ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/1-78-002
Inspection And Evaluation Of
Rollins Environmental Services, Inc.
Houston, Texas And Baton Rou^e, Louisiana
ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO
MAY 1978
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Environmental Protection Agency
Office of Enforcement
EPA-330/1-78-002
INSPECTION AND EVALUATION OF
ROLLINS ENVIRONMENTAL SERVICES, INC.
HOUSTON, TEXAS AND BATON ROUGE, LOUISIANA
May 1978
National Enforcement Investigations Center
Denver, Colorado
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CONTENTS
I INTRODUCTION 1
II SUMMARY AND WASTE CONCLUSIONS 4
NATIONAL NEEDS FOR WASTE DISPOSAL 4
ROLLINS FACILITY 5
III BACKGROUND 12
DISPOSAL SITES 12
PERMITTING AUTHORITY 17
IV WASTE MATERIALS TREATED 20
PROCEDURES 20
MATERIALS RECEIVED 22
MANIFEST SYSTEM 28
V TREATMENT AND DISPOSAL METHODS . 29
INCINERATION 29
CHEMICAL LANDFILL 37
CHEMICAL TREATMENT 44
LAND CULTIVATION 46
BIOLOGICAL TREATMENT 48
WASTEWATER EFFLUENT SYSTEM 56
STORAGE FACILITIES 63
TRANSPORTATION 72
VI SAFETY 75
FIRE PROTECTION 75
SAFETY AND TRAINING 76
REFERENCES 78
APPENDICES
A PART III - Other Requirements
(NPDES Permit No. TX0005941)
B Texas Air Control Board
Operating Permit No. 679
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TABLES
1. WASTE MATERIALS TREATED - RES BATON ROUGE PLANT . . 23
2. WASTE MATERIALS TREATED - RES HOUSTON PLANT 25
3. NPDES PERMIT EFFLUENT LIMITATIONS -
RES - DEER PARK PLANT 58
4. NPDES PERMIT EFFLUENT LIMITATIONS -
RES - BATON ROUGE PLANT 61
5. TANK CAPACITIES - RES - HOUSTON 65
6. TANK CAPACITIES - RES - BATON ROUGE 70
7. WASTE MATERIAL TRANSPORTATION EQUIPMENT 73
FIGURES
1. RES Site Layout - Baton Rouge Plant 15
2. RES Site Layout - Houston Plant 16
3. RES Incineration System - Houston Plant 30
4. Emission Control System - Incinerator
RES - Houston Plant 34
5. RES - Baton Rouge Plant 47
6. Biological Treatment Schematic - RES - Houston ... 50
7. Biological Treatment Schematic -
RES - Baton Rouge Plant 53
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I. INTRODUCTION
According to current estimates by the Environmental Protection
Agency (EPA), 336 million m. tons (370 million tons), wet weight, of
industrial wastes* are produced annually in the United States, with a
yearly growth rate of about 3%. EPA also estimates that about 10% of
this industrial waste is potentially hazardous.1 There are approxi-
mately 77,000 hazardous waste generators within the industrial sector
and about 30,000 hazardous waste generators and handlers within the
government sector.2 The inadequate management of these hazardous
wastes has the potential of causing an adverse impact on public health
and the environment. This impact combines both the acute (short-range)
and chronic (long-range) effects of hazardous compounds and is related
to production quantities and distribution. In the 1977 EPA report to
Congress, it was concluded that the prevailing methods of hazardous
waste management were inadequate and result in the uncontrolled dis-
charge of hazardous residues to the environment.1
The EPA has identified 110 facilities which accept hazardous
wastes for disposal or recovery.3 Only 9 of these facilities are
municipally controlled (8 are located in EPA Region IX and 1 in
Region III). The current overall storage, treatment and disposal
capacity of the industry is approximately 7.3 million m. tons (8
million tons)/yr on a wet basis. However, some of this capacity
represents processes which may not be considered environmentally
adequate; the environmentally adequate capacity in 1975 was 5.3
million m. tons (5.8 million tons)/yr. Based on these estimates,
The industrial wastes would be defined as solid wastes under
PL 94-580, Resource Conservation and Recovery Act of 1976.
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about 28 million m. tons (31 million tons) or 83% of the hazardous
wastes may receive inadequate disposal. Because the hazardous waste
management industry cannot compete in price with environmentally
inadequate practices, only 53% of the overall industry capacity is
currently used. If 100% of the industry's capacity were utilized,
about 15 million m. tons (16.5 million tons) of hazardous wastes
would be subject to unsafe disposal practices.
Until the enactment of PL 94-580, the Resource Conservation and
Recovery Act of 1976 (RCRA), the Federal regulation of nonradioactive
wastes was nonexistent on both the State and local level, regulation
was variable in extent and inconsistent in enforcement. In addition,
there was little economic incentive for generators to dispose of their
hazardous wastes in an environmentally adequate manner. Currently,
EPA discourages the disposal of hazardous wastes by ocean dumping,
deep-well injection, and in nonsecure landfills, although each method
is permissible under certain circumstances. The RCRA Act will require
a strict management of hazardous wastes which will result in a heavier
use of existing private disposal sites, require new sites, and create
new firms within the industry. New sites will have to be evaluated
before an operating permit is issued. In addition, existing sites
will have to conform to the provisions of RCRA. This will result in
some existing facilities being eliminated as hazardous wastes sites,
thereby increasing the burden on the remaining sites.
The geographic distribution of disposal sites is concentrated in
EPA Regions II, V, and IX which contain approximately 60% of the total.
Region VI, ranking fourth with ten sites, requested that the National
Enforcement Investigations Center (NEIC) conduct a thorough inspection
of two sites to evaluate the methods of disposal and to determine if
action was required to upgrade disposal techniques. This report sum-
marizes the inspections conducted at Rollins Environmental Services,
Inc., at Houston (Deer Park), Texas and Baton Rouge, Louisiana on
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November 8-11 and December 6-8, 1977, respectively. The inspections
consisted of a detailed interview with plant management and a visual
inspection of all processes and disposal methods.
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II. SUMMARY AND CONCLUSIONS
NATIONAL NEEDS FOR HAZARDOUS WASTE DISPOSAL
Based on EPA estimates, much of the hazardous waste generated in
the United States may receive inadequate treatment or disposal. Al-
though there are more than 100 commercial hazardous waste disposal
facilities, they are not being fully utilized. If the total capaci-
ties of the sites were used, there still would be a need for environ-
mentally safe disposal areas. Therefore, the use of approved sites
should be encouraged. New sites should be located throughout the
United States to increase the capacity for environmentally safe dis-
posal and reduce the transportation distances, thus decreasing the
potential for spills or accidents.
The States should approve the locations of the sites since they
are more familiar with the geology of the area. However, EPA should
be available for assistance and should disapprove any site that could
not comply with the provisions under RCRA.
Due to the hazardous characteristics of the materials handled at
these sites, permits should be issued for air control equipment, waste-
water discharges, and land disposal operations. Conventional pollutant
parameters may be included as limitations in the permits, but limita-
tions on toxic materials should also be included. Biomonitoring should
be incorporated into the permits for wastewater discharges. Monitoring
wells should be located in areas surrounding site property so that
groundwater contamination can be detected before, not as, it leaves
the property.
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ROLLINS FACILITIES
Rollins Environmental Services, Inc. (RES) operates two hazardous
waste disposal facilities in EPA Region VI. The facilities are located
at Houston, Texas, and Baton Rouge, Louisiana. Each facility has the
capability of treating, destroying, or burying waste materials. Pro-
cesses include chemical and biological treatment, incineration, and
landfilling; the Baton Rouge plant also land-cultivates oily sludges.
Both facilities have a drum storage area and a tank farm for storage
of liquid waste material prior to incineration.
Due to the characteristics of the wastes received at each loca-
tion, the emphasis on disposal processes differs. At Houston, most
of the wastes are incinerated, and the majority of the wastes not
burned are landfilled. There is very little chemical or biological
treatment. At Baton Rouge, chemical and biological treatment and
landfilling constitute the major processes. About 20% of the in-
coming wastes are incinerated and about 50% receive chemical or bio-
logical treatment.
All waste materials received at the RES facilities are considered
hazardous or toxic, even if the waste is not. Because of this philoso-
phy, personnel are aware of the problems which could arise if the
material is handled improperly. The facilities are located in areas
geologically suited for disposal activity, especially for the landfill
process. Each facility lies on top of at least 30 m (100 ft) of imper-
vious clay.
Based on the observations made during the inspection, both plants
are capable of handling, treating, and disposing of hazardous and
toxic wastes. The Texas Water Quality Board (TWQB) and Louisiana
Department of Health (LDH) have approved each site under their juris-
dictions and are generally satisfied with the operations. The TWQB
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has made numerous requests for site and process improvements which
have been implemented over the past several years. The LDH requires
that wastes received from out-of-state be approved before disposal
can occur; the TWQB does not have this requirement. Each State re-
quires that the receipt of all incoming wastes be permanently recorded
along with the method of disposal. Each facility submits a monthly
report of its activities, which in Texas includes the information on
the manifest,* and in Louisiana includes copies of either the bill-of-
lading or manifest supplied by the generator.
The evaluation of RES sites and operations is summarized below.
Incineration
Identical incineration systems have been installed at each faci-
lity; the only dissimilarity is in the emission control units after
incineration. The incineration system consists of a rotary kiln for
burning solids, semi-solids and liquids, a Loddby burner for liquid
burning, and an after-burner (hottest area of the system) for thermal
oxidation of highly toxic liquids.
Each incineration system has been designed to shut down immediately
(within 30 seconds) should a malfunction occur which precludes gases
being emitted. The system shutdown provisions were incorporated pri-
marily to protect the equipment, however it is also adequate to protect
the surrounding environment from accidental emission of toxic fumes
and gases.
Similar to a bill-of-lading, a manifest is defined by RCRA
as the form used for identifying the quantity, composition,
origin, routing and destination of hazardous waste during
its transportation from the point of generation to the point
of disposal, treatment, or storage.
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Liquid Polychlorinated Biphenyl (PCB) mixtures and chemical sub-
stances must be burned in an incinerator approved by the EPA. The
incinerator must comply with the requirements of Annex I-Part 761* of
the Toxic Substances Control Act. PCB have been successfully de-
stroyed in the Houston system and the incinerators at both locations
comply with the requirements. However, each incinerator should be
required to conduct a test burn as specified in the regulations before
being authorized to destroy PCB material.
Landfill
The landfill area at each facility is ideally suited for disposal
of hazardous wastes. At Houston, all material not buried in cells is
mixed with cement flue dust and encapsulated in clay. At Baton Rouge,
liquids, sludges and drums of waste material are deposited in the same
pits. When the pits are full, they are backfilled with clay soil and
mixed. Each landfill area has been surveyed and permanent bench marks
constructed to accurately locate the areas where wastes have been
buried. This information, plus the quantities and types of wastes,
is recorded in logbooks.
Although the geological formations reduce the probability of
leaching, an environmentally safe disposal area demands that adequate
monitoring be implemented. Leaching must be detected before the ground-
work leaves the site boundaries.
Federal Register, Vol. 43, No. 34, February 17, 1978
pp 7150-7164.
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Wells have not been installed at either of the landfills which
will monitor all possibilities of leaching to the groundwater. Both
facilities intend to install a well monitoring system surrounding the
landfill sites; in addition, wells will be installed within the land-
fill area adjacent to the various burial area. Currently, the wells
used to dewater the sand lenses in the clay soil are used for monitor-
ing. To date, leaching has not been detected.
The road to the Houston landfill has been paved, which reduces
fugitive emissions and mud tracking from vehicle traffic. A lime-rock
road will be completed soon at the Baton Rouge landfill; during the
NEIC inspection, mud tracking from the site was a major problem be-
cause of the heavy rains.
Land Cultivation
Land farming, or cultivation of oily sludges, is practiced at
Baton Rouge only. Before disposal operations began, the system was
designed to collect contaminated runoff and provide biological treat-
ment before discharge. Land cultivation is currently conducted in
hazardous waste disposal areas in California and is an acceptable
method for disposing of oily sludges.
A well-monitoring system is needed at the land cultivation area
to determine if leaching is occurring.
Chemical and Biological Treatment
Both facilities discharge wastewaters to receiving streams after
biological or chemical treatment. The effluents also include scrubber
water from the incinerator. Each discharge is monitored by the facility
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as required by the respective National Pollutant Discharge Elimination
System (NPDES) permits. However, the permits specifically limit only
the conventional pollutants such as solids, BOD, phenol, heavy metals,
etc. Because of the nature of the business, each facility could dis-
charge toxic or hazardous constituents to the waterways without detec-
tion. It is not economically feasible to monitor for each toxic con-
stituent which is treated at the sites, however, there are constituents
which are continually treated, such as PCBs, which could be monitored.
In addition, biomonitoring of the effluents should be incorporated to
determine aquatic toxicity.
Rainfall Runoff
The Houston facility has adequately provided for collection and
impoundment of runoff before it can be discharged. This water is
used for incinerator scrubber water makeup rather than being discharged.
During periods of extremely heavy rains, the impoundment system could
overflow, but this would occur rarely and the quantity of runoff might
be sufficient to dilute the toxic pollutants to very low levels. The
active disposal area of the landfill is about 1.4 hectares (3.5) acres,
12 m (40 ft) deep, which would retain over 3,080 m3 (0.81 million
gal) of runoff which could be contaminated, thus requiring treatment.
Runoff is not as well controlled at the Baton Rouge facility
except at the land farm area. During heavy rains, it appeared that
contaminated runoff could flow from the landfill area without being
contained. Currently vacuum trucks are used to collect runoff accu-
mulating in low lying areas of the landfill.
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Drum Storage
Drums are stored in specified areas at each facility prior to
disposal. The storage area at Houston is on a concrete slab which
slopes to a sump; Curbs have been placed on each end to aid in lat-
eral drainage. However these curbs are in poor condition and are
nonexistent in some areas. If a drum would leak, the contents would
drain to the sump and discharge to the equalization basin prior to
biological treatment.
