design and operation,  air pollution control  equipment  performance,
 and waste  handling and. charging  practices that  could potentially produce
 fugitive emissions of infectious agents.  Potential  pollutants of concern
 from hospital incinerators  that  are affected  by waste composition include
 particulate matter, particulate metals, acid  gases  (hydrogen  chloride
                                   6-15

-------
Figure 6-3.  The biological hazard symool.
                     6-16

-------
 [HC1-J, hydrogen fluoride, sulfur dioxide, su If uric acid, nitrogen oxides),
 toxic organics (e.g., dioxins and furans), radionuclides, and infectious
 agents.  The characteristics of the wastes that contribute to the forma-
 tion and emission of these pollutants are discussed below.
     Particulate matter.  The quantity and characteristics of emissions of
 particulate matter from the combustion of hospital wastes are determined
 by three factors:  (1) entrainment of noncombustible materials,
 (2) Incomplete combustion of combustible materials, and (3) condensation
 of vaporous material.  The noncombustible materials contained in hospital
 wastes are dependent on the ash content of the combustible materials and
 other miscellaneous noncombustible materials contained in the wastes, such
 as powdered inorganic materials and fines from the fracture of sharps.
 Particulate emissions from incomplete combustion of combustible materials
 are influenced by the moisture content, heating value, and bulk density of
 the feed wastes.  These factors should be considered in the design and
 operation of the incinerator to maximize combustion efficiency.
 Condensation of vaporous materials results from volatilization of
 noncombustible substances that have vaporization temperatures within the
 range of those in the primary chamber with subsequent cooling in the flue
 gas.  These materials usually condense on the surface of other fine
 particles.  Because of the inverse relationship between surface area and
 particle size, condensible materials are often selectively distributed on
 fine particles which makes their capture by conventional air pollution
 control  devices difficult.  Particulate emissions from one study of
 18 uncontrolled hospital incinerators ranged from 1.37 to 36.49 Ib per ton
 of feed  with an average of 7.52 Ib/ton.
     Particulate metals.  Particulate metal  emissions are dependent on the
 metals content of the feed material.  Metals may exist in the waste as
 either parts of discarded instruments or utensils, in plastics and inks,
or as discarded heavy metals used in laboratories.  An example is mercury
 from dental  clinics.   Many metals are converted'to oxides during combus-
tion and are emitted  primarily as submicron to micron size particles.
Metals that  volatilize at primary chamber temperatures may selectively
condense on  small,  difficult to control particles in the incinerator flue
gas.   Metals generally thought to exhibit fine-particle enrichment are As,
Cd,  Cr,  Mn,  Ni, Mo,  Pb,  Sb,  Se,  V,  and Zn."*

                                   6-17

-------
      Acid gases.  Sulfur dioxide (S02)  emissions  are  directly  related  to
 the sulfur content of the waste material.   Two parts  by  weight of  S02  are
 generated for each part of sulfur combusted.   Alkaline materials that  may
 exist 1n the waste materials could potentially react  with  the  S02  and
 produce solid salts that would be either retained in  the bottom ash  or
 emitted as particulate with the flue gas.   However, the  relatively large
 amounts of halogenated plastics in typical  hospital waste  result in  the
 formation of HC1 which has a higher affinity  for  the  available alkaline
 materials.  As a result, most of the sulfur in the waste is  emitted  as
 S02t  with a small  amount emitted as sulfur  trioxide (S03).   Moisture in
 the flue gas can react with the S02 and S03 to produce suIfuric acid.
 Uncontrolled SOX emissions from one study of  two  hospital  incinerators
 ranged  from 1.47 to 3.01 Ib per ton of  feed with  an average  of
 1.85  lb/ton.5
      Halogens such as  chlorine,  fluorine, and bromine in the wastes  will
 produce HC1,  hydrogen  fluoride (HF),  hydrogen bromide (HBr)  when
 combusted.   Potential  sources of halogens in  the  waste stream  include
 polyvinyl  chloride (PVC),  other halogenated plastics, and  halogen-
 containing  salts.   Because  of the relatively  large amounts of  plastics in
 hospital wastes, concentrations  of HC1  from hospital  incinerators  can  be
 significantly higher than  from municipal incinerators.   Hospital wastes
 typically contain  about  20  percent plastics with  levels  as high as
 30 percent  reported.6  Table  6-1  presents an  ultimate analysis of  four
 plastics usually found  in  hospital  wastes.  Uncontrolled HC1 emissions
 from hospital  incinerators  from one study of  18 hospitals ranged from  6.6
 to 99.4  Ib  per ton of feed with an  average  of  45.4 lb/ton.7
     Nitrous  oxides (NOX) emissions from hospital  incinerators result  from
 conversion of the nitrogen  in  the  combustion  air,  referred to  as thermal
 NOX, and the  nitrogen contained in  the fuel,  fuel  NOX.  Thermal NOX  is
 extremely sensitive'to temperature.  Fuel NOX  is  less temperature
 sensitive and will increase proportionally with waste nitrogen content.8
Uncontrolled NOX emissions from one study of two hospital incinerators
ranged from 4.64 to 7.82 Ib per ton of feed with an average of
6.02 lb/ton.9
                                   6-18

-------
              TABLE 6-1.   ULTIMATE ANALYSES OF FOUR PLASTICS4
                             (Weight  Percent)

Moisture
Carbon
Hydrogen
Oxygen
Nitrogen
Sulfur
Chlorine
Ash
Higher heating
value, Btu/lb
Polyethylene
0.20 ,
84.38
14.14
0.00
0.06
0.03
Tr
1.19
19,687
Polystyrene
0.20
86.91
8.42 •
3.96
0.21
0.02
Tr
0.45
16,419
Polyurethane
0.20
63.14
6.25
17.61
5.98
0.02
2.42
4.38-
11,203
Polyvinyl
chloride
0.20
45.04
5.60
1.56
0.08
0.14
45.32
2.06
9,754
Reference 10.
                                      6-19

-------
      Infectious agents or pathogens.  Hospital incinerators have
 traditionally been used to treat infectious wastes.  The presence of
 infectious wastes in the incinerator feed is easily identified by red or
 orange plastic bags or containers marked with the biological hazard
 symbol.  Proper operation of the incinerator with adequate combustion
 temperatures, excess air rates, and retention times should effectively
 destroy the pathogens.  Many States now require combustion temperature of
 1800'F and retention times in the secondary chamber of 1 second.  Because
 of the potential  for fugitive releases of infectious agents, bag and
 container integrity should be maintained.  Bags and containers should be-
 handled, transported, and stored in a manner that will prevent tears.  If
 syringes or other sharps are included, these sharp wastes should be placed
 in rigid, puncture-resistant containers.
 6.4.1  Waste Characteristics That Affect Incinerator Operation
      Waste moisture and  heat content have major impacts on the thermal
 input to the incinerator.   The heating value of waste corresponds to the
 quantity of heat  released when the waste is  burned, commonly expressed  in
 Btu/lb.   The net  heating value of a waste decreases with increased
 moisture content  since approximately 1,200 Btu of heat are necessary to
 evaporate each pound  of  water in the waste.   The net heating value of the
 waste should be considered  in assessing  the  need for auxiliary fuel
 firing.   As  a rule of thumb,  a minimum heat  content of about 5,000 Btu/lb
 1s  required  to sustain combustion.11   Most incinerator manufacturers rate
 the burn  rate capacities for  their  units  utilizing  the Incinerator
 Institute of America  (IIA) Solid  Waste Classification  system which is
 based on  moisture content and  heating  value.   The  IIA  was  absorbed by the
 National  Solid Wastes Management  Association  in  1974.   Table 6-2  presents
 the IIA classification system.
     Wide variations  in thermal  input  will affect the  temperatures,  excess
 air rates, and retention times  required for efficient  combustion.   Charge
 rates should be varied with the moisture content and heating value to
 prevent overcharging or refractory damage  and  slagging.  During normal
 operation of the incinerator, the operator should mix  feed material  with
different heating values to prevent upset combustion conditions.   The
 loading hopper should be loaded with bags of red bag waste,  trash, and
                                   6-20

-------
TABLE 6-2.  INCINERATOR INSTITUTE OF AMERICA SOLID WASTE CLASSIFICATIONS4

Type   Description

0      Trash, a mixture of highly combustible waste such as paper,
         cardboard, cartons, wood boxes, and combustible floor sweepings
         from commercial and industrial activities.  The mixture contain
         up to 10 percent by weight of plastic bags, coated
         paper,laminated paper, treated corrugated cardboard, oil rags,
         and plastic or rubber scraps.
       This type of waste contains 10 percent moisture, 5 percent
         incombustible solids and has a heating value of 8,500 Btu per
         pound as fired.
1      Rubbish, a mixture of combustible waste such as paper,'cardboard
         cartons, wood scrap, foliage, and combustible floor sweepings,
         from domestic, commercial, and industrial activities.  The
         mixture contains up to 20 percent by weight of restaurant or
         cafeteria waste, but contains little or no treated papers,
         plastics, or rubber wastes.
       This type of waste contains 25 percent moisture, 10 percent
         incombustible solids and has a heating value of 6,500 Btu per
         pound as fired.
2      Refuse, consisting of an approximately even mixture of rubbish and
         garbage by weight.                                              J
       This type of waste is common to apartment and residential
         tjccupancy, consisting of up to 50 percent.moisture, 7 percent
         incombustible solids, and has a heating value of 4,300 Btu per
         pound as fired.                               *
3      Garbage, consisting of animal and vegetable wastes from
         restaurants, cafeterias, hotels, hospitals, markets, and like
         installations.
       This type of waste contains up to 70 percent moisutre, up to
         5 percent incombustible solids, and has a heating value of 2,500
         Btu per pound as fired.
4      Human and animal remains, consisting of carcasses, organs, and
         solid organic wastes from hospitals, laboratories, abattoirs,
         animal pounds, and similar sources, consisting of up to
         85 percent moisture, 5 percent incombustible solids, and having a
         heating value of 1,000 Btu per pound as fired.

5      Byproduct waste, gaseous, liquid or semi liquid, such as tar,
         paints, solvents, sludge, fumes, etc., from industrial
         operations.  Btu values must be determined by the individual
         materials to be destroyed.
6      Solid byproduct waste, such as rubber, plastics, wood waste, etc.,
         from industrial operations.  Btu values must be determined by the
         individual materials to be destroyed.

Reference 12.
                                      6-21

-------
 garbage, rather than charging all the red bag waste at one time,  then all
 the garbage, etc.  The objective is to maintain a constant thermal  input
 rate (Btu/h).
      Wastes containing metals and plastics are a particular concern for
 pollutants from hospital incinerators.  When burned,  metals may become
 metal oxides with particle size distributions primarily in the submicron
       •                                    '
 to micron size range.  These small  particles may become easily entrained
 with limited capture by conventional  air pollution control  equipment.
 Some plastics such as polyethylene  and polystyrene do not  contain
 significant amounts of halogens and can be incinerated efficiently  without
 major concern for toxic pollutant formation.  However, the high heating
 value of these and other plastic materials can cause  excessively  high
 temperatures in the primary combustion chambers with  increased potential
 for refractory -damage,  slagging, and  clinker formation.  Chlorinated
 plastics, such as  polyvinyl  chloride,  produce HC1.
 6.4.2 Handling of Infectious Wastes
      Infectious wastes  require unique  handling, transport,  and charging   >
 procedures  to  prevent fugitive emissions  of  infectious agents.  Infectious
 waste should be transported  to the  incinerator in  either red or orange
 plastic  bags or in containers marked with the biological hazard symbol.
 In  no case  should  the inspector open the  bags or containers.   Handling and
 transport of these wastes  should be performed with  care to  protect  the
 integrity of the bags and  to  ensure containment of  the wastes.  In
 general,  plastic bags containing infectious  waste  should not be
 transported  through a chute or loaded  by  mechanical devices.   Storage of
 these wastes prior to incineration should  be in a  specially designated
 area with limited  access.  The  area should be kept  clean and free of
 rodents and vermin.   Storage  temperature  and duration should be kept  to  a
 minimum to limit microbial growth and  putrefaction.  The presence of
 obnoxious odors may indicate  that materials  are  bejing stored for excessive
 periods of time at elevated temperatures.  If a  continuous feed
 incinerator is used to burn both  infectious  wastes  and general  refuse,
 infectious waste should not be charged to the  incinerator during startup
unless the incinerator is brought to proper  operating temperature on
fossil fuel.  It is recommended  that general  refuse be charged until  the
unit is operating at normal combustion chamber temperatures.

                                   6-22

-------
 6.4.3  Waste Inspection
      6.4.3.1  General  Considerations.   Inspection of waste at  a hospital
 waste incineration  facility  is  an  important  part of each  inspection
 regardless  of whether  a  Level 4, 3, or  2  inspection is performed.  The
 main purpose of  the waste  inspection from an air inspector's perspective
 is to gather data to determine  the potential for fugitive emissions  (i.e.,
 odors, particulate) and  stack emission  problems related to waste
 composition (e.g.,  high  plastic content).  The air inspector will probably
 not have  authority  regarding waste handling  or management at the
 facility.   However, he/she can  be  on the  look out. for potential
 infractions by reviewing operating permits,  noting any prohibited wastes
 (e.g., low-level radioactive, hazardous wastes) and observing  the waste
 contents.   For example,  an incinerator  that  does not have an Nuclear
 Regulation  Commission  (NRC) permit or a permit from an agreement State (a
 State that  has an agreement with the NRC  to  issue permits) for burning
•low-level radioactive waste should not be  burning such waste.  Similarly,
 an incinerator without a RCRA permit or State permit/license cannot burn  >
 hazardous waste.  However, the  air inspector should be concerned mainly
with  identifying the components 1n the waste that could contribute to
 stack  emissions and with observing the waste storage and  handling
 procedures  that could promote fugitive emissions of particulate matter
 and/or odors.  Table 6-3 presents  a matrix that shows the types of waste
 inspections  included in  each Inspection level.
      6.4.3.2  Level  4 Waste Inspection Procedures.  The Level  4 waste
inspection procedures include the  following:  preparation of a waste
generation, storage, and handling  flowchart; the identification of
potential safety problems, the review of waste management records; the
characterization of waste composition; the observation of waste storage
and handling procedures; and the preparation of a waste inspection
checklist.  These procedures are discussed in detail  below.
     6.4.3.2.1  Preparation of flowchart.  A flowchart of the  waste
generation, handling,  storage, and charging system should be prepared for
use in subsequent Level 2 and 3 inspections.  It should consist of a chart
that identifies:
                                   6-23

-------
              TABLE  6-3.    MATRIX OF  MEDICAL  WASTE  INSPECTION  ACTIVITIES
                    ASSOCIATED  WITH  INSPECTION  LEVELS  1,  2,  3,  AND  4
Follouup Basic
Inspection actlvlty/equipaent Level 4 Level 3 Level 2 Level 2
I.
2.
3.
4.
5. ,
Prepare waste management system flowchart x
Identify potential safety problems x x x x
Modify standard inspection checklist x
Su*Mr1zt waste management records x
Estimate the relative voluaes of the following:
Level I Text reference
6.4.3.
x 6.3.2
6.3.9
6.4.3.
6.4.3.
2.1


2.3
2.4
      a.  Central  refuse                                 x                  x
      b.  Red bag  wast*                                  x                  x
      c.  Solid waste                                    x                  x
      d.  Liquid wastt                       '            x                  x
      e.  Plastic  wast*                                '  x                  x
      f.  PVC plastic waste                              x                  x
      9.  Hetals                                        x                  x
      h.  Toxic materials                                x
    .  I.  Radioactive naterials                           x         x

 6.    Estimate the following properties of the waste:                                                  6.4.3.2.4
      a.  Moisture content                               x         x         x
      b.  Bulk density                                   x         x         x

 J.    Perfor» waste survey if warranted                   x         x         x                        6.4.3.2.4

 3.    Evaluate waste handling procedure by:                                                           6.4.3.2.5
      4.  Checking for properly  labeled/colored            x         x         x        x
           packages
      b.  Checking for liquids packed in capped or         x         x         x        x
           stoppered bottles/flasks
      c.  Noting whether contaminated sharps are           x         x         x        x
           packed in rigid, puncture-resistant                                                                     •*
           containers
      d.  Checking packaging integrity                    x         x         x        x
      e.  Noting tears, punctures, and leaking .liquids      x         x         x        x
      f.  Determining potential  for ruptures of waste       x         x         x        x
           packaging

 9.    Evaluate waste storage procedures by:                                                           6.4.3.2.6
      a.  Inspecting packaging for tears, ruptures,         x         x         x        x
           and leaking liquids
      b.  Estimating storage temperature (i.e.,            x         x         x        x
           dnoient)
      c.  Measuring storage temperature                   x         x
      d.  Determining waste storage durations by           x         x         x        x
           consulting hospital  records or
           personnel
      e.  Note general housekeeping procedures             x         x         x        x

10.    Determine if prohibited wastes are being             «    ,     x                                  6.4.3.2.3
       incinerated
                                                      6-24

-------
      1.  Generation sites of infectious and  laboratory wastes;
      2.  Method of transporting to storage area;
      3.  Any refuse holding or staging area;
      4.  Storage areas  and charging pits, chutes,  or  rams,
      6.4.3.2.2  Identify  potential  safety problems.   The  identification of
 potential safety problems is addressed in Section  6.3.2.
      6.4.3.2.3  Waste management records.  A  summary  of the  normal  waste
 generation and management records,  if  any, maintained by  the hospital
 should  be compiled.  These data will be invaluable during Levels  2  and  3
 Inspections since infectious waste  will  be contained  in plastic bags or
 containers at the incinerator site  and should not  be  opened  by the
 inspector.  Prohibited wastes should be listed.  Special  procedures for
 handling  bulk liquids (if any)  should  be addressed.
      As soon as  regulations  have been  promulgated  implementing the  Medical
 Waste Tracking Act of 1988,  medical facilities in  the 10  affected States
 will  be required  to keep  records regarding waste generation.  Therefore,
 inspectors in these States will  be  able  to determine  to some extent the
 types and  volumes of waste being incinerated.  The requirements for these
 facilities under  this pilot  program are  detailed in Section  2.2.2.3.
 Eventually,  all 50 States may have  to  implement a  tracking system
 depending  on  the  success of  this  pilot program.
      6.4.3.2.4  Waste composition.  The waste produced  by a  hospital for •
 incineration  can vary in composition from day-to-day  or hour-to-hour.   The
 incinerator  is designed to handle a particular range  of waste physical  and
 chemical properties.  Operation of  the incinerator should be varied with
 respect to feed rates,  combustion air rates,  and auxiliary fuel firing  to
 account for the variation in wastes charged.   The range of variation in
waste composition that  can be successfully processed  by the  incinerator
with routine operational adjustments represents the baseline waste  levels
 (i.e., the waste being  burned is within the heat content range for which
the incinerator was designed).
     The relative 'distribution (i.e., fraction of total waste) and volumes
(e.g., the number of 13-gallon size waste bags)  of general refuse versus
infectious "red bag" wastes should be estimated and noted during  the
inspection.  Depending upon the packaging procedures for hospital, waste,
                                   6-25

-------
 1t may be difficult for the  inspector to assess the waste composition.
 Infectious waste bags or containers should not be opened by the
 inspector.   If there are questions about waste composition, the
 appropriate  hospital personnel should be located and questioned.  If
 possible, the physical nature of the waste with respect to solids and
 liquids should be noted (I.e., are bottles of liquids being incinerated).
 Large quantities of liquid wastes should not be incinerated unless the
 Incinerator  is designed for  their combustion, i.e., includes properly
 designed hearths with catch  troughs or special injection nozzles.  Waste
 components with high moisture contents (e.g., pathological waste) and high
 bulk densities (e.g., compacted waste, computer paper) should be noted..
 Special care should be taken to note any potentially toxic material, such
 as  mercury, contained in the waste stream.  The plastic content of the
 wastes also should be identified.  If possible through consultation with
 hospital personnel, the inspector should identify the relative portion of
 the plastics that are halogenated plastic, i.e., PVC.
     During a Level 3 or Level 2 inspection (i.e., inspection prompted by j
 public complaints and/or continued compliance problems), in some cases, it
 may be necessary to evaluate the waste composition and heat content more
 accurately.  The most realistic method of obtaining more accurate
 information on the waste is to consult the waste management records at the
 hospital  to Identify each waste type generated and to determine the rate
 at which each waste type is generated.  This information allows weight
 fractions for each waste type based on the total amount of waste generated
 to  be calculated.  (If records are unavailable, a waste generation survey
 may be required.)  A chemical analysis could then be performed by an
 experienced laboratory on a representative sample of each waste type.  The
 heat content of the waste can be estimated using v/aste fractions and
 tabulated heat contents for each waste type.  This type of analysis need
only be performed if the cause of the problem prompting the inspection is
suspected to'be the waste mixture, i.e.,  if the incinerator and air
pollution control device are operating properly and consequently, waste
problems  are indicated.
     6.4.3.2.5  Handling practices—infectious waste.    Handling practices
are of concern to the air pollution inspector because of the potential for
                                   6-26

-------
 fugitive releases of pathogens  or  toxic chemicals.   For  proper
 accreditation, each hospital  should  have in place a waste management  plan
 for infectious and toxic  wastes.   These plans should require  that  the
 waste material be disposed  in properly marked containers that prevent •
 release of the wastes and exposure to  humans.  Liquid infectious wastes
 should be placed in capped  or tightly  stoppered bottles  or  flasks.  Solid
 or semisol id  infectious wastes  should  be placed in  red or orange plastic
 bags  or marked containers.  Contaminated sharps should be placed in
 impervious, rigid, and puncture-resistant containers.  The  infectious
 wastes should be transported  to the  incineration facility in  these bags or
 containers.   The .inspector  should  visually inspect  the bags and containers
 at the incineration facility  to ensure that the integrity of  the packaging
 is being maintained.   Obvious tears, ruptures,  or leaking liquids  should
 be noted.  Handling practices at the incineration facility  should  be
 evaluated  to  assess the potential  for  tearing or rupturing  the packaging
 materials.  In general, these plastic  bags and  containers should be moved
 by hand  without the use of  mechanical  loaders or manually loaded carefully
 into  dutnpsters for transport.
      Observations should  be made of material  charging  practices.   Because
 of the possible variations  in feed material  moisture and heat contents,
 materials of  varying  heat and moisture  values should be  mixed to produce a
 heterogenous  feed charge with relatively  consistent  combustion
 characteristics.
      6.4.3.2.6  Storage practices-?-infectious waste.     Ideally, infectious
 wastes should  be  incinerated  as soon as possible after generation.
 However, same-day incineration is  not always  possible, necessitating
 storage of the material at  the incineration  facility.  The  four important
 factors to be  considered  in storing infectious  wastes are' protecting  the
 integrity of the  packaging,  storage temperature,  duration of  storage, and
 design of the  storage area,.    The packaging should be  inspected to ensure
 that there are  no  ruptures,  tears, or  leaking liquids.   Storage
 temperature and duration affect microbia!  growth  and putrefaction.
 Inspectors should  note any odors and should review hospital  records or
consult operators  to assess  storage times.  Temperatures in the storage
area should be measured and  noted.  Storage of  material  for longer than 4
                                   6-27

