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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REFERENCE (other documents):
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VE DIRECTIVE DIRECTIVE Dl
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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 ?
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Subject* PAT Consents: Stauffer Chemicals, Dominguez Hills
"
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From: Randolph L. Chrisnon £
PAT Incineration Coordinator £
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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. .
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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 . ' • • .
cc» A. Glazer • . ''. .: .;- •' • ..'••' '; • . - • .. •
P. Guerrero -..'•.'
B. Weddlo * . .
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