Drums, stored on the ground at Baton Rouge, are contained with
earthen dikes. A concrete pad will be installed in the immediate
future in the drum storage area. All spills will drain to a sump
which must be emptied with a vacuum truck. A new system will be built
which will pump runoff to the biosystem.
Neither drum storage facility will comply with the requirements
for PCB storage. The storage area must be enclosed to contain the
contents of spilled material, and protected by a roof to prevent rain-
water from reaching the drums. (PCB liquids for disposal can only be
stored in drums.) Since each facility handles PCBs, storage facilities
should be upgraded immediately.
To protect the biological systems from spills from the drums,
each storage area should be completely diked with no drains, valves,
or pumps. Runoff could be collected in a sump and removed by vacuum
truck or portable pump.
Tank Farm
Adequate diking at each facility was not provided for the tank
farm, although the Houston plant did have most of its diking in good
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repair. The Baton Rouge tank farm is not diked and all drainage flows
to a catch basin. Runoff will flow to the catch basin and be treated
biologically before discharge.
Almost all of the hazardous waste received is stored in the tank
farms or in special, dedicated tanks. If a rupture or spill occurs,
the material should be contained in as small an area as possible.
Therefore, the tank farm and each tank outside of the farm receiving
waste material should be adequately diked.
A vent collection system for each tank at Houston is a require-
ment of the Texas Air Quality Board. All tanks vent to the incinerator
or to carbon filters when the incinerator is down. However, there is
no method of checking for leaks in the system. A leak could release
the fumes to the ambient air.
The Baton Rouge facility is not required by the State to have a
vent system since it complies with the Louisiana Air Control Commission
regulations for storage. However, if new types of waste material are
accepted at the facility which are similar to those received at Houston,
a vent system should be installed on all tanks storing the material.
Safety
Fire protection is provided at each facility, however, explosions
could occur at either location as occurred at the RES Logan, New Jersey
site under similar conditions.
Safety equipment is issued to employees involved with the handling
of wastes and all employees are given annual physicals.
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III. BACKGROUND
DISPOSAL SITES
Rollins-Purle, Inc. was formed in 1970-71 as a subsidiary of the
RLC Corporation for the purpose of treating and disposing of industrial
toxic and hazardous wastes. Three disposal facilities were built:
the first in Bridgeport, New Jersey; the second in Baton Rouge, Louisiana;
and the third in Houston (Deer Park), Texas. In 1974, the Rollins-Purle
Inc. name was changed to Rollins Environmental Service, Inc. (RES).
The disposal facilities consist of treatment systems for almost
all types of waste materials except radioactive substances and true
explosives. The primary sources of waste materials are the petro-
chemical, refining, chemical, metal and metal finishing, pharmaceuti-
cal, and synthetic polymer industries.
Each facility is operated by a plant manager who has the authority
and responsibility for handling all waste material. Each facility
has salesmen who cover their assigned territory, securing contracts
with industries for disposal of wastes. About 90% of the time, waste
generators make the initial contact with RES salesmen. If the wastes
cannot be safely disposed of at one RES facility, it may be sent to
one of the other two facilities for safe disposal. If the wastes
cannot be safely treated or disposed of at any of the three sites,
the firm will not accept it.
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Bridgeport, New Jersey
The eastern region of the United States is served by the Logan
Plant. This plant handles from 300 to 400 different hazardous waste
streams of wide variety in constituents and quantities. The facility
services about 150 customers each month.
On December 8, 1977, a series of explosions in the tank farm
storage area resulted in the release of chemical fumes and in the
closure of the facility. If the State permits the plant to continue
in the disposal of hazardous wastes, the facility will be inspected
by NEIC and a separate report prepared.
Baton Rouge, Louisiana
Operations at this facility began in December 1970, primarily
for incineration and biological treatment of hazardous wastes. With
the recent purchase of 8 hectares (20 acres) of adjacent land, the
site has 73 hectares (180 acres) of area available for disposal.
Additional land adjacent to the site is also available which, if pur-
chased, would increase the area by more than 40 hectares (100 acres).
With the exception of the 8-hectare area, the entire facility is se-
cured with a 1.8 m (6 ft) wire mesh fence; the newest addition will
also be secured with fencing.
The site is located on a 33 m (108 ft) high, clay bluff adjacent
to the Mississippi River. From data obtained from their wells, the
depth to the groundwater table is believed to be about 20 m (67 ft);
however, plant personnel cannot confirm this depth. Sand lenses are
dispersed throughout the clay area.
Approximately 4 hectares (10 acres) of the site support the in-
cineration facilities, tank farm, drum storage, shops, laboratory,
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and offices. The remainder of the land is used for biological treat-
ment, landfilling, and land farming [Figure 1]. Over the past 7 years,
approximately 5 to 6 hectares (12 to 15 acres) have been landfilled
to an average depth of 6 m (20 ft). The firm estimates that there is
sufficient land available for another 10 to 25 years, depending on
the nature and quantity of wastes received. To preserve land, the
facility may have to modify operations to limit the amount of material
landfilled. Shredders and other equipment will have to be used to
reduce burnable material into sizes amenable to incineration.
The site is open 24 hours/day, 7 days/week for the entire year.
There are 50 employees including 15 clerical, laboratory, and technical
personnel. The site is available for contract disposal of wastes for
private industry, State, Federal, and local government agencies; it
is closed to the public.
Houston, Texas
This facility is located on 34 hectares (85 acres) at Deer Park.
Disposal processes include incineration, landfill, chemical and bio-
logical treatment. The latter two methods are used infrequently as
most of the incoming wastes are burned or must be landfilled [Figure 2].
The entire facility is secured with wire mesh fence.
Incineration facilities occupy about 0.4 hectare (1 acre) on the
northwest corner of the site. Landfill ing of wastes began on September
1976, on about 16 hectares (40 acres). About 7 years of life remains
for disposal as the rate of use averages 2 hectares (5 acres)/ year.
Originally, the landfill depth ranged from 4.6 to 5.5 m (15 to 18
ft) deep, but to better utilize the remaining area, the depth for
disposal has been increased to 12 m (40 ft). Land is available ad-
jacent to the site for purchase if the firm wishes to expand.
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15
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Figure 1. Rollins Environmental Services, Inc.
Site Layout
Baton Rouge, Louisiana.
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O oooooo oooooo
pOQQQ OOOOO_QQji
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16
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1 IFu'ture Expansion Undeveloped - 30 acres-i-
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Figure 2. Rollins-^ Environmental
Services,. Inc. Site Layout
Houston, Texas
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The site is situated on top of approximately 30 m (100 ft) of
clay which is interspersed with sand lenses. Although the water table
is within 3 m (10 ft) of the surface, water movement in the clay is
extremely slow.
PERMITTING AUTHORITY
Louisiana
Although the State had the authority to regulate solid waste
disposal since the 1920's, the State program in this area did not
become active until 1972 when the authority for control was given to
the State Department of Health (DOH). To date, the Health Department
does not have a permit application form or special form permitting
and regulating a hazardous waste site. However, all five hazardous
waste sites have been approved by means of an official letter.
With the exception of Rollins, which predates the DOH's control,
all of the disposal sites had to submit a proposal to the Department
outlining disposal methods, wastes received, quantities, etc. The
Department then evaluated the proposals. Rollins submitted a resume
of their disposal methods, wastes received, etc. and was approved.
Land cultivation of oily waste sludges was approved on March 3, 1977.
Although the disposal firms have a blanket approval to dispose
of all hazardous wastes generated within the State without notifying
the Health Department, all wastes from out-of-State must be approved
before the material can be transported to the site for disposal
(Louisiana Act 675 of 1977).
The hazardous waste sites are inspected at least once a month by
personnel from the New Orleans DOH office. Local sanitarians in the
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regional parish* health unit offices inspect on a more frequent basis.
Reports are not prepared for each inspection.
The latest inspection report by the Health Department (June 13,
1977) judged the operation to be satisfactory.
Discharges of wastewater to the Mississippi River via the Baton
Rouge Bayou are regulated by the NPDES Permit No. LA0038245; the Permit
to discharge was issued by the EPA.
The Louisiana Air Control Commission (ACC) issues the permits
for the two incinerators at the site. In December 1976, Rollins de-
cided to shut down one incinerator designed to burn highly chlorinated
hydrocarbons because the unit could not comply with the 20% opacity
limitation for visible emissions.
The last monitoring of the active incinerator was conducted in
September 1975 by Chem Tech of Baton Rouge at the request of EPA Region
VI and the State ACC. Both EPA and State personnel were present as
observers. The stack was monitored for particulate emission and com-
plied with the limitation of 0.08 gr/dscf**; Chem Tech determined that
the emission of particulates was 0.0815 gr/dscf. Previous stack tests
for HC1, CO, C02, 02, Cl, and S02 showed negligible amounts.
Texas
All disposal sites are controlled by the Texas Water Quality
Board (TWQB). Currently, the disposal site is permitted under Part III,
* A civil division of the State of Louisiana corresponding
to a county in other states.
** Dry standard cubic feet.
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Other Requirements, of the TWQB Permit No. 01429 (which corresponds
to the NPDES Permit No. TX0005941 issued by the EPA). The TWQB Permit
requires that earthen facilities for receiving and processing liquid
and for final disposition of solid wastes will conform to the require-
ments set forth for Class I sites in Board Order No. 71-0820-18. Addi-
tional requirements for drum storage, rainfall runoff, records, security,
monitoring and surveillance are included [Appendix A],
Compliance monitoring conducted on April 20-21, 1977 by EPA per-
sonnel showed that the effluent from Outfall 001 complied with the
permit limitations for all parameters except phenol. The permit limits
phenol to 0.09 kg (0.26 lb)/day (daily average) and 0.18 kg (0.4 lb)/day
(daily maximum); the phenol discharged was 2.1 kg (4.6 Ib) on April
20-21. The concentrations of barium and lead in Outfall 001 (scrubber
water discharge) were 3 mg/1 and 1.20 mg/1, respectively; TWQB Order
No. 75-1125-5 limits these concentrations to 2 mg/1 and 1 mg/1.
The Texas Air Control Board issued Permit No. R-679 on June 17,
1976 for the incinerator [Appendix B]; provisions are also included
which require that the tank farm and drum storage areas be properly
maintained and the vapor control system serving the tank farm be kept
in good working order. The stack is monitored yearly as required by
the permit by an independent laboratory, Sonics International, for
particulates, S02, HC1, 02, Cl, CO, C02, and percent hydrocarbon.
The incinerator complied with the limitations during monitoring.
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IV. WASTE MATERIALS TREATED
PROCEDURE
Before a waste is accepted at either facility, the characteristics
of the material are determined by analyses. In addition, the generator
must supply information on toxicity, handling requirements, protection
for workers, and any other pertinent characteristics. The initial
analyses are conducted on a sample obtained by the sales personnel.
The initial sample volume is approximately 1 liter (1.1 quart). The
RES Laboratory determines the waste's compatibility with other waste
streams received and the treatment procedure is established along
with the costs. Occasionally, an initial sample cannot be obtained.
Then, the procedure is to analyze the material in the first load re-
ceived and thereby establish treatment requirements and costs. Although
each generator normally ships the same waste material to the facilities
on a continuous basis, in some instances, especially at Baton Rouge,
customers will ship isolated material requiring a "one-time" disposal.
The Houston facility can accept waste from any generator within
the United States without prior approval from the State. However, a
waste cannot be imported for disposal if the State in which the waste
is generated does not allow disposal within its boundaries. In addi-
tion, the State is notified if "potentially hot" wastes such as dioxin*
or hexachlorobenzene are to be treated at Houston. In Louisiana, all
Also known as TCDD or 2,3,7,8-tetrachlorodigenzo-p-dioxin.
State Board refused permission for dioxin to be transported
to and treated at Houston facility because the State TCDD
was generated in would not allow the material to be disposed
of within its borders.
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out-of-state wastes must be approved by the State Department of Health;
no approval or notification is required for intrastate shipments.
However, if they receive a request to treat a "politically hot" waste,
which can be treated or disposed of, they will notify the Board of
Health and request approval.
Most truckloads of the incoming wastes are sampled upon arrival
at the sites before the material is treated, stored, or landfilled.
This sampling is conducted to confirm that the wastes conform to the
characteristics of the initial sample and data supplied by the generator.
For some waste streams, sampling of each shipment is not required as
the characteristics do not change significantly. These include sludges
from other waste treatment plants, catalysts, filter material, etc.
Waste materials in 55-gallon drums are spot sampled upon arrival. In
addition, the customer is required to place the RES identification
number on each drum.
All incoming trucks are weighed (about 2% of the incoming wastes
are measured on a volume basis) either on a public scale or customer's
scale. RES chemists, dressed in rain suits and other protective gear,
collect the sample through the dome in the tank trailer. A 1 liter
(quart) open top bottle is pushed to the bottom of the tank. If the
waste is stratified, samples are collected from the top through the
dome and from the bottom unloading port. The truck driver must wait
from 15 to 60 minutes until the samples are analyzed before proceeding
to the appropriate area.
The samples are analyzed for parameters predetermined for the
particular material. Both facilities can analyze for specific gravity,
pH, Btu value and ash content (calorimeter), odor, COD, cyanides,
metals, acidity, flash temperature, compatibility with other stored
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waste materials, and scrubbing characteristics.* The Houston facility
can also determine the total organic carbon content. Some parameters
cannot be tested on site, such as PCBs. The analyses are performed
by a commercial laboratory.
After the waste has been analyzed and approved, a disposal slip
is completed and given to the shift supervisor who must initial and
approve it. The supervisor then gives the slip to the operator who
unloads the material. The operator records when the material is un-
loaded. All of the information on the slip is kept in a log book in
the incinerator control room. One copy of the slip is retained per-
manently by the bookkeeper. This procedure is followed for all waste
loads, except the oily sludges which are landfilled.