-------
 to 5 days should only be allowed 1n refrigerated facilities.  The storage
 area itself should be specially designated with limited access.  The
 inspector should note general housekeeping procedures to prevent vermin or
 rodent infestation that could damage the integrity of the containment
 packaging.
      6.4.3.2.7  Preparation of site-specific checklist.  The senior
 inspection personnel  should prepare a site-specific waste inspection
 checklist for the hospital.  The checklist should specify the specific
 waste conditions and  locations to be inspected.  The checklist should note
 any site-specific safety hazards associated with each inspection point.
 Additionally, the checklist should include permit specifications or
 regulations that limit storage duration and temperature and that exclude
 certain wastes from being incinerated or that allow incineration of
 certain wastes.   An example of a waste inspection checklist is included as
 Appendix A.
 6.5  EVALUATION  OF COMBUSTION EQUIPMENT
      Variations  in emission rates from hospital  incinerators are due to
 variations  in the chemical  and physical  properties of the hospital  wastes,
 variations  in incinerator design, and variations in incinerator opera-
 tion.   The baseline inspection technique is  predicated on establishing
 baseline  conditions and  evaluating  variations  in performance that result
 from  shifts  1n operating  conditions.   Incinerator design  does not vary
 over  time.   Inspections  of  waste  characteristic  effects were discussed in
 Section 6.3.  The purpose of  this section  is to  present background
 information on how  combustion  processes  influence pollutant  formation  and
 emission  rates, how incinerator operation can  be adjusted  to reduce
 emissions, and guidance on  how to perform inspections  of  the incinerator
 itself.
 6.5.1  Partlculate Matter and  Particulate Metals
     As stated in Section 6.4.1,.  particulate emissions from  hospital
 Incinerators are determined by three factors:   (1)  entrainment  of
noncombustible materials  (2) incomplete combustion  of combustible
materials, and (3) condensation of vaporous materials.  The  presence of
noncombustible materials in the incinerator,feed  is a characteristic of
the waste feed material.  This noncombustible material or ash can either
                                   6-28

-------
 be retained in the Incinerator bottom ash or be entrained and emitted with
 the flue gas.  The potential for entrainment of the ash is a function of
 the.incinerator design and operation and will increase with increased
 turbulence and gas velocities in the primary combustion chamber.  The
 relatively lower turbulence and gas velocities in the primary combustion
 chamber of a controlled-air incinerator (compared to a multiple-chamber
 design) contributes to the relatively lower particulate emission rates
 from these types of units.  Complete combustion of combustible material
 requires adequate temperatures, excess air, turbulence or mixing, and
 retention time.  Because of the variability in hospital waste with respect
 to heating values, moisture contents, etc., incinerator operating
 parameters should be varied with the variations in the waste to maximize
 combustion.  In general, higher temperatures, excess air rates,
 turbulence, and retention time result in improved combustion.  However,
 factors that result in higher gas velocities (e.g., higher excess air
 rate)  can result in increased particulate entrainment.
      Condensation of vaporous materials occurs when temperatures in the
"primary chamber exceed the volatilization temperature of the material  with
 subsequent cooling and condensation in the flue gas exhaust.  Generally,
 primary chamber combustion temperatures should be in the range of 1400° to
 1800°F for good combustion.  Temperatures in excess of 1800°F may result
 in excessive slagging and refractory damage.15
 6.5.2   Acid Gases
     The principal  acid gas of concern from hospital  incinerators is
 HC1.   The determining factor in HC1  formation and emission is the
 availability of chlorine in the feed material.   Combustion modifications
 and incinerator operational  adjustments have little,  if any, affect on HC1
 generation  and  emissions.   In  the  presence of available hydrogen, as would
 exist  in the typical  highly organic  hospital  wastes,  most  of the available
 chlorine will be converted  to  HC1.
     From an incinerator design  and  operation standpoint,  S02  is like
 HC1.  Most of the  sulfur in the  wastes  will  be  converted to S02 regardless
 of incinerator  design  or operation.                  .
     Of  the principal  add  gases, only  NOX  formation  will  be significantly
 affected  by incinerator  design and operation.   The  two  types of NOX
                                   6-29

-------
 formation mechanisms are thermal  formation and waste  feed  nitrogen  conver-
 sion.  Thermal NOX results from exposure of air to  high  temperatures  in
 the combustion zone.  The higher the excess-air rate  at  the  flame zone,
 the higher the thermal  NOX formation potential.  Fuel  NOX  formation is
 less temperature sensitive than thermal  NOX and is  more  dependent on  the
 waste nitrogen content.   NOX formation in hospital  incinerators  should be
 lower than in coal-fired boilers  due to  the relatively lower flame
 temperatures.  Thermal  and fuel  NOX formation  is lower in  starved-air
 units than in excess-air units  due to the staged combustion  design.
 Operational  modifications that  lower excess-air rates  and  temperatures
 will  reduce  NOX formation.   However, these same modifications may result
 in lower combustion efficiency  with resulting  increases  in particulate
 emissions and dioxin and furan  formation.
 6.5.3  Organics
      Combustion conditions  that favor increased particulate  emissions due
 to incomplete~~combustion also favor increased  organic  emissions.  Organic
 material  is  found in the waste  and can be formed during  combustion.  Sincey
 these formation mechanisms  are  not fully understood, there are no
 straight-forward design  procedures or operating procedures that  can-
 prevent the  formation of all organic compounds.   Instead,  reliance  is
 placed  on the destruction of the  pollutants created in the combustion
 process.   There are  three basic goals for controlling  the  emission  of
 organics,  namely:
      1.-  Mixing of fuel  and air to minimize the existence  of  long-lived,
 fuel-rich  pockets of combustion products;
      2.   Attainment  of sufficiently high temperatures  in the  presence of
 oxygen  for the  destruction of hydrocarbon species; and
      3.   Prevention of quench zones or low temperature pathways  th.at  will
 allow partially combusted waste (solid or gaseous) from exiting  the
 combustion chamber.                                          .     .
 6.5.4   Infectious Agents
      Incineration has been traditionally used to treat infectious waste at
 hospitals.   Incineration  is especially advantageous with pathological
wastes and contaminated  sharps because it  renders body parts  unrecogniz-
 able and sharps unuseable.  Properly  designed and operated incinerators
                                   6-30

-------
 can be effective  in killing organisms present in the waste.  In general,
 combustion conditions that are favorable to complete combustion and low
 particulate emissions are also favorable to sterilizing infectious
 wastes.  Because of the variation in the moisture content and heating
 value of infectious waste* it is important to adjust waste feed and excess
 air rates to maintain proper incineration conditions.  It is important to
 avoid overloading.  When incinerating hospital wastes, it is essential
 that the secondary chamber operating temperatures be attained before
 loading the waste.
 6.5.5  Inspection of Combustion Equipment
     This section provides detailed descriptions of the types of
 inspections required when inspecting combustion equipment.  Section 6.4.5.1
 provides an overview of the types of inspections that should be performed
 and questions that should be answered on a combustion equipment inspec-
 tion.   Section 6.4.5.2 provides detailed descriptions of each inspection
 activity that should be performed on a Level 4 inspection.  Table 6-4 is a
matrix that identifies the various inspection activities and the inspec-  y
 tion level  in which they are included.
     6.5.5.1  Combustion Equipment Inspection Overview.
                               
-------
         TABLE 6-4.   MATRIX  OF COMBUSTION  EQUIPMENT  INSPECTION ACTIVITIES
                    ASSOCIATED  WITH INSPECTION  LEVELS 1,  2,  3,  AND  4
Inspection activity/equipment
t.
2.
3.
4.
5.
6.
7.



a.



9.






10.





11.





12.

13.




14.



Evaluate Incinerator visible Missions
Prepare system; flowchart
Identify potential safety problem
Evaluate locations for measurement ports
Modify standard Inspection checklists
Review all available records
Utste charging procedures
a. Obtain waste feed rate
b. Review charging records for overcharging
e. Observe charging procedures
Observe combustion zone condition
a. Note burner flae* pattern
b. Not* combustion zone condition (color)
c. Note ash bed condition
Observe bottoei am condition/handling
a. Observe ash handling practices
b. Take V£ readings when fugitive dust Is
apparent
c. Inspect ash for burnout
d. Review ash disposal records
e. Obtain ash samole
Evaluate startup/shutdown procedures
a. Proper minimum temperatures achieved before
charging
b. Proper waste charging
c. Observe stack gas opacity during startup/
shutdown
Underflre and overflre air ports
a. Record incinerator airflow or air pressure
if monitor available
b. Obtain readings for previous 8 hours
c. Review operator's log to determina frequency
of cleaning
Incinerator draft— record Incinerator static
pressure If monitor available
Primary and secondary chamber' temperature
a. Record primary and secondary temperatures
fro* control panel
b. Review previous 12 months data
c. Measure exit gas temperature
Oxygen (0.) level
a. Record exit gas 0. level from available
nonitor
b. Review prevous 12 (tenths' data
c. Measure exic gas 0 level
Level 4 Level 3
X
X
t
X.
X
X

X
X
X

X
X
X

X
X

X
*
4

t

X
\


X

X
X .*

X
*"V

X

X
X
X •

X
X
X

X




X
X
X

X
X
X

X
X

X
<
X

4

X
X


X

X
X

X


X

X
X
X

X
X
Followio Basic
Level 2 Level 2
* *

X X




X X
X
X

X X
X ' X
X X

X X
X X

X X
X X
X







X X

X X
X X

X X


X X

X
X
X X

X

Level I Text reference
x 6.3.4
6.5.5.2.1
x 6.3.2
6.3.3
6.3.9
6.S.S.2.S
6.5.5.2.6



6.5.5.2.7



6. S. 5. 2. 14






6. 5. S. 2. 19





6.5.5.2.3. 9
j
^



6.5.5.2.10

6.5.5.2.11




6.5.5.2.12



15.





IS.



17.


13.





19.
Carbon monoxide (CO)  level
a.  Record exit gas CO level  from available
     monitor
b.  Review previous 12 aonths* data
c.  Measure exit gas  CO level

Incinerator shell
a.  Inspect exterior  shell for corrosion
b.  Inspect exterior  shell for irfiite soots
c.  Listen for audible air infiltration
Incinerator charging  area
a.  Listen for audible air Infiltration
b.  Inspect charge door for warping
Evaluate genera) physical condition of:
a.  Incinerator
b.  Transmissometer
c.  Sulfur dioxide monitor
d.  Nitrogen oxides monitor
e.  HC1 monitor
Review opacity, SO..
  emission data
NO . and HC1 monitors
                                                                      6.5.5.2.13
                                                                      6.5.5.2.15. 16
                                                                      6.5.5.2.17
                                                       6-32

-------
      •  Observe charging procedure
        —  Evaluate temporal variations in waste and combustion  .
            conditions.  Does operator adjust waste charging or combustion
            conditions to accommodate variations?
      •  Are fugitive emissions from incinerator/charge assembly emitted
        during charging?
      •  If bulk liquids are being handled, are these properly fed to the
        incinerator via burner or atomizing nozzle?
      •  If pathological (Type 4) waste is being incinerated, is/are
        charging rate/procedures appropriate for this waste type?
    .  Incineration system/procedures.
      1.  Evaluate adequacy of primary chamber and secondary chamber exit
gas temperatures.  These are important operating parameters relating to
combustion efficiency and infectious agent destruction.  Gas temperature
also  affects nitrogen oxides generation by thermal mechanisms.
      2.  Evaluate flue gas oxygen concentrations to assure adequate
excess air is available.  High levels may also indicate air               j
infiltration.
      3.  Evaluate CO concentration of exhaust gas.  Excessive CO
indicates poor combustion conditions.
      4.  Evaluate physical condition of incinerator shell and waste feed
delivery equipment.  Check for audible air infiltration into incinerator
and for audible air losses from undergrate plenums and forced draft supply
ducts.
      5.  Inspect physical condition of air blower/burner assemblies.
      a.  Do combustion air fans appear to be operating smoothly (no
squealing or vibration)?  Physical condition of dampers (rusted or
properly lubricated)?  For automatic modulated systems, are dampers
modulating as thermal load to incinerator changes?
      b.  Visually inspect burner assemblies and flame pattern (if
viewports exist).   For automatic systems, are burners modulating with
thermal  load of incinerator?
      6«  If pathological  wastes are charged to incinerator, are proper
operating conditions maintained? (i.e., does the primary chamber burner
remain on?)                   .
                                   6-33

-------
       7.   Evaluate  stack  emissions
       a.   Visually  observe  the  stack  emissions opacity
       b.   For  cases where a bypass  stack  is present, observe whether
 emissions  are  present  from  the  bypass stack.
       8.   Note whether the  incinerator draft  is measured/recorded
       9.   Inspect data recording  systems  to assure  all parameters which
 are required to  be  monitored by the operating permit are monitored and
 that data  recording systems are operating properly.  Depending upon the
 size/operating frequency  of the unit  and  operating  permit conditions,
 monitored  parameters for  the'combustion system can  include any of the
 following:
       a.   Primary chamber temperature;
       b.   Secondary chamber temperature;
       c.   Oxygen concentration  of the effluent gas;
       d.   Carbon monoxide concentration of the effluent gas;
       e.   Opacity of the  effluent gas;
       f.   Combustion chamber pressures (draft);                           j
       g.   Charging  frequency and  mass;
       h.  Ash  removal  frequency;
       1.  Auxiliary fuel  usage.
     10.   Review startup  and  shutdown procedures since these can cause
 short  term emission problems  and  can  lead to  rapid equipment deteriora-
 tion.  For batch feed  units,  the  charging and startup of the incinerator
 should be observed  during an  inspection.  Insure that secondary chamber
 temperatures have reached acceptable  levels before  infectious wastes are
 charged.
     6.5.5.1.2  Residue handling  and  disposal.
     1.  Check any  available  records  concerning incinerator bottom ash
composition since this could  indicate combustion problems.
     2.  Inspect bottom ash  to  determine obvious combustion problems.
     3.  Observe bottom ash cleanout, storage, and disposal procedures for
fugitive particulate emissions.
     6.5.5.2   Level  4 Combustion  Equipment Inspection.  The Level 4
combustion equipment inspection is  a comprehensive inspection that
includes all of the elements of inspection Levels 1, 2, and 3.  Table 6-4
                                   6-34

-------
 provides a matrix  of  the  types of  inspection  activities included in each
 inspection level for  combustion equipment.  The following paragraphs
 describe the  Level  4  combustion equipment  inspection activities in detail
 while the matrix points out differences  between the different levels.
      6.5.5.2.1  Prepare a system flowchart.   A combustion equipment system
 flowchart should consist  of a simple diagram  that  includes the following
 elements:
      1.   Location  of  waste storage and handling area and schematic of
 waste charging  system;
      2.   Incinerator  chamber(s), overfire  and underfire air ports; blowers
 and air  auxiliary  burner  locations;
      3.   Location  of  incinerator chamber viewports;
      4.   Schematic  of ash handling system  and disposal/storage area;
      5.   Locations  of major instruments  and monitoring locations on the
 equipment (static  pressure gauges, temperature monitors, oxygen analyzers,
 carbon monoxide analyzers, and operating meter); and
      6.   Location of  control panel and monitor output and recording       j
 instrumentation.
      6.5.5.2.2  Identify  potential safety  problems.  The identification of
 potential  safety problems  is addressed in  Section  6.3.2.
      6.5.5.2.3  Evaluate  potential safety  problems.  The evaluation of
 locations  for measurement  ports is discussed  in Section 6.3.3.
      6*5.5.2.4  Evaluate  the incinerator visible emissions.  The evaluation
 of visible emissions  is discussed in Section  6.3.4.
      6.5.5.2.5  Review types of records.  A summary of the normal operating
 records and routine laboratory analyses  (e.g., analysis of incinerator
 ash,  baghouse catch,  scrubber sludge) should  be compiled.  If possible,
 example photocopies of these forms should  be  included in the inspection
 file  so that new personnel assigned inspection responsibilities will knowe
what  data and information  are"available  on these forms.
      6.5.5.2.6  Waste charging practices.  Waste composition affects
combustion conditions due  to variations  in moisture content and heating
value.  The incinerator's control  system can operate only within a
specified range to control air levels and auxiliary fuel.  Therefore, it
 is important to establish  a proper loading rate to maintain the proper
                                   6-35

-------
 combination of fuel, excess-air rate, and temperature for effective
 combustion.  If waste compositions vary dramatically, it may be necessary
 to vary the charging rate.  When wastes are fed to the incinerator,
 different waste types should be mixed to achieve a more uniform moisture
 content and heating value.  Large volumes of plastic should not be charged
 all  at once due to possible high temperature damage to the refractory and
 slagging.  If Infectious wastes containing pathogens are included in the
 waste feed, it is important that the secondary chamber gas temperature be
 brought up to normal operating temperatures before any infectious wastes
 are  fed to the unit.  Overloading, which often results in incomplete
 combustion, should be avoided.  The incinerator should be rated by the
 manufacture'r for feed rates for the various Incinerator Institute of
 America waste classes.  Obtain the feed rate that prevails during the
 inspection and visually identify,  if possible, the waste composition and
 moisture content.   This feed rate  and waste class can then be compared to
 the  specifications from the incinerator manufacturer.  Batch loading units
 should  be loaded as quickly as possible, especially if the refractory is
 still warm from the previous burn.   If a hot unit is loaded and not sealed
 properly in a short period of time,  the remaining heat in the firebrick
 may  ignite the waste while improper  combustion conditions exist in the
 unit.
     6.5.5.2.7  Evaluate combustion  zone condition.   If viewports are
 installed  in  the combustion chambers,  the inspector should visually
 inspect  the combustion  zone(s).  Only  glass  covered viewports should be
 used.  The  inspector should not open charging  doors,  ash  removal  doors,  or
 inspection doors to  view the combustion  chambers  since serious  injury can
 result.
     During visual  inspection, the observer  should  note:
     1.  The flame pattern;
     2.  Combustion  zone  condition (color);  and
     3.  Ash bed condition.
     The flame should not  be smoking or  impinging on  the  refractory  wall.
For starved-air units, the  primary chamber should be  operating  at
substoichiometric conditions and consequently  the combustion  zone  should
be quiescent (entrainment of  large particles/pieces .of waste  to the
                                   6-36

-------
 secondary chamber should not occur) and dark red or orange in color.
 Complete combustion should be occurring in the secondary chamber where the
 combustion zone should appear bright orange/yellow.  For intermittent duty
 and continuous-duty incinerators, the waste/ash bed should be signifi-
 cantly reduced in volume (50 to 75 percent)  before another charge is
 loaded into the incinerator.  Pathological waste must be exposed to the
 flame; consequently, the waste bed should not be deeply piled.
      6.5.5.2.8  Evaluate underfire air ports.  If monitors are  available
 that measure airflow rate or air pressure, readings should be taken of the
 values indicated.   If readings are recorded  by operator personnel,  obtain
 readings taken for the last 8 hours.  The inspector should review the
 operator's log to  determine the frequency of cleaning of the air ports.
      6.5.5.2.9  Evaluate overfire air ports.  Same procedure as underfire
 air ports.
      6.5.5.2.10 Evaluate incinerator draft. - If pressure monitoring
 gauges are available,  recordings of the static pressure should  be taken.
 Incinerator drafts that are 0.0 inches of water or higher demonstrate that
 the incinerator is operating under a positive pressure.   This positive
 pressure indicates a severe combustion problem and a severe personnel.
 exposure problem.   Under no circumstances should the incinerator operate
 with  positive  pressures.   Positive pressure  indicates an induced draft fan
 problem or a gas flow  resistance problem either in the incinerator  or in
 the air pollution  control  system.
      6.5.5.2.11  Evaluate  primary and  secondary gas  temperatures.   The
 primary and  secondary  chamber exit gas  temperatures  are  usually monitored
 by  thermocouples.   These data can be obtained from the main incinerator
 control  panels.  However,  in  some of the  especially  small  units,  this  is
 not recorded on a  continuous  basis.  The  gas  temperature  records  (if
 records  are  kept)  since the  last  inspection  should be reviewed  to identify
 any problems in maintaining acceptable  primary  and secondary  chamber  gas
 temperatures.  The auxiliary  burners are  used  to maintain minimum
 temperature during periods of waste  feed  interruption or during  periods
when excessive quantities of wet or  noncombustible waste have been
charged.  The gas temperature fluctuations and  the status of  the auxiliary
burner may" be determined by scanning the daily  operating  logs of the
                                   6-37

-------
 incinerator, by scanning available temperature record strip charts,  or by
 reviewing operator logs.
      Measurements should be taken of exit gas temperature at the stack or
 breeching as close to the exit of the secondary combustion chamber as
 practicable.  The data should be compared to any available baseline  data
 as well as to the incinerator thermocouple data to determine if a
 significant change in temperature exists.
      The appropriate temperature in the primary chamber for effective
 burnout and in the secondary chamber for effective combustion will  vary
 with each individual  unit.   Baseline unit-specific temperatures should be
 set during the Level  4 inspection.
      6.5.5.2.12  Evaluate exit gas oxygen level.   If  available, the
 continuous oxygen analyzer data for the past year should  be scanned  to
 determine if the  oxygen concentrations  have remained  in the.normal
 range.   The typical  oxygen  concentrations are generally in the range of 6
 to 12 percent.  Values lower than 6 percent generally indicate inadequate
 excess  air rates  and  incomplete combustion of volatile compounds.  Values >•"
 higher  than 12  percent generally indicate severe  air  infiltration  through
 the charging area,  the incinerator shell,  or the  ash  pit.   The values
 presented here  are  typical  values.   However,  incinerator-specific  baseline
 levels  should be  set  during the Level 4 inspection.   Subsequent inspec-
 tions should compare  observed  values  to the baseline  values  for the
 particular unit being  inspected.   Instrument  calibration  and  routine
 maintenance  records should  be  reviewed.
      The  exit gas oxygen  concentration  should  be  measured  when there are
 indications  of combustion related  emission  problems and when  there is  no
 onsite oxygen analyzer.   When  an oxygen analyzer  is present,  measurement
 of  oxygen  levels by the inspector  can be used to  verify the  accuracy of
 the onsite monitor.
      The types of instruments  available  include multigas combustion  gas
 analyzers, ORSAT analyzers,  and manual  single-gas absorbers.   The oxygen
concentration should be measured at several locations  along the  duct
diameter.  Stratification of the gas stream can result  in  nonuniform
oxygen concentrations across the duct diameter.  Also, the measurements
should be repeated several times over a reasonable time span  to  account
                                   6-38

