oEPA
                United States
                Environmental Protection
                Agency
             Office of
             Solid Waste and
             Emergency Response
DIRECTIVE NUMBER:

TITLE:
9523.09(84)
                      Criteria for Using Trial Burn Information Obtained
                      from One Incinerator to Issue a Permit at a Second
                      Incinerator in Lieu of Conducting a Second Trial
                      Burn at the Second Facility
                 APPROVAL DATE: n-23-84

                 EFFECTIVE DATE: n-23-84

                 ORIGINATING OFFICE: office of solid waste

                 E FINAL
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                 D DRAFT

                  STATUS:
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PART 270  SUBPART B - PERMIT APPLICATION
                                                DOC:  9523.09(84)
Key Words:

Regulations:

Subject:



Addressee:

Originator:


Source Doc:

Date:

Summary:
Trial Burn, Incineration

40 CFR 270.19(d)(2)

Criteria for Using Trial Burn Information Obtained from One
Incinerator to Issue a Permit at a Second Incinerator in Lieu
of Conducting a Second Trial Burn at the Second Facility

John Hart, Permits Section, Region IX

Randolph L. Chrismon, Permit Assistance Team (PAT) Incineration
Coordinator

#9523.09(84)

11-23-84
     If an applicant does not want to conduct a trial burn at one incinerator,-
§270.19(d)(2) requires the applicant to submit adequate data obtained from
another facility to specify "sufficiently similar" operating conditions that
will ensure compliance with the incinerator performance standards at the facility
requesting the permit.  The .Director must find that the wastes and incinerators
are "sufficiently similar" and that the data submitted is adequate to specify
operating conditions at the facility seeking a permit.  The Director has
authority to evaluate both incinerator design and .waste characteristics to
determine if operating conditions could be set in the permit without conducting
a second trial burn.

     The regulations do not specify what consititutes "sufficient similarity"
in incinerator design.  However, The Guidance Manual for Hazardous Waste Incin-
erator Permits provides details on similarity of incinerator design.

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                                                                        (84
                           NOV  2 3 !93A                                  ?
                                                                       •73
                                                                       .O
                                                                       UJ
 Subject*   PAT Consents: Stauffer Chemicals, Dominguez Hills
                                                  "
                                                                       0
                                                                       D
 From:      Randolph L.  Chrisnon                                        £
           PAT Incineration Coordinator                                £
                                                                       U)
 To:        ,7ohn Hflrt                                                   £>
                ts  Section, Region IX                                  ^
      Per  P.c^ion  lY.'s  re-quest,  the Headquarter 's Permit Assistance     tT
 Team (PAT)  has reviev/ed trie 1?CRA Part R application submitted by      £
 Stauffer  Chemicals  for its Doninquoz Hills facility.  This applies--   ^
 tion raiB«p  for the first time thf? issue of whether information       b
 obtained  fron one  incinerator  is sufficient to  issue a pernit to      ^
 nnother incinerator in lieu of conducting a trial burn at the         j^-
 socond facility.   As  discussod with ?>ill Vtilson and you, the          ~
 PAT  cpnfinori it*? analysis to the issue  of incinerator similarity,     *.
 since an  aiiv^rse determination on this  issue changes tho nature of    a-
 anv  further analysis  of  this application.                           •  ^.
                                                                       en
      It is the PAT's  conclusion that the 3 ay town incinerator (where   —
 the  original trial  burn  was conducted)  is not sufficiently similar    £*
 to the two nor.inrpuez  Hills  incinerators to allow EPA to issue a       *"
 RCT>A permit wtihout the  applicant first conducting a trial burn at    t
 tho  Domnquez facility.   If  an  applicant does not want to conduct a    H
 trial burn, 5270.19 requires hire to submit data obtained fr.oa a       n
 facility  adequate to  soocify operating  conditions that will ensure    o
corrplianca with the incinerator performance standards at the facility 3
 requesting a pemit.   S«e 40 CFR 270.19(d) {2 ).   ThQ Director nust     3
 find that the wastes  and  incinerators are "sufficiently similar"      ^
and  that  the data submitted, indeed,  is  adequate to specify operating
conditions at the requesting facility.