Although incoming waste loads are not scheduled for specific
times, the customers try to ship their wastes so that the arrival
time falls within the two RES shifts. If a load arrives during the
off-shift, an employee is called back to the site to unload the material
MATERIALS RECEIVED
The general classifications of waste materials received at the
Baton Rouge and Houston facilities are listed in Tables 1 and 2, re-
spectively.
The bulk of waste materials received at Houston are chlorinated
organics which are incinerated. About 12 of the 129 priority
Scrubbing characteristics are evaluated to determine if the
air pollution control equipment will remove pollutants from
the gas streams.
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Table 1
WASTE MATERIALS TREATED
RES BATON ROUGE PLANT
I. CHEMICAL TREATMENT
1. Acids
a) Pickle liquors including sulfuric, hydrochloric, nitric,
hydrofluoric acids and mixtures of these with various
dissolved metals
b) Chromic acid and sulfuric acid - dichromate mixtures
c) Ferric and cupric chloride
2. Alkalis
a) Caustic soda (sodium hydroxide) stripping solutions
b) Carbonate-phosphate wash solutions
c) Ammoniacal copper solutions
d) Sodium sulfide - sodium hydrogen sulfide mixtures
e) Mixed cyanide plating wastes
f) Latex suspensions
3. Other
a) Oil-water emulsions
b) Mixed acrylate emulsions
II. BIOLOGICAL TREATMENT
1. Paper and rag digestion sludges
2. Glycol wastes
3. Organic acids and selected alcohols
4. Fats and oils of.vegetable and animal origin
5. Dilute phenolic solutions
6. Ammonia, phosphate and nitrate - containing salt solutions
7. Secondary sewage sludge
8. Acrylic resin wash waters
9. Starch and cellulose solutions
10. Amino acids and some other soluble amines and amides
11. Denatured proteins
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Table 1 (Continued)
III. INCINERATION
1. Light Liquids
a) Aliphatic and aromatic hydrocarbons
b) Ketones, alcohols and esters
c) Organic acids
d) Hetero-and homocyclic solvents
e) Isoprenoid compounds
f) Aqueous phenol and cresol
g) Aliphatic nitriles
h) Aliphatic and aromatic amines
2. Viscous Liquids
a) Aromatic and aliphatic oils
b) Long chain fatty acids
c) Polyglycols
d) Polyethoxy compounds
e) Polynuclear Hydrocarbons
f) Aqueous emulsions of acrylic acids
g) Surfacant emulsions
3. Semi-solids
. a) Nitrobenzene recovery tar
b) Mixed chlorobenzene recovery tar
c) Formimide recovery bar
d) Refinery API separator sludges
4. Chlorinated Hydrocarbons
a) Chlorinated aliphatics including methylene chloride,
chloroform and carbon tetrachloride mixtures
b) Chlorinated benzenes and other chlorinated aromatics
c) Vinyl chloride and vinylidene chloride
5. Solids
a) Solidified surfacants
b) Tackified still bottoms
c) Waxes
d) Polyethylene and polypropylene scrap
e) Synthetic rubber scrap (Polyisobutylene)
f) Toluene diisocyanate tar
g) Acrylic polymers and other resins
h) Bulk paper and synthetic fabrics
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Table 2
WASTE MATERIALS TREATED
RES HOUSTON PLANT
I. CHEMICAL TREATMENT
1. Acids
a) Pickle liquors (sulfuric, hydrochloric, nitric, phos-
phoric, hydrofluoric acids and mixtures of these with
various dissolved metals).
b) Chromic acid and sulfuric acid - dichromate mixtures
c) Ferric and cupric chloride
d) Lab. COD wastes
2. Alkalis
a) Caustic soda
b) Sodium sulfide - sodium hydrogen sulfide mixtures
c) Cyanide plating wastes
d) Latex suspensions
e) Soda Ash
3. Other
a) Metal salts solutions
b) Oil-water emulsions
c) Mixed acrylate emulsions
d) Metallic oxides, halides, nitrates phosphates
e) Spent welding flux
f) Calcium sulfate, sludge
II. BIOLOGICAL TREATMENT
1. Organic acids and selected alcohols
2. Ammonia, phosphate - containing salt solutions
3. Secondary sewage sludge
4. Aqueous truck washings
III. INCINERATION
1. Light Liquids
a) Aliphatic and aromatic hydrocarbons
b) Ketones, alcohols and esters
c) Organic acids
d) Mixed solvents
e) Isoprenoid compounds
f) Aqueous phenol and cresols
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Table 2 (Continued)
g) Aliphatic nitriles
h) Aliphatic and aromatic amines
i) Organo - sulfur wastes
j) Nitrated aromatics
k) Organo - phosphates
2. Viscous Liquids
a) Aromatic and aliphatic oils
b) Polyglycols
c) Polyethoxy compounds
d) Polynuclear Hydrocarbons
e) Aqueous emulsions of acrylics
f) Surfactant emulsions
g) Waste printing ink
3. Semi-Solids
a) Nitrobenzene recovery tar
b) Mixed chlorobenzene recovery tar
c) Refinery API separator sludges
d) Paint, oil and asphalt emulsions
4. Halogenated Hydrocarbons
a) Chlorinated aliphatic compounds
b) Chlorinated aromatic compounds
c) Freons
5. Solids
a) Solidified surfactants
b) Tarry still bottoms
c) Waxes
d) Polyethylene and polypropylene scrap
e) Scrap plastic
f) Toluene diisocyanate tar
g) Polymers and resins
h) Spent filter cakes, filter cartridges and filter cloths
i) Pesticides, herbicides
j) Paint sludges & pigments
k) Phenolic sludge
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pollutants* are incinerated. In October and November 1977, the faci-
lity incinerated about 0.91 x TO6 kg (2 x 106 Ib) of polychlorinated
biphenyls (PCBs). Vinyl chloride monomers (VCM) are also incinerated
monthly on a periodic basis. From 22,600 to 27,200 kg (50,000 to
60,000 Ib) of pyrophoric material are injected directly into the in-
cinerator each week. The Houston facility services about 20 customers
on a regular basis.
The Baton Rouge facility has about 100 active customers, 40 to
50 of whom ship wastes monthly. Many customers send small amounts of
PCBs to the site for incineration, although the total volume isn't
large. Pesticides, nitrochlorobenzenes and other benzene materials
are treated. Oily pretreatment sludges from customer wastewater ment
plants are routinely received for land disposal and cultivation.
Innocuous filter material and catalysts are received from the petro-
chemical industry for landfill ing.
The facilities will not accept explosive wastes, radioactive
wastes, and wastes containing high concentrations of bromides or sul-
fur (because pollutants cannot be removed from stack gas). The Baton
Rouge facility will only accept highly chlorinated hydrocarbons if
the waste can be blended with another waste to reduce the concentra-
tion. The Louisiana Air Quality Board prohibits the acceptance of
highly volatile material. The Baton Rouge facility selectively ac-
cepts lead, selenium, aluminum, cadmium, arsenic, mercury, and wastes
containing concentrations of any of the 129 Priority Pollutants.
These wastes may be rejected if they are in the wrong form, have a
potential for leaching, or are too toxic.
The Priority Pollutants are derived from the June 7, 1976
Settlement Agreement, Natural Resources Defense Council
(NRDC) vs USEPA.
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MANIFEST SYSTEM
Each truck load arriving at the RES sites must have a Department
of Transportation (DOT) bill of lading which describes the waste ma-
terial hauled. RES has assigned a unique number for each waste ma-
terial; this number must be on the bill of lading and on all drums.
In Texas, each generator within the state has an assigned num-
ber. The Texas Water Quality Board has also classified and coded
most waste materials; all waste codes beginning with the number "1"
are hazardous or toxic. These code numbers must be on the bill of
lading.
The generator is required to send a copy of the manifest to
either the TWQB or Louisiana Department of Health. The Houston per-
sonnel send a monthly report with unique manifest numbers, correspond-
ing waste quantities, and date received to the TWQB. Split loads are
reported as total loads. The Baton Rouge personnel forward copies of
the bill of lading to the Department of Health.
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V. TREATMENT AND DISPOSAL METHODS
Hazardous and toxic wastes are treated at the Baton Rouge and
Houston facilities by high-temperature incineration, chemical land-
fill, chemical treatment, and biological treatment. In addition,
industrial and oily sludges are land cultivated at Baton Rouge. Al-
though processes are similar, the constituents in the waste materials
received differ markedly at each facility, therefore requiring dis-
similar operating procedures.
INCINERATION
Each facility has one operating incinerator* consisting of the
following basic components [Figure 3]:**
1. Bartlett-Snow rotary kiln
2. Loddby liquid burner
3. After-burner chamber
4. Waste feed systems
5. Instrumentation
6. Emission control system
The kiln and Loddby burner use natural gas igniters and burners for
initial refractory heat-up, flame stability, and supplemental heat,
* The Baton Rouge facility shut down its second incinerator,
designed to burn highly chlorinated hydrocarbons, in December
1976 because it would not meet VEO regulations and because of
high maintenance costs.
** Figure depicts the Houston, Texas incineration system.
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Solid l<'a.&te. Feed Chute
T/C K-iln Ex-t*
Overall length 35'
Feed WaA-te L
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31
if necessary. The temperatures are normally maintained by the waste
material during incineration. Sludges, solids, semi-solids and
liquids are burned in the kiln, while only liquids are injected into
the Loddby burner. The kiln and Loddby burner share a common after-
burner chamber, used for the thermal oxidation of liquid waste ma-
terial. The after-burner is the hottest area of the incineration
system; the liquid wastes must be vaporized either by spraying or
atomizing during injection to the after-burner to support combustion.
Kiln
The kiln is 4.9 m (16 ft) long and 3.1 m (10 ft) in diameter;
rotation speed varies, but nominally operates at one revolution every
3 to 4 minutes. The kiln is maintained at 1 to 2 inches H20 negative
pressure. The flame temperature is nominally 1,300°C (2,340°F) and
the exit gas temperature ranges from 550° to 875°C (1,000 to 1,600°F).
Primary air for combustion is introduced with the flame at the exit
end of the kiln. The flame is directed towards the head end. The
kiln was designed to leak in excess air. A temperature sensor moni-
tors the exit gas temperature.
Solids, contained in 35-gallon fiber packs, are manually loaded
onto a conveyor which empties into the head end of the kiln via a
chute equipped with a guillotine door. The Houston facility burns
more fiber packs than Baton Rouge; the latter burns about 200 fiber
packs/month. The fiber packs contain a propylene liner and are
sealed with steel rings on the bottom and top. The rings are col-
lected in the concrete ash pit below the kiln and are landfilled.
Viscous and tarry materials at the Houston facility are centrifu-
gally pumped into the head end of the kiln from two agitated blend
tanks. At Baton Rouge, viscous material, contaminated oil, etc., are
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fed to the kiln through Moyno pumps serving injectors. The Moyno
pumps can be fed directly from the tank trailers or from the 26.5 m3
(7,000 gal) agitated blend tank. At Houston, liquid wastes from the
tank trailers or from two 22.7 m3 (6,000 gal) pressure tanks are
atomized and injected into the flame at the exit end of the kiln.
The trailers and pressure tanks are purged with nitrogen. The solid
waste material moves through the kiln via the rolling motion and the
buildup of ash at the head end; about 100 kg (200 Ib) of ash are
hauled to the landfill once a week.
The kiln is connected to the after-burner with a 2.4 m wide x
0.75 m high (8 x 2.5 ft) duct. The vapor control system from the
tank farm at the Houston facility exhausts to the duct. The Baton
Rouge facility does not have a vapor control system.
Loddby Liquid Burner
The Loddby burner is 4.9 m long x 1.6 m in diameter (16 x 5.25
ft). The temperature of the flame directed towards the after-burner
is approximately 1,500°C (2,600°F). Looking towards the after-burner,
the Loddby burner forced-draft fan produces a cyclonic rotation of
the gases in a clockwise direction.
Atomized liquids are fed into the head end of the Loddby burner
directly from the tank trucks or from the blending tanks. Primary
air is supplied at the head end while secondary air is introduced
midway.
After-burner
Particulates and gases from the kiln are pulled into the Loddby
burner due to the cyclonic spin, resulting in a longer retention time.
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The Loddby flame shoots into the after-burner, creating the thermal
oxidation zone. The temperature averages 1,300°C (2,350°F). The
overall retention time in the incineration system is from 2 to 3
seconds.
Emission Control
Houston Facility - The after-burner exhausts to a hot duct, ven-
turi and absorption chamber scrubber system. A thermocouple located
in the hot duct is the main control point for the incineration system.
The gas temperature at the thermocouple is maintained at 1,065°C
(1,950°F) +10°C (50°F). The hot gases from the hot duct enter the
venturi which is equipped with a plumb bob mounted on a shaft in the
throat to control pressure. The pressure drop across the venturi is
114 cm (45 in) of water. Approximately 1,130 liters (300 gal) of
fresh well water and 2,270 liters (600 gal)/min of recycled water are
added to the venturi upstream of the throat. The gas stream exits
into the absorption chamber; particulates are removed at the plumb
bob in the scrubber water which drains into the south retention tank
which feeds the north retention tank [Figure 4]. Recycle water used
in the venturi and absorption chamber is taken from this latter tank.
About 1,500 to 1,900 liters (400 to 500 gal)/min feeds the absorption
trays (flexitrays) on a once-through basis and drains directly to the
north retention tank. Excess water in the recycle system overflows
the south retention tank and is discharged to the hypalon-lined scrub-
ber water basin for solids sedimentation prior to discharge to the
lagoon system. The recycle water is pumped from the north retention
tank to the venturi.
A lime slurry is added to the suction side of the recycle pump.
The pH of the overflow from the south retention tank, sensed by a
probe in the overflow, controls a valve which feeds the lime slurry
to the recycled water. The lime is slaked at the Houston plant.
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GASES
TO STACK
I
FROM HOT DUCT
GASES (2,000°F)
J
VENTURI
600 GPM
FRESH
WELL WATER
300 GPM
500 GPM
PLUfIB BOB T/C
SHAFT
\\\\\\\\
ABSORBER
I
FLEXITRAY
LIME SLURRY
FEED
L
OVERFLOW
TO LAGOON
NORTH
RETENT
TANK
SOUTH
RETENT
TANK
Figure 4. Emission Control System - Incinerator
Rollins Environmental Services, Inc.