-------
   for short term fluctuations in the oxygen  levels.  This is especially
   important since charging can create frequent short term oxygen
   concentration changes.  The EPA Reference  Method 3 (40 CFR Part 60
   Appendix A) should be used as a guide for  making oxygen measurements.
       6.5.5.2.13  Evaluate exit gas carbon  monoxide level.  Exit gas carbon
   monoxide level is used as one of the indirect indicators of the
   completeness of combustion.  Observed CO levels should be compared with
   baseline levels for the unit.  Higher than normal CO values suggest
   significant combustion problems.  Plant personnel should be asked about
   possible corrective actions to improve combustion.  Also, the instrument
   calibration and routine maintenance records should be briefly reviewed.
       Carbon monoxide concentration measurements should be made when there
   are indications of combustion problems and when there is no carbon
  monoxide analyzer installed on the unit.  Values greater than normal
  baseline values suggest nonideal  combustion conditions and the emission of
  partially combusted organic compounds.   To ensure representative results,
  the measurements  should be made at several  locations in the duct and
  should  be made several  times  over a reasonable time span.   When the
  facility does  have a CO monitor installed,  measurement of CO levels by the
  inspector can  be  used to verify the accuracy of the facility's monitor.
      6.5.5.2.14  Evaluate  ash  handling  practices.   Ash handling practices
  should  be observed and  noted.   The inspector should observe manual  removal
•  of  the  ash  from the incinerator for batch  and intermittent duty
  incinerators and  inspection of  the mechanical  removal  systems  for
  continuous duty incinerators.   Additionally,  the inspector should evaluate
  the measures taken  to prevent fugitive  dust emissions  including quenching
  the ash  and the placement of the  ash  in  a covered  metal  container.
  Visible  emission observations should  be  performed  whenever there are
  apparent  fugitive  emissions from  the  bottom ash  handling equipment.   Ash
  storage  procedures  should be observed and any fugitive emissions noted.
  The ash  should be  inspected for burnout  quality.   Large pieces  of
  uncombusted material  indicates poor burnout.  Records  should be  reviewed
  to determine ultimate disposal methods and  procedures.
      Samples should be obtained of the ash  and sent to a laboratory  for
  analysis of the combustible organic content and -other  contaminants  such  as
                                    6-39

-------
pathogens and metals.  The samples should be handled carefully and
properly marked as potentially -containing infectious organisms.
     6.5.5.2.15  Evaluate incinerator shell corrosion.  Evaluate the
exterior of both the primary and secondary chambers for signs of
corrosion.  This can be caused by the infiltration of cold air that in
turn results in the absorption of highly corrosive hydrogen chloride into
water droplets on the metal surfaces.  The air infiltration condition
worsens as the corrosion continues.  This can lead to "cold" zones in the
affected chamber and thereby contribute to increased emissions of
partially combusted organic compounds.
     6.5.5.2.16  Evaluate incinerator shell audible air infiltration.
This condition leads to cold zones within the incinerator and increased
emissions of partially combusted or reacted organic compounds.  Most of
these leaks occur in the refractory in inaccessible locations.
     6.5.5.2.17  Evaluate audible air infiltration through charging
area.  Air infiltration through warped charging doors can lead to
localized "cold" zones in the primary chamber.  It can also cause some
undesirable particle reentrainment and carryover into the secondary
chamber.  Care must be exercised in attempting to find audible leaks,
since there may be moving equipment around the charge pit and since there
can be fugitive pollutant emissions accumulating in the poorly ventilated
areas around the primary chambers.
     6.5.5.2.18  'Review charging records.  Available charging-records
should be reviewed to determine if the incinerator capacity is being
exceeded and if proper charging procedures are being followed.  Where
charging records are not available, observation of the charging procedures
over an extended period of time (1 to 2 days) may be warranted.
     6.5.5.2.19  Evaluate startup and shutdown procedures.  If the
facility has frequent startups, the startup and shutdown procedures should
be evaluated.  All batch type and intermittent duty incinerators fall into
this category.  The emphasis should be on techniques used to maintain
minimum furnace exit gas temperatures and on the criteria for beginning
waste charging to the unit.  Stack gas opacity should be observed to
determine the duration of nonideal combustion conditions after waste
charging has begun.  If a problem is evident, continuous measurement of CO
                                   6-40

-------
 and 02 levels in the combustion gas may be  warranted.   Detailed  startup
 and shutdown procedures for different types of incinerators are  provided
 in Section 7.4.
 6.6  INSPECTION  OF AIR POLLUTION CONTROLS16
 6.6.1  Inspection of Wet Scrubbers
      6.6.1.1  Wet Scrubber Inspection Overview.
      6.6.1.1.1  Stack.
      1.  Average opacity of the residual plume is observed  since this
 provides an  indication of particulate matter penetration  and vapor
 condensation in  the scrubber.
      2.  Short-term variations  in residual  opacity  are  an indication of
 variations in  combustion conditions.
      3.  Obvious mist reentrainment is  a clear indication of demister
 failure.
      6.6.1.1.2  Induced draft fan.
      1.  Inspectors  must be aware of  severely  vibrating fans downstream
 from  wet scrubbers.   The inspection is  terminated immediately when this isy
 noticed.
      6.6.1.1.3   Scrubber.
       1.  Static pressure  drop  across the scrubber  is used  as an indirect
 indicator of the particulate removal effectiveness.  The  present value is
 compared with  baseline  values to  determine  if  there has been a significant
 decrease.
      2.  Scrubber static  pressure drop records for the time since the last
 inspection are reviewed  to  identify any operating periods with low
 pressure drops.
      3.  Scrubber vessel general physical  condition is observed during the
 walkthrough inspection  to  identify any obvious physical conditions which
 could threaten the compliance status of the unit in the immediate future.
      4.  Recirculation  liquor turbidity rates are observed  using a small
 sample provided by plant personnel.  High turbidities indicate.greater
chance of nozzle pluggage, nozzle erosion,  and pipe scaling.
      5.  Presaturator/gas cooler liquor turbidity is observed using a small
sample provided by plant personnel.  Moderate turbidities indicate the
potential  for severe particle generation due to evaporation of the solids-
containing  droplets.

                                   6-41

-------
      6.  Recirculation liquor pH provides an indirect indication of the
scrubber vessel's capacity to absorb acid gases.  This is also important
with respect to corrosion of the scrubber vessel, the recirculation tank,
and the piping.
      7.  Scrubber vessel liquor header pressure is used as an indirect
indicator of the condition of internal nozzles which cannot be seen during
the inspection.  Higher than baseline values may indicate pluggage.
      8.  Deinister pressure drop is a direct indicator of partial pluggage
and reduced droplet collection efficiency.  The present value should be
compared with baseline values.
      9.  Scrubber outlet gas temperature is an indicator of the adequacy of
the gas-liquor distribution within the scrubber vessel.  Values above
adiabatic saturation suggest severe gas-liquor maldistribution.
     10.  Induced draft fan "motor currents provide an indirect indicator of
gas flow rates through the scrubber.
     11.  Audible air infiltration sites are 'noted since this contributes to
scrubber vessel corrosion.                                   .             j
     6.6.1.2  Level 4 wet scrubber inspection.  The Level 4 wet scrubber
inspection is a comprehensive inspection that includes all of the elements
of inspection Levels 1, 2, and 3. ' Table 6-5 provides a matrix of the
types of inspection activities included in each inspection level for air
pollution control devices including wet scrubbers.   The following
paragraphs describe the Level 4 wet scrubber inspection activities in
detail  while the matrix points out differences between the different
levels.
     6.6.1.2.1  Prepare a system flowchart.  A wet; scrubber system flowchart
should consist of a simple block diagram which includes the following
elements:
     1.   Source or sources of emissions controlled by a single wet
scrubber system;
     2.   Location(s)  of any fans used for gas movement through the system
(used to evaluate inhalation hazards due to positive static pressures);
     3.   Locations of any main stacks and bypass stacks;
     4.   Location of wet scrubber; and
                                   6-42

-------
  TABLE 6-5.    MATRIX  OF  AIR  POLLUTION  CONTROL  DEVICE  INSPECTION  ACTIVITIES
                     ASSOCIATED WITH  INSPECTION  LEVELS  1,  2,   3,  AND  4
Inspection activity/equipment
                                                      Level 4   Level 3
                                                                          Followuo
                                                                          Level  2
 Basic
Level  2
                                                                                             Level  1   Text  reference
 Wet scrubbers

  1.   Evaluate wet scrueber visible emissions
  2.   Prepare systea flowchart
  3.   Identify potential  safety problems
  4.   Evaluate locations  for measurement ports
  5.   Modify standard inspection checklists
  6.   Inspect for droplet reentrainment
       a.  Check for rainout of droplets adjacent
            to the stack
       b.  Check for moisture/stains on adjacent
            support columns/tanks/stacks
       c.  Mudltp at stack discharge
  7.   Evaluate liquor inlet pressure
  3.   Induced-draft fan
       a.  Check fan for vibration
       b.  Check fan motor current
  9.    Scrubber liquor pH
       a.  Review routine  pH meter calibration records
       b.  If meter properly calibrated, observe
            previous months' data
       c.  Measure scrubber outlet liquor pri
 10.    Scrubber liquor flow rate
       a.  Record liquor flow rate from available monitor
       b.  Record puma discharge pressure froa gauge
       c.  Record nozzle header pressure from  gauge
 11.    Scrubber static pressure drop
       a.  Record scrubber static pressure readings
            fro* available  monitor
       b.  Measure scrubber  static pressure drop
            froa available  monitor
 12.    Record deaister static pressure drop froa
        available monitor
 13.   Measure outlet  gas  temperature
 14.    Evaluate general physical  condition of:
       a.  Wet scrubber systea
      b.  Packed  beds
      c.  Venturl  throat  daapers
      d.  Transaissoaeter
      e.  Sulfur  dioxide  monitor
      f.  Nitrogen  oxides monitor
      g.  Hydrogen  chloride monitor
 IS.   Observe turbidity of:
      a.  Scrubber  inlet  liquor
      b.  Presaturator/cooler liquor
 16.   Review ooacity.  SO  , HO ,  HC1  monitors'
        eaisslon  data        *
                                  •issionx
Qry scrubbers

 1.   Evaluate dry scrubber visible
 2.   Prepare systea flowchart
 3.   Identify potential safety problems
 4.   Evaluate locations for measurement ports
 5.   Modify standard inspection checklists
 6.   Note condensing plume conditions
 7.   Record feed rates for the following systems
        froa available monitors
      a.   Sprcy dryer absorber (calcium hydroxide)
      b.   Dry Injection (caliua hydroxide)
      c.   Seaiwet/dry (calcium silicate/calcium
           hydroxide)
 3.   Evaluate general physical condition of:
      a.   Dry scrubber
      b.   Transaissoaeter
      c.   Sulfur dioxide monitor
      d.   Nitrogen oxides monitor
      e.   Hydrogen chloride monitor
 9.   Record solids recycle rate'on seaiwet/dry
        systems
10.   Record spray dryer absorber system nozzle air
        and slurry pressures
                                                                                                      6.6.1.1.1.
                                                                                                      5.6.1.2.1
                                                                                                      6.3.2
                                                                                                      6.3.3
                                                                                                      6.3.9
                                                                                                      6.6.1.2.6
                                                                                                      6.6.1.2.3
                                                                                                      6.6.1.2.5
                                                                                                      6.6.1.2.11
                                                                                                      6.6.1.2.12
                                                                                                      6.6.1.2.7
                                                                                                      6.6.1.2.14

                                                                                                      6.6.1.2.16
                                                                                                      6.1.2.15
                                                                                                      6.6.2.1.1
                                                                                                      6.6.2.2.1
                                                                                                      6.3.2
                                                                                                      6.3.3
                                                                                                      6.3.9
                                                                                                      6.6.2.2.6
                                                                                                      6.6.2.2.8. 10. 11
                                                                                                      6.6.2.2.13
                                                                                                      6.6.2.2.2

                                                                                                      6.6.2.2.9
                                                                                                           (continued)
                                                            6-43

-------
                                          TABLE  6-5.     (continued)
Inspection  act1v1ty/eouip«*nt
                                                        Level 4   Level 3
FollowuD
Level 2
 Basic
Level  2
                                                                                               l,evel 1   Text  reference
 Ory scruooers (continued)

 U.    -1st and dry bulb temperatures
       a.   Record wet and dry  bulb temperatures from
             available monitors
       b.   Measure wet and  dry bulb temperatures
 12.    Review the previous  12  nonths1  data for the
         following:
       ».   Opacity
       b.   Spray dryer absorber approacn-to-saturatlon
             (wet/dry bulb  temperatures)
       c.   Spray dryer absoreer reagent feed rate
       d.   Slaker slurry outlet temperature
       e.   Spray dryer absorber slurry flow rate and
             density  monitor maintenance recoras
       f.   Spray dryer absorber inlet  gas temperature
       g.   Dry Injection systea fee* rate
       h.   Sealwct/dry calcium silicate/calcium
             hydroxide feed rate
 13,    Measure spray  dryer absorber/dry injection
        systeei inlet temperature
 14.    Review opacity,  SO . MO , and HC1
        monitors'  Mission data

 fabric filter!

  I.    Evaluate fabric  filter visible  emissions
  2.    Prepare syste* flowchart
  J.    Prepare comoressed-air syste* flowchart
  4.    Evaluate  locations for measurement ports
  5.    Identify potential safety premlems
  S.   Modify  standard  inspection checklist
  7.    Evaluate startup/shutdown procedures
 a.   Evaluate puffing conditions
 9.   Evaluate condensing plume conditions
 10.   Evaluate physical condition of:
      a.   Fabric filter
      b.   Transmissometer
      c.   Sulfur dioxide monitor
      d.   Nitrogen oxides monitor
      e.   Hydrogen cnlorlde monitor
 U.   Evaluate fabric filter clean-side conditions
 12.   Evaluate compressed-air cleaning  s'ystea
 13.   Confirm operation of  cleaning equipment controllers
 14.   Evaluate fabric performance
      a.   Perform fabric rip test
      b.   Evaluate bag failure records
 IS.   Evaluate bag cages
 16.   Static pressure drop
      a.   Record Itatlc pressure  drop from available
            monitor
      b.   Measure static  pressure drop
17.   Gas  temperatures
      a.   Record Inlet and  outlet gas temperatures from
            available monitors
      b.   Review fabric filter temperature records
      c.   Measure inlet and outlet gas  temperatures
U.   Measure inlet/outlet  oxygen levels
19.   Review opacity, SO,,  NO  and HC1  Connor's
       data            z    *
                                                                                                         6.6.2.2.7
                                                                                                         6.6.2.2.16

                                                                                                         6.6.2.1.2
                                                                                                        6.6.3.1.1.
                                                                                                        6.6.3.2.1
                                                                                                        6.6.3.2.2
                                                                                                        6.3.3
                                                                                                        6.3.2
                                                                                                        6.3.9
                                                                                                        6.6.3.2.4
                                                                                                        6.6.3.2.7
                                                                                                        6.6.3.2.S
                                                                                                        6.6.3.2.10
                                                                                                        6.6.3.2.1
                                                                                                        6.6.3.2.12
                                                                                                        6.6.3.2.15

                                                                                                        6.6.3.2.18
                                                                                                        6.6.3.2.9
                                                                                                        6.6.3.2. U. 15
                                                                                                        6.6.3.2.19
                                                             6-44

-------
      5.  Locations of major instruments (pH meters,  static pressure
 gauges, thermocouples, liquor flow meters).
      6.6.1.2.2  Identify potential safety problems.   The identification  of
 potential safety problems is addressed in Section 6.3.2.
      6.6.1.2.3  Evaluate locations for measurement ports.   The evaluation of
 locations for measurement ports is discussed in  Section 6.3.3.
      6.6.1.2.4  Evaluate the wet scrubber visible emissions.   The  evaluation
 of visible emissions is discussed in Section 6.3.4.
      6.6.1.2.5  Observe induced-draft fan vibration.   If the  fan downstream
 of                                                        ••
 the scrubber vessel  is vibrating severely,  the inspection  should be
 terminated at once and responsible plant  personnel should  be  advised  of
 the condition.   Fans can disintegrate due to fan wheel  corrosion,  fan
 wheel  solids buildup,  bearing failure,  and  operation  in an unstable
 aerodynamic range.   All  of  these are possible downstream of the wet
 scrubber.   Shrapnel  from the disintegrating fan  can cause  fatal injuries.
     6.6.1.2.6   Evaluate droplet reentrainment.   Droplet reentrainment    j
 Indicates  a significant  demister problem  which can create  a local  nuisance
 and'which  can affect stack  sampling  results.  The presence of  droplet
 reentrainment is  indicated  by the  conditions  listed below:
     1.  Obvious  rainout of droplets  in the immediate vicinity of  the
 stack;
     2.  Moisture and  stains  on  adjacent  support columns,  tanks, and
 stacks; and
     3.  Mud  lip around  the  stack  discharge.
     6.6.1.2.7  Measure  the wet  scrubber  static pressure drop.  The static
 pressure drop is directly related  to the  effectiveness of  particle
 impaction for particle capture.  Generally, the particulate removal
 efficiency  increases as  the static pressure drop increases.  The steps in
measuring the static pressure drop are described below.
     1.  Locate safe and convenient measurement ports.   In  some cases it
may be possible to temporarily disconnect the onsite gauge  in  order to use
the portable static pressure gauge.  It also may be possible to find  small
ports in the ductwork ahead of and after the scrubber vessel.
     2.  Clean any deposits out of the measurement ports.
                                   6-45

-------
     3.  If the inlet and outlet ports are close together, connect both
 sides of the static pressure gauge to the ports and observe the static
 pressure for a period of 1 to 5 minutes.
     4.  If the ports are not close together, measure the static pressure
 in one port for 10 to 30 seconds and then proceed to the other port for 10
 to 30 seconds.  As long as the static pressure drop is reasonably stable
 (the typical condition) then the two values can be subtracted to determine
 the static pressure drop.
     5.  Under no circumstances should onsite instruments be disconnected
 without the explicit approval of responsible plant personnel.  Also,
 instruments connected to differential pressure transducers should not be
 disconnected.
     If a portable pressure gauge is unavailable, the wet scrubber static
 pressure drop should be recorded if the onsite gauge appears to be working
 properly.  The following items should be checked to confirm the adequacy
 of the onsite gauge.
     1.  The gauge "face" should be clear of obvious water and deposits;
 and
     2.  The lines leading to the inlet and outlet of the scrubber appear
 to be intact.
     If there is any question concerning the gauge, ask plant personnel to
 disconnect each line one at a time to see if the gauge responds.  If it
 does not move when a line is disconnected, the line may be plugged or the
 gauge is inoperable.  Note:  the lines should only be disconnected by
 plant personnel and only when this will not affect plant operations.
     Wet scrubber systems operate with a wide' range of static pressure
drops as indicated in the list below.
     Packed bed—2 to 6 in. w.c.
     Venturi—10 to 40 in.  w.c.
     It should also be noted that there is a wide range of required static
pressure drops for identical  wet scrubbers operating on similar industrial
processes due to the differences in particle size distributions.  For
these reasons, it is preferable to compare the present readings with the
baseline values for this specific source.
                                   6-46

-------
      Increased static pressure drops generally indicate the following
 possible conditlon(s).
      1.  Packed-bed scrubbers
          •  High gas flow rates
          •  Partial bed pluggage
      2.  Venturi scrubbers
          •  High gas flow rate               ,
          •  High Hquor flow rates
          •  Constricted venturi throats
          •  Mlsadjustment of variable throat activator
      Decreased static pressure drops generally indicate the following
 possible condltlon(s).
      1.  Packed-bed scrubbers
          •  Low gas flow rates
          •  Bed collapse
      2.  Venturi  scrubbers
          •  Low gas flow rate
          •   Low liquor  flow  rates
          •   Eroded  venturi dampers
          •   Increased venturi  throat openings
          •   Mlsadjustment of  variable throat activator
      6.6.1.2.8   Evaluate the  liquor  inlet pressure.  The pressure of  the
header  which supplies the scrubber spray nozzle can provide .an indirect
indication of the liquor flow  rate and the nozzle condition.  When the
present value is lower than the baseline value(s) the liquor flow rate has
increased and there is a possibility of nozzle orifice erosion.
Conversely,  if the present value is higher than the baseline value(s) the
liquor  flow rate has decreased and nozzle and/or header pluggage is
possible.
     Unfortunately, these pressure gauges are very vulnerable to error due
to solids deposits and corrosion.  It is difficult to confirm that these
are working properly.  For these reasons, other indicators of low liquor
flow such as the pump discharge pressure and the outlet gas temperature
should be checked whenever low header or pipe pressures  are observed.
                                   6-47

-------
      6.6.1.2.9   Evaluate the wet  scrubber  system general physical
 conditions.  While walking around the wet  scrubber system and its inlet
 and outlet ductwork,  check for obvious corrosion and erosion.  If any
 material damage  is evident, check for fugitive emissions (positive
 pressure systems) or  air infiltration (negative pressure systems).  Avoid
 inhalation hazards and walking hazards while checking the scrubber system
 general physical condition.  Prepare a sketch showing the locations of the
 corrosion and/or erosion.damage.   In addition to corrosion and erosion,
 inspectors should also check for  any of the conditions listed below.
      1.  Cracked or worn ductwork expansion joints;
      2.  Obviously sagging piping; and
      3.  Pipes which  cannot be drained and/or flushed.
      6.6.1.2.10  Evaluate the liquor turbidity.  Ask a responsible and
 experienced plant representative  to obtain a sample of the liquor entering
 the scrubber vessel.  This can usually be obtained at a sample tap
 downstream from the main recirculation pump.  The agency inspector should
 provide a clear sample bottle.  Observe the turbidity of the liquor for ay-
 few seconds immediately after the sample is taken.  The turbidity should
 be  qualitatively evaluated as clear, very light, light, -moderate, heavy,
 or  very heavy.
      On some hospital Incinerators, the inlet gas temperature may be
 reduced prior to entry to the scrubber.  This may be done by means of a
 presaturator immediately upstream of the scrubber vessel.  There is the
 potential for small particle formation as the droplets containing solids
 evaporate to dryness.  The turbidity of the liquor used in the
 presaturator should be very low to avoid this condition.
      6.6.1.2.11  Measure the scrubber outlet liquor pH.  Prior to
 obtaining a liquor sample,  warm up the portable pH meter and check it
using at least two different fresh buffer solutions which bracket the
 normal liquor pH range.  Then request a responsible and experienced plant
representative to obtain a sample of the scrubber outlet liquor.  Measure
the  liquor pH as soon as possible after obtaining the sample so that the
value does not change due to dissolution of alkaline material or due to
ongoing reactions.  Compare this  to the baseline value(s).
                                   6-48