     The  regulations  do not  specify  what consititutea  "sufficient
similarity" in incinerator  design.   The  Guidance Manual for Hazardous
V?aste Incinerator Permits does  set  forth guidance  on the issue.
The manual represents  an  exercise of  the  Agency's  best engineering
judqs^ent as to w&at  factors are significant in  determining whether
two  incine»rators arcs  similar.   Great weight was  given  to the  manual
and the factors identified  there  in  this  analysis.

     Very cjenorally,  the  guidance suggests  tftat  the two incinerators
not Vi».ry by noro than  10-20  %  in various  dimensions (seo  Table  3-1
in the r.anual on paqo  3-4 for  a  brief synopsis of  these factors).
The rationale given tor this eugoestion  is  that  the effects of

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 different incinerator geometries on factors such as turbulence
 are difficult to quantify.  It is assumed that similar performance
 may bo expected from geometrically similar incinerators.  In
 addition, if the geometries are too dissimilar, the operating
 parameters used to achieve the requisite 99.99% ORE in the one
 facility, cannot be inferred to be appropriate at the second
 facility.  Significantly different geometries  may affect combustion
 gas velocity, CO levels, waste feed rate, thermal duty to the
 combustion chamber, and a variety of other operating parameters^
 that are subject to control through the  permit.

      An examination of  Stauffer's application  shows that the two
 Dominguez units exceed  the 10-20% limit  in nearly every dimension.
 Table 1, below, summarizes the comparison between the Baytown incin-
 erator and the two Dominguez units,       ;    "

                      "':"'   '•   TABLE l' .. :     '•  r;r -'   •  •
          \       COMPARISON OF PHYSICAL  DIMENSIONS  .
                 BETWEEN BAYTOWN AND DOHINGUE2  UNITS
                                (in %)                 :
*
Volume
Refrac. ID
Furn. Length
Cross Sec . Area
Dora. #1
-60.5
-19.5
-39.0
-34.0
Don. $2
-41.9
-19.5
-10.2
-35.5
Stauffer provides some documentation comparing various operating
parameters between the Baytown and Doraingue? units but because of
the widely varying geometries we cannot conclude that similar
operating parameters will result in achieving the required ORE
at the Dominguez units.               .

     Section 270,19 was primarily intended for facilities with
interim status to conduct trial burns without formal Agency approval,
and to minimize the necessity for trial burns for package or off-
the-shelf units."  In either case, nearly all the parameters
controlling ORE would be identical.  It is understood, however,
that even off-the-shelf incinerators may vary in some design parameters
even though they have the same operating conditions.  Thus, the     -
regulations gave the Director the authority to evaluate both         :;
incinerator design and waste characteristics to determine if
operating conditions could be set in the permit witho'ut conducting
a second trial burn. . Hhere,' as here, the various factors assessing   '
similarity vary by over 50%, setting operating parameters in the    !
permit for one facility on the basis of a trial burn conducted at
the other facility becomes an enormously difficult, if not impossible
task.                   .
                                -2-

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     Based on the above considerations/  it  is  the  PAT's conclusion
 that the Baytown incinerator  is  not. sufficiently similar  to  the  two
 Dominguez incinerators.    Stauffer  may "not  obtain  a  RCRA  permit  for
 incineration without  first conducting a  trial  burn at  Dorainguez.
 The PAT has not determined whether  a trial  burn must bo conducted
 on both of the Dominguez units.   It is possible that Dorainguez No.
 1 and No. 2 are sufficiently  similar that only one trial  burn need
 be conducted.  Additional  information may be necessary to make-this
 determination.  We will await word  from  Stauffer,  however, that  '•••".
 they intend to pursue a RCRA  permit for  the Dorainguez  facility
 before we taake any further analysis on this point.

     Please forward Stauffer'g. response  to your HOD  to the PAT for  !
 evaluation.  The PAT will continue  to provide  technical support to -. •
 Region IX in evaluating Stauffer's  application, and  any trial burn
 plan proposed for Dorainguez.
                                    •\         f    .   '     •        • .


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