Houston, Texas
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35
After passing through the absorption trays, the gas stream
passes through a mist eliminator and then through two 400-horsepower
induced draft fans operating in parallel. When the Houston facility
first started incineration, the fans were a major problem as corro-
sion would occur within one week. After several years of research,
corrosion-resistant fans (proprietary) were developed. The fans are
routinely inspected every two weeks. Vibration equipment detects
buildup on the fan blades; if the buildup exceeds 3 1/2 mils, the
fans are removed from service and repaired.
The entire incineration system can be shut down within 30 sec-
onds. The pneumatic control valves are spring-loaded; a loss of air
pressure will close all valves. Automatic shutdown occurs if there
is a power failure, loss of recirculation flow to the venturi, plug-
ging of the absorber trays or drain into the south retention tank
from the bottom of the absorption chamber, a decrease in the water
level in the north retention tank sensed by a level detector which
shuts the recycle pump off, or if a thermocouple located between the
venturi and absortion chamber reaches 93°C (200 °F). This temperature
indicates that gases are passing straight through the venturi via
channeling (the plumb bob may have moved; the plumb bob position is
controlled with a jack stand).
When an emergency shutdown occurs, fuel flow and waste material
feed to the incineration system cease. Airflow through the system is
cut off by closing the Loddby forced-draft fan and the louvers on the
ID fans. Two valves in a 30-m3 (8,000-gal) quench tank, located above
the venturi and absorption chamber, lock in the open position; the
water floods both the venturi and absorption chamber. It requires
between 10 and 15 minutes to drain the quench tank. If there is a
leak in the absorption chamber, thus draining the chamber, a fire
pump continues to feed water to the quench tank to maintain flooding
conditions. The quench water fills the absorption chamber to a level
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36
about 30 cm (1 ft) above the venturi duct connection to the chamber.
An overflow is located about 45 cm (1.5 ft) above the duct connection
to protect the absorption trays. Hot gases are prevented from being
emitted.
To restart, the quench tank is filled and the absorption chamber
is drained. The fans are turned on and the system is purged for 3
minutes (residual contaminated gases are burned due to the high tem-
peratures in the kiln, Loddby, and after-burner).
Baton Rouge Facility - The after-burner is connected directly to
a spray chamber, ID fan, and special demister. The 6.1 x 6.1 m (20 x
20 ft) primary spray chamber is 9 m (30 ft) long and terminates at
the exit end of the 0.6 m (2 ft) long wet wall baffle chamber. Resi-
dence time in the spray chamber is 3 to 4 seconds. Scrubbing solu-
tion, 2,270 liters (600 gal)/min, is sprayed into the chamber from
the ceiling and both walls. About 1,700 liters (450 gal)/min drains
to the scrubber water basin; the rest is emitted as steam. Between
750 and 950 liters (200 to 250 ga1)/min of the spent solution is dis-
charged from the basin to the facility's wastewater treatment system;
the remaining solution is recycled to the spray chamber. The scrub-
bing solution contains about 5% NaOH; the strength is automatically
controlled by a system which blends 20% NaOH with fresh water and
recycled scrubbing solution to maintain an approximate pH of 7.5.
Caustic is purchased as 50% NaOH and stored as 20% NaOH in a 76 m3
(20,000 gal) tank next to the incinerator.
One induced draft fan is located 7.6 m (25 ft) downstream from
the spray chamber. A special demister was being installed immediately
downstream from the ID fan during the December visit; the kiln was
also being relined with refractory. The demister is a wetted slot
configuration which will remove the larger droplets of water for dis-
charge to the scrubber water basin.
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Similar safeguards described for the Houston facility have been
designed into the Baton Rouge incinerator. All pneumatic valves are
spring-loaded to fail in the closed position. An automatically con-
trolled louvered system locks the heat into the after-burner. Fuel
and waste material feed systems have automatic shutoffs. A fire pump
has been incorporated into the spray chamber system. Whenever an
unscheduled shutdown occurs, the fire pump supplies water to the
chamber on a once-through basis. This spray water is discharged to
the facility's effluent lagoon via the scrubber water basin. If
there is a power failure, the fire pump must be manually activated.
Stack
The stacks serving both facilities are identical in design; how-
ever, the Baton Rouge stack is lined with gunnite while special liners
(proprietary) have been installed in the Houston stack. Each stack
is 30 m (100 ft) high, 2 m (7 ft) in diameter, and tapered for the
first 6 m (20 ft); the bottom of each stack is 3.6 m (12 ft) in diam-
eter. The walls are steel and 0.9 m (3 ft) thick. Sampling ports
have been installed 18 m (60 ft) from the ground.
CHEMICAL LANDFILL
Houston Facility
The disposal site is open 24 hr/day, 7 days/week; however, loads
normally arrive during daylight hours, and rarely on Sunday. All
loads are prescheduled into the landfill area. One supervisor and
two workmen are located at the site; additional personnel are as-
signed on an as-needed basis. If loads arrive at night or Sunday, a
Company supervisor will be called back to work and will accompany the
truck for disposal.
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Excess clay from the landfill is sold to a private contractor;
the top 0.9 to 1.2 m (3 to 4 ft) of topsoil is saved for final cover
material. The contractor does all of the excavating in the landfill
area, plus maintaining the roads.
Equipment at the site includes a D-8 bulldozer, a dragline, and
a front-end loader (rented when needed).
The entire Houston facility is located on top of approximately
30 m (100 ft) of clay in the Beaumont Formation. Sand zones or len-
ses are interspersed throughout this formation. Although the water
table is within 3 m (10 ft) of the surface, water movement in the
clay is extremely slow.
Landfilling of solids and sludges is conducted on a 16-hectare
(40-acre) site on the southern portion of the plant. Open pits,
about 24 x 80 m (80 x 260 ft) are excavated to a depth of 12 m (40
ft). The working face is maintained at a 3 to 1 slope. Between 1.4
and 1.6 hectares (3 1/2 to 4 acres) are used at one time. Until 1976,
the pits were excavated to a depth of 6 m (20 ft), however the depth
was increased for better utilization of the land.
To prevent contamination of most runoff, coffer dams are con-
structed in the pits to isolate the working area from the nonworking
area. In addition, clay dikes are constructed around the pits to
eliminate runoff flow into the pit from the surrounding terrain. The
uncontaminated runoff is collected and discharged from NPDES Outfall
002. Runoff collected in the working area is analyzed in the RES
laboratory for pH, heavy metals, and COD. After analysis, the runoff
is either pumped or hauled by tank truck to the biosystem basin (L-12),
depending upon the capacity of L-12 at the time.
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39
Two methods of disposal are used: encapsulation of inorganic and
oily sludges, and direct burying of solid material. Solid material
(containers of wood, paper, cardboard, or synthetic material are not
landfilled) is placed in the excavated pit used for the solid waste
and crushed with an 1,800 kg (2 ton) concrete block. Clay is com-
pacted around this mass with a minimum thickness of 30 cm (1 ft);
compacted cells of solid materials are built on top of each other
until the pit is filled. Filled drums and fiber packs are not
crushed, but are placed in an area of the pit (cell) and encapsulated
with a 0.6 m (2 ft) thickness of clay. This waste is stored in the
cell until enough waste is available to cover. Daily back covering
is not practiced unless the material exhibits severe leaching char-
acteristics.
Inorganic and oily sludges are discharged to a special pit and
mixed with cement flue dust by a dragline. The mixture is then moved
to the excavated pit used for sludge disposal (not the same pit used
for solid waste disposal) by either dragline or bulldozer, compacted
into the working face and encapsulated in a layer of clay. The
sludges are hauled to the landfill area in open-bin trailer trucks
(RAM-E-JEC), and discharged directly into the mixing pit. The sludge
residue is scraped off by the truck driver. Flue dust is added to
the mixing pit from either a 73 m. ton (80 ton) skid mounted temporary
storage tank or directly from enclosed 18 m. ton (20 ton) trucks.
RES plans to locate two movable storage tanks, 225 m. ton (250 ton)
each, at the landfill site. The plans include the purchase of one or
more pug mills for direct mixing of the flue dust with the waste sludges.
The quantity of flue dust mixed with the sludge is dependent upon the
moisture content of the sludge determined by the RES laboratory.
Dewatering wells have been drilled to a depth of 12 m (40 ft)
into the sand lenses in the landfill area. The water was discharged
to the Tucker Bayou before landfill ing began. The Company plans to
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40
place monitoring wells around the landfill boundary for leachate
monitoring. Each burial site will have its own well system. To
date, leachate has not been observed in the dewatering wells, indi-
cating that the material is adequately encapsulated. The Company is
required to monitor these wells every four months and report the re-
sults to the State.
In some instances, special solid wastes not received on a routine
basis are landfilled. A large quantity of hexachlorobenzene, received
in block form, was buried upon arrival. Capacitors from Austin, Texas
were incinerated and the residue landfilled. As an alternate to incin-
eration, PCB capacitors will be placed in a cell and encapsulated
with clay. Flue dust will be placed around the capacitors prior to
encapsulation.
Final closure of a landfill pit consists of backfilling and com-
pacting with a minimum of 1.8 (6 ft) of impermeable clay. From 1.2
to 1.8 m (4 to 6 ft) of topsoil is placed over the clay, increasing
the elevation of the ground about 1.2 to 1.5 m (4 to 5 ft) above its
original contour. Runoff drains to Tucker Bayou.
Permanent benchmarks have been constructed throughout the land-
fill site. The exact location of each cell or pit containing sludges
can be determined from the RES records.
Fugitive emissions, a major problem in the landfill area, are
controlled by keeping the soil wet. An asphalt road has been con-
structed to the landfill to reduce traffic dusts. Dusts are released
when the truck drivers improperly direct the hose used to empty the
flue dust from the truck into the mixing pot. The pug mill and new
storage facilities should minimize this problem.
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41
Communications between the landfill site and the main office is
maintained by walkie-talkie. Power has been extended to the site,
but had not been placed into service in November. A permanent build-
ing will be installed in the future. A portable eyewash, shower, and
water tank are available at the site. Workers must wear goggles,
respirators, rubber boots and a rain suit. The dragline is enclosed,
the bulldozer is equipped with a roll bar, and all the equipment carry
fire extinguishers.
Baton Rouge Facility
The disposal site is open 24 hr/day, 7 days/week; however, only
2 shifts are manned daily at the landfill. All wasteloads are scheduled
into the site, thereby minimizing off-hour arrivals.
All excavation, backfilling and maintenance are conducted by RES
employees. Equipment at the site includes 2 draglines, 2 bulldozers,
1 grader, 1 backhoe, and forklifts. The site is lighted, power is
provided by generators. A single lane lime-rock road has been con-
structed and the Company plans to widen the road to two lanes.
The Baton Rouge facility is located on 73 hectares (180 acres)
on a bluff adjacent to the Mississippi River. The bluff consists of
33 m (108 ft) of stiff clay. Sand lenses exist in the clay formation
and the depth to the water table is approximately 20 m (65 ft), deter-
mined from monitoring well data. The direction of groundwater move-
ment is not known.
Landfill ing is conducted on the west side of the facility's prop-
erty [Figure 1]. In the past 7 years, from 5 to 6 hectares (12 to 15
acres) have been used for disposal and have been closed; the depth of
the fills was approximately 6 m (20 ft). The entire landfill site
has been surveyed, staked, and permanent benchmarks constructed. The
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42
locations and types of wastes placed in the landfill can be determined
from the records and scale map. Currently, less than 0.8 hectares (2
acres) are used for landfill ing.
The disposal method is different than that used at Houston. An
individual cell is excavated and solid wastes and sludges are placed
in the cell together. A working face is not used. The cells are
unlined and are about 10 m (35 ft) wide x 45 m (150 ft) long, and 6 m
(20 ft) deep or greater. Approximately 10% of the incoming wastes
goes to the landfill. Transport trucks unload directly into the
cells. After the sludges, drums, and other solid materials fill the
cell, dirt and clay are mixed in with a dragline and allowed to set
for several days. Once the mixture hardens, the cell is covered with
a minimum of 1.5 m (5 ft) of clay and topsoil to a height of about
0.9 m (3 ft) above the ground surface. There is little settlement of
the completed dome. Drums, fiber packs, etc., are unloaded randomly
and generally sink into the sludge mixture. Solid catalysts are
mixed directly with the oily sludges before discharge to-the cells.
Transformers containing PCBs are drained, then incinerated. Capaci-
tors are placed into the metallic sludge landfill cells.
During the December NEIC inspection, 8 cells were open [Figure 1].
Cell 511 was in the process of being closed, 514C and 518 were active,
and the 515B, C, and D cells were receiving metallic sludges. The
newest cell, 518, was excavated to a depth of 10 m (35 ft). Future
cells will be this deep. Cells 509 and 510 contain oil and water
mixtures. Oil is skimmed from the two cells and burned in the incin-
erator. The water is sent to the biosystem while the oily sludge is
placed in basins 514C and 518. Cells 601 and 602 were being con-
structed.
After trucks have discharged the waste materials to the landfill
cells, they are washed in the cleaning area (only one truck can be
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43
washed at a time). The cleaning area consists of a sloped clay pad
(will soon be covered with concrete); the trucks are washed with plant
water with a high-pressure nozzle. The wastewater flow into a collec-
tion basin and is then pumped to the equalization basins (301, 302,
303) for the biosystem. RES trucks and customer trucks use this fa-
cility. Whenever needed, trucks are chemically and/or steam cleaned
at a subsidiary of RLC Corporation's Matlock truck division, Brite-Sol.
Sludges from Brite-Sol's treatment system are hauled to the RES facility
and placed in the oil and water basins 509 and 510.
Working and nonworking areas are not isolated as is done at Houston.