-------
      If the Inspector does  not have a portable pH meter, the pH may be
 checked by using the following steps.  Locate the onsite pH meter(s).
 Permanently mounted  units are generally in the recirculation tank or in
 the  liquor outlet lines  from the scrubber vessel.  Confirm that the
 instrument is working properly by reviewing the routine calibration
 records.   In some cases, it is possible to watch plant personnel calibrate
 these instruments during the inspection.
      If the pH meter(s)  appears to be working properly, review the pH data
 for  at least the previous month.  In units with instruments on the outlet
 and  the Inlet, the outlet values are often 0.5 to 2.0 pH units lower due
 to the adsorption of carbon dioxide, sulfur dioxide, hydrogen chloride,
 and  other  add gases.  Generally, all of the pH measurements should be
 within the range from 5.5 to 10.0.  Furthermore, any significant shifts in
 the  pH values from baseline conditions can indicate acid gas removal
 problems and corrosion problems.
      Corrosion can be  severe in most systems when the pH levels are less
 than  5.5.   Also,  high  chloride concentrations accelerate corrosion at low j
 pH levels.   Precipitation of calcium and magnesium compounds at pH levels
 above  10 can lead  to  severe scaling and gas-liquor maldistribution.
      6.6.1.2.12   Evaluate the scrubber liquor recirculation rate.  One
 frequent cause of  scrubber  emission problems is inadequate liquor
 recirculation rate.  Unfortunately, many commercial types of liquor flow
 monitors are subject to frequent maintenance problems and many small
 systems do  not have  any liquor flow meters at all.  For these reasons, a
 combination of factors are considered to determine if the scrubber liquor
 recirculation rate is much  less than the baseline level(s).  These factors
 include the following:
      1.  Liquor flow meter  (if available,  and if it appears to be working
properly);
     2.  Pump discharge pressure (higher values indicate lower flow);
     3.  Pump motor current (lower values  indicate lower flow);
     4.  Nozzle header pressure (higher values indicate lower flow);
     5.  Scrubber exit gas  temperature (higher values indicate lower
flow); and                                                              *
                                   6-49

-------
      6.  Quantity of liquor draining back  into  recirculation  tank or pond
 (lower flow rates indicate lower recirculation  rates).
      6.6.1.2.13  Evaluate fan motor currents.   Changes  in  gas, flow  rate
 occur routinely in most incinerators due to  variations  in  charging  rates
 and waste heating values.  Information concerning  gas flow rate  changes is
 necessary when evaluating changes in the scrubber  static pressure drop.
      Check the scrubber system fan motor current.   Correct the fan  motor
 current to standard conditions using the equation  below.
        .Corrected current = [actual current]x((gas temp.+460)/520]
      An increase in the fan motor current  indicates an  increase  in  the gas
 flow rate.
      6.6.1.2.14  Evaluate demister conditions.  The static pressure drop
 across the demister should be noted and compared with the  baseline
 values.   An increase in the pressure drop  normally is due  to  deposits
 which partially plug the demister vanes.   The static pressure drops of
 clean demisters are usually in the range of  1 to 2 inches  of  water.
      6.6.1.2.15  Evaluate physical  condition of scrubber packed  beds and  ^
 venturi throat  dampers.   This  inspection step can  be performed only when
 the  scrubber system is  out-of-service.   Locate a hatch  on  the scrubber
 vessel  shell which  is either above or below the internal component  of
 interest.   Look  for the  problem listed  below.
      1.   Packed-bed scrubbers
          •   Corroded or  collapsed  bed  supports
          •   Plugged  or  eroded  liquor distribution  nozzles
      2.   Venturi  scrubbers
          •   Eroded  throat dampers
          •   Restricted  throat  damper movement due  to solids deposits
      Note:   Safety  conditions  sometime  preclude observations  of  internal
conditions.  Respirators  and other  personal protection  equipment should be
used  even  if the  scrubber vessel has been purged out prior to the
observations.
      6.6.1.2.16  Measure  the outlet  gas temperatures.   This measurement is
conducted whenever  it is  necessary  to determine if poor liquor-gas
distribution and/or  inadequate  liquor flow rate is seriously  reducing
particulate collection efficiency.  The steps in measuring the gas
temperature are outlined  below.

                                    6-50

-------
      1.  Locate safe and convenient measurement ports on the outlet
 portion of the scrubber vessel shell or on the outlet ductwork of the
 system.  Often small ports of % to % in. diameter are adequate.
      2.  Attach a grounding/bonding cable to the probe if vapor,  gas,
 and/or particulate levels are potentially explosive.
      3.  Seal  the temperature probe in the port to avoid any air
 infiltration which would result in a low reading.
      4.  Measure the gas temperature at a position near the middle of the
 duct if possible.  Conduct the measurement for several  minutes to ensure a
 representative reading.   Some fluctuation in the readings is possible if
 the probe is occasionally hit by a liquor droplet.
      5.  Compare the outlet gas temperature with the  baseline value(s).
 If the present value is  more than 10°F higher,  then either gas-liquor
 maldistribution or inadequate liquor is possible.
 6.6.2  Inspection of Dry Scrubbers
      6.6.2.1  Dry Scrubber Inspection  Overview.
      6.6.2.1.1  Stack.                                                     j
      1.   Evaluate average opacities  and puffing  conditions as direct
 indications  of particulate device operating problems.
      2.   The presence of a secondary plume  is a  direct  indication of  severe
 combustion problems  or dry scrubber  problems.
      6.6.2.1.2  Continuous emission  monitors.
      Evaluate  frequency  and  severity of  excess emissions  of  particulate
 matter, hydrogen  chloride,  sulfur  dioxide,  and nitrogen oxides  from
 monitor records.
      6.5.2.1.3  Dry  scrubber vessel.
      1.   Evaluate operating conditions which are  indirectly related to the
 acid gas removal efficiency.  Most important of these is  the  outlet dry
 bulb and wet bulb temperatures.  Compare the present operating  levels with
 baseline values.
     2.  Evaluate inlet gas temperatures at present and variations of this
 value since the last inspection.  Low inlet temperatures could  lead to
 solids buildup  problems in spray dryer type system.
     3.  Determine if solids recycle from the absorber vessel and/or the
particulate control device is being used.
                                   6-51

-------
      4.   Review records  to  evaluate frequency and  severity of deviations
 from normal  operating  conditions.
      5.   Evaluate corrosion problems which  could 'lead  to future excess
 emission problems.
      6.6.2.1.'4  Alkaline reagent preparation.
      1.   Review maintenance records to  evaluate efforts to maintain slurry
 feed and density instruments.
      2.   Evaluate s.laker (if present) liquor outlet temperature as an
 indirect Indication of the  adequacy of  calcium hydroxide slurry
 preparation.
      3.   Evaluate procedures used  to adjust dry scrubber operation to
 various  incinerator loads and  Inlet pollutant concentrations.
      6.6.2.2   Level 4 Dry Scrubber Inspection.  The Level 4 dry scrubber
 inspection is  a comprehensive  inspection  that includes all of the elements
 of Inspection  Levels 1,  2,  and 3.   Table  6-5 provides  a matrix of the
 types of inspection activities included in  each inspection level for air *~
 pollutlon control  devices including dry scrubbers.  The following
 paragraphs describe the  inspection activities in detail and the matrix
 points out differences between the different levels.
     6.6.2.2.1   Dry scrubber and process  system flowchart.  A dry scrubber
 system flowchart should  consist of a simple block diagram that includes
 the  following elements.
     1.  Source(s) of emissions controlled  by the system;
     2.  Locatlon(s) of  any  fans and  blowers used for gas movement and
 solids conveying;
     3.  Locations of any main stacks and bypass stacks;
     4.  Alkali  preparation  equipment, adsorber vessel or contactor,
 particulate control device,  and recycle streams; and
     5.  Locations of major  process  instruments and gas stream continuous
monitors.
     6.6.2.2.2   Identify potential   safety problems.  The identification of
potential safety problems is addressed in Section 6.3.2.
     6.6.2.2.3   Evaluate locations   for measurement ports.  Evaluation of
 locations for measurement ports is  discussed  in Section 6.3.3.
                                   6-52

-------
       6.6.2.2.4  Startup and shutdown procedures.  The startup and shutdown
.  procedures used at the plant should be discussed to confirm the following.
       1.  The plant has taken reasonable precautions to minimize the number
  of startup/shutdown cycles.
       2.  The dry scrubber is started up in a reasonable time after startup
  of the process equipment.  Inspectors should remember that starting the
  atomizer (1n spray dryer type systems) when the inlet gas temperatures are
  low can lead to absorber vessel deposits.
       6.6.2.2.5  Dry scrubber system visible emissions*  The evaluation of
  visible emlssiions is discussed in Section 6.3.4.
       6.6.2.2.6  Condensing plume conditions.  Condensing plume conditions
  in dry scrubber systems are unusual  since  most vapor state species which
  could cause such plumes are partially removed.  The presence of a
  condensing plume would indicate a major malfunction of the dry scrubber
  system.
       The principal  characteristics of a condensing plume include a bluish-
  white color,  opacities which are higher when the weather is cold or very  j
  humid,  a low opacity at the stack discharge, and increasing opacities  in  ,
  the first few seconds of plume  travel.
       6.6.2.2.7  Spray dryer absorber approach-to-saturation.   One of the
  most important operating parameters  affecting the  efficiency of a wet-dry
  type dry scrubber is the approach-to-saturation.   This is simply the
  difference between  the wet bulb and  dry bulb temperatures measured at  the
  .exit of the spray dryer vessel.   The normal  approach-to-saturation varies
  between 90° and  180°F.   The approach-to-saturation is  monitored
  continuously  by  a set of dry bulb and wet  bulb temperature monitors.   A
  change  in this  value is  sensed  by the automatic control  system which
  either  increases  or  decreases the slurry feed rate to  the atomizer.
       If there is  significant question concerning the ability  of the  dry
  scrubber system  to maintain proper operation on a  long-term basis,  the
  approach-to-saturation  values indicated on the dry scrubber system daily
  operating  log  sheets  should  be checked.  Values much higher than baseline
  values  or  permit  stipulations indicate chronic problems  such  as:
       1.   Fouled absorber  vessel temperature  instruments;
       2.  Corrosion/scaling  of absorber vessel  atomizer;
                                    6-53

-------
      3.   Corrosion/scaling of  absorber gas dispersion equipment;
      4.   Low  absorber vessel inlet gas temperatures during  low  load
 periods;
      5.   Nozzle  erosion  or blockage; and
      6.   Slurry  supply line scaling.
      Due  to the  vulnerability  of the temperature monitors to  scaling and
 blinding, inspectors  may find  that some plants must occasionally bypass
 the automatic process control  system and operate manually for limited time
 periods.  Manual operation generally means slightly worse approach-to-
 saturation values  so  that operators have a margin for error when sudden
 process changes  occur such as  load changes.  Gradually plants should be
 able  to increase the  reliability of the temperature monitors  by relocation
 of the sensors and by improved operation of the dryer.
      Spray dryer absorber vessel dry bulb and wet bulb outlet gas
 temperature measurements  are taken if there is a significant  question
 concerning-the adequacy  of the onsite gauges and if there are safe and
 convenient measurement ports between the absorber vessel and  the          >
 particulate control device.  The measurements should be made  at several
 locations in the duct to  ensure that the values observed are.
 representative of actual  conditions.  The values should be  averaged and
 compared with the value  indicated by the onsite instruments (if
 operational) and with baseline data sets.  It should be noted that it is
 rarely necessary to make  this  measurement since the onsite  gauges are a
 critical part of the  overall process control system for the dry scrubber
 system.  Failure to maintain these instruments drastically  increases the
 potential  for absorber vessel  wall deposits and increased emissions.
 These temperature monitors are normally very well maintained.
     6.6.2.2.8  Spray dryer absorber reagent feed rates.  The calcium
 hydroxide (or other alkali) feed rates are important since  they partially
 determine the stoichiometric ratio between the moles of reagent and the
moles of acid gas.  Low stoichiometric ratios result in reduced collection
efficiencies.  Higher than needed stoichiometric ratios use excessive
reagent and may result in poor drying of the sorbent.
     The reagent feed rate is generally determined using a magnetic flow
meter on the slurry supply line to the atomizer feed tank.  The slurry
                                   6-54

-------
 density, another important operating parameter,  is  monitored by a nuclear-
 type density monitor.   Typical  slurry densities  are in  the range of 5 to
 20 percent by weight.   It should be noted that both the magnetic flow
 meter and the nuclear  density meter are vulnerable  to scaling due to the
 nature of the slurry.
      Another way to  determine the reagent feed rate is  to  record the feed
 rates of new pebble  lime  and  recycled solids  indicated  by  the weigh belt
 feeders.  The weigh  belt  for  the pebble lime  is  between the lime storage
 silo and the slaker.   The weigh belt feeder for  the recycled solids is
 close to the spray dryer  absorber vessel.
      The feed rates  of makeup pebble lime and recycle solids are generally
 indicated on the daily operating logs of the dry scrubber  system.   Values
 for the last 12  months should be compared with the  corresponding
 combustion load  data to determine if significant changes in the overall
 reagent stoichiometric ratios have occurred.  Data  concerning the system
 load must be obtained  from the  combustion system daily  operating log
 sheets.   If  available,  dry scrubber system'inlet sulfur dioxide          >•
 concentrations also should be used in this qualitative  evaluation of
 reagent/acid gas  stoichiometric ratios.
      6.6.2.2.9   Spray  dryer absorber nozzle air  and slurry pressures.  For
 units  equipped with nozzles rather than  rotary atomizers,  the air
 pressures and  slurry pressures  should be recorded and compared with
 baseline  levels.  Some  variation  in the  slurry pressures are necessary in
 order  to  maintain proper  approach-to-saturation  values  during combustion
 system load  variations.
     6.6.2.2.10  Dry injection  system feed rates.   The  long-term .
 performance  of the calcium  hydroxide  supply system  should  be checked if
 the  emissions data indicates occasional  emission excursions.   The  feed
 rate of calcium hydroxide  to the pressurized pneumatic  system is generally
monitored by either a weigh belt feeder  or a volumetric  screw-type
 feeder.   Both of these feeders  are  located close to the calcium hydroxide
 storage silos, and the feed rates  are generally  indicated on  the main
system control panel.  The feed rate data for the previous  12  months
provided by the weigh belt feeder or the volumetric screw feeder should be
compared against the combustion system loads and against the  inlet acid
                                   6-55

-------
 gas concentration monitors (when available).   The  automatic control  system
 should be able to vary calcium hydroxide  (or  other alkali) addition  rates
 with load variations  and  inlet gas  acid gas concentrations.  Decreased
 reagent feed  rates indicate possible  reductions  in the  stoichiometric
 ratio and thereby a reduction  in acid gas collection effectiveness.  The
 blower motor  currents and the  pneumatic line  static pressures also should
 be  recorded and checked against baseline data sets.  Higher motor currents
 and higher conveying  line static pressures indicate increases in the
 airflow rates.
      6.6.2.2.11  Calcium  silicate feed rates.  The Research Cottrell
 semiwet/dry system utilizes a  calcium silicate/calcium  hydroxide dry
 injection system downstream from the  calcium  hydroxide  spray dryer
 absorber.  The  feed rate  of calcium silicate/calcium hydroxide is
 monitored by  weigh'belt feeders or  volumetric  screw conveyors.  The
 variability and reliability of the  calcium silicate/ calcium hydroxide dry
 injection system in Research-Cottrell  systems  should be evaluated by
 reviewing  the daily system operating  logs.  Some loss in acid gas         ;
 collection efficiency could occur if  feed rates were low.
      6.6.2-.2.12  Control  device solids recycle rates.  The Teller
 semiwet/dry system utilizes a  recycle  stream from  the fabric filter  in
 order to  improve  overall  reagent  utilization.  The solids recycle rate
 during the inspection  should be recorded and compared to baseline values.
      The recycle  rates  used in the  Research-Cottrell semiwet/dry type
 systems have  some  impact  on the overall acid gas collection efficiency.
 Low recycle rates  indicate  slightly reduced acid gas collection
 efficiency.
      6.6.2.2.13   Dry  scrubber  system general physical conditions.  While
walking around  the  dry  scrubber and its inlet and  outlet ductwork, check
 for obvious corrosion around the  potential cold spots such as the bottom
of the absorber vessel  and  the  particulate control device hoppers and
around the access hatches.  Check for audible air  infiltration through the
corroded areas, warped  access  hatches, and eroded  solids discharge valves.
     6.6.2.2.14  Slaker slurry  outlet temperatures during past
12 months.  The slaker  slurry outlet temperature provides a rough
 indication of the adequacy  of the conversion from  lime (calcium oxide) to
                                   6-56

-------
 calcium hydroxide.  The temperatures should be compared to baseline
 values.  Improper slaking can result in poor reagent reactivity and
 reduced acid gas collection efficiency.
                            »
      6.6.2.2.15  Spray dryer absorber slurry flow rate and density monitor
 maintenance records.  The calcium hydroxide slurry monitors generally
 consist of a magnetic flow meter and a nuclear density meter.   Both of
 these are sensitive to scaling especially when slurry densities are
 high.  The plant should have maintenance records for the monitors  either
 in the form of completed work orders, a computerized maintenance record,
 an instrument maintenance log, or notes on the daily dry scrubbing
 operations log.  The records should  be reviewed for the previous 12 months
 whenever there is concern that there are periods of low slurry  supply to
 the atomizer.
      6.6.2..2.16  Dry scrubber inlet  gas temperatures.   Dry scrubbing
 systems have a limited turndown capability due to the  need for  complete
 drying of the atomized slurry.   Low  gas inlet temperatures during  periods
 of low combustion system load can cause poor drying of the droplets.   The
 process control  system is generally  designed to block  atomizer  operation
 once inlet  temperature drops  below a preset value.   The inlet gas
 temperature data should be reviewed  to  confirm that the controller is
 working properly,  since operation under these conditions  could  lead  to
 absorber vessel  deposits and  nonideal operation once loads  increase.   The
 inlet  temperature  data may be  available on the dry  scrubber system daily
 operating  logs,  the  archived  continuous strip charts,  or  on the
 computerized  data  acquisition  file.
     When the onsite gauge  is  not  available,  is  malfunctioning,  or is in a
 potentially  nonrepresentative  location,  the  spray dryer absorber vessel  or
 dry  injection system inlet gas temperature should be measured with  a
 portable thermocouple  and monitor.   For spray dryers,  the measurement
 should  be taken  in the main duct  leading to  the  atomizer or in one or .more
of the  ducts  that  lead to the gas dispersion  system within  the vessel.
 For dry  injection  systems, the measurement  should be taken  upstream of the
gas stream/reagent mixing point (such as the  venturi contactor).   The
measurements  should be taken at several  locations in the duct and
averaged.  Locations near air infiltration sites should be  avoided.
                                   6-57

-------
 6.6.3   Inspection  of  Fabric  Filters
     6.6.3.1   Fabric  Filter  Inspection Overview.
     6.6.3.1.1 Stack.
     1.  Observe the  average opacity  and puffing conditions as a direct
 indication of  fabric  filter  performance.
     2.  Observe any  secondary  plume  conditions since these indicate a
 serious combustion problem and/or  dry scrubbing problem.
     6.6.3.1.2 Transmi ssometer.
     1.  Evaluate  transmissometer  physical condition prior to reviewing
 opacity data.
     .2.  Observe average opacity at the present time and for the last
 8 hours to determine  the representativeness of the inspection period.
     3.  Review average opacity records since the last inspection to
 determine the  frequency and  severity  of excess emission problems.
     6.6.3.1.3  Fabric filter.
      1.  Evaluate fabric fi.lter pressure drop as an indirect indication of
 bag  blinding problems, bag cleaning problems, and gas flow changes.       j
      2.  Observe  fabric filter physical condition as an indirect indication
 of corrosion and air  filtration.
      3.  Evaluate present inlet gas  temperature to confirm that it 'does not
 exceed the high temperature  limitations of the fabric being used.  Review
 inlet gas temperature records since the last inspection to determine
 frequency and severity of gas temperature excursion.
      4.  Evaluate fabric filter outlet gas temperatures as an indication of
 air  infiltration and  possible fabric  chemical attack.  The outlet
 temperature should be at least  20°F above the acid dewpoints.  The gas
 temperature difference across the  fabric filter should be only 20° to 50°F
 depending on ambient  temperature,  ambient wind speed, and the adequacy of
 fabric filter insulation.
      5.  Listen for  audible air infiltration around access hatches,
 hoppers, and expansion joints.
      6.  Evaluate cleaning system operation to confirm that the bags are
being cleaned on a regular frequency  and to identify any possible bag
problems due to nonideal  cleaning conditions.
                                   6-58

-------
       7.   Observe clean side conditions  on units  in  which  one  or more
 compartments can be isolated.  Solids  deposits  are an  indication of
 emission  problems.   Physical  condition of the bags and other components
 are also  observed to the extent possible without  entering  the  fabric
 filter.
       8.   Review bag failure rate  and  location  records as  a indirect
 indication of fabric filter excess emission problems and of misguided
 maintenance efforts.
       9.   Perform or observe "rip" tests (described  below) as  a  rough
 indicator of the reasons for frequent  bag failures.
      10.   Observe cage  conditions  (pulse jet only) to  determine  possible
 reasons for frequent  bag failures.
      6.6.3.2  Level  4 Fabric  Filter Inspection
      The  Level 4 fabric filter  inspection is a  comprehensive inspection
 that  includes  all of  the elements  of inspection Levels 1,  2, and 3.
 Table 6-5 provides  a  matrix of  the types of inspection activities  included
 in  each inspection  level  for  air pollution control devices including
 pulse-jet fabric  filters.   The  following paragraphs  describe the Level 4
 pulse-jet fabric  filter inspection  activities in  detail while  the  matrix
 points out  differences  between  the  different levels.
      6.6.3.2.1   Prepare  a system flowchart.   A  fabric  filter system
 flowchart should  consist of a simple block diagram that includes the
 following elements.
      1.   Source(s) of emissions controlled by a single fabric  filter;
      2.   Location(s) of any fans used for gas movement through the system
 (used to  evaluate inhalation problems due to positive  static pressures);
      3.   Locations of any main  stacks and bypass  stacks;
      4.   Location of fabric filter; and
      5.   Locations of major instruments (transmissometers, static  pressure
gauges, thermocouples).    •
     6.6.3.2.2  Prepare a flowchart of the compressed air system.  The
purpose of the flowchart is to indicate the  presence of compressed air
system components that could influence the vulnerability of the pulse jet
fabric filter to bag cleaning problems.  The flowchart should consist of a
simple block diagram showing the following  components.
                                   '6-59

