oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9523.05(83)
TITLE: Supplemental PAT Comments on McDonnell-Douglas
Electronics Part B .Applications
APPROVAL DATE: 7-29-83
EFFECTIVE DATE: 7-29-83
ORIGINATING OFFICE: Office of Solid Waste
0 FINAL
D DRAFT
STATUS:
A- Pendir^ OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other document*): headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 270 SUBPART B - PERMIT APPLICATION
DOC: 9523.05(83)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Trial Burn, DRE, Incineration
40 CFR 270.62(b)(2)(i)(c), 264.15(b)
Supplemental PAT Comments on McDonnell-Douglas Electronics
Part B Application
Steve Busch, PAT Contact, Permits Section, Region VII
Randolph Chrismon, PAT Incineration Coordinator
#9523.05(83)
7-29-83
A permit applicant for a new facility may not incinerate hazardous waste,
even for a trial burn, without a finally effective RCRA permit. If the appli-
cant incinerates any waste defined as hazardous by the EPA without a finally -
effective RCRA permit, s/he may be subject to criminal sanctions for imminent
endangerment of human health and the environment.
The DRE values for a trial burn cannot be averaged together. The applicant
must provide a DRE result for each of the individual burns each of which must
satisfy the 99.99 DRE standard. If one of the three required test-burns fails
to meet the DRE standard and the reason for this failure is traceable to an
operating parameter that can be used as an automatic waste feed trigger, then
the Regional Administrator may use his best engineering judgment and declare
the facility to have met the required standard.
An applicant must list both the Appendix VIII hazardous organic constituents
not reasonably expected to be found in the waste and the reason for such belief.
Further, the inspection"schedule for the incinerator must be developed for
incorporation into the permit.
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9523.05 (83)
Memorandum
Subject! Supplemental PAT Comments on HcDonnell-Dougl«
Electronics Part B Application
Promt Randolph L. Chrisraon
PAT Incineration Coordinator
Tot Steve Busch
PAT Contact* Permits Section
I have completed a review of the supplemental material^
provided by the applicant in response to the 26 May 1983
NOD* I have tvo major concerns about issues raised for the
first tine in the supplemental material (comments 1 and 2).
I also have a few other coranents of less significance. Once
these issues are addressed to EPA's satisfaction, the appli-
cation should be considered complete and technically adequate
to support developing a draft permit and issuance of public
notice. My cownents are set out below.
1. First, the applicant suggests that he will begin the
trial burn in August. The applicant must be made to under-
stand that he cannot incinerate hazardous waste, even for a
trial burn, without a finally effective RCRA permit. If the
applicant incinerates any waste defined as hazardous by the
EPA without a finally effective permit he stay be subject to
criminal sanctions for imminent endangerment of human health
and the environment. It may be appropriate to reiterate
this point in the*Administrative Order about construction
without a permit being^ prepared by the Region.
2. On page 23 of the revised trial burn plan, the applicant
states that the ORE values for the three runs will be averaged
and if the average meets the 99.99 ORE standard the RCRA
performance standard will have been met. This is a completely
Incorrect statement of the demonstration required of the
applicant. The applicant mist provide a ORE result for each
of the three individual runs. Each of the runs must satisfy
the 99.99 DK£ standard. If one of the three required test
burns fails to meet the ORE standard and the reason for fail-
ing to achieve the standard is traceable to an operating
parameter that can be used as an autonatic waste feed cutotf
trigger, then the Regional Administrator, using his best en-
gineering judgement, may declare the facility to have net the
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DKE performance standard. See the Handbook for Hazardous Waste
incinerator Permits, April 1983*
3. The regulations require the applicant to list all
the Appendix VIII hazardous organic constituents not reasonably
expected to be found in the waste and the reason for such
belief. 40 CFR 270.62(b)(2)(1)(c). The applicant has provided
an adequate reason but has not provided the list of wastes not
expected to be found. The other side of this coin is that
the applicant Must provide an approximate quantification of
all the potential POHCs found in the vaste. Although the
applicant's original application did provide waste analyses
identifying potential POHCs, the Agency cannot determine
whether these are all the potential POHCs without the additional
listing described above. The applicant should also realize
that with respect to any Appendix VI i* constituent found in
the waste* the discretion rests with the permit writer to
determine which will be considered POHCs. It is through an
exercise of that discretion that we accept the use of CC14
as a surrogate for any potential POflC. The decision to
accept the use of a surrogate, however, nust be based on a
complete knowledge of the other Appendix VIII constituents
in the waste.
4. In the revised material, the applicant states he "will
develop" an inspection schedule for the incinerator. The
applicant must develop this schedule now and sutmit it to
the Royion for review and incorporation into the permit.
See 40 CPR 264.15
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on the procedures to manually activate the
»otor swithces.
applicant needs to provide a simple schematic drawing
«4hg where the items of equiwent described on page 9 of the
revised application are located.
k_
8._ During Incinerator shake-down the applicant proposes to
burn two <5r acre cycles of non-halogenated or low halogenated
waste streams. The applicant indicates, however, that if
Insufficient quantities of waste streams 9, 11, 12 and 13 are
available, they will spike with waste stream tl. This is
unacceptable for this early stage in the ahafee-down. Only
in the final shake-down cycles (see pg 14 item 3.2.1.1.C) can
the applicant incinerate any waste containing a POHC.
9. On page IS, the applicant presents a long list of incin-
erator operating parameters, I aia not sure what the applicant
means by control set point. The applicant, however, must pro-
pose a waste feed cut off limit for combustion air flow. The
regulations specifically identify sone measure of conbustion
gas velocity as a waste feed cutoff Unit, The applicant's-
use of combustion air flow as a means of Measuring conbustion
gas velocity is acceptable.
10. On page 16 the applicant states .that measures of heat
value and viscosity are irrelevant to this unit. This may
or may not be true but the regulations still require a de-
scription of physical properties including heat of combustion
for all materials and viscosity for liquids. Providing this
information is not a burden. Heat of combustion, in any
event, is a nost critical factor in the Agency's strategy
for regulating incinerators.
m
1-1. On page 18 the applicant indicates that the read-outs
from the continuous monitors will be recorded once per minute.
The applicant must understand that during the trial burn
all read-outs from continuous monitors will be recorded con-
tinuously. The permit writer will determine the appropriate-
ness of discontinuous recording and the frequency of such
recording biased on the "frequency and duration of excursions
Identified in the continuous record.
12. In the detailed interlock list at the end of tne revised
material the applicant suggests that a pH of 3.0 is the lower
limit for scrubber operations. I am not familiar with the
operating characteristics of scrubbers but it strikes me that
pH 3 is too low to effectively remove acid jases from the
exhaust stream. Your own air program people would have a better
handle on this.
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13. In addition to the daily trip blanks tor the VO6T sorbent
tubes, the applicant must also analyze a trip blank for th«
shipment of tubes from ESB's tfCMS lab in Florida.
A review of the above.comments will snow that most of
the comments are administrative in nature* i.e. the applicant^
shall or shall not do one thing or another. Nith a few excep-
tions, all the materials necessary to write a draft permit
have now been submitted to the legion. The applicant must be
made aware of the outlined administrative requirements and
understsnd that failure to abide by them may result in denial*
of the permit or an enforcement action.
As usual I remain available to answer any questions or
provide additional review and comment. In addition, since
this is a mandatory PAT effort, please continue to keep me
informed of any significant communications with the applicant.
As stated earlier, you do not need PAT concurrence on any
follow up letters or orders. X would like, however, to
receive copies of such correspondence to keep in the file.
cci Steve Levy
Terry Grogan
Melissa Fri«dl«nd
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