Therefore, the storm water runoff is pumped to the biosystem via a
PVC pipe. However, there are areas where the runoff will not drain
to collection systems. These areas are generally around the working
disposal pits. If the water accumulates to an appreciable amount, it
is removed by vacuum truck.
A series of monitoring wells will be placed at the periphery of
the landfill area. These wells will range in depth from 23 to 38 m
(125 ft). The installation of these wells was scheduled for early
1978.
Fugitive emissions are a problem in the area. With only a single
lane road, covered with lime-rock, mud tracking from the vehicles is
significant. Most of the mud is lost through vibration and movement
before a vehicle leaves the plant grounds.
A pressure tank and safety shower will be located at the landfill.
Hard hats, safety glasses and shoes, rain suits and gloves are supplied
to the workers.
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44
CHEMICAL TREATMENT
Houston Facility
Chemical treatment is not a major process at Houston. Aqueous
material to be chemically treated is either stored in clay-lined la-
goons, LF-6 and 9 in the landfill area, or treated immediately in the
area just east of the incinerator. Acidic wastes stored in the LF
lagoons are treated in situ with lime; precipitates from neutrali-
zation settle and remain in the lagoons because they will ultimately
be converted into landfill cells. The neutralized supernatant is
pumped to another clay-lined lagoon, L-1001, then to the biosystem via
the Hy-Purle filters.
Aqueous material with a total metal concentration greater than 5
mg/1 is placed in two 38 m3 (10,000 gal) fiberglass tanks (T-43 and
44) and mixed with lime. Each tank has its own top-mounted agita-
tors. The mixture is then discharged by gravity to a 130 m3 (35,000
gal) clay-lined lagoon, L-14, for metals precipitation as hydroxides
or sulfides. The supernatant from L-14 is either hauled by vacuum
truck or pumped directly to the surface of the Hy-Purle filters. The
L-14 sludge is mixed with flue dust and then sent to the landfill for
disposal.
If the aqueous material does not require neutralization and con-
tains less than 5 mg/1 total metals, it is discharged directly into
the biosystem1s equalization basin L-12.
Baton Rouge Facility
From 5 to 10% of the wastes received at this facility are sub-
jected to chemical treatment. The major contributors are platers and
chemical cleaning firms. Treatment consists of acid neutralization
-------
45
and metal precipitation. Metal contained in the wastes include cop-
per, zinc, chromium, and nickel. Most of the acid solutions are
either sulfuric or hydrochloric; the facility will not accept nitric
or hydrofluoric acids.
There are five clay-lined lagoons used for chemical treatment:
206, 304, 305, 307 and 308. The 300 series lagoons are located south
of the biosystem stabilization basin and north of the Hy-Purle filters.
The 206 basin is located south of the Hy-Purle filters and equalization
lagoon. Basins 304 and 305, each 1,135 m3 (300,000 gal) capacity are
used for storage of either type of waste. Basin 307, 95 m3 (25,000
gal) capacity, is used for metal precipitation, as a polishing basin,
or for specialized treatment. Basin 308, 38 m3 (10,000 gal) capacity,
usually receives clean hydrochloric acid (e.g., 5 to 10% HC1 and low
in organics). Sulfuric acid is neutralized with lime in basin 206.
The 300 series basins are interconnected [Figure 1]. Transport
trucks can unload directly to either 304 or 305. Once these two ba-
sins fill up, they will be covered with soil and new basins excavated.
Each basin should last 3 to 4 years, and land is available for additional
basins. Supernatant from basins 304, 305 and 308 flows into 307, and
the overflow from 307 goes to the biosystem equalization ponds (301,
302 and 303). The supernatant from basin 206 is also sent to the
equalization ponds, and the settled solids are cleaned out upon demand,
and landfilled.
The amount of time required for metal precipitation and acid
neutralization is determined by the RES laboratory. Lime is pur-
chased locally, and is added to the treatment basins directly from a
truck. The lime-waste solutions are mixed either by compressed air
jets in the basins or with portable recirculating pumps. The pH range
for precipitation is 7.5 to 9.0.
-------
46
Chemical treatment is used primarily for the same group of cus-
tomers. The customers ship wastes to RES on an infrequent basis.
Acids are not hauled in the RES trucks; wastes containing metals
rarely are hauled by RES trucks.
LAND CULTIVATION
Land farming of oily wastes began in April 1977 at Baton Rouge.
Only oil-pretreatment sludge from industrial wastewater treatment
plants is accepted. Currently RES has only one customer using this
disposal method but other industrial facilities have expressed in-
terest in the system. About 15% of the incoming waste material is
land farmed.
About 9.7 hectares (24 acres) of land have been divided into 5
plots for disposal [Figure 5]. Plot No. 1 is 1.67 hectares (4.13
acres) and plots Nos. 2 through 5 are each 1.99 hectares (4.91 acres).
In addition, there is sufficient land adjacent to the area for 4 more
plots of equivalent size.
The oily wastes are discharged from a RES owned RAM-E-JEC Truck
onto a plot, spread with a bulldozer, and disced into the soil to a
depth of 15 cm (6 in). The application rate is 1,345 m. tons/hectares
(600 tons/acre, or 3,000 tons/5 acres). When a plot is removed from
service, it is disced once/month to maintain aerobic conditions. The
plot will be ready to accept new loads of oily waste after six months.
The plots slope either east or west and drain to a collection
ditch between the plots. The collection ditches are located between
plots 4 and 5, and 2 and 3; plot 1 is served by its own ditch. Access
roads are located between plots 1 and 2, and 3 and 4; plot 5 is served
by its own road. The drainage ditches are not sloped, but connect at
each end to a contaminated ditch or a noncontaminated ditch. Storm
-------
Figure 5. Rollins Environmental Services, Inc.
Baton Rouge, Louisiana
-------
48
water runoff from an active plot drains to the contaminated ditch
while runoff from inactive plots flows to the noncontaminated ditch.
Barriers are placed at the end of the drainage ditches to direct the
flows to either the contaminated or noncontaminated ditches.
The runoff collection in the contaminated ditch flows to the
holding basin serving the activated sludge basin, D-3. This biologi-
cal treatment system was placed in service in November 1977. D-3 is
identical in design to D-2. The final clarifier has a 9.1 m (30 ft)
diameter with a 151 m3 (40,000 gal) capacity. The sludge is recycled
to D-3 and excess sludge will be sent to the land farm. A 50-horsepower
surface aerator provides mixing and oxygenation. The effluent from
the clarifier is discharged to the SE corner of the final stabiliza-
tion basin.
Runoff in the noncontaminated ditch flows to a second holding
basin. The water is analyzed in the RES laboratory and discharged to
the stabilization basin if treatment is not required, or to the acti-
vated sludge system if it requires treatment.
BIOLOGICAL TREATMENT
Houston Facility
The original treatment system consisted of 2 Hy-Purle filter
beds in series, an equalization basin, an activated sludge basin, and
final clarifier. The effluent was discharged to Tucker Bayou via a
lagoon system. Scrubbing water from the incinerator was discharged
to the scrubber water basin, then to the lagoon system.
The Hy-Purle filter media was placed in two clay pits, each 61 m
(200 ft) square, on top of a liquid collection system. A 0.9 m (3 ft)
-------
49
layer of bagasse was placed on top of the collection system, followed
by 0.9 m layers of rice hulls and pine bark. The filters were intended
to reduce the high BOD of the raw wastes by 50% but were never too
successful. The treatment concept was to collect the wastewater after
it passed through the filter, then spray it back over the filters for
aeration. Aerobic degradation was to occur in the top 0.3 m (1 ft)
of the filter followed by anaerobic degradation. A 2.5 cm (1 in)
water layer was to be maintained on the surface and the solids accumu-
lation periodically scraped off the surface. The spraying system
clogged with fine particles from the rice hulls and organic material
was leached from the filter media, thus negating any BOD reduction.
The filters were removed as a treatment sequence from the bio-
system in the fall of 1972. They are still used however, as waste-
waters containing high metal concentrations are chemically treated
and then applied to the filters before biological treatment. Accord-
ing to Houston personnel, the filters may be eliminated and the pits
used for chemical treatment, equalization, pH adjustment, or as aer-
ated lagoons. The filter media would be landfilled.
The present biosystem is kept in a recycle mode to maintain the
biomass because very little of the incoming waste material is amen-
able to biological treatment. Raw wastewater is discharged directly
from the transport trucks to the south end of the equalization basin,
L-12, unless chemical treatment is required [Figure 6]. A lime slurry
is also added at the south end to maintain the pH between 8 and 9.
The clay-lined basin has rectangular surface dimensions of 30 x 60 m
(100 x 200 ft), and a volume of 4,540 m3 (1.2 x 106 gal). A 50 horse-
power floating aerator is located near the center of the south half
to provide mixing. The effluent is removed from the surface of L-12
at the northwest corner with a 750 liters (200 gal)/min portable pump
throttled down to produce a flow between 75 and 95 liters (20 and 25
gal)/min. The effluent is pumped into the bottom of a 38 m3 (10,000 gal)
-------
50
(Excess Sludge)
.ime
ste ,
L*
0
I
i
Hy-P
Fi
Dry-
ing
Beds
I
L-12
Equal .
3 s<; i n
v 1
T"Rec\
Valvr T i Alum
IS— t ^ /-v f~\ T_ I rr\
D O U •*"•( FC )
Drum ASB V J
'cie
i . .
i Sludge j . Outfall
Jl 1 C
Iter
-Y Hv-Purlp
Filter
tui
SWB By-Pass
-
^
Outfall 001
" r i -«*-- - T . ,
'-' CUR •* Incinerator
Laqoons - SWB Canal * ° ' 9rnihh(ar
i
F-2
. F-3
Runoff Lagoons
R-2 *~ R-2 "*" R-l
Outfall 002 u ' _.. ru
Hnnc+nn Vhin rl-i^nn^l
Outfall 001 via Tucker Bayou
O Surface Aerator
ASB: Activated Sludge Basin
SWB: Scrubber Water Basin
FC: Final Clarifier
• »- Sludge Underflow
. Wast.pwatPr
Figure 6. Biological Treatment Schematic
Rollins Environmental Services, Inc.
Houston, Texas
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51
clarifier tank (T-49) and discharges at the top. The underflow from
the clarifier is returned by gravity on a batch basis twice/week, [19
m3 (5,000 gal)/batch], to the Hy-Purle filters.
The overflow from T-49 flows by gravity to the activated sludge
basin (ASB). Before discharging to the ASB, the flow enters a 55
gallon drum, laid horizontally, which has a 3° V-notch weir in the
exit end. A flow control valve, positioned in the pipe just upstream
of the drum, is used to control the flow to the ASB. An operator
adjusts the flow rate with the valve, then resets the pumping rate of
the portable pump at L-12 to maintain a flow of 416 m3 (110,000 gal)/day
from T-49. This flow restriction was established by the Texas Water
Quality Control Board.
The ASB is a hypalon-lined lagoon with a rectangular surface
dimensions of 17 x 33 m (57 x 107 ft), and an operating volume of
1,020 m3 (270,000 gal). Two 10-horsepower surface aerators are
located symmetrically on the longitudinal center!ine.
Effluent from the ASB flows by gravity through a 20 cm (8 in)
pipe to the final clarifier. An alum solution is added to the ASB
effluent through a standpipe connected to the 20 cm diameter pipe.
The solution drains from an elevated 55-gallon drum to a feeder cup
attached to the standpipe. The alum concentration in the clarifier
is maintained around 100 mg/1; the solution, 9 kg (2 Ib) alum/190
liters (50 gal) water, is added to the 55-gallon drum every 8 hours.
The cylindrically shaped final clarifier is 6 m (20 ft) in dia-
meter, 7.3 m (24 ft) deep and has a cone bottom. The operating vol-
ume is 150 m3 (40,000 gal). Between 750 and 1,130 liters (200 and
300 gal) of sludge (solids concentration ranging from 4,000 to 5,000
mg/1) is recycled to the ASB for 1-1/2 minutes every 15 minutes (the
minimum setting on the centrifugal pump's timer). Excess sludge is
-------
52
returned to the equalization basin, L-12, at the surface about 15 m
(50 ft) from the northwest corner.
Under normal operating conditions, the ASB mixed-liquor suspended
solids (MLSS) range from 3,500 to 6,000 mg/1, with a food-to-micro-
organism ratio (F/M) between 0.15 and 0.30. Under the recycling mode,
the F/M ratio ranges between 0.02 and 0.1 with a MLSS of 2,000 mg/1.
At a flow rate of 95 liters (25 gal)/min, the residence time is 7.5
days. Currently, the influent BOD to the ASB ranges between 500 and
800 mg/1 with removals ranging between 40 and 70%. Normal operating
influent BOD concentrations are 800 to 1,200 mg/1 and removals average
90%.
The overflow from the final clarifier can be sent to the incin-
erator venturi scrubber, returned to the equalization basin L-12 when
the system is on recycle, or discharged to the scrubber water basin
canal downstream of the basin, thus bypassing the incinerator. Dur-
ing the November inspection, the effluent was recycled to L-12.
Baton Rouge Facility
An estimated 35% by volume of all wastes received at Baton Rouge
are treated biologically. The biosystem is operated at capacity.
The Hy-Purle filters are used as part of the normal treatment process.
The wastewaters are discharged to an equalization basin shown as
301, 302, and 303 in Figure 7, but called 300 by plant personnel.
This basin was originally 2 m (7 ft) deep, but solids deposition has
reduced the effective depth to 1.2 m (4 ft); the surface area of the
basin is about 0.8 hectares (2 acres). Most of the wastewater dis-
charged to the equalization basin comes from other processes within
the plant.
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53
Sand ^
Filter
^Collection
"Basin
Landfill
Raw Wastes
In-Plant
Equaliza-
tion Basin
#300
(301,302,
3031
V?
o
I
Incinerator
Scrubber
Outfall 002
D-l
n
o
,D-2:
SWB:
FC:
Flow Meter
Surface Aerator
Activated Sludge Basins
Scrubber Water Basin
Final Clarifier
Sludge Underflow
Wastewater '
Outfall 001
To Mississippi River
via Baton Rouge Bayou
Figure 7. Biological Treatment Schematic
Rollins Environmental Services, Inc.