-------
      1.   Source of compressed  air  (plant  air  or compressor);
      2.   A1r drier (if present);
      3.   011 filter (if present);
      4.   Main shutoff valve(s);
      5.   Compressed air manifolds  on  fabric filter;
      6.   Drains for manifolds  and  compressed  air lines;
      7.   Heaters for compressed air lines and manifolds; and
      8.   Controllers for pilot valves (timers or pneumatic sensors).
      6.6.3.2.3  Evaluate locations for measurement ports.  Evaluation of
 locations for measurement points are  discussed in Section 6.3.3.
      6.6.3.2.4  Evaluate startup and  shutdown procedures.  The startup and
 shutdown  procedures  used at the plant should  be discussed to confirm the
 following.
      1.   The plant  has taken reasonable precautions to minimize the number
 of startup/shutdown  cycles.
      2.   The fabric  filter system  bypass  times have been minimized.
      3.   The fabric  filter system  bypass  times have not been limited to   ^
 the extent that  irreversible damage has occurred.
      6.6.3.2.5   Identify potential safety problems.  The identification of
 potential safety problems is addressed in Section 6.3.2.
      6.6.3.2.6  Evaluate the fabric.filter visible emissions.  The
 evaluation of visible emissions is discussed  in Section 6.3.4.
      6.6.3.2.7  Evaluate puffing conditions (pulse jet units only).
 Evaluate  the frequency and severity of puffs.  These are often caused by
 small holes  in one or more rows of bags.
      6.6.3.2.8  Evaluate condensing plume  conditions.  Condensing plume
 conditions in fabric filters systems  serving  hospital waste incinerators
 could conceivably be caused by partially  combusted organic vapors or
 hydrogen chloride vapors.   The vaporous material  condenses once the gas
 enters the cold ambient air.  Condensing  plumes usually have a bluish-
white color.  In some cases, the plume forms  5 to 10 feet after leaving
 the stack.   If the fabric filter operating temperature drops
 substantially, this material can condense  inside the fabric filter and
cause fabric blinding problems.  Corrective actions must, focus on the
 incinerator or dry scrubber system.
                                   6-60

-------
      6.6.3.2.9  Measure the fabric filter static pressure drop.   Fabric
.filters operate with a wide range of static pressure drops (2  to  12 in.
 w.c.).  It is preferable to compare the present readings with  the baseline
 values for this specific source.  Increased static pressure drops
 generally indicate high gas flow rates and/or fabric blinding  and/or
 system cleaning problems.  Lower static pressure drops are generally due
 to reduced gas flow rates, excessive cleaning intensities/frequencies,  or
 reduced inlet particulate loadings.  The steps in measuring the stack
 pressure with a portable pressure drop gauge are described below.
      1.  Locate safe and convenient measurement ports on the inlet and
 outlet ductwork or on the fabric filter shell.  In some cases  it  may be
 possible to temporarily disconnect the onsite gauge in order to use the
 portable gauge.
      2.  Clean any deposits out  of the measurement ports.
      3.  If the inlet and outlet ports are .close together,  connect both
 sides of the static pressure gauge to the ports and observe the static
 pressure for 1 to 5 minutes.                                              ^
      4.  If the ports are not close together,  measure the  static  pressure
 in one port for 10 to 30 seconds and then proceed to the other port for 10
 to 30 seconds.   As long as the static pressure drop is stable  the two
 values can be subtracted to determine the stack pressure drop.
      5.   Under no circumstances  should onsite  plant instruments be
 disconnected  without the explicit approval of  responsible plant
 personnel.  Also,  instruments connected to differential  pressure
 transducers should not  be disconnected.
      If the inspector does not have a portable pressure  gauge, the fabric
 filter static pressure  drop should  be recorded if the  gauge  appears  to  be
working  properly.   The  gauge face  should  be clear of obvious water and
deposits.   The  gauge should fluctuate slightly each  time one of the
diaphragm  valves  activates.  These  valves can  be  heard easily when close
to the  pulse  jet  fabric filter.   If  there is any  question about the  gauge,
ask plant  personnel  to  disconnect each  line one at  a time to see  if  the,
gauge responds.   If  it  does not move  when a line  is  disconnected,  the line
may be plugged  or  the gauge  inoperable.
                                   6-61

-------
      6.6.3.2.10  Evaluate fabric filter general physical conditions.
 While walking around the fabric filter and its inlet and outlet ductwork,
 check for obvious corrosion around the potential "cold" spots such as  the
 corners of the hoppers, near the solids discharge valve, and the access
                                                  i      * i'i"  '        •        ,:
 hatches.  On negative pressure fabric filters, check for any audible air
 infiltration through the corroded areas, warped access hatches, eroded
 solids discharge valves, or other sites.  On positive pressure fabric
 filters, check for fugitive emissions of dust from any corroded areas  of
 the system.                                         '
      6.6.3.2.11  Evaluate the clean side conditions when possible.  If
 there is any question about the performance of the fabric filter,  request
 that plant personnel open one or more hatches on the clean side (not
 available on some commercial  models).  Note the presence of any fresh  dust
 deposits more than 1/8 in.  deep since this indicates particulate emission
 problems.
      In the case of pulse jet-fabric filters, also observe the conditions
 of  the bags, cages, and compressed air delivery tubes.   The compressed air/
 delivery tubes should be oriented directly into the bags so that the sides
 of  the bags are not subjected to the blast of cleaning  air..  The cages and
 bags should be securely sealed to the tube sheet in units where the bag
 comes up through the tube sheet.   There should be no oily or crusty
 deposits at the top of the  bags due to oil  in the compressed air line.
      In some cases  ,  operators will  be unable to isolate any compartments
 without causing major gas flow problems with  the incinerator and/or the
 dry  scrubber.   Obviously,  the request to check clean side conditions
 should  be withdrawn under such circumstances.
      6.6.3.2.12   Evaluate compressed  air cleaning system.   The  purpose of
 checking the compressed  air cleaning  system is to determine if  this
 contributes  to  a  significant  shift  in the fabric filter static  pressure
 drop  and/or  if this  contributes to  an excess  emission problem.   The
 inspection procedures  for the  compressed  air  cleaning system can include
 one or more  of the  following.
      1.   Record the compressed  air pressure if  the  gauge appears to be
working  properly.   It  should fluctuate  slightly  each time  a diaphragm
valve is  activated.  Do  not remove this valve  since  the compressed air
 lines and manifold have  high pressure  air  inside.

                                    6-62

-------
      2.  Listen  for operating  diaphragm valves.   If  none  are  heard  over  a
 10 to 30 minute  time period, the cleaning  system  controller may not be
 operating.
      3.  Check the  compressed  air shutoff  valve to confirm  that the line
 is open*
      4.  Count the  number  of diaphragm  valves that do  not activate  during
 a cleaning sequence.  This can be done  by  simply  listing  for  diaphragm
 valve operation.  Alternatively, the  puff  of compressed air released from
 the trigger  lines can sometimes be felt at the solenoid valve (pilot
 valve)  outlet.
      5.  Check for  the presence of a-compressed air  drier.  This removes
 water which  can  freeze at  the  inlet of  the diaphragm valves.   Also  check
 for compressed air  oil filter.
      6.  Check for  a  drain on  the compressed air  supply pipe  or on  the air
 manifold.  This  is  helpful for routinely draining the  condensed water and
 oil  in  the manifold.
      6.6.3.2.13  Confirm operation of cleaning equipment  controllers.
 Observe the  fabric  filter  control  panel during cleaning of  one or more
 compartments to confirm that the controller is operating  properly.   Each
 compartment  should  be Isolated  for cleaning before the static pressure
 drop  Increases to very high levels that preclude adequate gas flow.  Also,
 cleaning  should not be so  frequent that the bags do  not build up an
 adequate  dust cake  to ensure high  efficiency'filtration.
      6.6.3.2.14  Measure inlet  and outlet gas temperature.  The primary
 purpose of determining the present gas  inlet temperture is  to evaluate
 possible excess emission problems  and/or high bag failure rate conditions
 that  can be caused by very high  or very low gas inlet temperatures.
      These measurements are conducted whenever it is necessary to
 determine 1f air infiltration  is causing fabric chemical  attack due  to
 reduced gas outlet temperatures.   A large difference between  the baseline
 temperature and the temperature measured during a subsequent  inspection  is
 an indication that air infiltration is a problem.   It also  is  helpful to
measure the inlet gas temperature  to evaluate the potential for high gas
 temperature damage to the bags.  The average inlet gas temperature should
 be 25° to 50°F below the maximum rated temperature limit of the fabric.
                                   6-63

-------
 Fifteen to 30 minute spikes  of  less  than  25"F  above the maximum rated
 limit can usually be tolerated  without  fabric  damage.  The average inlet
 gas temperature should be 25° to  50°F above  the  acid gas dewpoint
 temperature.   For most comnercial  combustion processes, the acid dewpoint
 is usually between 225° to 300°F.  The  inlet gas temperature also should
 be above the_water vapor dewpoint.   The steps  in measuring the gas
 temperature are outlined below.
      1.   Locate safe and convenient  measurement  ports on the inlet and
 outlet ductwork of the collector.  Often  small ports less than % in.
 diameter are  adequate.  Measurements using ports on the fabric filter
 shell  often are inadequate since moderately  cool  gas is trapped against
 the shell.
      2.   Attach a grounding/bonding  cable to the probe if vapor, gas,
 and/or particulate levels  are potentially explosive.
      3.   Seal  the temperature probe  in  the port  to avoid any air
 infiltration  that would result  in a  low reading.
      4.   Measure  the  gas temperature at a position near the middle of the
 duct  if  possible.   Conduct the measurement for several minutes to ensure a
 representative  reading.
      5.   Measure  the  gas temperature at another  port and compare the
 values.   On combustion sources, a gas temperature drop of more than 20° to
 40°F  indicates  severe air  infiltration.
      6.   Compare  the  inlet gas temperature with  the maximum rated
 temperature limit  of  the fabric present.  If the average gas temperature
 is within 25° to  5D°F of the maximum, short  bag  life and frequent bag
 failures  are possible.  Also, if there  are short-term excursions more than
 25° to 50eF above  the maximum temperature limits, irreversible fabric
damage may occur.
     Locate any onsite thermocouples mounted on the inlet to the fabric
filter.   If this  instrument appears  to  be in a representative position,
record the temperature value displayed  in the control  room.
     6.6.3.2.15  Evaluate the fabric filter gas temperature records.  The
purpose of reviewing  continuous temperature recorder data is to determine
if temperature excursions contribute to excess emission problems and/or
high bag failure rates.  Review selected strip charts  to determine if the •
                                   6-64

-------
 gas inlet temperatures have been above the maximum rated fabric
 temperature or below the acid vapor or water vapor dewpoints.
      6.6.3.2.16  Perform fabric rip test and review fabric laboratory
 analyses.  The purpose of evaluating fabric condition is to determine if
 any corrective actions planned by the owner/operators have a reasonable
 probability of reducing frequent excess emissions.
      To perform a rip test, ask the plant personnel for a bag  that has
 been recently removed from the fabric filter.  Attempt to rip  the bag near
 the site of the bag hole or tear.  If the bag cannot be ripped easily,
 then the probable cause of the failure is abrasion and/or flex damage.:
 These bags can usually be patched and reinstalled.  If the bag can be
 ripped easily, then the fabric has been weakened by chemical attack or
 high temperature damage.   Weakened bags should not be patched  and
 reinstalled.   It may be. necessary to install  new bags throughout  the
 entire chamber if the bag failure rates are high.
      6.6.3.2.17  Evaluate bag failure records.  The purpose of reviewing
 bag failure records is to determine the present bag failure rate  and to   ^
 determine if  the rate of  failure is increasing.  Plot the number  of bag
 failures per  month for the last  6 to 24 months.  If there has  been a
 sudden Increase,  the owner/operators should consider replacing all  of the
 bags  in the compartment(s)  affected.   If there 1s  a distinct spatial
 pattern to the failures,  the  owner/operators  should consider repair and/or
 modification  of the internal  conditions causing the failures.
      6.6.3.2.18  Evaluate the bag  cages.   The bag  cages  are evaluated
 whenever there are frequent abrasion/flex failures at the bottoms of the
 bags  or along  the  ribs  of the cage.   Ask  the  plant personnel to provide a
 spare  cage for examination.   There  should be  adequate support  for the bag
 and there should not  be any sharp  edges along the  bottom cups  of  the
 cage.   Also check  the cages for  bows  that .would cause rubbing  between two
 bags at the bottom of the  fabric filter.
     6.6.3.2.19  Evaluate  the  inlet  and outlet  gas  oxygen  levels.   These
measurements are performed to  further evaluate  the  extent of air  infiltra-
tion.   An  increase of more than  1 percent  oxygen going from the inlet to
the outlet  indicates severe air  infiltration  (e.g.,  inlet oxygen  at
6.5. percent and outlet oxygen at 7.5 percent).  The  steps involved  in
measuring the flue gas oxygen  levels are  itemized  below.

                                    6-65

-------
      1.   Locate  safe and convenient measurement ports.  Generally, the
 ports used for the temperature measurements are adequate for the oxygen
 measurements.
      2.   Attach  a grounding/bonding cable to the probe 1f there are
 potentially explosive vapors, gases, and/or particulate.
      3.   Seal the probe to prevent any ambient air infiltration around the
 probe.
      4.   Measure the oxygen concentration at a position near the center of
 the duct  to avoid false readings due to localized air infiltration.  The
               *
 measurement should be repeated twice in the case of gas absorption
 instruments.  For continuous monitoring instruments, the measurement
 should be conducted for 1 to 5 minutes to ensure a representative value.
      5.   If possible, measure the carbon dioxide concentration at the same
 locations.  The sum of the oxygen and carbon dioxide concentrations should
 be in the normal  stoichiometric range for the fuel being burned.  If the
 sum is not in this range, a measurement error has occurred.
     6.  As soon as possible, complete the measurements at the other
port.  Compare the oxygen readings obtained.  If the outlet values are
substantially higher, severe air infiltration is occurring.
6.7  REFERENCES FOR CHAPTER 6
 1.  U. S. Environmental  Protection Agency.   EPA Guide for Infectious
     Waste Management.   Office of Solid Waste.   Washington, D.C.
     Publication  No.  EPA/530-SW-86-014.  May 1986.  p. ix.
 2.  Ibid.  p. 3-7.
 3.  Hospital  Waste  Combustion Study:   Data  Gathering Phase.  Final
     Report.  U. S.  Environmental  Protection  Agency,  Office of Air Quality
     Planning  and Standards,   Research Triangle Park, North Carolina.
     EPA-450/3-88-017.   December 1988.   p. 3-10 to 3-24.
 4.  Ibid.  p. 3-6.
 5.  Ibid.  p. 3-20.
 6.  Ibid.  p. 1-9.
 7.  Ibid.  p. 3-16.
 8.  Ibid.  p. 3-4.
                                   6-66

-------
 9.  Ibid.  p. 3-ZO.
10.  Ibid.  p. 1-13.
11.  McCree, R. E.  Operation and Maintenance of Controlled Air
     Incinerators.  Ecolaire Environmental Control Products, Inc.
     Charlotte, North Carolina.  .
12...  Reference 3.  p. 1-11, 12.
13.  Reference 1.  p. 3-9.
14.  Reference 1.  p. 3-12.
15.  Reference 11.  p. 10.
16.  Richards, J.  Municipal Waste Incinerator Field Inspection Notebook
     (Draft); Prepared for U.S. EPA.
                                   6-67

-------

-------
                         7.0   SPECIAL CONSIDERATIONS

 7.1  INCINERATOR OPERATOR TRAINING AND OPERATOR EXPERIENCE
      The success of incineration as a technique for treating hospital
 waste depends on the proper operation of the Incinerator and its
 associated air pollution control device.  Proper operating techniques  can
 affect equipment reliability, on-line availability,  combustion efficiency,
 and regulatory compliance with air pollution regulations.  The operator is
 in control of many of the factors that have an impact on the performance
 of a hospital waste incinerator and air pollution control device
 including:  (1) waste charging procedures, (2) incinerator startup and
 shutdown,  (3) air pollution  control  device startup and shutdown,
.(4) monitoring and adjusting operating parameters for the incinerator  and
 air pollution control  system, and (5) ash handling.   Poorly trained and/or
 inexperienced operators  have neither the knowledge nor the skills  to
 operate the equipment  properly or react appropriately to upset
 conditions.  Therefore,  the  value of appropriate operator training and/or j
 experience should be apparent to the inspector.
      Typically, incinerator  and air  pollution control  device manufacturers,
 once their equipment 1s  installed, offer a hands-on  operator training
 program that includes  Instruction in the proper  operating procedures and
 the necessary preventive maintenance activities  that should  be
 performed.   While.this training is desirable,  it is  often lost when the
 operator decides  to  take another,  higher paying  job.   Operator turnover is
 experienced by many  hospitals  and causes problems  in maintaining proper
 operation  of equipment and necessitates  almost continual  training  of
 operators.   Turnover and proper operation are  particular  problems  at
 hospitals where housekeeping  personnel  operate the incinerator system
 because  their level  of understanding  of  the combustion process  is  limited,
 their level  of commitment to proper  operation  is  low,  and  the  tendency  to
 move to  other,  higher paying jobs  is  high.  One  solution  to  these  problems
 is  to create  a dedicated position where  one employee operates  the
 incinerator  and air  pollution control device and  is more  highly  paid than
 housekeeping  personnel.  This tends to reduce  the turnover thereby
producing a more experienced operator.
                                    7-1

-------
      At most hospitals, a hospital  engineer is in charge of the  operation
 and maintenance of the incinerator.  The engineer should have  a  good
 working knowledge of the incinerator and should be able to  provide  some
 operator training in the proper operational procedures.  Additionally, the
 facility engineer should ensure that preventive maintenance activities are
 carried out on a regular basis  to minimize operational  problems  and
 downtime.   Some States have included specific requirements  for operator
 training in proposed regulations for infectious waste incinerators.
      The inspector should be aware  of the above considerations.   He/she.
 should  inquire as to the experience level of the operator,  the amount of
 hands-on training the operator  has  received, and the availability of a
 hospital  engineer to direct the operator as required.  The  inspector
 should  evaluate whether the operator meets the necessary training
 requirements (where applicable).
 7.2  EMERGENCY OPERATING PLAN
      The permit for the incineration facility may stipulate that  an
 emergency operating plan be developed and implemented to prevent  exposure ;
 of  the  public  or operator personnel  to spills or leaks  of infectious
 wastes.   In general,  most plans should include the responsible individual
 to  be notified in case of an emergency,  emergency contacts .(such  as fire
 departments) and procedures  to  be followed in the case  of an emergency.
 The inspector  should  become familiar with the permit-stipulated
 requirements for an emergency operating  plan prior to the inspection.
 During  the  inspection,  the  inspector should  ask  to see  the  plan  (if
 applicable).   The plan'should be reviewed to ensure that all stipulated
 requirements are addressed.  The inspector should also  ensure  that  the
 plan  is accessible  to  operator  personnel  and that they  are  familiar with
 its requirements.
 7.3  CROSS-MEDIA INSPECTIONS
     Hospital  incinerators  are  potentially subject to two environmental
media regulatory  programs.   These are  air pollution and solid  waste.  If a
wet scrubber is  used for  pollution control,  water discharge  also  is of
concern.
                                    7-2

-------
 7.3.1   Air Pollution
     The Agency's  authority,  regulations,  and inspection  procedures under
 the  Clean  Air Act  are  discussed  earlier  in this manual.
 7.3.2   Solid  Waste                                           '•"•':
     7.3.2.1   Resource Conservation and  Recovery Act:  Section 3007 of  the
 Resource Conservation  and  Recovery Act (RCRA) allows a duly  authorized
 inspector:
     1.  To enter  at reasonable  times any  establishment or other place
 maintained  by any  person where hazardous wastes are generated, stored,
 treated, disposed  of,  or transported from; and
     2.  To inspect  and obtain samples from any person of any such waste
 and  samples of any containers or labeling  of such wastes.
     As a first step in fulfilling the Congressional mandate to establish
 a hazardous waste  management  system, EPA published proposed  regulations in
 the  Federal Register on December 18, 1978, which included a  proposed
 definition  and treatment methods for infectious wastes.l  During the
 public comment period  for  this rulemaking, EPA received approximately     j
 60 comments which  specifically addressed the infectious waste provisions
 of the proposed regulations.2
     On May 19,  1980,  EPA  published the  first phase of the hazardous waste
 regulations.   The  Agency stated  in the preamble to the regulations that
 the  sections  on infectious waste would be  published when work on
 treatment,  storage,  and disposal  standards was completed.  While the
 Agency has  evaluated management  techniques for infectious waste,
 considerable  evidence  that these wastes  cause harm to human  health and the
 environment is  needed  to support Federal  rulemaking.3  While EPA has not
yet promulgated  rules  for  infectious wastes,  guidance on  handling,
 treatment,  and  disposal of infectious wastes  is  provided  in  EPA Guide to
 Infectious Waste Management.4                                           <
     7.3.2.2   State Regulations  for Solid  Waste.  Over 25 States have
passed hazardous waste legislation specifically  to control the treatment,
storage, and disposal of infectious waste  (as  part of their  hazardous
waste management program).   Some States  have  already promulgated
regulations controlling infectious waste,  while  other States are preparing
such regulations.  Because there is no unanimity of opinion on the hazards
                                    7-3

-------
 posed by infectious waste and appropriate techniques for safe disposal of
 these wastes, control requirements vary from State to State.
 7.3.3   Inspector Multimedia Responsibilities
      In addition to the air pollutant emission concerns, an inspector
 should be cognizant of the solid waste handling requirements that may be
 associated with the incineration facility.
      Of particular concern are wastes that may be regulated as hazardous
 under Subtitle C of RCRA.  Table 7-1 lists the types of Subtitle C wastes
 (i.e., F, U, or P wastes) that may be generated at; a medical facility.  A
 facility is determined to be a hazardous waste generator if it generates
 more than 100 kg per calendar month of hazardous waste.   The facility must
 comply with the requirements of 40 CFR Parts 262 through 266, 268, 270,
 and 124 and the notification requirements of Section 3010 of RCRA.  These
 regulations include specific requirements for generators, transporters,
 and owners/operators of  hazardous waste treatment, storage, and disposal
 facilities.   These requirements  also are applicable to  generators of
 greater than 1 kg  of acute hazardous waste or "P"  waste  per calendar      _/
 month.   If  a facility generates  100 kg of Subtitle C waste  and 1 kg or
 less of  P waste  per calendar month or less,  then the facility is called a
 conditionally exempt small  quantity generator and  is not subject to the
 aforementioned requirements.   In order to  prove  that a facility is a small
 quantity generator,  it must  keep detailed  records  of the types and
 quantities of hazardous waste generated,  and  where,  when, and  by whom it
 was  disposed.  However, small quantity  generators  are exempt from the
 manifest requirements  for generators  described in  40  CFR Part  262.   In
 order to burn  any of the Subtitle  C wastes in an onsite  incinerator,  the
 incinerator must be permitted to burn the wastes under 40 CFR  270 (EPA
 Adminstered Permit Programs:  The  Hazardous Waste  Permit Program)  or  must
 be licensed or permitted by the State to burn waste.  The inspector  should
 check the waste generation records and appropriate permit if he/she
 suspects that hazardous waste is being improperly disposed  in  the
 incinerator.
     In many States, the treatment, storage,  and disposal of infectious
waste will  be subject to State regulations or permit conditions.  At  the
 initial  Level 4 inspection, the inspectors should obtain copies of any
                                    7-4

-------
             TABLE 7-1.  LIST OF HAZARDOUS WASTES THAT MAY BE
                      GENERATED AT A MEDICAL FACILITY
 F Wastesa         -                U Wastes5                      P Wastes0
                                  U206 - Streptozotocin         None
    0                             U010 - Mytomycin C
 F005e                             U150 - Melphalan
                                  U059 - Daunomycln
                                  U058 - Cyclophospharaide
                                  U0237 - Uracil Mustard
                                  U035 - Chlorambudl
                                  U015 - Azeserine
                                  U026 - Chlornaphazine
                                  U140 - Isobutyl Alcohol
                                  U151 - Mercury
                                  U044 - Chloroform
                                  U002 - Acetone
                                  U122 - Formaldehyde
                                  U220 - Toluene
                                  U239 - Xylene

^Hazardous wastes from nonspecific sources.
°Tox.ic hazardous wastes.
^Acute hazardous wastes.
 Scintillation wastes using xylene as a solvent would be included in this
 category.
Scintillation wastes using toluene  as a solvent would be included in this
 category.
                                   7-5

-------
 State or Federal solid-waste-related permits or regulations that pertain
 to the incinerator waste feed material or incinerator residue ash.   Prior
 to any subsequent inspections, the inspector should become familiar with
 the conditions of the permits or regulations.  During the inspection,  the
 inspector should identify any deviations from the regulations or permit
 conditions.  These deviations should be documented in the inspection
 report.  All supporting data or photographs should also be recorded and
 identified for possible followup activities.  After the inspection, the
 inspector should report all  observed environmental problems to his  or  her
 immediate supervisor for notification of the appropriate Federal  or State
 agency.
 7.4  STARTUP AND SHUTDOWN PROCEDURES FOR HOSPITAL WASTE INCINERATORS AND
      ASSOCIATED AIR POLLUTION CONTROL DEVICES
      Because each incinerator model  is designed differently,  design
 criteria, operating parameters,  and  operating procedures will  vary. This
 kind  of variation applies to the startup and shutdown procedures
 associated with the different incinerator types.   Therefore,  a discussion'
 of  the  proper execution of these procedures  is provided below on  each  of
 the incinerator types  discussed  in Chapter 5.   Additionally,  general
 discussions are presented on the proper startup and shutdown  procedures
 for wet scrubbers,  dry scrubbers,  and fabric filters.   The  inspector
 should  be well  versed  in the startup  and shutdown procedures  for  all of
 these types of  equipment because emissions can be the highest  during
 startup and shutdown.   The inspector  should  observe these procedures,
 especially startup,  during the inspection  if at all  possible.
     Special  concerns  during startup  include the  following:
     1.   Assuring that all air pollution control  equipment  is  online and
 properly  operating prior to  initiating  waste charging;  and
     2.   Assuring that the secondary  combustion chamber is  preheated and
 above a minimum  acceptable operating  temperature  before charging  (or
 igniting  for  batch feed  systems) waste.
 7.4.1  Batch  Feed Starved-Air Incinerator
     This type of incinerator, typically,  is a  small unit with a capacity
 that may  range up to 500  Ib/h but  is more  typically  less than 200 Ib/h.
The incinerator  is operated  in a "batch-mode,"  which entails a single
                                    7-6

-------
 charge at the beginning of the operating cycle, followed by combustion,
 ash burnout, cooldown, and ash removal over a 12- to 24-h period.   The
 following sections describe the startup and shutdown procedures  for a
 batch feed starved-air incinerator.
      7.4.1.1  Startup.  Startup of the incinerator actually begins  with
 removal  of the ash generated from the previous operating cycle.  The
 following are guidelines for good operating practice:5
      1.   The incinerator should be allowed to cool sufficiently  so  that  it
 is  safe  for the operator to remove the ash.  This cooling can take  as long
 as  8 h.
      2.   The operator should exercise extreme caution since the  refractory
 may still be hot and the ash may contain local hot spots, as well as sharp
 objects.
      3.   The ash and combustion chamber should not be sprayed with  water
 to  cool  the chamber because rapid cooling from water sprays can  adversely
 affect the refractory.
      4.   A flat blunt shovel,  not sharp objects that can damage  the
 refractory material, should be used for cleanup.
      5.   Avoid  pushing  ash  into the underfire air ports.
      6.   Place  the ash  into a  noncombustable  heat resistant container,
 i.e., metal.  Dampen the ash with water to  cool  and  minimize fugitive
 emissions.
      7.   Assure that the ash door is  securely closed  and  the integrity of
 the  seal  is maintained  after ash  removal  is completed.
      Prior  to initiating charging,  operation  of  the  ignition and secondary
 burners and combustion  air  blowers  should be  checked.  The  incinerator is
 charged cold.   Because  these units  generally  are  small,   they are usually
manually  loaded.   The waste  is  loaded into the  ignition chamber, which is
filled to the capacity  recommended  by the manufacturer.   Typically,  the
manufacturer will  recommend  filling the  incinerator completely, but  not
overstuffing the chamber.  Overstuffing can result in blockage of the air
port to the combustion chamber and  in premature ignition of the waste and
poor performance (i.e., excess emissions) during startup.  Overstuffing
also can result in blockage of the  ignition burner port  and damage to the
burner.  After charging  is.completed, the charge door is closed,  the seal
                                    7-7

-------
 visually checked for irregularities, and the door is locked.  Once
 operation is initiated, no further charges will be made until the next
 operating cycle is initiated, i.e., after cooldown and ash removal.
      Prior to ignition of the waste, the secondary combustion chamber is
 preheated to a predetermined temperature by igniting the secondary
 burner.  A minimum secondary chamber temperature of 1600°F is recommended
 prior to ignition of the waste.  Preheat takes from 15 to 60 minutes.11
      After the secondary chamber is preheated, the secondary combustion
 air blower is turned on to provide excess air for mixing with the
 combustion gases from the ignition chamber.
    •  The ignition chamber combustion air blower is activated and the
 primary burner is ignited to initiate waste  combustion.  When the primary
 chamber reaches a preset temperature and the waste combustion is self-
 sustaining,  the primary burner is shut down.  A typical temperature is
 1100°F.
      The primary combustion  air and secondary combustion air are adjusted
 to maintain  the desired primary and secondary chamber  temperatures.
 (Typically,  this adjustment  is automatic and can encompass  switching from
 high  td  low  settings or complete modulation  over an  operating range.)
      During  operation,  the primary  burner is reignited  if the ignition
 chamber  temperature falls below  a preset temperature.   Similarly, the
 secondary burner is reduced  to its  lowest firing level  if the secondary
 chamber  rises above a preset high-temperature  setting.  Again, control of
 the burners, like the combustion air,  is  typically automated.  A
 barometric damper on the stack is used to maintain draft.   The incinerator
 chambers should  both be maintained under  negative draft.
      7.4.1.2  Shutdown.  After the waste  burns down and all volatiles  have
 been  released, the primary chamber combustion air level  is  increased to
 facilitate complete combustion of the fixed carbon remaining  in  the  ash.
 The temperature  in the primary chamber will continue to decrease
 indicating combustion is complete.  A typical burndown period is 2 to
 4 h.   When combustion is complete, the secondary burner is shut down.
     Shutdown of the secondary burner, which initiates the cooldown
period, usually is automatically controlled to occur at a preset length of
time into the cycle.s»7  The combustion air blowers are left operating to
                                    7-8

-------
 cool the chambers prior to subsequent ash removal.  The blowers are shut
 down when the chambers are completely cooled or prior to opening the ash
 door for ash removal.  Cooldown typically lasts 5 to 8 h.6
      As described in Chapter 3, appropriate safety precautions should be
 taken when removing ash from the incinerator, including the use of
 protective clothing, thick rubber or plastic gloves, eye protection, and a
 respirator or dust mask filter.  The ash should be gently removed with a
 rake and blunt shovel to prevent fugitive dust emissions and to prevent
 damage to the refractory.
      The final step in the cycle is examination of ash burnout quality.
 Inspection of the ash is one tool the operator and inspector has for
 evaluating incinerator performance.
 7.4.2  Intermittent-Duty. Starved-Air Incinerators
      Intermittent-duty, starved-air incinerators typically are used for
 "shift" type operation.  The incinerator must  be shutdown routinely for
 ash-removal.   Hence,  there is a distinct operating cycle.   The main
 feature which distinguishes  this type of incinerator from the batch
 incinerator  is the charging  procedures which are used.   The charging
 system  is  designed to accommodate multiple charges safely  throughout the
 operating  cycle  rather than  to  rely on a single batch charge at the
 beginning  of  the operating cycle.   Either manual  or automated charging
 systems can be used.
      7.4.2.1   Startup.  The residual  ash from the  previous  operating cycle
 must  be removed  before  a cycle  can  be initiated.   Ash removal  procedures
 are essentially  the same as those described  in  Section 7.5.1.1  for  batch
 mode  incinerators.
     Before the operator initiates  startup,  proper operation  of the
 primary  and secondary burners and combustion air blowers should be
 checked.  The following steps are conducted during startup:
     1.  The primary and secondary burner(s) are ignited, and preheat of
 the combustion chambers is initiated;
     2.  The secondary chamber must reach a predetermined temperature
 (e.g., 1400°F) before the incinerator is ready for charging.  A minimum
warmup time of 30 to 60 minutes is recommended; and
     3.   After the predetermined secondary chamber temperature  is
                                    7-9

-------
 attained, the primary and secondary combustion air blowers  are
 activated.  The incinerator is ready to be charged.
      Stable combustion can be maintained most readily with  a  constant
 thermal input to the incinerator.  Feeding too much  waste in  a  charge
 causes the incinerator to overload.  These overloads can result in  poor
 burndown (because of waste pile buildup on the hearth)  or can cause
 excessive emissions because the rapid generation  of  volatiles overloads
 the capacity of the secondary chamber.  Feeding too  little  waste results
 in inadequate thermal  input and consequent excessive auxiliary  fuel
 use.   The recommended charge frequency and quantity is 15  to 25 percent
 of, the rated capacity (Ib/h)  at 10- to 15-minute  intervals.5'8   Another
 rule of thumb is to recharge  the incinerator after the  previous charge  has
 been reduced by 50 to  75  percent in volume.8  Charging  volume and
 frequency will  vary with  waste composition,  and the  operator  must use some
 judgment to determine  appropriate rates.   Monitoring the temperature
 profile of the  combustion chambers will  assist the operator in  determining
 the proper charging rates.                                                j
      After the  last charge of the day is  completed,  the incinerator is  set
 to  initiate the burndown  cycle.   The limiting  factor on how long  the
 charging period can be  sustained  without  initiating  the burndown  cycle  is
 the  degree of,ash  buildup  on  the  hearth.   Typically,  the charging period
 is  limited to 12 to 14  hours.6
      7.4.2.2  Shutdown.  The  burndown cycle  is  essentially  the  same as
 that  described  for  batch  incinerators and  is initiated  after  the  last
 charge  of  the day  is made.  For  intermittent-duty  incinerators, the
 burndown sequence can be initiated manually or  automatically.
 7.4.3   Continuous-Duty, Starved-Air  Incinerators
      Continuous-duty incinerators  have the capability of continuously
removing the ash from the  incinerator hearth.  Consequently, the
 incinerator can be operated at a. hear-steady-state condition by
continuously charging the unit at regularly timed   intervals  and,
similarly, by removing the ash at regularly timed   intervals.
     7.4.3.1  Startup.  Startup procedures for continuous-duty
incinerators are essentially the same as those for the intermittent-duty
                                   7-10

-------
 incinerators.  The chambers are first preheated before the initial  charge
 is loaded to the incinerator.
      7.4.3.2  Shutdown.  Shutdown of the incinerator involves stopping the
 charging prpcess and maintaining temperatures in the combustion chamber
 until the remaining waste burns down to ash and is finally discharged from
 the system in the normal manner.
 7.4.4  Excess-Air Incinerators
      Incinerators operating at excess-air levels in the primary chamber
 likely will  be used only for Type 4 (anatomical) wastes.9  Type 4 wastes
 have a fairly consistent composition,  contain high moisture levels,  and
 have a low Btu value.   Wide variations in Btu content are not expected,
 and the combustion rate can be well  controlled at excess-air levels.   The
 incinerator  is operated at high primary combustion chamber temperatures
 with constant use of auxiliary burners.9
      Typical  applications include batch or intermittent operation;
 continuous-duty operation with automatic ash  removal  is atypical.  Startup
 and shutdown  of excess-air/pathological  waste incinerators are  briefly    j
 discussed  in  this section.
      7.4.4.1   Startup.   Startup of the  excess-air incinerator is similar
 to  startup for the  batch-mode,  starved-air incinerators.   The secondary
 chamber  is first  preheated  to  a predetermined  chamber temperature.  The
 incinerator is then  charged with  the waste.
     The waste is charged to the  ignition  chamber  prior to burner ignition
 or preheat of  the ignition chamber.  The waste is  placed on the hearth  in
 a Banner to provide maximum exposure to the primary chamber burner
 flame.  Consequently, placing several components of the charge one on  top
 of the other is not good practice.  The charging door is closed, and the
 primary burner  ignited.
     Additional charges, if any, are made only after the previous charge
 has been significantly reduced in volume.  The primary burner is shut off
before the charge door is opened.  If necessary, the ash bed  is stoked
before the new charge is added.  After the new charge is added, the  door
 is closed and sealed and the primary burner reignited.
     7.4.4.2   Shutdown.  There is no burndown period in the operation of
excess-air/pathological incinerators.  The degree of burnout achieved is
                                   7-11

-------
  dictated  by the length  of time that the primary  burner  is  left  in
  operation.   After complete destruction of  the waste  has  been  achieved  (as
  noted by  visual  observation through a viewport), the primary  burner  is
  shutdown.   The  secondary  burner is  not shut  off  until all  smoldering from
  residual  material  on the  hearth in  the primary chamber has ceased.8  After
  all smoldering  in  the ignition chamber has ceased, the secondary burner is
  shutdown, and the  incinerator  allowed  to cool.  Once the incinerator is
  cool, the ash residue is ntanually removed by shoveling and/or raking.
  7.4.5  Wet  Scrubbers
      Proper operation of a  scrubber requires that the operator
  (1) establish a fixed liquid flow rate to the scrubbing section,
  (2) initiate gas flow through  the system by  starting a fan, and (3) set up
 the liquid  recirculatlon system so that suspended and dissolved solids
 buildup does not create operating problems.  Once the system  has been
 started and operation has stabilized, little additional  operator attention
 will be needed,  other than for routine operation and maintenance
 activities.   Operators  should refer to the instruction manual  provided by >
 the scrubber manufacturer for adjustment of site-specific operating
 conditions.
      7.4.5.1  Startup.   The following sequence must  be  adhered
 to during  startup of a  scrubbing system to  ensure proper operation:
      1.  Turn on the liquid recirculatlon system  or  liquid  supply(s)  to
 the scrubber(s)  and mist eliminator.
     2.  Adjust  the liquid flow rates to those specified  in the
 instructions supplied by the scrubber manufacturer.
     3.  If  the  induced  draft or forced draft fan feeding the  scrubbing
 system has a damper installed at its  inlet  or outlet, close the  damper.
     4,  Start the  induced  draft or  forced draft  fan  feeding the scrubbing
 system.
     5.  If  the system is equipped with  a damper, gradually open the
 damper until the proper gas  flow rate  is established.
     6.  Again, recheck the  liquid flow rate(s) and adjust as  necessary.
     7.  Check the differential  pressure across the scrubber and compare
with the design pressure drop specified in the manual.  If the pressure
drop is too high, either the  liquid flow rate or the  gas 'flow  rate  is.too
                                   7-12,

-------
 high.  If the system is equipped with a damper,  close the damper off
 slightly until  the differential  pressure reaches the proper level,  or if
 it is not possible to decrease gas flow rates, decrease the liquid  flow
 rate to the scrubber until  the proper differential  pressure is
 established.   If the differential pressure is too low across the scrubber,
 either the liquid rate is  too low or the gas flow rate is too low.   To
 correct this  condition, either increase the gas  flow rate by opening a
 damper, or increase the liquid flow rate to the  scrubber.
      8.  Initiate the liquid bleed to treatment  or disposal, as specified
 in the manufacturer's manual.  If the bleed is taken by an overflow from
 the recirculation tank, the flow rate at this point is established:by the
 rate at which makeup water  is introduced to the  recirculation tank-.  The
 manufacturer's manual  should show the anticipated water evaporation rate
 in the scrubbing  system.   If, as an example, the evaporation rate is
 1  gallon per minute,  and if you  wish to  establish a bleed rate of 1 gallon
 per minute, it will  be  necessary to feed 2  gallons  per minute of total
 water to the recirculation  tank.   The bleed rate is  determined by the rate/
 at which the sol Ids  build up in  the scrubbing system.   These solids can  be
 either suspended  or  dissolved solids  or  both.  A scrubber is capable of
 handling a maximum of 3 percent  (weight)  suspended  solids,  and it 1s
 suggested that the dissolved solids  not  exceed 10 percent (weight).  Based
 on design data, a recommended bleed  rate  from the system  should  be
 provided by the manufacturer.  The operator should combine  this  figure
 with the evaporation figures to give a total recommended  makeup  water rate
 to  the recirculation tank if an overflow  type bleed  system  is  used.   If  a
 bleed  system is; provided from a slip stream off  the  pump  feeding  the    .  '
 venturi scrubber, liquid makeup is normally provided by a  level  control
 device in the recirculation  tank.  The flow rate required will be the  same
 as the flow rate required for  the overflow bleed system.  However,  it  is
only necessary to ensure that  adequate water supply  is available  to  the
 level control  device on a continuous basis.
     7.4.5.2  Shutdown.  To  shut the system down without overloading  the
fan or causing any damage to the scrubbing equipment, the following
procedures should be adhered to:
                                   7-13

-------
      1. . Shut off the induced draft or forced draft fan feeding the
 scrubbing system.
      2.  Wait until the fan impeller has stopped rotation and shutoff the
 scrubbing water recirculation pump.
      3.  Shut off the makeup water supply system.
 7.4.6  Dry Scrubbers
      Dry scrubbers either inject an alkaline slurry, which is subsequently
 dried by the hot flue gas, or a dry alkaline powder into the flue gas
 stream for acid gas control.  Problems associated with startup and
 shutdown of dry scrubbers are directly related to excess moisture in the
 system.  Excessive moisture refers to condensed water vapor and is a
 function of the moisture content, temperature, and resulting saturation of
 the flue gas in the system.  Condensed water creates problems with solids
 buildup due to the hygroscopic nature of the alkaline sorbent materials
 and corrosion due to the corrosive nature of the salts,  such as calcium
 chloride,  resulting from the acid/alkaline neutralization reactions.
 Proper  startup and shutdown procedures are intended to prohibit the      j
 condensation of water vapor in the presence of the alkaline sorbent or the
 reaction product salts.
      7.4.6.1  Startup.   Prevention of condensation during startup can be
 achieved by  bringing the temperatures of  the incinerator  and  flue gas up
 to  normal operating  levels  before injection of the slurry or  dry  sorbent.
 Ideally, auxiliary fuel  firing should be  utilized  to  achieve  these temper-
 atures  before charging with wastes  to prevent  uncontrolled  emissions  of
 acid gases.   If  the  incinerator  is  started  up  with  waste  feed material,
 slurry  feed  should be regulated  to  provide  a minimum wet  bulb/dry bulb
 temperature  difference of 90°  to  100°F.   This  temperature differential
will prevent condensation and will  allow  efficient  removal of the  acid  gas.
     7.4.6.2  Shutdown.  At shutdown  the  system will eventually cool  down
to ambient temperature.  If the temperature  cools below the saturation
temperature, condensation will occur.  The approach to preventing  solids
buildup and salt corrosion at shutdown should be to eliminate, as much  as
possible, the alkaline sorbent materials and reaction products from the
system before saturation temperatures are reached.  Sorbent injection
should be terminated and the exhaust system allowed to purge itself of  all
                                   7-14

-------
  sorbent and reaction products before the temperature cools to the
  saturation point.  To achieve this goal, auxiliary fuel-firing should be
  utilized to maintain a minimum wet bulb/dry bulb temperature difference of
  90° to 100°F until all waste are combusted.  The auxiliary fuel firing
  should be continued long enough to maintain flue gas temperatures above
  saturation until the system is purged of sorbent and reaction products.
  Purging of the system should include a complete cleaning cycle for the
  fabric filter before the system is allowed to cool.  If the alkaline
 filter cake is retained on the bags, condensation can result in blinding
 of the bags.
 7.4.7  Fabric Filters
      While the performance of a fabric filter is dependent on proper
 design, recordkeeping practices, and the timely detection of upset
 conditions, proper operation and preventive maintenance procedures are
 necessary  to  ensure satisfactory,  long-term performance.  This section
 discusses  general  operating procedures that can minimize unexpected
 malfunctions  and improve the performance of the fabric filter.   Preventives
 maintenance practices  are discussed  in Chapter 4.   Proper operating
 procedures are  important during  startup, normal  operation,  shutdown,  and
 emergency  conditions.
      7.4.7.1  Startup.   Prior to operation  of  a  new fabric  filter,  all
 components including the cleaning system, the  dust-discharge  system,  and
 the  isolation dampers and fans should undergo  a  complete check for  proper
 operation.  Clean  ambient air should be  passed through  the  system to  con-
 firm that all bags  are properly  installed.  New  bags are prone to abrasion
 if subjected to  high dust loadings and full-load gas flows', particularly
 during the initial  startup before the bags  have  the benefit of 'a dust
 buildup cake to protect  the fibers from  abrasion or to  increase their
 resistance to gas flow.   Full gas flow at high dust loadings can allow the
 particulate matter to impinge on the fabric at high velocity and result  in
 abrasion that may shorten bag life.  In addition, the dust may penetrate
 so deeply into the fabric that the cleaning system cannot remove it,  and a
 "permanent11 pressure drop results.  Bag abrasion may be prevented by
either (1)  operating the  incinerator at a low throughput and reduced  gas
volume to allow the dust cake to build gradually or (2) precoating the
                                   7-15
                                 *