Baton Rouge, Louisiana
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54
The effluent from the equalization basin is sprayed onto the
Hy-Purle filters. There are 0.8 hectares (2 acres) of filter beds in
use, each approximately 2 m (7 ft) deep. The spraying apparatus is
portable, however most of the wastewater is pumped through hoses di-
rectly onto the beds. The filter media, bagasse, is about 1.8 m (6
ft) deep; additional bagasse has been added to the original bagasse.
The hydraulic loading to the filters ranges between 230 and 265 m3
(60,000 and 70,000 gal)/day. The COD load averages 4,500 kg (10,000
lb)/day; about 20% is removed in the filters.
A high-rate sand filter is located adjacent to the equalization
basin for treatment of special wastes. The sand filter drains into
an adjacent 15 m3 (40,000 gal) collection basin and the wastes can be
returned to the sand filter or sent to the Hy-Purle filters. Acti-
vated carbon can be placed in with the sand. The filter media is
washed river sand with a gravel base. This unit is used for metal
removal and pH adjustment. The total metal concentration discharged
to the Hy-Purle filters is kept below 15 mg/1. The sand filter has
not been used in the last 1-1/2 years.
The Hy-Purle filter leachate is collected in a sump and pumped
to two activated sludge basins, D-l and D-2. The original basin,
D-l, is a rectangular, asphalt-lined, earthen basin, approximately 18
x 36 m (60 x 120 ft), and 3.6 m (12 ft) deep. The operating volume
is 870 m3 (230,000 gal). D-2 was installed in January 1977 and is a
13 m (43 ft) diameter flat-bottomed steel tank, 5 m (16 ft) deep,
with a capacity of 720 m3 (190,000 gal). D-l has three surface
aerators; two aerators are 10 horsepower each and the third is 25
horsepower. A 50-horsepower surface aerator is used in D-2. Each
basin is considered as a complete mix system; the contents are turned
over every 10 minutes.
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55
The two activated sludge units are operated in parallel. The
flows to each are measured with 2-inch water meters and are propor-
tioned to each basin. The effluent from each basin is sent to one
final clarifier, a steel conical tank with a 9 m (30 ft) diameter,
and depth of 2.4 m (8 ft). The clarifier1s capacity is 15 m3 (40,000
gal), providing 14 to 16 hours' detention. Settled solids are re-
turned to each activated sludge unit on a proportional basis. The
recycle is for a specified period of time each hour; the time period
will vary depending upon the daily operations. All of the sludge is
recycled from the clarifier except that sludge is wasted on Mondays,
Wednesdays, and Fridays over an 8-hour period. As the sludge age in-
creases, it is wasted over a 24-hour period. The wasted sludge can
be sent to the Hy-Purle filters, or to the equalization basin 300.
The clarifier overflow is discharged by gravity through a 30 cm
(12 in) diameter pipe which connects to a 15 cm (6 in) diameter pipe
serving the incinerator scrubber water basin. This basin is 18 m (60
ft) square and 2.4 m (8 ft) deep. If the incinerator is not opera-
ting, or if the scrubber water basin is full, the effluent is diver-
ted at the junction of the 2 pipes to the stabilization basin. The
effluent from the stabilization basin is discharged to a ditch and
flows into Baton Rouge Bayou, then into the Mississippi River. The
water in the scrubber water basin is recycled to the incinerator; the
excess water is discharged to the stabilization basin.
The influent COD and BOD concentrations to the activated sludge
basins range from 8,000 to 15,000 mg/1 and 4,000 to 8,000 mg/1, re-
spectively. The total suspended solids are low. The clarifier ef-
fluent COD and BOD concentrations range from 1,000 to 2,500 mg/1 and
150 to 300 mg/1, respectively. Solids are again low. The F/M ratio
is not measured. Phosphorus as phosphoric acid is added as a nutrient.
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56
WASTEWATER EFFLUENT SYSTEM
Houston Facility
All rainwater runoff and process wastewater from the facility is
discharged to Tucker Bayou which flows into the Houston Ship Channel.
Uncontaminated runoff is collected in a series of three retention
lagoons, R-l, R-2, and R-3; if the laboratory analyses confirm that
contamination has not occurred, the runoff may be discharged from
NPDES Outfall 002 to Tucker Bayou. However, discharge is rare and
the runoff is generally used as make-up water for the incinerator
scrubber. Contaminated runoff will be sent either to the biosystem
or burned in the incinerator. Rainfall collected behind impoundment
dikes in the tank farm, landfill, etc., is collected in vacuum trucks
and discharged to the biosystem.
Process wastewater from the biosystem, when not recycled back to
the head end of the biosystem, is sent to the incinerator scrubber
and then to the hypalon-lined scrubber water basin (SWB); the waste-
water can also bypass the incinerator scrubber and discharge to the
SWB canal downstream of the basin. The overflow from the SWB dis-
charges into the first of four clay-lined lagoons, F-l through F-4,
via the clay-lined SWB canal. The total volume of the four lagoons
is approximately 18,900 m3 (5 x 106 gal) with a retention time be-
tween 5 and 7 days. The lagoons are used for pH control, cooling,
solids sedimentation, and flow equalization. The pH of the discharge
from the SWB and each of the four lagoons is continuously monitored;
if the pH falls out of the range of 6 to 9 between lagoons F-l and
F-4, baffles are manually placed in the channels connecting the
lagoons, shutting off the flow. After the pH is adjusted or returns
to the 6 to 9 range, the baffles are removed. This system was in-
stalled because the pH of the final effluent from F-4 (NPDES Outfall
001) frequently failed to comply with the NPDES permit limitation.
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57
During the inspection, the pH of the wastewater discharged from the
SWP was 11. The pH's of the F-l, F-2, and F-3 effluents were 7.2,
7.8, and 7.8, respectively. Bags containing absorbent material were
located in the channel connecting F-2 and F-3; these are used to con-
trol foam and floatables.
Most of the solids sedimentation occurs in the F-l lagoon.
Sludge is pumped from the lagoon every 9 months, or as needed, to
drying beds west of the F-l. The influent to F-l was chalky white in
appearance with steam vapors. The effluent from F-l was clear and
the wastewater temperature had decreased sufficiently as vapors were
absent.
All NPDES effluent parameters [Table 3] are monitored at the
discharge from F-4, Outfall 001. Temperature and pH are continuously
recorded with a Delta Automatic Analyzer. The flow is continuously
recorded on a strip chart and totalized with a Manning Environmental
Corporation C-2000 Total Flow Computer. Instantaneous pH, temper-
ature, and flow values were 7.8, 19°C, and 510 gpm, respectively,
during the NEIC inspection. According to RES personnel, the flow
ranges between 2,200 and 4,500 mVday (0.6 and 1.2 mgd, or 416 and
832 gpm).
The flow from F-4 passes over a 60° V-notch weir; the upstream
approach to the weir complies with the established criteria, however
the notch in the weir is flat-crested instead of sharp-crested, and
therefore does not comply with criteria for a standard V-notch weir.*
RES personnel did not know if the recording equipment had been cali-
brated for this weir installation or for a standard V-notch weir. If
Water Measurement Manual, U.S. Dept. of the Interior,
Bureau of Reclamation, Denver, Colorado, 1976.
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Table 3
NPDES PERMIT EFFLUENT LIMITATIONS (PERMIT NO. TX0005941)
ROLLINS ENVIRONMENTAL SERVICES INC.
DEER PARK, TEXAS
Effective November 26, 1976 through December 4, 1979
Discharge Limitations
Effluent Characteristics
Flow-m3/day (mgd)
Temperature
pH S.U.
TSS
TOC
0/G
Phenol
Flow-m3/day (mgd)
BOD
Daily Avg
kg/day 1 b/day
Outfall 001 (Combined
N/A
N/A
6.0-9.0
132 290
184 406
30 66
0.09 0.2
Outfall 101 (Scrubber
N/A
72.6 160
Daily Max
kg/day 1 b/day
Process Discharge)
N/A
N/A
N/A
263 580
368 812
60 132
0.18 0.4
Water Discharge)
N/A
145 320
Outfall 201 (Biological Waste Treatment Effl
Flow-m3/day (mgd)
pH S.U.
BOD
Flow-m3/day (mgd)
pH S.U.
TOC
0/G
N/A
6.0-9.0
20.9 46
Outfall 002 (Storm
N/A
6.0-9.0
N/A
N/A
N/A
N/A
41.7 92
Water Runoff)
N/A
N/A
35 mg/1
15 mg/1
Monitoring
Measurement
Frequency
Continuous
Continuous
Continuous
3/week
3/week
3/week
3/week
3/day
2/week
uent)
3/day
3/week
3/week
3/day;*
Daily
Daily!!
Daily3
Requirements
Sample
Type
Record
Record
Record
24-hr. Composite
24-hr. Composite
24-hr. Composite
24-hr. Composite
Instantaneous
24-hr. Composite
Instantaneous
Grab
24- hr. Composite
Instantaneous
Grab
Grab
Grab
a While flowing
en
00
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59
the equipment was calibrated for a standard weir, flow measurements
will not represent actual conditions and therefore will not comply
with permit requirements. If the weir had been rated with another
type of flow device, and the measuring equipment calibrated for this
rating, then flow measurements are in compliance.
Samples are collected with a SIRCO Vary Sampler which incorpor-
ates air purging of the intake line. The composite sample is col-
lected on a flow-weighted basis; aliquots are withdrawn from the ef-
fluent every 113 m3 (30,000 gal), and stored in a refrigerated con-
tainer. Composite samples must be collected three times/week for
total suspended solids (TSS), total organic carbon (TOC), oil and
grease (0/G), and phenol. Samples for 0/G should be collected on a
grab sample basis, otherwise they will not comply with section 304(g)
of PL 92-500. This approved method requires that samples must be
collected in a single container, stainless steel or glass, and ex-
tracted with freon. In addition, the collection vessel contents must
also be rinsed with freon. Because aliquots are withdrawn from the
composite sample for TSS, TOC, and phenol, the entire sample cannot
be analyzed for 0/G.
There are three additional NPDES monitoring locations: Outfalls
101 (scrubber water basin effluent); 201 (biosystem final clarifier
effluent); and 002 (storm water runoff discharged from lagoon R-3).
Effluent limitations are listed in Table 3.
The Discharge Monitoring Reports (DMRs) for April through June,
1977, show that the effluents from Outfalls 001 and 101 complied with
permit limitations. The DMRs also indicate that there was no discharge
from 201 and 002. During the NEIC inspection, there was no discharge
from 002 and the effluent from the biosystem was being recycled to
the equalization basin.
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60
Sanitary wastewaters are discharged to four septic tanks operated
in series. The effluent from the fourth tank is sent to the acti-
vated sludge basin. Solids from the first three septic tanks are
periodically pumped out and deposited into the fourth septic tank.
The fourth tank can be mechanically stirred; chlorine gas or sodium
hypochlorite (HTH) can be added to the tank's effluent to comply with
the Texas State Board's requirement that all raw sanitary wastewater
be chlorinated either before entering a secondary treatment system or
leaving the secondary system.
Baton Rouge Facility
As previously described, all process wastewaters are eventually
discharged directly to the final stabilization basin or to the in-
cinerator scrubber water basin which overflows to the stabilization
basin. The effluent discharged from the stabilization basin is NPDES
Outfall 001. This wastewater flows through a ditch on Company prop-
erty and discharges into the Baton Rouge Bayou; the bayou flows into
the Mississippi River. Uncontaminated runoff is discharged through
Outfall 002, which joins the process wastewater flow in the effluent
ditch upstream of the bayou. If the runoff is contaminated, it is
treated in the biosystems and discharged via Outfall 001. Effluent
limitations for both outfalls are shown in Table 4.
The process effluent is monitored at Outfall 001 for NPDES limi-
tations as it leaves the stabilization basin. A 60° V-notch weir is
used to determine flow. The upstream approach to the weir complies
with the established criteria, however the notch in the weir is flat-
crested instead of sharp-crested, and therefore does not comply with
the criteria for a standard V-notch weir. The maximum thickness of a
standard V-notch weir, measured in the direction of flow, should be
between 1 and 2 mm (0.03 to 0.08 in), the thickness of the effluent
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Table 4
NPDES PERMIT EFFLUENT LIMITATIONS (PERMIT NO. LA0038245)
ROLLINS ENVIRONMENTAL SERVICES INC.
BATON ROUGE, LOUISIANA
Effective January 1, 1977 through October 30, 1979
Discharge Limitations
Effluent Characteristics
Flow-m3/day (mgd)
Temperature, °F
pH S.U.
BOD.
coo'3
TSS
0/G
Copper
Phenol
Daily Avg
kg/day Ib/day
Outfall 001
N/A
N/A
6.0-9.0
76 168
672 1 ,482
76 167
30 67
0.6 1.33
0.91 2.0
Daily Max
kg/day 1 b/day
(Process Effluent)
N/A
N/A
N/A
152 336
1,344 2,964
151 333
60 134
0.91 2.0
3.2 7.0
Monitoring Requirements
Measurement
Frequency
Continuous
Continuous
Continuous
I/week
3/week
3/week
3/week
I/week
I/week
Sample
Type
Record
Record
Record
24-hr. Composite
24-hr. Composite
24-hr. Composite
24-hr. Composite
24-hr. Composite
24-hr. Composite
Outfall 002 (Stormwater Effluent)
Flow-m3/day (mgd)
pH S.U.
BODc - mg/1
COD - mg/1
Oil & Grease-mg/1
N/A
6.0-9.0
25
50
10
N/A
N/A
50
100
10
Daily3
Daily3
Daily3
Daily3
Daily3
Instantaneous
Grab
Grab
Grab
Grab
a When flowing
en
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62
weir at Outfall 001 is 6 mm (0.25 in). As was the case at the Houston
facility, the RES personnel did not know if the recording equipment
had been calibrated for this weir installation or for a standard
V-notch weir. The effluent flow may be incorrectly measured and re-
corded.