-------
 bags to provide a protective cake before  the incinerator  exhaust  is  intro-
 duced.   Precoat materials may include either flyash  or  pulverized limestone.
      If the fabric filter is operated at  temperatures below the dewpoint
 of water and/or the hydrochloric  acid formed by  the  combustion of
 chlorinated plastics,  serious operating problems may arise.  Warm, moist
 gas that is introduced into  a cool  or cold  fabric filter  will cause
 condensation on the bags  or  on the  fabric filter shell.   Condensation can
 cause a condition known as "mudded" bags  where the bags are blinded  by
 dust and moisture.   The acid dewpoint depends on the amount of moisture
 and acidic  material  in the gas stream.  Condensation of acid can  cause
 corrosion of the fabric filter components,  sticky particulate and cake-
 release problems, and  acid attack on some fabrics,.   Preheating the fabric
 filter  to a temperature above the acid dewpoint  will prevent condensation
 and enhance fabric  filter performance.  Because  the  incinerator goes
 through a warmup period using natural  gas or fuel oil burners prior  to
 waste combustion, the  problems associated with condensation of water or
 hydrochloric acid are  unlikely to occur.  If sufficient heat in the  fabrics
 filter  collector is  not obtained  from the incinerator auxiliary burner
 during  startup,  then additional auxiliary burners for preheating  the
 baghouse should  be  added.
      Unstable combustion  during startup can  cause some carbon carryover,
 which may result in  a  sticky  particulate.  This  situation creates the
 potential for fires  in the fabric filter  when a  combustion source and an
 adequate oxygen  supply are available.  Therefore, during  startup, the
 fabric  filter hoppers  that collect  the particulate should be emptied
 continually.  More  importantly, unstable  combustion  conditions during
 startup  should be minimized by going  through proper  incinerator startup
 procedures.
      7.4.7.2  Shutdown.  The  top  priority during shutdown of a fabric
 filter  is avoiding dewpoint conditions.   Bag cleaning and hopper  emptying
 are lower priority items.
     When processes operate on a  daily cycle, the last operation  of  the
 day should be to  purge moisture and acidic materials from the fabric
 filter without passing through the dewpoint.  In the case of a hospital
waste incinerator, the operator should leave the secondary chamber burner
                                   7-16

-------
 on for a few minutes after combustion is completed to remove moisture from
 the fabric filter.  Ambient air could then be drawn through the system to
 purge the remaining combustion products.
      After shutdown, 5 to 20 minutes of cleaning should be allowed in
 pulse-jet systems.  This procedure will help prevent blinding of the
 bags.  Additionally, continuing to operate the hopper discharge system
 while the cleaning system 1s in operation will minimize the potential of
 hopper pluggage.
      It is Important to note that bypassing the fabric filter during
 startup, soot blowing,  or an emergency may not be acceptable to the
 applicable regulatory agency.  Such occurrences should be investigated and
 addressed during the design stages of development.
 7.5  WASTE HEAT BOILER
      Many hospital  Incinerator systems utilize a waste heat boiler for
 producing steam.   When  a waste heat boiler is  included in the incineration
 system,  the air Inspector should  be cognizant  of the following additional
 items related to  incinerator operation:                                   j
      1.   Boiler soot  blowing cycle and
      2.   Use of the bypass  stack.
      The  inspector should find out what  soot blowing cycle  is used by the
 facility  and should understand any special  provisions  in  the  air regula-
 tions  related  to  soot blowing;  e.g.,  does  the  opacity  regulation allow one
 6-minute  period of increased  opacity  per hour  to  accommodate  excursions
 such as soot blowing?   If possible, the  inspector should  observe the
 opacity of emissions during  a  soot blowing  cycle.
     Typically, an Incinerator/boiler system will include a bypass  stack
 (or duct) to allow the  incinerator emissions to bypass the boiler when  the
 boiler is off-line or during an emergency situation  (such as  loss  of  power
 to the Induced draft fan).  On  Incineration systems that  include a waste
 heat boiler but do not include an  add-on air pollution control device,  the
emissions to the atmosphere are not significantly affected when the bypass
system is used..  However, when both an add-on air pollution control device
and a boiler are part of the incineration system, the combustion gases
typically bypass both the boiler and the air pollution control device when
the bypass stack is used; bypassing the air pollution control device will
                                   7-17

-------
 affect tfie emissions to the atmosphere.   Consequently, the air inspector

 should be aware of any special permit conditions (or general  provisions  of
 the regulations) relative to use of the  bypass stack (i.e., bypassing  the

 air pollution control).  The inspector should obtain information about the
 facility's operating procedures, frequency of use,  and recordkeeping
 procedures relative to use of the bypass stack.
 7.6  CITIZENS COMPLAINT FOLLOWUP

      Air pollution agencies, including EPA,  receive many citizens
 complaints.  Complaints should be welcomed by the Agency since they serve

 to Increase overall surveillance and provide early  warnings of developing
 problems.   Appendix F provides a form which  can  be  used to document

 citizen complaints.
 7.7  REFERENCES FOR CHAPTER 7

 1.   Hospital  Waste Combustion Study:   Data Gathering Phase.   Final Draft
     Report.  U.  S.  Environmental  Protection  Agency,  Office of Air Quality
     Planning  and Standards,  Research  Triangle Park,  North  Carolina.
     EPA 450/3-88-017.   December 1988.  p.  5-2.

 2.   Ibid.

 3.   Ibid.

 4.   U.  S.  Environmental  Protection Agency.   EPA  Guide  for  Infectious Waste
     Management.   Office  of  Solid Waste.  Washington, D.C.
     EPA 530-SW-86-014.   May  1986.

 5.   Ecolaire  Combustion  Products,  Inc.   Equipment Operating Manual for
     Model  No. 480E.

 6.   Doucet, L. C.   Controlled-Air  Incineration:  Design, Procurement, and
     Operational Considerations.  American Hospital! Association Technical
    Series, Document No. 055872.  January  1986.

 7.  Simonds Incinerators.  Operation and Maintenance Manual for
    Models  751B,  1121B,  and 2151B.  January  1985.

8.  Consumat Systems, Inc.  Technical Data Sheet.

9.  Ontario Ministry of the Environment.   Incinerator Design and Operating
    Criteria, Volume II-Biomedical Waste  Incinerators.  October 1986*

10. Air Pollution Control District of Los Angeles County.  Air Pollution
    Engineering Manual, AP-40.  U. S. Environmental  Protection Agency.
    May 1973.
                                   7-18

-------
                                 8.0  GLOSSARY
             3
  ABSORPTION.   The process by which gas molecules are transferred to a
       liquid phase.
  ACID GASES.1*  Corrosive gases formed during combustion of chlorinated or
       halogenated compounds,  e.g., hydrogen chloride (HC1).
  ACTUAL CUBIC FEET PER MINUTE (acfm).3  A gas flow rate expressed with
       respect to temperature  and pressure conditions.
  ADIABATIC SATURATION.1   A process in which an air or gas stream is
       saturated with water vapor without adding or subtracting heat from
       the system.
  AIR,  DRY/  Air containing no water vapor.
  ASH.    The solid  debris that is the byproduct of the combustion of solid
       materials.
  ATOMIZATION.1*   The reduction of liquid to a fine spray.
  BAROMETRIC SEAL.1  A  column  of liquid used to hydraulically  seal  a
       scrubber,  or  any component thereof,  from the atmosphere or any other
       part  of the system.
  BURN  RATE."*  The total  quantity of  waste  that is  burned  per  unit  of time
       that  is usually  expressed  in pounds  of waste per  hour.
              i*                            v                    •
  CHARGE  RATE.?  Quantity of waste material  loaded  into  an  incinerator  over
       a  unit of time but which  is not  necessarily  burned.   Usually
       expressed  in pounds of waste per hour.
 COCURRENT OR CONCURRENT."*  Flow  of  scrubbing  liquid  in the same direction
       as the gas stream.
 COLLECTION EFFICIENCY.1  The ratio  of the weight of pollutant collected  to
       the total weight of pollutant  entering the collector.
            *+
 COMBUSTION.   A thermal process  in  which organic compounds are broken down
       into carbon dioxide (C02) and water (H20).
 CONDENSATION.1  The physical  process6of converting a substance from the
      gaseous phase to  the liquid phase via the removal of heat and/or the
      application of pressure.
.CROSSFLOW.*  Flow of  scrubbing liquid normal  (perpendicular)  to the gas
      stream.
                                     8-1

-------
 CYCLONE.   A device 1n which the velocity of an inlet'gas stream is
      transformed into a confined vortex from which inertia!  forces tend to
      drive particles to the wall.
        2
 DAMPER.   An adjustable plate installed in a duct to regulate gas flow.
 DEHUMIDIFY.   To remove water vapor from a gas stream.
          4.
 DEMISTER.    A mechanical device used to remove entrained water droplets
      from  a scrubbed gas stream.
 DENSITY.   The ratio of the mass of an object to the volume  of the
      object.
 DIFFUSION  (AEROSOL).**  Random motion of particles caused by  repeated
   ,   collisions of gas molecules.
 DRAFT.   A gas flow resulting from pressure difference;  for  example,
      between an.incinerator and the atmosphere,  which moves  the products
      of combustion from the incinerator to the atmosphere.   (1)  Natural
      draft:  the  negative pressure created by the difference in density
      between the  hot flue gases and the atmosphere.   (2)  Induced draft:
      the negative pressure created by the  vacuum action  of a fan or blowery
      between the  incinerator and the stack.   (3)  Forced  draft:   the
      positive pressure created  by the fan  or blower,  which supplies the
      primary or secondary air.
DRAG  FORCE.**   Resistance of motion of an object  through  a medium.
DUST.    Solid particles  less than 100 micrometers  created by  the breakdown
      of  larger particles.
DUST  LOADING.   The  weight of solid particulate  suspended in  an  airstream
      (gas).   Usually expressed  in terms of grains  per cubic foot, grams
     per cubic meter, or pounds per thousand pounds of gas.
     CHERMIC.1*  A chemical reaction that absorbs heat fi
     surroundings.  For example:  C+H20+heat —> CO+H2
     UNMENTY
     stream.
ENDOTHERMIC."  A chemical reaction that absorbs heat from its
            id-
ENTRAINMENT.3  The suspension of solids, liquid droplets, or mist in a gas
EXCESS AIR INCINERATION."  Controlled burning at greater than
     stoichiometric air requirements.
EXOTHERMIC.**  A chemical reaction that liberates heat to its
     surroundings.  Combustion is an exothermic reaction.  For example:
     C+02 --> C02+heat
                                    8-2

-------
 FEEDBACK CONTROL.3  An automatic control system in which information about
      the controlled parameter is fed back and used for control of another
      parameter.
 FIXED CARBON/  The nonvolatile organic portion of waste.
 GRID.   A stationary support or retainer for a bed of packing in a packed
      bed scrubber.               ,
 HEADER.    A pipe used to supply and distribute liquid to downstream
      outlets.
 HEAT RELEASE RATE."  The energy released over a unit of time during
      combustion.  Calculated as the heating value (Btu/pound)xburn rate
      (pound/hour).  Usually expressed as Btu/hour (Btu/h).
 HEATING  VALUE."*  The amount of heat that is released when a material  is
     . combusted usually expressed as Btu/lb.
 HUMIDITY,  ABSOLUTE.2  The weight of water vapor carried by  a unit weight
      of  dry air or gas.
 HUMIDITY,  RELATIVE.2  The ratio of  the absolute humidity in a gas to  the
      absolute humidity of a saturated gas at the same temperature.
 HYDROPHILIC MATERIAL/  Particulate matter that adsorbs moisture.
 INCINERATOR.1*  A thermal  device which combusts organic compounds  using
      heat  and oxygen.        '
 INDUCED  DRAFT FAN.3  A fan used to  move a gas stream by creating  'a
      negative pressure.
 INERTIA."*   Tendency  of a  particle to  remain in a fixed direction,
      proportional  to mass  and  velocity.
 INTERCEPTION.1*   A  type of  aerosol collection related  to  impaction,  in
     which  an aerosol  impacts  the side  of an obstacle  because  of  reduced
     mobility across streamlines.
 LIQUID-TO-GAS RATIO.3  The  ratio of the  liquid  (in gallons  per minute)  to
     the inlet gas flow rate (in acfm).
 LIQUOR.   A  solution of dissolved substance  in  a  liquid  (as opposed to  a
     slurry,  in which  the materials are  insoluble).
MAKEUP WATER.   Water  added to compensate for water  losses  resulting from
     evaporation and water disposal.
MIST ELIMINATOR.   Equipment that removes entrained water droplets
     downstream from a scrubber.                                    .
                                    8-3

-------
 MOISTURE.Water contained in the waste which must  be evaporated by the
      heat generated during combustion.
     [TY/  Measure
      parti oil ate.
OPACITY.**  Measure of the fraction of light attenuated by suspended
 PACKED-BED  SCRUBBER.3   Equipment using small plastic  or  ceramic  pieces,
     with high  surface area to volume ratios for  intimate  gas/liquid
     contact for mass  transfer.
 PARTICLE.1*  Small  discrete mass of solid or liquid matter.
 PARTICLE SIZE."*  An  expression for the size of  liquid or solid particle
     usually expressed in  microns.
 PARTICULATE EMISSION/  Fine solid matter suspended in combustion gases
     carried to the  atmosphere.  The  emission rate is usually expressed as
     a concentration such  as grains per dry standard  cubic  feet  (gr/dscf)
     corrected to  a  common base,  usually 12 percent C02.
 PARTICULATE MATTER."*  As related  to control technology,  any material
     except uncombined water that exists as a solid or liquid in the
     atmosphere or in  a gas stream as measured  by a standard (reference)
     method at specified conditions.   The standard method of measurement
     and the specified conditions should be implied in or  included with
     the particulate matter definition.
 PATHOGENIC.  Waste material  capable of causing  disease.
 PATHOLOGICAL.  Waste material  relating to the study of the  essential
     nature of disease and  generally  altered or caused by disease.
 PENETRATION.**  Fraction of  suspended  particulate that passes through a
     collection device.
pH.1'  A measure of acidity-alkalinity of a solution;  determined  by
     calculating the negative  logarithm of the  hydrogen  ion concentration.
PRESSURE DROP.3  The difference in static pressure between  two points due
     to energy losses  in a  gas  stream.
PRESSURE, STATIC/   The pressure  exerted in all directions  by a  fluid;
     measured in a direction normal (perpendicular) to the  direction of
     flow.
PRESSURE, TOTAL."*  The  algebraic  sum  of the'velocity  pressure and the
     static pressure.
PRESSURE, VELOCITY/  The kinetic  pressure in the direction of gas flow.  •
                                    8-4

-------
 PROXIMATE ANALYSIS/  The determination of the amounts of volatile matter,
      fixed carbon, moisture, and noncombustible (ash) matter in any given
      waste material.
 PYROLYSIS.  The chemical destruction of organic.materials in the presence
      of heat and the absence of oxygen.
 QUENCH.   Cooling of hot gases by rapid evaporation of water.
 REAGENT.   The material used to react with the gaseous pollutants.
 RETENTION TIME/  Amount of time the combustion gases are exposed to
      mixing, temperature, and excess air for final combustion.
 SATURATED GAS.   A mixture of gas and vapor to which no additional vapor
      can be added, at specified conditions.  Partial pressure of vapor is
      equal to vapor pressure of the liquid at the gas-vapor mixture
      temperature.
 SIZE DISTRIBUTION/  Distribution of particles of different sizes within a
      matrix of aerosols; numbers of particles of specified sizes or size
      ranges,  usually in micrometers.
 SLURRY.1  A mixture of liquid and finely divided insoluble solid
      materials.
       i^
 SMOKE.    Small  gasborne particles resulting from incomplete combustion;
      particles  consist predominantly of carbon and other  combustible
      material;  present in sufficient quantity to be observable
      independently of other  solids.
 SPECIFIC GRAVITY.1   The ratio between the  density  of a  substance at  a
      given temperature and the  density of  water at 4°C.
 SPRAY NOZZLE.1  A  device used for the controlled  introduction of scrubbing
      liquid at predetermined  rates,  distribution patterns,  pressures,  and
      droplet sizes.
 STANDARD  CUBIC FEET  PER  MINUTE  (scfm).3  A  gas  flow rate expressed with
      respect to standard  temperature  and pressure  conditions.
 STARVED AIR INCINERATION.  Controlled  burning at less than  stoichiometri-c"
      air  requirements.
STOICHIOMETRIC.  The theoretical  amount of air  required for complete
     combustion of waste to C02 and H20 vapor.
STREAMLINE."*  The visualized path of a fluid in motion.
                                    8-5

-------
 STUFF AND BURN.   A  situation  in which  the  charging rate is greater than

      burning  rate to the  incinerator.

 TEMPERATURE,  ABSOLUTE.2   Temperature expressed  in degrees above absolute
      zero.

 VAPOR.*   The  gaseous form of  substances that are normally in the solid or

      liquid state and whose states can be  changed either by increasing the
      pressure or  by decreasing the temperature.

 VOLATILE  MATTER.  That portion of waste material which can be liberated
      with the application of  heat only.


 REFERENCES FOR CHAPTER 8

 1.  Industrial Gas Cleaning Institute.  Wet Scrubber Technology.
    Publication WS-1, July 1985.

 2.  Industrial Gas Cleaning Institute.  Fundamentals of Fabric Collectors
    and Glossary of Terms.  Publication F-2, August 1972.

 3.  Flue Gas  Desulfurization  Inspection and Performance Evaluation.
    EAP/625/1-85-019.  October 1985.

4.  U. S. Environmental  Protection Agency, Control  Techniques for
    Particulate Emissions from Stationary Sources.   Volume I.
    EPA-450/3-81-005a.   September 1982.
                                   8-6

-------
                 APPENDIX A.



INSPECTION CHECKLIST FOR WASTE CHARACTERIZATION

-------

-------
              INSPECTION CHECKLIST FOR WASTE CHARACTERIZATION
 Date:
 Inspectors name:
 Agency affiliation:
 Facility name:  	
 Address:
 Facility contact person:	 Telephone No.
 Refuse volume, Ib/d:	
                "  .                                             Approximate
Description of waste                                              percent
  General trash                                               	'
  Garbage                                                     	•
  Pathological                                                	
  Red bag infectious	.
Heavy metals in waste, yes/no:  ___________ _
Total plastics content, percent:  _ _
Halogenated plastics content, percent:  _
Estimated moisture content, percent:  _ ______
Estimating heating value, Btu/lb:  __ _
Waste handling practices
   1.  Are infectious waste properly bagged and marked, yes/no:
   2.  Are sharps contained in puncture resistant containers,
       yes /no:  __ _
   3.  Are torn or ruptured "red bags" obvious, yes/no:
   4.  Are liquids leaking from the bags, yes/no:
   5.  Are all reasonable steps being taken to assure integrity of red
       bags prior to charging to the incinerator?  	•
Storage practices
   1.  Storage duration, days:
   2,  Storage area temperature, °F:
Comments:
                                   A-l

-------

-------
             APPENDIX B.
INSPECTION CHECKLIST FOR INCINERATORS

-------

-------
             APPENDIX B.  INSPECTION CHECKLIST FOR- INCINERATORS
 Date:	
 Inspectors name:   	    ..'	
 Agency affiliation:	
 Facility name:           -  .	      .     	
 Address:
 Facility contact person:  	Telephone No.
 Incinerator type/operating mode:
   Starved air	__	
   Excess air
   Batch fed                 -	
   Intermittent duty	     ,
   Continuous duty
 Charging  rate,  Ib/h:
 No.  of  charges/h:
 Is  primary air system  in good working order, yes/no:	-
 Is  secondary air system, in good working order, yes/no:
 Static pressure in primary chamber,  in. w.c.:  	.    	
 Primary combustion chamber temperature, °F:     •	-
 Secondary combustion chamber temperature,  °F:	
 Exit gas oxygen level, %:  	   '	
 Exit gas CO level, %:	
Opacity CEMS inspected, yes/no, comments:
Visible emissions from stack, %:       •
Fugitive visible emissions from ash removal:  	
  (Attach Method 9 data form)
Other fugitive emissions observed:	
Incinerator shell corrosion and/or hot spots, yes/no:
Audible air leaks, yes/no:	
Ash quality:  	
Visual inspection of waste bed:  	
Visual inspection of secondary burner:
                                    B-3

-------
Startup procedures:
  1.  Frequency:
  2.  Temperature in secondary chamber before charging, °F:  	
Shutdown procedures:
  1.  Temperature in primary chamber at cutoff of secondary burners,  °F:
Comments:
                                   B-4

-------
                   APPENDIX C.
INSPECTION CHECKLIST FOR POLLUTION CONTROL SYSTEM

-------

-------
            INSPECTION CHECKLIST FOR VENTURI/PACKED-BED  SCRUBBERS
 Date:
 Inspectors  name:   _
 Agency  affiliation:
 Facility  name:  	
 Address:
 Facility contact  person:   	Telephone No.
 Stack emissions opacity, yes/no (see  Method 9 form):   	
 Process fugitives emission,  opacity average:	•
 Plume color:
 Water vapor plume present  (yes/no):
 Fan vibration problem  (yes/no):	
 Fan current, amperes:     	
Scrubber pressure drop,  in. w.c.:  	
Mist eliminator pressure drop,  in. w.c.:
Scrubber liquid flow rate, gpm:  '
Scrubber liquid pressure, psig:	
Scrubber liquid pump current:  	
Audible pump cavitation  (yes/no):  	
Nozzle pressure, psig:  	'
Physical problems of scrubber (yes/no):
Physical problems of ducting (yes/no):
Scrubber liquid effluent, pH level:  	
Recirculation tank pH level:	
Recirculation tank percent suspended solids:  ______
Mist eliminator feed water percent suspended solids:
Gas temperature at scrubber inlet, °F:	
Gas temperature at scrubber outlet, °F:  •	
Comments:
                                   C-6

-------

-------
                   INSPECTION CHECKLIST FOR DRY SCRUBBERS
 Date:          '     	'     	   •'
 Inspectors name:	
 Agency aff 111at1on:	•  '   	    -	
 Facility name:	-    	•
 Address:
 Facility  contact person:      •	.	Telephone No,
 Process fugitive emissions  (yes/no):	'
 Plume color:
Average opacity,  percent:  	
Spray dryer
&
  Approach-to-saturat1on temperature:
  Inlet gas temperature, dry bulb  °F:
  Outlet gas temperature, dry bulb °F:
  Outlet gas temperature, wet bulb °F:
  Makeup reagent  feed rate:	
  Recycle reagent feed rate:  	
  Nozzle air pressure, psig:  	
  Nozzle slurry pressure, psig:	
Dry scrubber
  Reagent feed rate:
  SolIds recycle rate:
Comments:
                                    C-7

-------
             INSPECTION CHECKLIST FOR PULSE-JET  FABRIC FILTERS
Date:
 Inspectors name:  _
Agency affiliation:
Facility name:  	
Address:  	
Facility contact person:	Telephone  No.
Stack emissions opacity, 6 min average:	'
Condensed water vapor plume, presence/absence:
Process fugitive emissions, average opacity:
Plume color:	
Pressure drop, baghouse compartment 1, in. w.c.:	^_
Pressure drop, baghouse compartment 2, in. w.c.:	,     	
Pressure drop, baghouse compartment 3, in. w.c.:	'
Pulse cleaning cycle, min:  	.	
Pulse cleaning pressure, psi:  	
Baghouse gas Inlet temperature, °F:	;	J
Baghouse gas outlet temperature, °F:	
SolIds discharge rate, Ib/h:	
Clean side deposits (yes/no):	
Comments:	
                                   C-8

-------
   APPENDIX D.
METHOD 9 WORK SHEET

-------

-------





CwWAWT *****
VISIBLE S.MISSICN OSSEnVATJCr,' FGriM NQ>

; STREET ADDRESS ;

CITY
PHONE  ' iv^^ri
SMI End

VOUT SKETCH Oww »«««l AI»W»
o
X- 	 - -
Kinvwv ^www
ObMrvwrt Petition
I>^^^^
nan tin*
ADOmONAL JNFOHMATK3N .
•
V\~ 3 . «S i 30 *5 1 COMMEMTS
UIM -VI
1 ;
2 ' ! '
3 - !
4 - !
5
6
?
1
1
10
11
1 .