The flow (Foxboro Flow Recorder), temperature and pH are con-
tinuously recorded in the incinerator control room. In addition, the
instantaneous flow and pH are also indicated at the outfall. During
the inspection, the instantaneous flow and pH were 1,590 m3 (420,000
gal)/day and 7.0 at the outfall, and 2,200 m3 (580,000 gal)/day and
6.8 at the control room. The instantaneous temperature was 56°F.
The RES personnel said the data for the permit are taken in the con-
trol room, and that the flow indicator at the outfall wet-well was
malfunctioning and would be corrected.
Samples are collected with a SIRCO Vary Sampler which incor-
porates air purging of the intake line. The composite sample is col-
lected on a flow-weighted basis over a 24-hour period; aliquots are
withdrawn from the effluent for a pre-set volume of flow and stored
in a single-glass container in a SIRCO refrigerator at 4°C. About 50
ml are withdrawn for each 3.8 m3 (1,000 gal) of flow. The samples
are not preserved chemically.
Oil and grease (0/G) samples are not collected as required by
the permit, i.e., 24-hour composite basis, but are grab sampled once
a day on Monday, Wednesday and Friday. The grab sample method com-
plies with correct monitoring procedures and is preferable over per-
mit requirement. However, a more accurate representation of the oil
and grease load could be determined by collecting samples three times
over the 24-hour period.
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63
Samples for the effluent parameters are collected on the same
day each week: copper on Monday; phenol on Tuesday; BOD on Thursday;
and COD, TSS and 0/G on Monday, Wednesday and Friday. The pH probe
in the effluent discharged from Outfall 001 is checked weekly using
pH buffers of 4, 7, and 10. The pH of the wastewater is also spot
checked with a laboratory pH meter. The pH of the effluent is only
controlled at the incinerator scrubber water basin where the pH is
adjusted through caustic addition to the scrubber make-up water.
Instantaneous flows at Outfall 002 are measured using a
Cipolletti weir.
The Discharge Monitoring Reports for April through June 1977
show that the wastewater discharged from Outfall 001 complied with
the permit limitations. Outfall 002 was active in April and the ef-
fluent complied with the limitations.
Sanitary wastewaters are discharged to a lift station and then
pumped to the activated sludge basin D-l.
STORAGE FACILITIES
Houston Facility
Tank Farm - Burnable liquid wastes are stored in steel tanks in
the 0.6 hectare (1.5 acre) tank farm located north of the incinerator
[Figure 1]. The total storage capacity in the farm is about 2,270 m3
(600,000 gal). Most of the tanks sit on concrete pads; others are on
sand pads. The tank area is enclosed by a 0.7 to 0.9 (2.5 to 3 ft)
high clay dike with a 3/1 slope. The dike is in fairly good condition,
although there were areas where repairs were required. According to
the Houston personnel, the enclosed area will contain the volume of
the largest tank plus some excess.
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64
Of the 20 tanks within the diking [Table 5], about 1/3 contain
solidified material or liquid slurries, or a combination of both, and
are not used. These tanks are being cleaned, one at a time, and re-
turned to service. Solid material is placed in fiber packs and in-
cinerated; the liquid slurries are also incinerated.
The storage tanks are constructed of carbon steel with nominal
thickness of 4.8 mm (3/16 in). Insulated tanks are 6.4 mm (1/4 in)
thick and all high-pressure tanks are thicker than 6.4 mm. The new-
est tank in the farm, T-60, is 9.5 mm (3/8 in) thick. A high-pressure
tank, T-40 [53 m3 (14,000 gal) capacity], located adjacent to the
incinerator outside of the diked area, is 19 mm (3/4 in) thick. There
is one tank in the farm which is not' used because the walls are too
thin. The tanks are inspected for thickness with an ultrasonic device
once a year and the ins ides are inspected visually once every two
years. If the original thickness is reduced more than 50%, the tank
will be removed from service and landfilled.
Liquid wastes are pumped from the vacuum trucks to the storage
tanks via pipelines located at unloading facilities on the north and
south sides of the tank farm. A sump is located at each unloading
area to catch spills or rain falling into the diked enclosure. The
sump contents are removed by a vacuum truck and either incinerated or
placed in the storm-water lagoon R-l. If the sumps overflow and are
not contained by the dike, the wastewater or runoff will eventually
flow to R-l via the sloped ground and plant sewer.
Each waste shipment is analyzed for ash content, sulfur, Btu
value, and chlorine (most of the wastes contain chlorinated hydro-
carbons). The wastes are then pumped from the trucks to the appro-
priate tank which contains similar or compatible wastes. There are
no level sensors in the tanks, however the level is checked manually
each time a tank is used. The level in each tank is also checked
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65
Table 5
TANK CAPACITIES
ROLLINS ENVIRONMENTAL SERVICES, INC.
HOUSTON, TEXAS
Tank No.
T-l thru T-10
T-ll thru T-26
T-28
T-32
T-60
Capacity
(each)
m3
98
49
38
79
378
gal
26,000
13,000
10,000
21,000
100,000
Operating Volume
(each)
ma
95
48
35
76
356
gal
25,000
12,600
9,300
20,100
94,200
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66
weekly. The average time that wastes remain in storage is approxi-
mately two weeks. After a tank has been filled or the contents are
ready for incineration, the wastes are sent to one of two blend tanks
and checked for the above parameters. The blend tanks have agitators
which can mix the wastes until they achieve RES specifications for
incineration. The blended wastes are transferred via centrifugal
pump and atomized as they enter the incinerator.
All of the tanks contain vapor spaces above the liquid wastes
which could be explosive, however little oxygen enters the system.
These vapors are withdrawn into a vent system which exhausts into the
after-burner of the incinerator. A blower in the vent system is used
to bring the vapors to the incinerator. The tanks are at atmospheric
pressure and have 2.5 cm (1 in) of positive water pressure. When the
incinerator is down, the vent system is manually switched to one of
two activated carbon beds. Each bed is 0.9 m (3 ft) in diameter and
height and contains about 450 kg (1,000 Ib) of carbon. The carbon is
replaced every 1 to 1-1/2 years, or more frequently if needed. The
exhausted carbon is burned in the kiln.
The vent system was constructed in flanged sections with sche-
dule 40 carbon steel. The system is completely above ground and the
longest distance from a tank to the incinerator is about 91 m (100 yd).
Unfortunately, other than visual inspection, there is no method to
detect a leak in the system. Potentially toxic, hazardous or ex-
plosive vapors could be emitted to the ambient air through a rupture
or leak.
Some of the storage tanks are dedicated to receive wastes from
individual customers. These waste streams are never blended, but are
fed directly to the incinerator from the tank. In some instances,
incoming wastes are fed directly to the incinerator, bypassing storage.
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67
Storage tanks adjacent to the incinerator are not diked.
Drum Storage - The Texas State Board required that all drums be
stored in one area by June 30, 1974. Steel drums and fiber packs are
now stored on an 82 x 24 m (270 x 80 ft) uncovered 15 cm (6 in) thick,
concrete pad west of the incinerator. The pad is sloped to the west;
the north and south ends of the pad have concrete curbs which are 10
cm (4 in) high on the east edge and taper off flush with the ground
on the west edge. All spills and runoff drain to a sump. Contents
of the sump are removed by vacuum truck and either incinerated or
discharged to the stormwater lagoon R-l. If the sump overflows, the
runoff will eventually flow into R-l.
Both 55-gallon steel drums and 35-gallon fiber packs are stored
on wooden pallets, and are stacked no more than 2 sections high.
Occasionally, odd-size steel drums are accepted for disposal. The
average residence period in the storage area is two months for the
steel drums and one week for the fiber packs. About 4,000 drums can
be stored, however the facility's policy is to store no more than
2,000 drums in the area. According to Company personnel, there never
has been an accident or explosion in the drum storage area.
Most of the material received in the steel drums is burnable.
After the material is removed, the drums are flushed, crushed and
landfilled. The pallets are reused unless they are contaminated, in
which case they are burned in the kiln. The Company stores excess
pallets in an area on the west side of the storage area. Fiber packs
are usually burned in the kiln, however if solid material is not com-
patible for incineration, the fiber packs are landfilled. The facility
generally will not accept solid material in steel drums unless it can
be heated and pumped to the incinerators. However, if solid material
is received in steel drums, the drums are crushed at the landfill and
buried.
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68
The material in the drums is spot-checked upon arrival at the
facility before it is accepted for disposal. The contents of steel
drums may be sucked into a Rollins 2,000-gallon vacuum truck at the
generation site to eliminate drum handling and storage. Rollins'
truck drivers will reject damaged drums at the generation site and
will not transport them.
The drum storage area was not well maintained. The curbs on the
north and south sides had been damaged or knocked down, thus spills
and runoff could flow onto the roadway instead of the sump. Empty
pallets were stored throughout the area. According to plant person-
nel, all of the drums will be disposed of by March 1978, and the area
will be cleaned up and the curbs repaired.
Baton Rouge Facility
Tank-Farm - Liquid wastes are stored in steel tanks in the tank
farm located north of the incinerator and west of the main office
[Figure 1], The total storage capacity is approximately 1,080 m3
(285,000 gal). All of the material in the tanks is incinerated. The
tank farm is sloped to a 150 m3 (40,000 gal) capacity sump on the
west side of the area. The east side of the area is not diked, how-
ever spills and runoff would naturally drain back to the sump.
According to the plant personnel, the tank farm will eventually be
paved and all the tanks repiped. Because there is no diking, a major
spill could possibly spread and contaminate the surrounding area.
However, it did not appear that the spill could leave Company prop-
erty. The sump can be pumped directly to the equalization basin,
300, or the contents can be collected into a vacuum tank and returned
to the tanks.
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69
There are 17 tanks in the area [Table 6]; only tank T-17, 19 m3
(5,000 gal) effective volume, is inactive as it contains solidified
material. Tanks T-6, T-7, and T-8 have agitators for mixing. Tank
T-l contains organic material which is filled directly from the
vacuum trucks and serves as the feed tank for the Thermal Oxidation
process. All other storage tanks are interconnected through a pipe-
line network. Vacuum trucks discharge into the tanks from a central
unloading area. The unloading area is not diked to contain spills.
The tanks are constructed of carbon steel of the same nominal
thicknesses reported for the Houston Facility. All of the tanks are
vented directly to the atmosphere, without any control equipment.
However, Company personnel stated that the material in the tanks
complies with the State legal requirements for storage.
The residence time in the tank farm varies between 1 and 4 weeks.
There are eight open basins west of the tank farm containing
liquid wastes. These basins were occasionally used as receiving areas
for the Thermal Oxidation process. The plant personnel stated that
the basins are no longer in use and will be closed in the future.
The material in the basins is reportedly rainwater, from its appearance,
however, it must be highly contaminated from leaching. These basins
should be emptied and closed if they are not going to be used.
Incoming liquid wastes are analyzed for ash content, chlorides,
specific gravity, acidity, flash temperature, metal concentration
(occasionally), compatibility and reactivity, Btu value, and acid
scrubbing characteristics. As is the practice at Houston, the wastes
are blended and then fed to the incinerator.
Drum Storage - Steel, 55-gallon drums are stored on 46 m long x
15 m wide (150 x 50 ft) pad, sloped to drain all runoff and spills to
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70
4
2
Table 6
TANK CAPACITIES
ROLLINS ENVIRONMENTAL SERVICES, INC.
BATON ROUGE, LOUISIANA
No. of Tanks
10
Effective Volume
m3 gal
95 25,000
Remarks
T-l is thermal
19
19
23
5,000
5,000
6,000
oxidation
process feed
tank
Blend tanks
for Loddby
burner
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71
a sump. Fiber packs are currently stored behind the incinerator con-
trol room. The pad consists of four bays; one bay is under a metal-
roofed structure, and will be used as the shop area. A second bay
will be used for polychlorinated biphenyl (PCB) storage; a concrete
curbing will be constructed surrounding the bay. However, to comply
with the PCB storage requirements, a roof will have to be built over
the bay to prevent rainwater from reaching the stored PCBs. The re-
maining two bays are diked with earth to contain and absorb spills.
About 600 steel drums are received weekly, but not all are stored.
These go to the landfill. The drums are off-loaded from the trucks
with a mechanized drum grabber, and placed in the storage area. Pallets
are not used. Residence time in the storage area may be as long as
several months, especially during wet weather.
Burnable wastes are either collected in vacuum trucks or in the
kiln blend tank. The drums are emptied either in the storage area or
next to the kiln blend tank. The empty drums are deposited uncrushed
in the landfill pits and sink into the liquid waste material. Lids
are also placed in the landfill pits.
A major problem at the facility is runoff from the storage area
during heavy rains. The present sump cannot contain the runoff.
Currently, excess runoff flows to the north ditch and out Outfall
002. A new sump collection system is to be built in early 1978. The
new sump will have a float-activated pump which will send the runoff
or spills to the biological treatment system.
The drum storage area was in the construction stages, therefore
it was not possible to determine the condition of the storage areas
or housekeeping procedures.
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72
The material in the drums is spot-checked upon arrival in the
same manner practiced at Houston. Rollins' trucks are not permitted
to pick up damaged or unsafe drums at the generation site. However,
the facility will accept damaged drums on customer trucks so as not
to create a hazard in further transportation.
TRANSPORTATION
Waste materials are transported to the facility either by cus-
tomer trucks, commercial carriers, or RES trucks; however, the use of
commercial carriers is discouraged due to possible contamination with
other material hauled. Each RES facility has its own fleet of trucks
and trailers [Table 7]. Although each facility manages its own fleet,
truck loads can be interchanged between any of the three plants.
There is no limit on the distance for hauling the waste material.
RES prefers to transport the waste materials to its facilities.
Once a shipment has been picked up at a generation site, RES assumes
responsibility for its safe handling and disposal. Although RES has
specific procedures for loading and unloading for their employees,
the customers do not have to comply with the procedures when loading
the RES trailers. However, the drivers can refuse to accept waste if
it is not the material contracted for. Also, the drivers refuse to
transport damaged steel drums or those which do not comply with the
Department of Transportation (DOT) specifications. The vacuum
trailers are loaded by the RES drivers.
At the Houston facility, several of the tank trailers use a
nitrogen gas (N2) blanket for loading and unloading. These trailers
are used for extremely hazardous and carcinogenic materials. Before
leaving the RES facility, trailers are pressurized with N2; the N2 is
released during loading at the generation site. The loading is done
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Table 7
WASTE MATERIAL TRANSPORTATION EQUIPMENT
ROLLINS ENVIRONMENTAL SERVICES, INC.
HOUSTON, TEXAS AND BATON ROUGE, LOUISIANA
December 1977
Description
Flat bed trailer
Vacuum trailer
No.
Houston
4
4
Units
Baton Rouge
4
5
Materials Hauled
Drums
Liquids
Remarks
75 regular drum capacity
Non-f lammables
Pressurized Tank trailers
Ram-E-Jec trailer
Insulated stainless steel
tank trailer
LPG tank trailer
Open bed box trailer
Flammable/corrosive tank
trailer
Tank truck (no trailer)
Belly mounted vacuum trailer
5
3
0
1
Solvents/other liquids
Solid slurries/sludges
1
2
0
0
0
0
0
0
1
1
1
1
Hot waste material
Carcinogenic and
toxic wastes
Solids
Flammable and corro
sive liquids
Liquids
Liquids
Houston Cap = 5,000 gal
Baton Rouge = 4,200 to
6,200 gal
30 Ib pressure supplied
by nitrogens
Open topped; sealed to
prevent leakage. Ram
pushes material through
tailgate.
Wastes blended before
storage
250-300 Ib pressure system,
supplied with nitrogen gas
30 cu. yd. capacity
DOT exemption. 5,100 gal
capacity.
3,000 gal. capacity
5,460 gal. capacity
CO
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74
by the RES driver and the pressurized system prevents contact with
waste material. The waste is unloaded at the disposal site (tank
farm or directly to the incinerator) by using N2 to pressurize the
trailer. After the trailer is emptied, N2 is used as a purge. The
nitrogen gas is collected in the tanks when storage of the waste is
required; only pressurized storage tanks are used to receive this
material. The nitrogen gas is also incinerated.
All liquid burnable material, drums, and fiber packs are un-
loaded by RES operating personnel. The RES truck drivers unload
sludges and solids at the landfill site. Customer's trucks are un-
loaded by RES operating personnel with the cooperation of the driver.
The Baton Rouge facility has one vacuum trailer which can le-
gally haul flammable and corrosive materials. This trailer has an
exemption from the DOT because of a special unloading system which
complies with the requirements for flammability. The DOT regulations
require an internal valve which makes it impossible to unload a stan-
dard vacuum trailer.
The trailers from the Houston facility are cleaned at the
Robertson Tank Lines facility. The washwaters are treated in an
activated sludge system. Trailers are also cleaned by Matlack, a
division of the RLC Corporation. The trailers from the Baton Rouge
facility can be cleaned on-site at the truck washing facility ad-
jacent to the landfill area. Chemicals are not used at this location
since the trucks are only washed down with well water. A division of
Matlack, Brite-Sol, cleans the trailers with caustic, steam, etc.,
whenever needed. The sludge from the Brite-Sol cleaning operation is
returned to RES and discharged into the API separation basins (509
and 510). Customer trucks are allowed to use the RES washing facility.
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VI. SAFETY
FIRE PROTECTION
Houston Facility
The entire operating area of the facility can be covered with
the fire protection system. A 7.6 m3 (2,000 gal) water tank is lo-
cated at the landfill, equipped with a portable nozzle. This system
provides protection at the landfill. There are numerous dry chemical
extinguishers located throughout the facility. The main fire system
consists of two permanently installed and one portable turret mounted
nozzles which are fed from the L-5 fire pump, located in the fire
house next to the 1,135 m3 (3,000 gal) fresh well water lagoon. A
foam system, 1.7 m3 (450 gal) in the fire house can add foam (3%
Aerofoam) to the main fire line, if needed. The L-5 fire pump, a
Cummings diesel, 6-cylinder, 240-horsepower, 24-volt DC-system, can
supply 3.8 m3 (1,000 gal)/min of water at 8.8 x 104 kg/m2 (125 psi).
The protection system also includes a Lister diesel, 6-cylinder, air-
cooled, 12-volt DC fire pump which can provide 0.4 m3 (100 gal)/min of
water at 8.8 x 104 kg/m2.
According to plant personnel, there has never been a fire in the
tank farm area but tanks have been cooled down with water from the
fire protection system.
Baton Rouge Facility
The tank farm and incinerator area can be covered by the main
fire protection system; the rest of the facility must rely on portable
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76
fire extinguishers. Fire water is taken from the final stabilization
basin and pumped through a diesel driven pump to three turret mounted
fire nozzles. The pump is checked every Sunday.
SAFETY AND TRAINING
Because of the nature of the business, personnel safety is em-
phasized at both facilities. All first-line supervisors are trained
in first aid. Each employee is given a mandatory physical once a
year. Safety equipment including hard hats, safety glasses, safety
shoes, rain suits, gloves, and uniforms are supplied to all employees
involved in handling wastes. The uniforms are cleaned by the Company.
All transport trucks are equipped with safety equipment and fire extin-
guishers. The bulldozers are equipped with roll bars and the operators
are provided respirators.
The Houston facility has a portable eyewash and safety shower
with portable pressure water tank at the landfill. A portable pres-
sure tank and safety shower is to be installed at the land farm area
in Baton Rouge. There are no such facilities at the landfill, however,
because the management feels that they are not necessary since the
materials deposited are not splashy. However, there are numerous
open pits containing hazardous wastes which could come into contact
with personnel.
The Houston landfill area currently has power at the site, but
service had not been installed. A building and phone will be installed
in the future. Communications are maintained by a walkie-talkie system.
At Houston, a safety document is prepared for each type of waste
coming into the plant. In addition, the facility has a Waste Information
Manual which describes characteristics of the wastes, handling procedures,
and safety information. The Baton Rouge facility does not have a
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77
Waste Information Manual because the facility receives numerous, new
and different wastes.
Except for operators who are trained before working in the dis-
posal area, new employees receive on-job training from a senior
employee for a minimum of 3 weeks. The operators at the Houston plant
are State certified smoke readers.
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78
REFERENCES
1. "State Decision-Makers Guide for Hazardous Waste Management,"
U.S. Environmental Protection Agency (SW-612), 1977.
2. "RCRA Hazardous Waste Enforcement Strategy, Part I: Enforcement
Goals, Plans and Programs," Fred C. Hart Associates, Inc., Report
#045-028, U.S. Environmental Protection Agency, Dec. 1977 (Draft).
3. "Potential for Capacity Creation in the Hazardous Waste Manage-
ment Service Industry," U.S. Environmental Protection Agency,
August 1976, U.S. Dept. of Commerce National Technical Information
Service PB-257-187.
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APPENDIX A
TEXAS MATER QUALITY BOARD PERMIT NO. 01429
(NPDES PERMIT NO. TX 0005941)
: PART III - OTHER REQUIREMTNTS
-------
Rollins Environmental Services, Inc. 01429 June 26, 1974
PART III
OTHER REQUIREMENTS
Earthen facilities for receiving and processing liquids
and for final disposition of solid wastes will conform
to the requirements set forth for Class I sites in Board
Order No. 71-0820-18. Solids will be those untreatable
solids which cannot be processed by biological, chemical
or incineration facilities and other sludges and ash which are
incidental to those processes. No material will be buried in a
container if the material is amenable to disposal by biological,
chemical or incineration processes. A hard surfaced drum
storage area with a capacity for 4,200 drums will be installed
and maintained to insure that all rainfall runoff from this area
will be directed to a storm water impoundment basin. Similar
hard surfaced areas will be provided at each point where
liquids are received and unloaded. Records will be kept
of all wastes that are not treatable through biological,
chemical or incineration processes, but disposed of in
landfill, ponds or other earthen facilities. These records
will include date, source, volume, characteristics, and facility
used for disposition. A minimum freeboard of 18 inches will
be maintained in all earthen facilities except the final
stabilization basin and those basins immediately preceding
the final stabilization basin
Man-proof fences will be installed and maintained to prevent
unauthorized access to all receiving and treatment basins or
similar facilities.
Monitoring and Continuing Surveillance^ Monitoring wells will
be installed for all facilities, as directed by the Executive
Director of the Texas Water Quality Board or his representative.
.The Texas Water Quality Board will, in the near future,
promulgate rules and regulations providing for long-term
surveillance and sampling of materials placed in Class I waste
disposal sites. Any such rules and regulations shall be
applicable to the permittee and all other operators of Class
I sites, but pending the adoption of such rules and regulations,
the permittee shall, upon the request of the Executive Director
but not more often than once each year, be required to provide
the Executive Director with an in-place sample of waste .
material which has previously been placed in covered disposal
sites from a location to be designated by the Executive
Director or his representative for such tests and analyses as
he may desire to conduct. During operation and after termina-
tion of operations at this site, the Executive Director shall
be given access, upon request but not more than twice each year,
for the purpose of taking such in-place samples.
WQB-.126 • Sheet C
Of A,3,C,D 11
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APPENDIX B
TEXAS AIR CONTROL BOARD OPERATING PERMIT NO. 679
FOR
LIQUID WASTE INCINERATOR
AT
ROLLINS ENVIRONMENTAL SERVICES, INC.
-------
TEXAS AIR CONTROL BOARD
AN OPERATING PERMIT
IS HEREBY ISSUED TO
ROLLINS ENVIRONMENTAL SERVICES, INC.
AUTHORIZING OPERATION OF
Liquid Waste Incinerator
WHICH IS LOCATED AT
Lat. 29°43'45", Long. 95°05M511
Deer Park, Harris County, Texas
and which is to be operated in accordance with and subject lo the Texas Clean Air Act, as amended (Article 4477-5.
VATSi. and all Rules, Regulations and Orders of the Texas Air Control Board. . Said operation is subject to any addi-
tional or amended rule*, regulations and orders ol the Board adopted pursuant to the Act, and to all of the following
conditions:
I This permit is non-transferable from person to person or from place to place.
2 Upon request by the Executive Director of the Texas Air Control Board, the holder of this permit shall make
sufficieni stack sampling analyses, or other tests, to prove satisfactory equipment performance. All sampling
and testing procedures shall be approved by the Executive Director and coordinated with the regional repre-
sentatives of the Texas Air Control Board.
3. The facilities covered by this permit shall not be operated unless all associated air pollution statement equip-
ment is maintained in good wotking order and operating properly during normal facility operations.
4. Special Provisions:
See attachment labeled "Special Provisions R-679," 1-14.
Acceptance of this permit conMilnles an acknowledgement and agreement thai the holder will comply with all Rules,
Regulations and Orders of the Board issued in conformity with the Act and the conditions precedent to the granting
of this permit.
PERMIT NO R-
679
DATE June 17, 1976
(4^ r?. LJL^
EXRCUTIVK DIRtCTOR
TF.XAS AIR CONTROL BOARD
fj /vnf^
^ P^JT
(WRi-rroR.
ANIi PKI VI
}( \
3JLu__J(,
CONTROL
NTION)
-------
SPECIAL PROVISIONS
1. Emissions from this facility must not cause or contribute to a condition of
'air pollution' as defined in Section 1.03.(3) of the Texas Clean Air Act,
Article 4477-5, V.A.T.S. If such a condition should exist, additional abate-
ment measures necessary to control and prevent the condition must be implemented.
2. Odorous emissions from this facility must not cause or contribute to a
condition of 'air pollution' as defined in Section 1.03.(3) of the Texas Clean
Air Act. If a condition of odorous air pollution develops, additional abate-
ment measures acceptable to the Executive Director must be implemented.
3. Opacity of emissions from the incinerator stack must not exceed 20%, averaged
over a 5-minute period, except for those periods described in Rule 103.1 of
Regulation I.
4. This facility must comply with Rule 105 of Regulation I of the Texas Air
Control Board.
5. Hydrogen chloride (HC1) emissions from the incinerator must not exceed ten
(10) pounds per hour.
6. Chlorine emissions from the incinerator must not exceed forty (40) pounds
per hour.
7. Sulfur dioxide emissions from this facility must not exceed two hundred
(200) pounds per hour.
8. The sulfur dioxide concentration in the stack effluent from the incinerator
must not exceed 440 ppm by volume.
9. The holder of this permit shall perform sampling on the incinerator stack
effluent at least once per year until otherwise directed by the Executive
Director. All sampling, testing, and procedures to establish proof of
performance shall be executed by an independent laboratory or testing
service acceptable to the Executive Director of the Texas Air Control Board.
The Executive Director or his designated representative shall be afforded
the opportunity to observe all such testing.
10. Air contaminants to be tested for include (but are not limited to) partic-
ulate matter, sulfur dioxide, vinyl chloride, chlorine, hydrogen chloride,
cadmium, copper, lead, vanadium, mercury, iron and arsenic.
11. A copy of all sampling reports shall be furnished to the Executive Director
of the Texas Air Control Board within 30 days after completion of sampling.
12. Upon request by the Executive Director of the Texas Air Control Board or any
local air pollution control program having jurisdiction, the holder of this
permit shall provide a sample and/or an analysis of the waste material
incinerated in this facility or shall allow air pollution control agency
representatives to obtain a sample for analysis.
CONTINUED
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Spi:iil Provisions
R-679
Page 2
13. The holder of this permit must submit monthly reports to the Executive
Director of the Texas Air Control Board. This report shall state the
quantity of material burned in each blend and the following specifics
on each blend: ash content, heating value, sulfur by weight, and chlorine
by weight. These reports shall be submitted by the last day of each month
for the previous month's operation and shall continue until otherwise
directed by the Executive Director.
14. The tank farm area and drum storage area must be properly maintained. The
vapor control system serving the tank farm area must be kept in good working
order and in operation at all times vapors are being emitted from the tank
farm.
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