12
13 :
14
19
1C
1T
11
It
20
21








22


J






a i
24
25
21
27
a
a
30














OBSERVER'S NAMC (PRtNT)
OSSERVER-S SIGNATURE °*TC .
i
ORGANIZATION
CERTIFIED BY °*TE
CONTfl
UUED ON VCO FORM NUMBER

. • • • D-l •

-------

-------
  APPENDIX  E.
SAFETY CHECKLIST

-------

-------
                       APPENDIX E.  SAFETY CHECKLIST
Waste handling
  1.  Is handling of red bags kept to a minimum?  yes/no
  2.  Is the integrity of red bag waste maintained during handling?
      yes/no
Operator protective equipment
  1.  Does the operator wear proper protective equipment?
      a.  Hard soled boats;
      b.  Thick rubber gloves;
      c.  Safety glasses;
      d.  Disposable or special coveralls; and
      e.  Dust mask/respirator
Operating hazards
  Are available safety hazards evident?
  1.  Spilled liquids in the waste handling area
  2.  Scrubber solution leaks, spills
                                   E-l

-------

-------
APPENDIX F.  CITIZEN COMPLAINT FORM

-------

-------
                                     COMPLAINT FORM"
                                            orww or tvo»i
Statement of  Mr
              ICMC* O«*
Home Address _

Mailing Address
                                                             Tel. No.
                  IK S*n* •• HOOK into S«—• i
Business Address
                  III Nan* imtf  Nan* I
Business Teleonone No. ______________
   NAME OF COMPANY OR SOURCE.
                                                         •.C.tyl
                                                        . Extension
                                            Ill Not HOW-" CM»« *•"•>
 2  Nature o* emission complained of:   (Check oox»       Smoke |—|
   Dust  C_]    Soot  Q     Odors  Q    Other  Q
   Oescrioe odor or emission:                        -
 3  Date ano time emissions observed _
 4  if oossioie. designate specific source
                                                          r o   v'•••» M inciuo* Oi
                                            <£«. Sun. !•"• itc.i
 5.  Have you or any member of your household oecome .11 because of these emissions?
                        Yes  D                 No  D
 6.  Oescrioe nature of illness                               .
    State any damage done to your orooertv. home, furn.ture. automoo.le. clothing, etc..
 8.  W,ll you testify .n court?     YesQ   No D  .«--.•««--»•-«"•"-• «••—-—'
    I declare under penalty of penury that the above mformauon .s true ano correct.
                    	 19.
    Executed on
                                      at
                                             F-l

-------

-------
APPENDIX G.  EXAMPLE INSPECTION REPORT

-------

-------
 Facility Name:
 Address:

 1.0. No.:
 Facility Contact:
 Title:
 Phone No.:
 Type of Inspection:
 Date:
 Time:
 Inspector's Name:
 Agency:

 Source Inspected:
APPENDIX 6.  EXAMPLE INSPECTION REPORT
      General  Hospital
      516 Memorial  Lane
      Raleigh,  North Carolina
      28421
      Mr.  George Brown
      Facility  Engineer
      (404) 596-2431
      Routine annual  Level  II inspection
      June  30,  1990
      7:00  - 11:30 a.m. EDST
      John Ooe
      U. Si Environmental Protection Agency
      Region IV
      Incineration Facility
 Background  Information
     General Hospital operates one Acme Model 200 controlled-air
 incinerator rated at 300 Ib per charge of refuse.  The unit is controlled
 by an Acme  Model 300 venturi scrubber.  The incinerator is subject to the
 State incinerator emission regulation, No. 4305, which limits particulate
 emissions to 0.08 gr/dscf at 12 percent C02 and visible emissions to
 20 percent  opacity.  The State operating permit'stipulates that secondary
 chamber combustion temperatures be maintained at a minimum of 1800°F with
 a retention time of 2 seconds.  The permit also stipulates that the
 venturi scrubber be operated at a pressure drop of 20 in. w.c. with a
 liquid-to-gas ratio of 8 gallons per 1,000 actual cubic feet of exhaust
gas.  The incinerator is operated in a batch mode.  On a typical day,
operation of the incinerator starts around 7 a.m. with cleanout of ash
from the previous day.   The unit is then charged with a mixture of general
hospital refuse and red bag waste and sealed.   The incinerator secondary
                                   G-l

-------
chamber is then preheated for approximately 30 minutes with auxiliary fuel
firing.  The waste charge is burned for a set time period of 5 hours and
allowed to cool down overnight for ash removal the following morning.
During the initial phases of the waste combustion, the waste material
provides the necessary heat, and the combustion is self-sustaining.
During the later phases of burnout, auxiliary fuel burners are used to
maintain the necessary temperatures.
General Inspection Information
     On June 20, 1990, I phoned Mr. George Brown, Facility Engineer, and
notified him that a representative'of the North Carolina Air Pollution
Control Division (APCD) and I would be conducting an annual inspection of
the incineration facility on June 30, 1990.  Because of the batch mode of
operation of the incinerator, notification of the facility was necessary
to obtain the'operating schedule to ensure that the important phases of
operation, including ash cleanout, charging, and burndown, could be
observed.
     On June 30, 1990, Mr. John Smith of the APCD and I arrived at the    j
facility at 7 a.m. and met with Mr. Brown.  Both Mr. Smith and I presented
our credentials and explained the purpose of the inspection.  Mr. Brown
stated that the incinerator was used to burn both general refuse and red
bag wastes.  He estimated that red bag wastes comprised approximately 40
percent of the waste burned.  Mr. Brown was unable to provide an estimate
of the percentage of PVC plastics in the waste.
Facility Inspection
     At approximately 7:45 a.m., Mr. Brown, Mr. Smith, and I moved to the
incinerator location.  The incinerator is located on a concrete pad
approximately 75 feet from the loading dock.  General refuse contained in
white plastic garbage bags was stored in two plastic bins on the loading
dock.  A third plastic bin contained red bag wastes.  The waste on the
dock represented the waste generated by the hospital the previous day for
incineration.  The red bag wastes were approximately 30 to 40 percent by
volume of the total wastes to be incinerated.  The control panel for the
incinerator contained maximum and minimum temperature thermostat settings
for both the primary and secondary chambers of the incinerator.
Temperature gauges for both chambers were also available on the control
                                    G-2

-------
 panel.  The exhaust duct from the incinerator passed through an adjustable
 throat venturi scrubber followed by a cyclonic mist eliminator.  The
 venturi scrubber was equipped with a differential pressure meter and
 liquid flow meter.  An induced-draft fan was located downstream of the
 mist eliminator.  The fan was equipped with a static pressure gauge.  The
 exhaust gases were emitted through a 25-fcot-tall steel stack.
 Inspection Findings
      I visually inspected each of the red bags on the loading dock.  All
 of the red bags were sealed with plastic ties.  There were no tears or
 punctures in the bags.  No sharps were protruding through the bags, and no
 liquids were leaking from the bags.   Because of safety considerations, I
 did not open any of the red bags to  characterize their contents.  The bags
 were stored for one day on the dock  at ambient temperatures (90°F max. on
 June 30,  1990).  I did not observe any garbage or refuse either on the
 loading dock or on the concrete incinerator pad.  I also did not detect
 any noticeable odors associated with the waste.   Attachment 1 presents an
 inspection checklist for the waste characterization.                      j
      At 8:00 a.m., the incinerator operator opened the charging door to
 the incinerator and moved a large steel  tray and several  empty open drums
 to  the  door of the unit.   He then scraped the bottom  ash  into the tray
 with a  large hoe  and shoveled the remaining ash  into  the  drums.   He
 immediately wetted down  the ash  with  a  nearby water hose.   I  observed a
 slight  amount  of  visible  fugitive dust  emissions during removal  of the ash
 prior to wetting.   The tray and  drums contained  fine  gray  ash intermixed
 with  a  small amount of glass  bottles  and metal cans and utensils.   I  did
 not observe any non-combusted  combustible material.   The operator dumped
 the wet bottom  ash  in a nearby dumpster for  subsequent  disposal  at the
 county  landfill.  While the doors were open,  I looked  inside  the
 incinerator  (I  did  not enter the unit).  There were no  obvious missing
 chunks  in the refractory.  Openings to the primary  chamber  air supply
 system did not  appear to be plugged.
     At approximately 8:30 a.m., the operator rolled the plastic bins
containing the wastes to the incinerator.  He manually  tossed the  red  bag
waste and the bags containing the general refuse onto the incinerator
hearth and closed the charging door.   At 8:55 a.m., the operator ignited
                                   G-3

-------
 the  secondary chamber auxiliary natural gas-fired burner to preheat the
 secondary chamber.   I observed that the control settings for the secondary
 chamber were set for a minimum temperature of 1800°F and a maximum of
 1975°F.  While the secondary chamber was heating up, the operator started
 the  draft fan and turned on the water flow to the venturi scrubber.  At
 9:18 a.m., the operator ignited the primary chamber burners.  I noted that
 the  temperature gauge for the secondary chamber indicated a value of
 1825°F.  I observed  that the control settings for the primary chamber were
 at a minimum temperature of 1300°F and a maximum of 1500°F.  At 9:43 a.m.,
 I noted that the primary chamber auxiliary burner had shut off.  The
 temperature readout  indicated a primary chamber temperature of 1425°F.
 HhUe the incinerator was operating, I slowly circled the entire unit.  I
 did  not observe any  hot spots on the incinerator casing.  Attachment 2
 presents an inspection checklist for .the incinerator.
     After inspecting the incinerator, I visually inspected the ductwork
 of the exhaust system.  I did not observe excessive corrosion or
 noticeable holes.  I also did not locate any audible air leaks.  I
 observed a pressure drop of 22 in.w.c. on the venturi scrubber pressure
 gauge and a liquid flow rate of 45 gallons per minute.  The draft fan
 seemed to be operating properly.  I did not observe any excessive
 vibrations.  The raagnehelic indicated a static pressure at the fan of
 25 in. w.c.  Attachment 3 presents an inspection checklist for the venturi
 scrubber.
     At 10:30 a.m., I assumed a position 75 feet northeast of the stack
 and took visible emission readings for 15 minutes.  The stack had an
 attached steam plume that dissipated approximately 40 feet from the
 stack.  Average opacity for the period was 6.5 percent.  Attachment 4
presents the visible emission observation form for the period.
Summary of Findings
     1.  Waste handling procedures complied with EPA recommended
procedures.  Infectious wastes were bagged in red plastic bags.  I
observed no tears, ruptures, punctures, or leaking liquids from the
bags.  Storage time for the wastes was a maximum of 24 hours.  I observed
no litter, vermin, or obnoxious odors.
                                    G-4

-------
      2.  The State operating permit requires a minimum secondary chamber
 temperature of 1800°F.  During my observations, the secondary chamber
 temperature fluctuated between 1810° and 1875°F.
      3.  The State operating permit requires a minimum gas retention time
 in the secondary chamber of 2 seconds.  During the State's initial
 compliance test (May 1988), the gas retention time was 2.2 seconds while
 burning a 243-lb charge of general refuse and red bag wastes.  During the
 test, the average secondary combustion chamber temperature was 1845°F and
 the fan static pressure was 26 in. w.c.  During this inspection, I
 estimated a charge weight of approximately 250 Ib.  The observed fan
 static pressure was 25 in. w.c.  and the average secondary chamber
 temperature was 1830°F.  Although I was unable to actually measure the
 flue gas volume,  and as a result calculate the gas retention time, the
 observed secondary chamber temperature and fan static pressure Indicate
 that the gas retention time in the secondary chamber should be similar to
 the measured rate  during  the initial performance test.
      4.   The State operating permit requires a minimum venturi  scrubber
 pressure drop of 20  in. w.c.  I  observed a pressure drop  of 20 in.  w.c.  as
 indicated by the scrubber  magnehelic.
      5.   The State operating  permit  requires a minimum  liquid-to-gas  ratio
 of  8  gallons per thousand  actual cubic  feet  of flue gas.   During  the
 State's  initial compliance  test, the liquid-to-gas  ratio  was
 8.2 gal/1,000 acf  with  a liquid flow rate to the venturi  scrubber of
 48  gal/min.  During this inspection, I  observed a  liquid  flow rate  of
 50  gal/min.  Although  I was unable to actually measure the  flue gas
 volume, and as a result the liquid-to-gas ratio, the observed liquid flow
 rate  indicates that the I1qu1d-to-gas ratio  should  be simillar to the
 measured rate during the initial  performance test.
     6.  State regulations require that average opacity as measured by EPA
Method 9 not exceed 20 percent.   I observed an average opacity of
6.5 percent for 15 minutes during the inspection.  Opacity did not  exceed
20 percent for any 6-minute period.
     7.  I did not observe any documentable violations of applicable rules
and regulations during this inspection.
                                   G-5

-------
                          INSPECTION  CHECKLIST FOR  INCINERATORS
 Date:
 Inspectors name:     ^T&/>*>  bee.
Agency affiliation:   t=P& - /?g
 Facility name:    G-c/»et-al
                                  g
                                   o/v
Address:    5/4 Me/Hot-/ o, /  La*je.  Rale',*!*  MC,
 Facility contact person:    ^^/-^a Arocw     Telephone No.fyM)596-a43f
 Incinerator type/operating mode:
  Starved air
  Excess air
  "Batch fed
  Intermittent duty
  Continuous duty
Charging rate, Ib/h:       5QO /As  —
No. of charges/h:  _ -±,  PC*
 Is primary air system in good working order, yes/no:
                                                            »
 Is secondary air system, in good working order, yes/no:     yes
 Static pressure in primary chamber, in. w.c.:	
 Primary combustion chamber temperature, °F:	
 Secondary combustion chamber temperature, °F:  __;	
Exit gas oxygen level, %:	///A
Exit gas CO level, %:	
Opacity CEMS inspected, yes/no, comments:
Visible emissions from stack, %:      '
Fugitive visible emissions from ash removal:  \Xgry g !;<=. A f emis<
  (Attach Method 9 data form)                    "    °
Other fugitive emissions observed:  _ A/QMC,
Incinerator shell corrosion and/or hot spots, yes/no:
Audible air leaks, yes/no:  _ A/o
Ash quality:   Fi'/ve. qro^sA - */o
Visual inspection of waste bed:  	
Visual Inspection of secondary burner:  	A//A

-------
Startup procedures:
  1.  Frequency:        tL per-
  2.  Temperature in secondary chamber before charging,  °F:
Shutdown procedures:
  1.  Temperature in primary chamber at cutoff of secondary burners,  °F:
Comments:
                              n/O
                e rra c-ter v
                            or

-------
            INSPECTION CHECKLIST FOR VENTURI/PACKEO-BED SCRUBBERS
 Date:
 Inspectors  name:        tJbA/y/ Doe.
Agency affiliation:     £pfi -
 Facility name:       General
                                 a
 Address:    Sf(> /Ste^/vaX £.**,& .   ftaJ&{    ./v.c.
 Facility contact person:   &eorae Rrouiu      Telephone
 Stack emissions opacity, yes/no  (see Method 9 form):      yes
 Process fugitives emission, opacity average:	
 Plume color:	Gray	
 Water vapor plume present (yes/no):      y&g	
 Fan vibration problem (yes/no):  	A/O	
 Fan current, amperes:        As/A    •— SMf/e. pressure.   as/»/.
 Scrubber pressure drop, in. w.c.:  	A-?..	
Mist eliminator pressure drop, in. w.c.:
Scrubber liquid flow rate, gpm:	
Scrubber liquid pressure, psig:  	
Scrubber liquid pump current:  __	
Audible pump cavitation (yes/no):  	
Nozzle pressure, psig:	
Physical problems of scrubber (yes/no):
Physical problems of ducting (yes/no):
Scrubber liquid effluent, pH level:  	
Recirculation tank pH level:  __	
Recirculatlon tank percent suspended solids:  	
M1st eliminator feed water percent suspended solids:
Gas temperature at scrubber inlet, °F:  	
Gas temperature at scrubber outlet, °F:	A//4
Comments:      "TAt   hsical cteai-a/ve.e.  &£ -Me  scf*lolocr  C//QJ
                             *
                         a M

-------
i COMPANY NAMfe
G- si^e ro I H ospi J-Q 1
STREET ADOflfiSS

CITY
O 1 ' 1
ftgAe/gA 	 	
PMON6*e.
EMffiSON COLOR1
SMI G-f-as/ End S"<5 n» tf.
* WATER DROPLET PLUME
PONT IN THE1 PLUMS AT WHICH OPACTrr WA* UfcibHMneu
DESCRIBE PLUME BACXGROUNO
SMI S/CV
BACKGROUND COLOR
SMI /{3/i/ &• End £<? g
wmo SPEED
SMI O-Sm
AMBIENT TEMP
Stut tyo ° £•
Siaot _
Ptam
wind -»»
•r
^
<5 A End 
t ""
>
euntoeat
Dnw Nam Anow
-
[ Emnton Point )
. 	 =»-> Ae«d her*
plu/w-e.
, ObMrv«ri Petition
lOnLin*
AOOtnONAL INFORMATION
•
OBSERVATON OATE START TIME =NO TIME
^//SO ' /JO /0?3OQ,/>1. /O'fi^ •
\SEu
\
MIN \
1
2
a
4
S
8
7
•
9
10
11
12
13
14
IS
18
17
11
19
20
21
22
23
24
25
29
27
29
29
30
0 ! IS 1 30 1 *S
5 ' /0 ! 5 5
/o
s
% z

£
?
c
£•
^.
^
5
<;
5
/ O
/d
/£
^
5
5
/o so
e
/o
s
















/tf
5















5
e;
5 O
5
5"
5"

^
^
5
/o
/ o
<
5
£
s
5
^
^r
/o
s
/o /o
/o
/o















^
/o















COMMEVTS
•»—





























OBSERVER'S NAME (PRINT)
OBSERVER'S SIGNATURE OATt
AoJi* A^-«L_ 6/30/fo
ORGANIZATION
CERTIFIED BY UA1B ,
CONTINUED ON VEO FORM NUMBER

-------
                                     TECHNICAL REPORT DATA
                             •Please read Instructions on me reverse oetore camcienmi
 ''t?A°-Wl-89-001
                                                             XREdPIENT'SACCESS.CNNO.
 4. TITLE AND SUBTITLE
   Hospital Waste  Incinerator Field  Inspection and Source i
   Evaluation Manual
                                                            jS. REPORT OAT^
                                                                     -'••'-'
                                                             S. PERFORMING ORGANIZATION CODE
  , AUTHORISJ
   Stacy Smith, Steven Schliesser, Mark  Turner,
   Stephen Edgerton
                                                             8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Midwest Research  Institute
   Suite 350
   401 Harrison Oaks  Boulevard
   Gary, North Carolina  27513
                                                             10. PROGRAM ELEMENT NO.
                                                             11. CONTRACT/GRANT NO.


                                                               68-02-4463
 12, SPONSORING AGENCY NAME ANO AOORESS
                                                             13. TYPE OF REPORT AND PERIOD COVERED
   U. S. Environmental  Protection Agency
   Stationary Source  Compliance Division
   Office of Air Quality Planning and Standards
   Washington, D.C.   20460         	
                                                             14. SPONSORING AGENCY CODE
 S.
   ,Ske,»»L£ME,NTAHY.NOTES
   EPA work Assignment Manager
   James Topsale,  Region III, Philadelphia,  Pennsylvania
   t>a:n ^sunders  £~£D  Washinton.  D.C.
 6. ABSTRACT
         This manual summarizes the information  necessary for conducting field   /
   inspections of hospital  waste incinerators.   The manual is intended for  use by
   Federal,  State, and  local  field inspectors.

         The  document presents the following  information:  (a) basic inspection
   procedures, (b) descriptions of the types- of hospital waste  incinerators,
   (c)  descriptions of  air  pollution control systems which might be used  on hospita,
   incinerators, and .(d)  inspection techniques  for hospital incinerators.   Inspection
   checklists also are  provided.
                                 KEY WORDS ANO DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lOENTIFIErlS/OPEN ENDED TERMS
                                                                          c.  COSATI l-icld/Croup
   Hospital Waste  Incineration  Field
   Inspections
18, CtSrP'BU-.CN STATEMENT
   Release unlimited
                                               19. SECURITY CLASS t This Reonrt,
                                                                          21. NO. OF PAGES
                                               :o. SECURIT^C-ASS ,T>'i*pa?ei
                                                                          22. PRICE
IPA
       2120-5 '3»*. 4-77^    - = evious eri
                                     i s OBSOLETE

-------